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UNITED STSTES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. ________________________

THE MATTER OF THE PETITION FOR EXEMPTION OF:

JP AERO

FOR AN EXEMPTION SEEKING RELIEF FROMTHE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+, DJI 

PHANTOM 3 PROFESSIONAL AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAAMODERNIZATION AND REFORMACT OF 2012 (PUBLIC LAW 112-95)

Submitted on Sept. 13th 2015:

JP AERO

James Palminteri

205 Pointe Drive

Brea, CA 92821

562-318-6112
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TABLE OF CONTENTS

GLOSSARY OF ABBEVIATIONS.............................................................3

I. SUMMARY................................................................................4

II. BACKGOUND............................................................................4

III. STATUTORY AUTHORITY............................................................4

IV. JP AERO EXEMPTION S REQUESTED............................................5-9

V. JP AERO’S OPERATIONS SATISFY SECTION 333 REQUIREMENTS

a. JP AERO’S UAS FLEET..........................................................9-11

b. PILOT IN COMMAND AND OPERTIONS..................................12-13

c. JP AERO’S UAS OPERATING PARAMETERS............................13-17

VI. JP AERO’S REQUESTED EXEMPTION PROMOTES THE PUBLIC 

INTEREST..................................................................................17

a. EXEMPTIOM FROM THE REQUIREMENTS OF SECTION 91.9(B) WOULD NOT 

ADVERSELY AFFECT SAFETY.................................................18-19

b. EXEMPTION FROM THE REQUIREMENTS OFSECTION 91.203(A) AND (B) 

WOULD NOT ADVERSELY AFFECT SAFETY...............................19-20

VII. CONCLUSION............................................................................20-21

 

MANUALS, TECHNICAL DATA AND FLEET LOG IN ATTACHED PDF FILES.
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer

SOP Standard OperatingProcedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

 VTOL Vertical Takeoff and Landing
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I. SUMMARY

JP AERO, a California company, located at 205 Pointe Drive Brea, Ca 92821 seeks authority 

to commercially operate a unmanned aircraft system fleet pursuant to Federal Aviation 

Regulations (14 C.F.R. § 1.61) and Section 333 of the FAA Modernization and Reform Act of 

2012, Special Rules for Certain Unmanned Aircraft Systems. JP AEERO also seeks exemption 

from the requirements of certain provisions of 14 C.F.R. Parts 21, 36, 45.23(b), 61.23(a) and (c), 

61.101(e)(4) and (5), 61.113(a) and (b), 61.133(b), 61.315(a), 91.7(a), 91.9 (b)(2), 91.103(b)(1), 

91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b) 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), and 91.417(a) and (b). The proposed exemptions, if granted, would allow JP AERO to 

conduct commercial operations of small unmanned aircraft systems (“UAS”) weighing 55 

pounds or less.

II. BACKGROUND

JP AERO is a cutting edge engineering, inspection, cinematography and drone design 

company. Consistent with Congressional intent in enacting Section 222, JP AERO seeks to utilize 

remote flying and viewing technology to achieve new heights of creativity and production cost 

savings. JP AERO seeks the requested exemptions and a Certificate of Authorization permitting 

JP AERO to offer a suite of services, such as: 

 Building and Agriculture Inspections;

 Search & Rescue;

 Closed-set filming and aerial photography;

 Aerial data collection
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III. STATUTORY AUTHORITY

Section 333, Special Rules for Certain Unmanned Aircraft Systems, provides a procedure 

for seeking expedited FAA authorization for UAS operations in the NAS. Subpart A states the 

FAA “shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by 332(b)(1) of this act 

or the guidance required by section 334 of this Act.” In Section 332(b) (1), Congress made it 

clear that section 333 provides a procedure for “expedited operational authorization.”

Section 333(b) identifies factors that the FAA should consider in determining whether 

commercial US operations should be approved when, “as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within the 

visual line of sight do not create a hazard to users of the [NAS] or the public or pose a threat to 

national security.”

In addition, Section 44701(f) confers a general authority to grant exemptions from the 

FAA’s safety regulations and minimum standards when the administrator decides a requested 

exemption is in the public interest.

IV. JP AERO EXEMPTIONS REQUESTED

JP AERO requests relief from:

14 C.F.R. Part 21 prescribes, in pertinent part, procedural requirements for issuing and 

changing design approvals; production approvals; airworthiness certificates; and airworthiness 

approvals.
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14 C.F.R. Part 36 sets forth noise standards for aircraft type and airworthiness 

certification.

14 C.F.R. Part 45.23(b) sets forth the requirement, if applicable, that the word 

“Restricted” be displayed on the unmanned aircraft near each entrance to the cabin, cockpit or 

pilot station.

14 C.F.R. Part 61.23(a) and (c) sets forth requirements for medical certificates.

14 C.F.R. Part 61.101(e) (4) and (5) prescribes recreational pilot privileges and 

limitations.

14 C.F.R. Part 61.113(a) and (b) prescribes private pilot privileges and limitations.

14 C.F.R. Part 61.133(b) prescribes commercial pilot privileges and limitations.

14 C.F.R. Part 91.7(a) prescribes, in pertinent part, that no person may operate a civil 

aircraft unless it is in an airworthy condition.

14 C.F.R. Part 91.9 (b)(2) prohibits operation of US registered civil aircraft unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and records, or any combination thereof.

14 C.F.R. Part 91.103(b)(1) prescribes, in pertinent part, that each pilot in command 

shell, before beginning a flight, become familiar with all available information concerning that 

flight, include, “for any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance:... For civil aircraft forwards and approved Airplane or Rotorcraft 

Flight Manual containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein.” 
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14 C.F.R. Part 91.109(a) provides that “no person may operate a civil aircraft (except in 

manned free balloon) that is being used for flight instruction unless the aircraft has fully 

functioning dual controls.”

14 C.F.R. Part 91.119(c) prescribes that, except when necessary for takeoff or landing, 

no person may operate an aircraft below the certain altitudes under certain conditions.

14 C.F.R. Part 91.121 requires, in pertinent part, each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set “to the elevation of the 

departure airport or an appropriate ultimate setting available before departure.”

14 C.F.R. Part 91.151 prescribes that no person may begin a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the 

day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 

minutes.

14 C.F.R. Part 91.203(a) and (b) prohibits, in subpart (a), any person operating a civil 

aircraft unless it has within it (1) an appropriate concurrent airworthiness certificate; and (2) an 

effective US registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft Registration Application as provided for in §43.3 7(c). 

Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless and 

airworthiness certificate or a special flight authorization issued under §91.715 legible to 

passengers or crew is displayed at the capital cockpit.
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14 C.F.R. Part 91.407(a)(1) prohibits, in pertinent part, any person from operating an 

aircraft that has undergone maintenance, inventive maintenance, rebuilding, or alteration 

unless it has been approved for return to service by a person authorized under §43.7 of the 

same chapter.

14 C.F.R. Part 91.409(a)(1) and (2) prescribes, in pertinent part, that no person may 

operate aircraft unless, within the preceding 12 calendar months, it has had an inspection for 

the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

14 C.F.R. Part 91.417(a) and (b) prescribes, in pertinent part, that each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: (1) Records of the maintenance, preventive maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include— (i) A description (or reference to data 

acceptable to the Administrator) of the work performed; and (ii) The date of completion of the 

work performed; and (iii) The signature, and certificate number of the person approving the 

aircraft for return to service. (2) Records containing the following information: (i) the total time 

in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of 

life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since 

last overhaul of all items installed on the aircraft which are required to be overhauled on a 

specified time basis, (iv) the current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the aircraft and its 
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appliances are maintained, and (v) The current status of applicable airworthiness directives 

(AD) and safety directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves recurring action, the 

time and date when the next action is required, and (vi) copies of the forms prescribed by 

§43.9(d) of this chapter for each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

The records specified in paragraph (a)(1) of this section shall be retained until the work 

is repeated or superseded by other work or for 1 year after the work is performed.

The records specified in paragraph (a) (2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold.

A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for return to 

service.

V. JP AERO’S OPERATIONS SATISFY SECTION 333 REQUIREMENTS

a. JP AERO’S UAS Fleet

JP AERO proposes to operate five small UAS under this exemption. 
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Phantom 2

JPAERO seeks an exemption to operate a DJI Phantom 2 for compensation or hire. The 

DJI Phantom 2is comprised of a multi-rotor unmanned aircraft and two handheld ground 

control stations. The DJI Phantom 2 has a maximum gross weight of approximately 2.86 

pounds, diagonal wheelbase of 13.78 inches, and height of approximately 7.5 inches. The DI 

Phantom 2 is equipped with four rotors driven by four lithium polymer battery powered electric 

motors. Design and operational characteristics are provided in DJI Phantom 2 Operating Manual 

(PDF attached).

Phantom 3

JP AERO seeks an exemption to operate a DJI Phantom 3 for compensation or hire. The 

DJI Phantom 3 is comprised of a multi-rotor unmanned aircraft and two handheld ground 

control stations. The DJI Phantom 3 has a maximum gross weight of approximately 2.821 

pounds, diagonal wheelbase of 13.78 inches, and height of approximately 7.5 inches. The DI 

Phantom 3 is equipped with four rotors driven by four lithium polymer battery powered electric 

motors. Design and operational characteristics are provided in DJI Phantom 3 Operating Manual 

(PDF attached).

DJI Inspire

JP AERO seeks an exemption to operate a DJI Inspire for compensation or hire. The DJI 

Inspire is comprised of a multi-rotor unmanned aircraft and two handheld ground control 

stations. The DJI Inspire has a maximum gross weight of approximately 6.5 pounds, diagonal 

wheelbase of 22.88 inches, and height of approximately 11.85 inches. The DJI- Inspire is 
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equipped with four rotors driven by four lithium polymer battery powered electric motors. 

Design and operational characteristics are provided in DJI Inspire Operating Manual (Page 57).

Flame Wheel 550

JP AERO seeks an exemption to operate a DJI Flame Wheel 550 for compensation or 

hire. The DJI Flame Wheel 550 is comprised of a multi-rotor unmanned aircraft and two 

handheld ground control stations. The DJI Flame Wheel 550 has a maximum gross weight of 

approximately 5.5 pounds, diagonal wheelbase of 21.65 inches, and height of approximately 10 

inches. The DJI- Flame Wheel 550 is equipped with six rotors driven by six lithium polymer 

battery powered electric motors. Design and operational characteristics are provided in DJI 

Flame Wheel 550 Operating Manual (Page 57).

DJI-S1000

JP AERO seeks an exemption to operate a DJI-S1000 for compensation or hire. The DJIS1000 is comprised of a multi-rotor unmanned aircraft and two handheld ground control 

stations. The DJI-S1000 has a maximum gross weight of approximately 24.25 pounds, diagonal 

wheelbase of 41.14 inches, and height of approximately 22 inches. The DJI- S1000 is equipped 

with eight rotors driven by eight lithium polymer battery powered electric motors. Design and 

operational characteristics are provided in DJI S1000 Operating Manual (Page 22).
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b. Pilot In Command (PIC) and Operations

All JP AERO Flight Crews, including PIC and Visual Observers (VO), will be qualified as 

directed by FAA and JP AERO Standard Operating Procedure (SOP).

All flight crewmembers, including PIC and VO, will have an understanding of, and comply 

with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, applicable 

to the airspace where the UAS will operate. Specifically all flight crew members will receive 

training on the rules and responsibilities described in 14 CFR Part 91 Sections 91.111, 91.113 

and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including 

standard ATC phraseology and communication. 

The PIC must possess at least a current private pilot certificate and third class medical 

certificate. The PIC must also meet the flight review requirements specified in 14 CFR Section 

61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 

Prior to operations, the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR Section 61.51(b), a minimum of 25 hours of total time as a UAS pilot and at least 

ten hours logged as a UAS pilot with similar UAS type (fixed wing or rotary). Prior documented 

flight experience that was obtained in compliance with applicable regulations may satisfy this 

requirement. Training, proficiency, and experience building flights are requested to be 

conducted under this grant of exception to accomplish the required flight cycles and flight time. 

During training, proficiency, and experience building flights, all persons not essential for flight 

operations will be considered non-participants and the PIC will operate the UAS with 

appropriate distance from non-participants in accordance with 14 CFR Section 91.119.
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The UAS shall remain clear and yield the right of way to all other manned aviation 

operations and activities at all times.

The UAS shall be operated at an altitude of no more than 400 feet above ground level 

(AGL). All altitudes reported to ATC will be in feet.

The multi-rotor UAS shall not be flown at a ground speed exceeding 30 mph.

Fixed wing and hybrid UAS shall be flown at a ground speed not to exceed the maximum 

design limitation air speed of 57 mph as stated in the operating manuals.

UAS Operations will be conducted under visual meteorological conditions (VMC). The 

UAS will not be operated less than 500 feet below or less than 2000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC.

If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance 

with JP AERO SOP.

The UAS PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with operating documents.

The UAS PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UAS with 25% battery power remaining.

c. JP AERO’s UAS Operating Parameters

The UAS operated in accordance with this proposed exemption shall be identified by 

serial numbers, registered in accordance with 14 CFR part 47, and have identification (N-
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Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable.

The UAS documents required under 14 CFR 91.9 and 91.203 shall be available to the PIC 

at the Ground Control Station of the UAS anytime the aircraft is operating. Those documents 

shall be available to the Administrator or any law enforcement official upon request.

Any UAS incidents, accidents or flight operations that transgress the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to the 

FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

Unless otherwise specified in this petition, the UAS PIC, and the UAS operations shall 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61 and 91.

The UAS shall not be operated over congested or densely populated areas. These areas 

include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), 

Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Each work site will 

also be evaluated based on local conditions.

Operations of UAS may be conducted at distances less than 500 feet from participating 

persons, vessels, vehicles or structures that perform an essential function in connection with 

these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator 

trainees and essential persons are permitted when operationally necessary; but never so close 

to present an undue hazard. This is consistent with Exemption No. 11138.
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Operations of UAS may be conducted at distances less than 500 feet from unoccupied 

vessels, vehicles or structures owned by the land owner/controller when the land 

owner/controller grants such permission, and the PIC makes a safety assessment of the risk 

from operations and determines that it does not present an undue hazard to persons or 

property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all nonparticipating persons 

unless barriers or structures are present that sufficiently protect nonparticipating persons from 

the UAS and/or debris in the event of an accident. JP AERO shall ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons 

leave such protection and are within 500 feet of the UAS, flight operations will cease 

immediately. This is consistent with Exemption No. 11138.

All operations of UAS shall be conducted with the permission from the land 

owner/controller or authorized representative. Permission from the land owner/controller or 

authorized representative will be obtained for each flight to be conducted.

The UAS will not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management will be made available to the Administrator upon request. This is consistent with 

Exemption No 11159.
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The UAS must be operated within VLOS of the PIC and VO at all times. This requires the 

PIC to be able to use human vision to see the UAS unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA issued medical certificate.

All UAS operations must utilize a VO. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times. The PIC and VO must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure that 

the VO can perform the functions prescribed in JP AERO’s SOP.

The UAS will not be operated by the PIC from any moving device or vehicle. Operations 

will not be conducted during night as defined in 14 CFR 1.1.

JP AERO will conduct preflight safety risk assessments to determine that the UAS is in a 

condition for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be 

completed safely. Specific procedures are addressed in JP AERO’s SOP, and UAS Operation 

Manuals.

JP AERO’s operations do not require a notification to Flight Standards District Offices 

(FSDOs).

JP AERO shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this requested grant of 

exemption. Additionally, JP AERO will request a Notice to Airmen (NOTAM) not more than 72 

hours, but not less than 48 hours prior to the operation.

Prior to operations conducted for the purpose of precision agriculture (or similar 

operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR 
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Section 61.51(b), a minimum of five hours as a UAS PIC operating the make and model of the 

UAS to be utilized for operations under this requested exemption, and three take-offs and 

landings in the preceding 90 days. Training, proficiency, experience-building, and take-off and 

landing currency flights are requested to be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, 

experience building, and take-off and landing currency flights all personnel not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UAS with 

appropriate distance from nonparticipants in accordance with 14 CFR Section 91.119. 

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight 

(VLOS) requirement as long as the PIC always maintain VLOS capability. The VO and PIC must be 

able to communicate verbally at all times. This condition and limitation is consistent with all 

FAA approved Exemptions.

VI. JP AERO’s Requested Exemption Promotes the Public Interest

Granting JP AERO’s petition for exemption will further the public interest because JP 

AERO seeks to perform necessary and vital services for public and private organizations. Such 

services include building inspections, agriculture surveys, search & rescue, research, 

engineering and education. The JP AERO unmanned aircraft fleet are battery-powered UAS that 

serve as a safe, efficient, and economical alternative to the demand aircraft traditionally 

utilized in obtaining aerial imagery within these industries. An exemption allowing JP AERO’s 

UAS fleet to operate would reduce the amount of manned aircraft operating in the NAS, reduce 

noise and air pollution. In addition, the safety of life and property both in the air and on the 

ground would be improved.
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By reducing the number of manned aircraft operating in the NAS airport congestion 

caused by arriving and departing aircraft will be reduced. The JP AERO UIS fleet does not 

require an airport to take off or land. A reduction of manned aircraft conducting aerial imagery 

flights would mean air traffic control handling less traffic during the ground, takeoff, departure, 

arrival and landing phases of flight operations.

Aerial imagery missions using the JP AERO UAS fleet, instead of manned aircraft, 

benefits the public by drastically reducing air and noise pollution generated during manned 

aircraft operations. The JP AERO UAS fleet, a battery powered electric motor, is the most viable 

environmentally conscious alternative to internal combustion aircraft. The maximum gross 

weight of 5 pounds per UAS has less physical mass for collateral damage to life and property 

whether on the ground or in the air.

a. Exemption From The Requirements Of Section 91.9(b) Would Not Adversely Affect 

Safety

This exemption would maintain the level of safety established by Section 91.9(b) 

because JP AERO will keep the approved Airplane Flight Manual at the ground control station 

where the pilot in command will have immediate access to the document. 

Previous exemptions granted by the FAA concerning Section 91.9(b) establish that 

safety is not adversely affected when the approved Aircraft Flight Manual is kept at the ground 

control station of a UAS, where it can be immediately accessed by the pilot in command. 

Section 91.9(b) “requires aircraft to carry the flight manual so the pilot would have ready access 

to the aircraft limitations while in flight.” Exemption No. 8607. However, the FAA has also found 
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that UAS will always be operated without any passengers or crew onboard, and that “requiring 

these special-use aircraft [UAS] to carry superfluous paper documents may present a safety 

hazard to the integrity of the [UAS].” Id. The FAA has previously granted exemptions in 

circumstances similar, in all material respects, to those presented herein (e.g., Exemption Nos. 

8607, 8737, 8738, 9299, 9430, 9554, 9564, 9565, 10167, 10602, 10673, 10835, 10869, 10968).

b. Exemption From The Requirements Of Section 91.203(a) and (b) Would Not Adversely 

Affect Safety

This exemption would maintain the level of safety established by Sections 91.203(a) and 

(b) because JP AERO will keep the required documents at the ground control station where the 

pilot in command will have immediate access.

Previous exemptions granted by the FAA concerning Sections 91.203(a) and (b) establish 

that safety is not adversely affected when the Airworthiness Certificate and U.S. registration 

certificate are kept at the ground control station of the UAS, where it can be immediately 

accessed by the pilot in command. Specifically, the FAA has held that the intent of Sections 

91.203(a) and (b) is better served by having the required documents in the control of the UAS 

operator (pilot in command), reasoning as follows: “The original intent of the subject regulation 

was to display the airworthiness and registration documents so they would be easily available 

to FAA inspectors and passengers for inspection and verification of the airworthiness and 

registration of the aircraft . . . In this case, the aircraft will always be operated without any 

passengers or crew.” 
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The missions for which UASs are intended will prevent the need for aircraft normally 

prescribed for civil aircraft. Further, it will be operated on strictly confined missions from a 

known departure and arrival point, under the constant control of a pilot-in-command. 

Requiring these special-use aircraft to carry superfluous paper documents may present a safety 

hazard to the integrity of the [UAS]. FAA operating limitations and special arrangements with 

Air Traffic Control (ATC) for surveillance of [UAS] flights adequately compensate for the 

requirements for carrying airworthiness and registration documents. The intent of the 

regulation is better served by having the required documents in the control of the aircraft 

operator and available for inspection under the special conditions prescribed in this exemption. 

The FAA has previously granted exemptions in circumstances similar, in all material 

respects, to those presented herein (e.g., Exemption Nos. 8607, 8737, 8738, 9299, 9564, 9565,

10167, 10602, 10673, 10835, 10869, 10968).

VII.CONCLUSION

As set forth above, JP AERO seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation 

of the JP AERO UAS fleet commercially, without an airworthiness certificate, for the purposes 

described above. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, and the public, by 

allowing JP AERO to safely, efficiently, and economically operate the UAS fleet commercially 

within the NAS.
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WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, JP AERO respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. Parts 21, 

36, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.133(b), 61.315(a), 

91.7(a), 91.9 (b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b) 

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).