U.S. Department of Transportation November 6, 2015

Docket Management System

1200 New Jersey Ave. SE 

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act

To Whom It May Concern,

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. 

Part 11, I, Robert J. Jones Jr., hereby apply for exemptions from the following Federal Aviation 

Regulations (FARs) in order to operate a Small Unmanned Aircraft System (sUAS) for commercial

applications in airspace that is governed by the Federal Aviation Administration (FAA). All flight 

operations will be conducted under the conditions and boundaries outlined herein or as established by

the FAA in accordance with Section 333.

The exemptions, as requested, would permit the provision of commercial services to customers that 

are in need of aerial data capture from a UAS. I requests these exemptions in order to perform

commercial flights in the following areas:

 Surveying

 Agriculture

 Aerial Inspection

 Real Estate Photography

 General Photography

 Special Events

All flights will be conducted over private or controlled access property with the consent and 

knowledge of the property owner or controlling party. All flight operations will maintain a 500 foot 

buffer from all nonparticipating persons, vessels, vehicles, and structures unless sufficient barriers 

are in place to protect nonparticipating persons from undue harm. Flight operations will also only be 

operated near vessels, vehicles, and structures where the property owner/controller has granted 

permission and a safety assessment has been made.

Regulations from which an exemption is requested:

14 CFR 61.113(a)

14 CFR 91.7(a)

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR Subpart E (91.401 – 91.417)
BACKGROUND

I have been building and flying remote control airplanes and helicopters since 1985. I have been 

flying drone type aircraft since 2012. I have held a Commercial Pilot License since January 1980. 

Additionally, in 2012 I retired from the FAA. Having been a District Manager for the Santa 

Barbara District, which covered central California, and a Manager at Van Nuys Tower, Burbank 

Tower, and Los Angeles Tower. I dealt heavily with the use of remote control aircraft near 

airports. I am well versed in the requirements and required coordination when flying near an 

airport or restricted airspace.

THE UNMANNED AIRCRAFT SYSTEMS

Due to the low cost of operation, increased safety to surrounding persons and property, reduced 

noise and environmental impact, and the versatility of the UAS platform, I believe that an UAS can 

be a great solution to consumers who would, otherwise, have to hire a larger aircraft, such as a

helicopter, in order to capture the data that they need.

I am seeking this exemption in order to operate a 3DR Solo quadcopter and a DJI Phantom 3 

Professional quadcopter, both equipped with a 3-axis gimbal and 1080p camera and weighing

4.0 pounds or less (battery, camera, and propellers included). The safety failsafe features

equipped on both aircraft ensuring safe operations include:

 Geo-fence capability that will limit the height and horizontal distance that the Solo/

Phantom can fly from the operator.

 RTL mode- In the case of low battery or lost communication between the 

Solo/Phantom and the operator, the aircraft will return to the point of takeoff and land

itself. This mode can be manually turned on by the operator at any point in the flight.

 Land mode- Loss of transmitter signal will engage auto-land mode. The Solo/Phantom

will return to it's departure point and land automatically.

 Telemetry radio communication on the Solo/Phantom provides real time feedback of

flight data, including current altitude (AGL), speed, latitude, altitude change rate, and GPS

coordinates.

The aforementioned safety features have undergone rigorous testing procedures by 3DR and DJI

as well as myself. These safety features combined with the PIC’s knowledge obtained during flight 

training will successfully mitigate operational safety risks.

FLIGHT

OPERATIONS

The owner/operator, PIC, and Observer will guarantee that operations adhere to strict standards as

set below:

 The PIC must show that they are able to safely operate the UAS in a safe manner

before proceeding with operations.

 The UA will be operated at airspeeds below 29 knots.

 The UA will be operated below 400 feet above ground level (AGL) at all times.

 The UA will be operated within visual line of sight (VLOS) at all times.
 All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the PIC and VO at all times.

 The VO will not perform any other duties beyond assisting the PIC with seeing and

avoiding traffic and other ground based obstacles.

 Proper preflight inspections will take place before each flight.

 The UA may not operate within 5 nautical miles of an airport reference point unless a 

letter of agreement with that airport’s management is obtained.

 The UA may not be operated less than 500 feet below or less than 2,000 feet

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

 The PIC must maintain a battery reserve that allows the UA to return to point of landing

at normal cruise speed and land with 10% battery power.

 The UA must remain clear of and yield to all other air traffic.

 Flight operations will remain 500 feet from all nonparticipating persons, vehicles, 

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from debris in the event of an accident.

b. All participating persons will be made aware of the dangers of flying a UA and the afety

precautions and features that are in place.

c. The aircraft is operated near vessel, vehicles, or structures where the property

owner/controller has granted permission and the PIC has made a safety assessment

in regard to the close operation to these objects.

d. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per

91.119(a).

 All operations will be conducted over private or controlled-access property with prior

permission from the property owner/controller or authorized representative.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I request an exemption from the following regulations as well as any additional regulations found by

the FAA to be necessary for safe and efficient UAS flight operations.

14 CFR 61.113(a), Private pilot privileges and limitations: Pilot in command

This regulation states that no person holding a private pilot certificate may act as pilot in command 

of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft.

I currently hold a Commercial Pilot License, but I believe that a PIC with a private pilot license

has sufficient skill and knowledge to complete operations, especially after completing a UAS

knowledge and training course. I do not believe that a commercial pilot license will significantly

improve a PIC’s performance while operating a UAV. Therefore, I ask for an exemption from 14 

CFR 61.113(a) in order to operate commercially with the minimum of a private pilot license.

14 CFR 91.7(a) Civil aircraft airworthiness

As a UAS will not require an airworthiness certificate, I believe that this regulation is not 

applicable. Therefore, I request exemption from this regulation.
14 CFR 91.119(c) Minimum safe altitudes

This regulation states that no person may operate an aircraft below 500 feet above the surface as

well as within 500 feet of any person, vessel, vehicle, or structure.

I believe that, because of the nature of most UAS operations, an exemption is required in order to 

allow operation closer than 500 feet to vessels, vehicles, or structures as long as permission is 

granted from the owning/controlling parties and an assessment is made to assure that people and 

property are safe from undue harm. I also request that operations be allowed over congested areas 

as long as the operations stay within the following standards:

 Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and

structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris

in the event of an accident.

b. Participating persons are made aware of the dangers of the UAS operation and the 

safety precautions that have been put into place.

c. The aircraft is operated near vessel, vehicles, or structures only where the property 

owner/controller has granted permission and the PIC has made a safety assessment in regard

to the close operation to these objects.

d. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per 91.119(a).

e. All operations will be conducted over private or controlled-access property with prior

permission from the property owner/controller or authorized representative.

14 CFR 91.121 Altimeter settings

As my UAS aircraft do not utilize a standard barometric altimeter, I request exemption from

91.121 to the extent necessary to comply with applicable conditions and limitations. The altimeter

reading for the UAS is calculated by GPS. The accurate and continuous readings received from

this GPS system allow operation of the drone below set minimums at all times.

14 CFR 91.151(a) Fuel requirements for flight in VFR conditions

This regulation states that no person may begin a flight in an airplane under day-VFR conditions

unless there is enough fuel to fly to the first point of intended landing and, after that, fly for an 

additional 30 minutes. This regulation is intended to create a safe flying environment by

creating sufficient fuel reserves. Therefore, I do not request an exemption from this regulation 

but, instead, request that the term “fuel” be changed to “battery power.” I also request that 

battery power reserve for UAS operations be 10%.

My UAS aircraft have capabilities that allow the PIC to monitor battery power levels as well as

a return to land feature that will engage when battery levels reach a critical level, therefore

returning the UAS automatically to the point of takeoff.

14 CFR Subpart E (91.401 – 91.417)

I request an exemption from the stringent maintenance regulations that are designed to increase

the safety of the flying environment by ensuring adequate inspections and servicing of aircraft. I 

am requesting exemption from these regulations because I believe that, due to the simplicity and 

the ease of repair, general and preventive maintenance can be performed by the PIC. The PIC is 

required to make a thorough preflight inspection before each operation. In the case of a 

discovery of faulty equipment, most replacement and repair can simply be done on site as long as 

repairs are of an airworthy manner. All repairs will be logged in the UAS records.
I believe that my comprehensive preflight inspection, the simplicity of the UAS itself, the nature of

the UAS’s operations, and the fact that no passengers are on board the aircraft make my operations

eligible for exemption from CFR Subpart E (91.401 – 91.417).

By following the strict safety standards set by myself, the FAA, and the physical safety

properties of the UAS, will allow for safe and efficient operations.

I, Robert J. Jones Jr., hereby request exemption under Section 333 in order to pursue commercial 

UAV applications with the intent to provide customers with the safest, highest quality platform

available.

Sincerely,

Robert J Jones Jr

6195 9th Ave Circle NE

Bradenton, FL 34212

(661) 252-3669