Dear Sir or Madam, 

Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 C.F.R. Part 11, JBI LLC, operator of Small Unmanned Aerial Vehicle (UAV) 

equipped to conduct aerial inspections for the Energy generation and distribution 

industries for pre-planned, controlled area, inspection services, hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial 

operation of its UAS(Unmanned Aircraft System), so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by 

the Federal Aviation Administration (FAA) as required by §333. 

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive multi rotor aircraft under controlled 

conditions in airspace that is 1) contained 2) predetermined 3) has on-site safety 

personnel controlling access, and 4) would provide increased safety to the public and 

enhancements to clients' business operations. 

The name and address of the applicant is: JB Aerial LLC(JBI LLC), 11822 Deer Path 

Way, Orlando, Florida FL32832.

JBI LLC respectfully requests a grant of an exemption of the following sections of Title 

14 of the Code of Federal Regulations: 

* 14 CFR 91.7(a)

* 14 CFR 91.119

* 14 CFR 91.121

* 14 CFR 91.151(a)

* 14 CFR 91.405(a)

* 14 CFR 91.407(a)(1)

* 14 CFR 91.409(a)(1) and (2)

* 14 CFR 91.417(a) and (b)
I. The Extent of JBI LLC Seeks and the Reason It Seeks Such Relief: 

JBI submits this application in accordance with the Reform Act, 112 P.L. 95 §§331-334, 

seeking relief from any currently applicable federal aviation regulations pertaining to 

UASs (unmanned aircraft systems) and operating to prevent JBI contemplated 

commercial inspections, and other flight operations within the U.S. national airspace 

system. 

The Reform Act in §332 provides for such integration of civil UASs into our national 

airspace system as it is in the public's interest to do so. JBIs lightweight UASs meet 

the definition of "small unmanned aircraft" as set forth in §333 and combined with a 

great safety record in similar industries, JBIs light duty UASs are ideal recipients of 

exemption by the intent of the Reform Act. 

Considerations for relief include a combination of sUAS physical characteristics, safety 

features, and safe practices identified in §333: 

* UAV weight,

* UAV overall size,

* UAV speed over ground

* UAV flight characteristics, 

14 C.P.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the 

Manual for maintenance and use of safety check lists prior to each flight, a subset of 

which are provided in enclosed Supplemental material, an equivalent level of safety will 

be provided.

14 C.F.R. §91.119: Minimum safe altitudes

§91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters 

by the FAA. As this exemption is for a UAS that closely mimics the behavior of a 

helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, 

an exemption may be needed to allow such operations. As set forth herein, the UAV

will never operate at higher than 400 AGL or beyond unaided visual line of sight, 

whichever is closer. It will however be operated in a restricted area with officials tasked 
with ensuring public safety, and where buildings and people will not be exposed to 

operations without their pre-obtained consent and training. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the location where it is operated. No flight operation will be taken without the 

permission of the controlling agency or right of way owner in the case of private 

property or local officials in the case of public property or private property with public 

interests. Because of the advance notice to the property owner and participants in the 

remote sensing activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far more 

than the maximum 8.2kg of JBIs heaviest UAS proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft operating at or below 500 AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between these 

small- UAV operations and the operations of conventional aircraft that must comply 

with §91.119. 

14 C.F.R. §91. 121 Altimeter Settings

§91.121 requires 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 altimeter setting available before departure." As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. The PIC 

and Technician will also ensure effective pairing with multiple GPS sources to 

guarantee accurate detection of height. 

14 C.F.R. §9 1.15l (a): Fuel Requirements for Flight in VFR Conditions

§91.151 (a) prohibits an individual from beginning "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:' The battery powering the UAS provides approximately 25 

minutes of powered flight in hover mode with payload. JBIs UAS will not be able to 

meet the 30 minute reserve requirement in 14 CPR §91.151. JBI believes that an 

equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of 

battery power whichever happens first. This restriction would be more than adequate 

to return the UAS to its planned landing zone from anywhere within its limited operating 

area.
14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter...;' and others shall inspect or maintain 

the aircraft in compliance with Part 43. Given that these section and Part 43 apply only 

to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight 

manual. An equivalent level of safety will be achieved because these small UAV are 

very limited in size and will carry a small payload and operate only in restricted areas 

for limited periods of time. If mechanical issues arise the UAS can land immediately 

and will be operating from no higher than 400 feet AGL. The operator will ensure that 

the UAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

An exemption granted to JBI would permit its operation of lightweight, unmanned, 

remotely controlled, UAS in a tightly controlled environment with limited airspace. JBI 

utilizes specifically determined areas (designed flight zone) to mitigate injury and 

property damage while fulfilling clients' goals. Technical enhancements to current 

safety controls will allow JBI to operate exceeding current safety specifications, and 

stay ahead of, or meet, new ones being implemented by the FAA and Department of 

Transportation. Further, JBI conducts its operations in compliance with protocols 

described herein or as otherwise established by the FAA 

II. Commercial and Public Benefits 

We at JBI believe that granting this exemption request furthers the public interest by 

providing safe (by way of an unmanned system) and efficient means to meet technical 

problems solvable by elevated data collection instruments. JBIs client base are 

typically business' looking to improve reliability and power delivery with their 

awareness of structures on their respective properties through data collection by 

photographic, video graphic based inspections. By moving these functions onto the 

UAS based platform the potential for loss of life or property is diminished due to the 

greater control in a smaller and safer aircraft that holds no persons. Second, there are 

no reactive or combustible materials on board the UAV and thus the potential for fire or 

explosions is greatly diminished. Third, the small size and extreme maneuverability of 

JBIs UAS allow the PIC to avoid hazards. Lastly, due to the nature of the remote 

sensing instrumentation onboard, the UAS can maintain quite a safe distance between 

the UAS and the object(s) undergoing scrutiny. Accordingly, JBI UAS have operated 

and will continue to operate at and above current safety levels. 
A. The costs and benefits of your proposed action to society in general and specific 

groups within society

The impact to society, financial and otherwise, would be extremely minimal. Indeed, it's 

been demonstrated that UASs have the ability to drastically increase the information 

available to policymakers at a fraction of the cost of measuring this data by terrestrial 

means. Electricity outages can be minimized, problems can be found before they 

become a hazard. One such impact would be inconvenience to directly proximal and 

non-essential personnel that would be displaced from public or business owned 

property if it is deemed to be unsafe. In this case we relay our needs for a flight zone 

with the requirement that it be safe from casual intrusions and allow the business time 

to shift operations in order to minimize potential safety issues.

1. The effect of an exemption for JBI on the quality of the natural and social 

environments 

Utilizing UAS minimizes the requirement for conventional aircraft. This eliminates the 

need for an onboard pilot, time consuming adherence to regulations surrounding book 

keeping and submission of flight paths to local civilian or military airports, and 

detrimental effects to the environment caused by operating a combustible fuel based, 

large scale aircraft, with restrictions on the proximity to the target for remote sensing. 

Ill. Flight Capabilities and Characteristics of JBIs UAV

Pursuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall 

capabilities and 1 characteristics of the UAS. JBI UAS utilizes six (hex) or four (quad) 

counter-rotating propellers paired oppositely to each other for balance, control and 

stability. The total span of the UAS Hex is 900mm, Quad 350mm allowing for stable 

flight or landing even with the sudden onset of detrimental environmental conditions. 

The Hex UAS has a maximum unit takeoff mass of 8.2kg, The Quad has a maximum 

takeoff weight of approximately 1.5kg, including cinematic/photographic or other 

surveying equipment. JBIs UAS is designed to primarily hover in place to capture 

photographic data and then operate at less than a 50 knot maximum speed to the next 

point of interest. They are capable of vertical and horizontal operations but, in practice, 

is operated only within unaided VLOS of the Pilot. In addition to the PIC, JBI will utilize 

a Visual Observer (VO) which are within unaided verbal communication range. These 

personnel may be supplemented by safety officials provided by the client who are 

instructed to cordon off and otherwise minimize pedestrian access in the flight zone of 

the client's grounds. In the event of loss of visual of the UAV, the PIC can change flight 

controls from cartesian (X,Y,Z) based controls to radial (r,a ,h) based controls which 

allows the PIC to utilize one controller axis to recall the UAS to the PIC's position 

without concern to the current heading of the UAV. In the event of loss of sight of the 

sUAS into an area containing hazards or possible hazards, the spotter or pilot has a 

heads-up-display containing a live video feed which can be used to locate the UAV 

while it maintains it's position in hover mode. The UAS has demonstrated it's ability to 
maintain it's position by GPS coordinates in hover mode in "-'25kph wind gusts at 

2.5m representing an extreme environmental condition beyond the range of conditions 

within the scope for UAV operation. All of JBIs UAV utilize LiPo (lithium polymer) battery 

based power sources, decreasing safety risks from more easily combustible, fuel 

based, power sources. Flight times generally last between fifteen (15) to twenty five 

(25) minutes allowing the staff to work with small flight areas per phase. The maximum 

flight time without payload is 45 minutes, however practical safe operation limits this to 

30 to give ample time to control the UAS to a safe landing zone. JBI further restricts 

flight time by not operating its UAS with less than twenty five percent battery capacity. 

Further safety management systems in place include a GPS mode that allows JBI UAV 

to hover in place and land if communication with the PIC is lost and optionally follow a 

set of waypoints at a set speed and height to a 'home base' predesignated safe 

landing zone. In the event of unforeseen motor failure, the Hex system will enter into a 

controlled hover mode while allowing full use of all UAS flight controls by the PIC. All 

commands sent via remote controller received during a controlled return to land are 

translated to an 'as meant' paradigm meaning the flight control package will use it's 

realtime 3 dimensional position and compensate rotors control the UAS regardless of 

spin velocity. Landing gear is also programmed to deploy based on sensing of range to 

ground from non-GPS based sources. This assures that if one system is compensated 

a safe and successful landing can still occur. 

IV. Reasons Why an Exemption to JBI Will Not Adversely Affect Safety Standards 

JBIs contends that operation of it's UAS will not "create a hazard to users of the 

national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the 

diminutive size and weight of JBIs UAS, combined with their operation in cordoned off

and well-controlled areas, JBIs UAS falls within Congress's contemplated safety zone. 

JBIs UAV have an established safety record. The pilots have many years of hobby UAS 

flying and a combined total 37 years full size helicopter flying within the Oil and Gas 

Industry, EMS, Army Aviation and part 135 operations. Bolstered by multi-point 

preflight checklist, General Operations Manual, Maintenance Manual, Training guides 

and awareness of their surroundings and intimate knowledge of the FARs and behavior 

of the UAV platform in many weather conditions. JBIs safety record and implemented 

operational practices demonstrate an awareness of public safety.

JBI operations routinely provide a level of safety at least equal to existing rules, and in 

nearly every instance, exceeds existing rules. JBI has worked very closely with the 

regional vendors and support for this unit to create a tightly integrated and highly fault 

tolerant platform that has been tested throughly by a vendor with a proven record for 

safety and solid designs. 

Though it does not mitigate safety it is of note that as of Nov 2014 there are few 

companies that will insure UAS operations and UAS based companies. The UAS of use 

at JBI is one of two models (by current awareness) that qualify for protection against 

damages or injury. JBI also continues to work closely with this organization (FAA) to 
identify and mitigate UAS platform risk due to their expertise in several industries 

closely related to the aviation and transportation.

JBI does not intend to operate its UAS on or near airports unless permission is granted 

and generally has only operated its fleet on grounds with cordoned off areas or areas 

under the control of the property owner I client with assistance by safety officials 

employed by the business. JBI determines the areas needed to fulfill the clients' goals 

and only operates its UAVs in these flight zones and only in compliance with well 

regarded safety protocols set forth initially by the RC UAS trade and hobby groups and 

recently by relevant FARs. 

JBI standardized on the following practices to ensure safe operation of it's UASs: 

* Work with on-site personnel to plan the flight goals,

* Work with on-site personnel to restrict access to non-essential persons,

* Operation by unaided VLOS operation only,

* Operation in phases 30 minutes max in length,

* Operation to minimal 25% battery power,

* Operation of device to GPS aided readout to 400ft at maximum,

* Numerous pre-programmed fail-safes that ensure specific behavior per issue,

* Three main roles supplemented by on-site safety personnel,

* Employ controlled lifecycle and total time management of components to guard 

against component failures, 

* Subscribe to relevant local weather and safety alerts, 

Expertly choose data collection instruments and accessories to minimize flight 

requirements or expertise, 

JBI has experience in similar fields and has adapted this experience in it's use of UAS’s 

to increase safety. In combination to the ever expanding knowledge repositories from 

hobbyists and experts alike, JBI is constantly evolving it's practices when there is a 

clear benefit to operations or increased safety element. 
A. Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

JBI {applicant) seeks an exemption from the following rules: 14 C.P.R. §§61.113 14 

CFR 91.7 (a); 91.119; 91.121; 91.151(a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 

(a) {2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (8.2kg or 

less) in elevated photographic and remote sensing operations. 

Approval of exemptions allowing commercial operations of UAS in the the media 

industry will enhance safety by reducing risk associated with conventional aircraft 

operations and other means of elevated remote sensing involving persons. The public 

benefit served by approval of this petition is increased awareness of characteristics of 

difficult imaging targets. A UAS weighing fewer than 8.2kg and powered by sealed 

batteries eliminates virtually all associated risk inherent in operating conventional 

aircraft in close proximity to buildings or persons or otherwise elevating persons to a 

position they would be able to collect needed data. 

The operation of small UAS’s, weighting less than 8.2kgs, conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. As identified and 

described herein, Gary Boozer and David James, and their company JB Aerial LLC (JBI 

LLC), are experienced, aviation professionals in the various industries. Gary Boozer 

and David James have a combined 37 years of violation, incident and accident free 

aviation experience. The FAA has been given the authority to issue the exemption to JB 

Aerial LLC (JBI LLC) pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as 

such, we humbly seek your consideration and approval of this petition. 

David James

Gary Boozer