JSM Marketing, LLC 299 Main Street We bster, Ma 01570

11/20/15 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Wa shington, D.C. 20590 by/for JSM Marketing, LLC 299 Main Street We bster, Ma 01570 **RE: Exemption Request Section 333 of the FAA**  **Reform Ac** **t** of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a);91.9(b) (2); 91.103(b);91.109; 91 .121;91.151(a); 91.203(a)&(b);91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) Dear Sir or Madam: This petition is being submitted with no legal counsel or consulting services. I am submitting a petition for exemption for unmanned aircraft systems operations on behalf of my company JSM Marketing, LLC , pursuant to t he FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11 . I am the owner of this business . I am born in the United States of America, and currently reside in Massachusetts

. I am also a graduate of Long Island University with a degree in Pharmacy

. I also am pursuing a career in real estate in the state of Massachusetts

. I am making a request for a waiver of the sections listed above so that my business , JSM Marketing, LLC , can legally operate unmanned aircraft systems commercially in order to conduct aerial photography and videography services for residential, commercial and industrial real estate , to survey private ly owned land, inspections, and for events and promotional purposes , motion picture production, surface mining, d isaster and catastrophe events closed set motion picture and television filming

. I understand that the current regulations require that a licensed pilot be at the controls of all unmanned aerial systems, and as a business, we intend to adhere to these regulations.
All sUAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowledge. Only people who have consented orotherwise have agreed to be in the area where photography and videography will take

place will be captured in any photos or videos.
I am requesting the following exemptions under Section 333 of the FAA Reform Act of the Federal Aviation Regulations : 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91 .121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) **Suggested Public Federal Register Summary :**  “The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new FAA “Summary Grant” approach, announced April 9th, 2015 ( http://www.faa.gov/news/updates/?newsId=82485 ) that will help speed up Section 333 exemption approvals for many commercial UAS operators prior to finalizing the small UAS proposed rules published this past February. It is my understanding that the FAA will still review each Section 333 petition individually. However, I am hoping that the agency will accept my particular petition, and inclu de it in the next summary grant, and issue me an exemption on the presumption that the FAA has “already granted a previous exemption similar to this request”. Apparently, the new interim policy includes the granting of a Certificate of Wa iver or Authorizat ion (COA) for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports such as 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from a n airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure. It is also understood that the “blanket” 200

-foot COA allows flights anywhere in the country except restricted airspace and othe r areas, such as major cities, where the FAA prohibits UAS operations.**UA S Description:** 

Although I am asking for an exemption for piloting unmanned aircraft systems up to 55 pounds , JSM Marketing, LLC plan s on using commercially manufactured systems that will weight much less

– somewhere between three and ten pounds

. Weare petitioning for exemption to enable JSM Marketing, LLC to operate a series of UAS platforms such as the DJI Phantom2, DJI Phantom 2 Vision, DJI Phantom 2 Vi sion+, DJI Inspire, DJI S1000, DJI S900, DJI S800 , Flamewheel 550, Q500 Typhoon, DJI Phanton 3 , 3D Robotics Iris , 3DRobotics Iris+, and the 3D Robotics Solo drones , Cinestar 8 Octo, Altavian Nova F6500, Blade 350 QX3, AgEagle, 3DRobotics X8, SenseFly eBee , Yuneec Q500 Typhoon, DraganFlyer X4

- ES, Trimble UX5, and Microdrones MD4

– weighing much less than 25 pound s . From a safety and operational perspective, both of these units can be manually operated and software controlled making flight more predictable. These units have “return to home” features, geo

- boundary limitations, and other safety features built into their hardware and software. Both of the companies that manufacture these devices have excellent reputations for providing all of the necessary too ls and education to fly safely and respect FAA rules and regulations. These UAS systems have limited flying time capabilities (approximately 20 minutes of flight on a charge), do not carry anything other than a camera, operate by battery power, and do not carry flammable fuel. In fact, in the event of the loss of communications with the pilot, these devices are programmed to “return to home” and/or travel a pre

-determined route to land safely. All pilots who operate unmanned aircraft systems for JSM Marketing, LLC will be licensed pilots and will receive proper training on the UAS that they will be flying. Each pilot will be responsible for assuring that their UAS is airworthy before each flight, and will be responsible for conduction pre and post flight inspections. At no time during a flight will the UAS ever be out of line of site, and aircrafts will never be flown more than 35 miles per hour.

**Ad ditional Points:**  UAS technology is changing rapidly, and so are the people that are piloting them. I und erstand the importance of choosing reliable products that are built by reliable companies. Both DJI and 3D Robotics are companies managed by smart people who work closely with their pilot

- clients to improve their products and the safety of them. Both of these companies respect the FAA’s rules and regulations and understand the value that a trained pilot add s to the safe operation of their products.
**Flight Operations and Maintenance**  **:** For the purpose of UAS activities, all flying will take place in VFR conditions and will end when the battery reserves reach 25 percent. Preflight and post

-flight check lists will beused to help identify any defects prior to and after flight. Any UAS th at do not meet the

qualifications for safe fl ight will be removed from service until they have been repaired and deem airworthy. A flight briefing will take place before each flight and shared with anyone in the general vicinity of the flight. All flying activity will be in accordance with current FAA UAS rules and regulations

.
**How this Request is to the Betterment of our Community**  Webelieve that the use of UAS to perform agricultural land imaging creates a benefit to the public. The ability to use an onboard geo

- referenced still camera to collect high

resolution data that can be used to increase crop production and reduce unnecessary chemical use will provide a less expensive and healthier food supply to the public. The unmanned aircraft does not carry any persons or flammable liquids, reducing public exposure in the event of an incident. Finally, the unmanned aircraft can be launched and recovered from the property which we have been contracted to image. The ability to avoid overflying private and pub lic properties provides the public with the benefit of privacy from aircraft flying overhead. Unmanned Aircraft Systems (sUAS) are also a feasible method to obtain information of agricultural cropland to determine optimum inputs that result in cost savings to farmers, yield security, and reduce environmental impact of excess fertilizers and chemicals in the soil. **Section 333 Compliance and A ppropriateness:**  Based on the size of the craft that we will be using , the experience of the owner of the company , and operational goals, this request appears to be well suited for approval using the current criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 (including new interim policies)

. I eagerly await your approval. Sincerely, JSM Marketing, LLC Mark J Rubin 299 Main Street We bster, Ma 01570