Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

JACK CARR MORGAN, PE/PS 

August 25, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Jack Carr Morgan, PE/PS Petition for Section 333 Exemption 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act and 14 C.F.R. Part 11, Jack 

Carr Morgan, PE/PS (“Applicant”), Professional Engineer and Land Surveyor and operator of 

small unmanned aircraft systems ("UAS") equipped to conduct professional aerial topographic 

land surveying and geospatial services, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FAR") to allow commercial operation of UAS, so long as such operations 

are conducted within and under the conditions outlined herein. 

The requested exemption would permit the operation of small, unmanned UAS to provide safety 

enhancements to the already safe operations in the mapping and surveying industry currently being 

conducted using manned aircraft. 

Applicant has provided topographic surveys to the Flood Protection community for over 35 years. 

Failures of levees and drainage present serious threats to the public safety. As part of agreements 

between states and federal governments, topographic surveys are required every two years to insure 

integrity of the levees. Because of the extensive levee system in south Louisiana, and the fact that 

many of the levees are remotely located, the surveys are difficult to conduct and expensive for the 

Levee Boards across the state that oversee the levees in their jurisdiction. The levees impact the 

health of wetlands and other plant and animal life. The use of UAS in commercial/residential 

areas and in remote rural areas will provide much clearer and current information for the Levee 

Boards than can be reasonably acquired using conventional on-the-ground surveying methods. 

The levees can also be accessed and surveyed more frequently than is currently fiscally possible 

using traditional manned aircraft methods. 

Applicant uses UAS’s which are battery-powered rotorcraft, weighing less than 55 lbs. including 

payload. They will operate only in line of sight of the Pilot in Charge (PIC). Given the small size of 

the UAS and the lack of flammable fuel, the approval of the application presents no national 

security issue. Given the significant public benefit, including enhanced safety, reduction in 

environmental impacts, including reduced emissions associated with allowing UAS for surveying 

and mapping operations, the grant of the requested exemption is in the public interest. 

 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

The limitations and conditions to which Applicant agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1) Operational Limitations

a) Unmanned aircraft must weigh less than 55 lbs. (25 kg). 

b) Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the 

operator or visual observer. 

c) At all times the small unmanned aircraft must remain close enough to the operator for the 

operator to be capable of seeing the aircraft with vision unaided by any device other than 

corrective lenses. 

d) Small unmanned aircraft may not operate over any persons not directly involved in the 

operation. 

e) Daylight-only operations (official sunrise to official sunset, local time). 

f) Must yield right-of-way to other aircraft, manned or unmanned. 

g) May use visual observer (VO) but not required. 

h) First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as 

long as requirement is satisfied in other ways. 

i) Maximum airspeed of 100 mph (87 knots). 

j) Maximum altitude of 500 feet above ground level. 

k) Minimum weather visibility of 3 miles from control station. 

l) No operations are allowed in Class A (18,000 feet & above) airspace. 

m) Operations in Class B, C, D and E airspace are allowed with the required ATC permission. 

n) Operations in Class G airspace are allowed without ATC permission 

o) No person may act as an operator or VO for more than one unmanned aircraft operation at 

one time. 

p) No careless or reckless operations. 

q) Requires preflight inspection by the operator. 

r) A person may not operate a small unmanned aircraft if he or she knows or has reason to 

know of any physical or mental condition that would interfere with the safe operation of a 

small UAS. 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

s) Regarding the Unmanned Aircraft System 

t) Applicant proposes that the proposed UAS operation will be safely conducted to minimize 

risk to the NAS or to persons and property on the ground. The design and operational 

characteristics for the types of UAS that Applicant intends to operate will be as described 

in this application. 

2) Operator Certification and Responsibilities

a) Pilots in Charge (“PIC”) of small UAS are considered “operators”.

b) Operators are required to: 

c) Pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center, 

when such test is available. 

d) Be vetted by the Transportation Security Administration. 

e) Obtain an unmanned aircraft operator certificate with a small UAS rating, when such 

certificate is available. In the meantime, operators will hold either a Commercial, Private, 

Recreational, or Sport Pilot’s license. 

f) Pass a recurrent aeronautical knowledge test every 24 months, when test is available. 

g) Be at least 17 years old. 

h) Make available to the FAA, upon request, the small UAS for inspection or testing, and any 

associated documents/records required to be kept under the proposed rule. 

i) Report an accident to the FAA within 10 days of any operation that results in injury or 

property damage. 

j) Conduct a preflight inspection, to include specific aircraft and control station systems 

checks, to ensure the small UAS is safe for operation. 

k) The Operator Certification and Responsibilities described in this Application are required 

of any PIC or other operator, including visual observers, who will be directly responsible 

for the operation of the UAS. 

l) Operators will be required to provide a valid driver’s license or pass the physical 

requirements associated with the active pilot license the operator holds.. 

3) Aircraft Requirements

a) FAA airworthiness certification will not be provided; however, operator must maintain 

small UAS in condition for safe operation, and prior to flight must inspect the UAS to 

ensure that it is in a condition for safe operation. Aircraft Registration is required (same 

requirements that apply to all other aircraft). 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

b) Aircraft markings are required. Because the aircraft is too small to display markings in 

standard size, the aircraft will display markings in the largest practicable manner. 

c) The Applicant assures that the Radio Frequency (RF) spectrum used for control of the UAS 

and associated equipment that is part of the UAS will be in compliance with Federal 

Communications Commission (FCC) or other appropriate government oversight agency 

requirements. Applicant will be able to provide the FCC approval letter or show 

compliance with FCC requirements upon request. 

d) FAA airworthiness certification will not be provided; however, operator must maintain 

small UAS in condition for safe operation and prior to flight must inspect the UAS to 

ensure that it is in a condition for safe operation. Aircraft Registration is required. 

4) Regarding the Operation of the Unmanned Aircraft

a) Applicant assures that the intended UAS operation will not adversely affect safety, and the 

following will describe how a level of safety will be provided that is at least equivalent to 

that provided by the rule from which exemption is sought. Applicant describes plans to 

implement clearly defined operational borders and procedures to ensure public safety, 

which includes persons and property both in the air and on the ground. Applicant will 

address the proposed operation with respect to safety of flight, NAS safety considerations, 

and the safety of the non-participating persons and property during the operational period 

and within the operational area. 

5) Regarding Safety of the Operation of the Unmanned Aircraft

a) Applicant assures the proposed maximum operating speed and altitude, and minimum 

flight visibility and distance from clouds for intended operation will be as described in this 

application. Potential hazards will consist primarily of interference with existing trees, 

towers, and power lines. All towers and power lines above 100 feet AGL will be mapped 

in advance of operation, and verified visually prior to ascent. Operation elevation will 

generally be above the trees. In some situations such as bridge structure assessment, very 

close proximity will be required to gather the level of detail required. In those unusual 

situations, there will be an increased possibility of impact damage to the UAS itself 

because of proximity to the structure, but the light weight and fragility of the UAS and the 

requirement that no unassociated persons or property are below the aircraft, will reduce the 

potential damage to only the UAS itself. As with all operations, each situation will be 

assessed prior to ascent to determine the appropriate level of additional or special 

precaution that the specific operation warrants. 

6) Regarding Air Space Restrictions

a) Applicant is requesting a general exemption to operate a UAS in Class G airspace without 

ATC permission, and in Class B, C, D, and E airspaces with the required ATC permission. 

No operation will be allowed in Class A airspace. Operations will generally be over 

restricted-access public property, including levees, flood walls, pump stations, treatment 

plants, wetlands, and open water. In all cases, no flights will be over persons or properties 

not associated with the operation. 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

b) Applicant assures that before conducting operations which have existing requirements to 

notify Flight Standards District Offices (FSDOs) prior to operations, Applicant will notify 

affected FSDO in advance with detailed flight plan and description of proposed operation. 

c) Applicant will occasionally need to operate UAS within a five-mile radius of airports. 

When flown within 5 miles of an airport, the operator of the aircraft will provide the airport 

operator and the airport air traffic control tower, if present, with prior notice of the 

operation. 

7) Regarding Preflight Procedures

a) Applicant assures procedures described in this Application will be implemented for 

conducting a preflight safety risk assessment to determine that the UAS is in a condition for 

safe flight and that the planned operation can be completed safely. Operators are required 

to conduct a preflight inspection, to include specific aircraft and control station systems 

checks, to ensure the small UAS is safe for operation. 

8) Regarding Certificate of Waiver or Authorization

a) The Applicant understands that the FAA intends to provide “blanket” Certificate of Waiver 

or Authorization (COA) as part of the UAS Exemption process for certain generic 

conditions and air spaces. If the Applicant desires to work in air space not included in the 

“blanket” COA, Applicant will acquire the appropriate approvals from the FAA Air Traffic 

Organization prior to conducting operations in the NAS. 

9) Regarding Exemptions from Specific Regulations

In seeking this authorization, Applicant will require exemptions from regulations with which 

he cannot fully comply. The table below provides specific information regarding regulations 

from which Applicant requires exemption. 

i) 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

(1) Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR § 

91.203 (a) (1). Given the size and limited operating area associated with the 

aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of 

the Reform Act. Section 44701 (t) of the Act and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS's operated without 

an airworthiness certificate, in the restricted environment and under the conditions 

proposed herein will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

(2) The UAS's to be operated hereunder are less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively within a secured area as set out in the Safety 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

Checklist. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the Applicant pursuant to the Safety 

Checklist's requirements, and under the requirements and in compliance with local 

public safety requirements, to provide security for the area of operation as is now 

done with conventional aerial mapping and surveying. These safety 

enhancements, which already apply to civil aircraft operated in connection with 

mapping and surveying operations, provide a greater degree of safety to the public 

and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed 

by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. 

ii) 14 C.F.R. § 45.23 (b). Marking of the Aircraft 

(1) This regulation requires: 

(a) "When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as 

applicable." 

(2) Even though the UAS's will have no airworthiness certificate, an exemption may 

be needed as the UAS's will have no entrance to the cabin, cockpit or pilot station 

on which the word "Experimental" can be placed. Given the size of the UAS's, 

two-inch lettering will be impossible. The FAA has issued the following 

exemptions to this regulation in Exemptions Nos. 10700, 8738, 10167 and 

10167A. 

iii) 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command 

(1) Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS' s will not carry a pilot or passengers, the proposed operations 

can achieve the equivalent level of safety of current operations by requiring the 

PIC's operating the UAS's to have a private pilot's license rather than a commercial 

pilot's license to operate this UAS's. Unlike a conventional aircraft that carries the 

pilot and passengers, the UAS's are remotely-controlled with no living thing on 

board. The area of operation is controlled and restricted, and all flights are planned 

and coordinated in advance. The risks associated with the operation of the UAS's 

are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the UAS's as 

requested with a private pilot as the PIC exceeds the present level of safety 

achieved by 14 C.F.R. §61.113 (a) & (b). 

iv) 14 C.F.R. §91.7(a): Civil aircraft airworthiness 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

(1) 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 Safety Checklist for maintenance and use of the Safety Checklist 

prior to each flight, an equivalent level of safety will be provided. 

v) 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

(1) Section 91.9 (b) (2) provides: 

(a) "No person may operate a U.S.-registered civil aircraft ... 

(b) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of 

this chapter, unless there is available in the aircraft a current approved airplane 

or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof." 

(2) The UAS's, given their size and configuration have no ability or place to carry such 

a flight manual on the aircraft, not only because there is no pilot on board, but 

because there is no room or capacity to carry such an item on the UAS's. 

(3) The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point to which the UAS's pilots flying the UAS's will have 

immediate access. The FAA has issued the following exemptions to this 

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 32827, and 10700. 

vi) VI. 14 C.F.R. § 91.103: Preflight action 

(1) This regulation requires each pilot in command to take certain actions before flight 

to insure the safety of flight. As FAA-approved rotorcraft flight manuals will not 

be provided for the aircraft, an exemption will be needed. The PIC will take all 

actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. 

vii) VI. 14 C.F.R. § 91.105 Flight crewmembers at stations 

(1) This regulation requires each crew member to take certain actions before flight to 

insure the safety of flight. As no crew members will be aboard the aircraft, the 

crew members do not require safety belts or harnesses. 

viii) VII. 14 C.F.R. § 91.109: Flight instruction 

(1) Section 91.109 provides that no person may operate a civil aircraft (except a 

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

has fully functioning dual controls. 

(2) UAS's and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

exemptions for flight training without fully functional dual controls for a number 

of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 

5778K & 9862A. The equivalent level of safety is provided by the fact that neither 

a pilot nor passengers will be carried in the aircraft and by the size and speed of the 

aircraft. 

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

(1) Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119(d) allows helicopters, powered parachutes and weight-shift-control 

aircraft to be operated at less than the minimums prescribed because their low 

speed and responsive controls allow operations to be conducted, "without hazard 

to persons or property on the surface ...".As UAS possess similar flight and control 

characteristics, and as the exemption requests authority to operate at altitudes up to 

400 feet AGL, an exemption may be needed to allow such operations. As set forth 

herein, except for the limited conditions stated in the Safety Checklist, the UAS's 

will never operate at higher than 400 feet AGL. 

(2) Compared to flight operations with aircraft or rotorcraft weighting far more than 

the maximum 55lbs. 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 feet AGL in the mapping and 

surveying industry. In addition, the low-altitude operations of the UAS's will 

ensure separation between these UAS operations and the operations of

conventional aircraft that must comply with Section 91.119. 

x) 14 C.F.R. § 91.121 Altimeter Settings 

(1) This regulation 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's 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. 

xi) 14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

(1) Section 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." 

(2) The current battery technology powering UAS's is much more limited than that of 

combustion powered flight. As such, the Applicant's UAS's cannot presently and 

likely may never will meet the reserve requirement in 14 CPR § 91.151. Given the 

limitations on the UAS's proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

VFR conditions is reasonable. As no night flight will occur, that portion is 

inapplicable. 

(3) Applicant believes that an exemption from 14 CPR § 91.151 (a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the 

UAS's in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risks that Section 91.151 (a) 

was intended to alleviate given the size, speed and limited operating area of the 

UAS's. 

(4) Applicant believes that an equivalent level of safety can be achieved by limiting 

flights based on expected battery life, currently 20 minutes, or 20% of battery 

power when future technology expands the battery life. This restriction would be 

more than adequate to return the UAS's to their planned landing zone from 

anywhere in its limited operating area. 

(5) Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673,and 10808. 

xii) 14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration 

(1) The regulation provides in pertinent part: 

(a) "(a) except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: 

(i) An appropriate and current airworthiness certificate... 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible 

to passengers or crew." 

(2) The UAS's fully loaded weigh no more than 55 lbs. and are operated without an 

onboard pilot. As such, there is no ability or place to carry certification and 

registration documents, or to display them on the UAS's. 

(3) An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the UAS's pilots flying the UAS's will have immediate 

access to them, to the extent they are applicable to the UAS's. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other 

exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 

9816A, and 10700. 

xiii) 14 C.F.R. § 91.405 (a): Maintenance Inspections 

(1) 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 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

repaired as prescribed in part 43 of this chapter ...," and others shall inspect or 

maintain the aircraft in compliance with Part 43. 

(2) Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the UAS's as proposed to be operated by 

the Applicant. Maintenance will be accomplished by the Applicant pursuant to the 

flight manual and operating handbook. An equivalent level of safety will be 

achieved because these UAS's 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's can land immediately and will be operating 

from no higher than 400 feet AGL. The Applicant 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 Applicant 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. 

xiv)14 C.F.R. § 91. 407 (a) (1): Maintenance Inspections 

(1) 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. 

(2) Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the UAS's as proposed to be operated by 

the Applicant. Maintenance will be accomplished by the Applicant pursuant to the 

flight manual and operating handbook. An equivalent level of safety will be 

achieved because these UAS's 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's can land immediately and will be operating 

from no higher than 400 feet AGL. The Applicant 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 Applicant 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. 

xv) 14 C.F.R. § 91. 409 (a) (1) & (2): Maintenance Inspections 

(1) 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. 

(2) Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the UAS's as proposed to be operated by 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

the Applicant. Maintenance will be accomplished by the Applicant pursuant to the 

flight manual and operating handbook. An equivalent level of safety will be 

achieved because these UAS's 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's can land immediately and will be operating 

from no higher than 400 feet AGL. The Applicant 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 Applicant 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. 

xvi)14 C.F.R. § 91. 417 (a) & (b): Maintenance Inspections 

(1) 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. 

(2) Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the UAS's as proposed to be operated by 

the Applicant. Maintenance will be accomplished by the Applicant pursuant to the 

flight manual and operating handbook. An equivalent level of safety will be 

achieved because these UAS's 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's can land immediately and will be operating 

from no higher than 400 feet AGL. The Applicant 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 Applicant 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. 

The name and address of the applicant ("Applicant") is: 

Jack Carr Morgan, PE/PS 

Attention: Jack Morgan 

118 Farrar Lane 

Waveland, Mississippi 39576 

Telephone: (504) 452-7694 

Email:JMorganPEPS@Hotmail.com

 
Jack Carr Morgan, PE/PS 

118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694 

Email: JMorganPEPS@Hotmail.com

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: 

Approval of exemptions allowing commercial operations of UAS's in the mapping and surveying 

industry will enhance safety by reducing risk associated with conventional mapping and surveying 

operations, using manned aircraft operating at low altitudes and in proximity to people and 

structures. UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of 

that risk given the reduced mass and lack of combustible fuel carried on board. The UAS are carried 

to the mapping or surveying site and not flown. The UAS crew remains in control from the ground, 

not exposed to the risks associated with manned aircraft flights. 

The operation of UAS's, weighing less than 55 lbs., 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. These lightweight aircraft operate at slow speeds and close to the ground, 

as a result, are far safer than conventional operations conducted with turbine helicopters or other 

manned aircraft operating in close proximity to the ground and people. 

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capabilities, proximity to airports and operation within visual line of sight and national 

security - provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of Applicant's UAS's in the mapping and surveying industry. 

Applicant seeks an exemption from the following rules: 

14 C.F.R. § 21, subpart H; 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); 91.105 (a) & (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 

91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to operate commercially 

small unmanned aircraft systems (55 lbs. or less) in mapping and surveying operations. 

The aircraft will be operated solely in the continental United States.

The aircraft used will be a mixture of professional-grade aircraft, including but not limited to DJI 

Phantom 3, DJI S1000, and other comparable aircraft by the same and other manufacturers. 

Aircraft are small all-electric drones that provide precision 3D mapping, real-time thermal infrared 

and high definition photographic and video capabilities. The systems deploy quickly in nearly 

every environment due to their light weight. The DJI aircraft have been previously approved by the 

FAA under this exemption process on numerous occasions, and any other brand and type aircraft 

used will have also been previously approved. All aircraft will be registered with FAA before 

deployment. 

Very truly yours, 

]tv~ VtÜÜ `ÉÜztÇ 

Jack Carr Morgan, PE/PS