July 16, 2015

U. S. Department of Transportation IFlyJax LLC

Docket Management System William Brady brady3@gmail.com

1200 New Jersey Ave ., SE 284 Odoms Mill Blvd

Washington , DC 20590 Ponte Vedra, FL 32082 

(253)222-1430

Re: Petition for exemption seeking relief from FAA Modernization and Reform Act of 2012, Public Law 

112-95 FEB 14,2012, Section 333.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, iFlyJax, LLC ("iflyjax"), the 

operator, William Brady (the applicant), planned operator of Unmanned Aircraft Systems (UASs) 

equipped to conduct aerial photography for various industries in United States National Airspace Not 

deemed a “No Drone Zone” by the FAA. 

On this day, iFlyJax hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow 

commercial operation of our UASs.

Relief from Title 14 Aeronautics and Space Code of Federal Regulations:

1. Part 21 subpart H - Airworthiness certification requirements.

Airworthiness certification relief to the extent required to perform UAS VLOS flights in safe conditions. 

2. Part 61 Pilot Certification

PIC relief to the extent practical for UAS operation. PIC will hold required certification and rating as 

described in FARS.
3. Part 91 General Operating Flight Rules

91.103(b)(2) Preflight action 

Prior to every flight, the PIC will perform preflight procedures including: compass calibration, camera 

verification, GPS hold test and flight control testing in a safe area at or below 10 feet AGL. Relief is 

requested to the extent applicable relating to UAS.

91.105 Flight crewmembers at stations

Relief is requested to the extent of UAS not having these physical crew members as described.

91.109 Flight Instruction

Relief is requested to the extent available for safe UAV flight training.

91.119 Minimum safe altitudes

Relief is requested in areas that safe altitudes described are not practical.

91.121 Altimeter settings

Relief requested to the extent altimeters are required. Altimeter will be calibrated with GPS prior to 

every flight.

91.151 Fuel requirements in VFR conditions

Relief is requested to the extent required to make practical conversions of battery life to a refillable fuel 

liquid fuel tank.

91.405 Maintenance required

Maintenance will be performed after every flight and software updates made when available. Relief 

requested to the extent available

91.407 Operation after maintenance

Operation and test flights will be made after software updates and recalibration, or after any part is 

removed or replaced. Relief is requested to the extent available.

91.409 Inspections
Inspections will be performed by the PIC relief is requested to the extent of another agency performing 

inspections.

91.417 Maintenance records

Maintenance records will be maintained by iFlyJax LLC, and available on request. Relief is being 

requested to the extent available. As described more fully, the requested exemption would permit the

operation of UASs by the operator for commercial use. Doing so in a safe manner with requested relief 

from the FAA would be in the best public interest. Providing these services in a safe and approved 

manner in accordance with local and State laws would benefit the public as a whole. Attaining the 

required exemptions would demonstrate to the public; capabilities of UAV operation in a controlled 

manner, demonstrating to potential future pilots safe methods and procedures to fly commercial UAVs.

1. Operations would be performed in an area of operation limited in size suitable to the

specific use, in advance of flight.

2. The flight would be planned in advance to minimize hazards to persons and property.

3 . The operator would reasonably limit or control access to provide safety to those not

involved in the operation.

4. Operation of a UAS would provide significant safety, environmental and other

enhancements not possible by larger sized aircraft.

It is possible to operate an UAS so to not create a hazard to users of the National

Airspace System (NAS), the public or pose a threat to national security if done so safely

and responsibly. The applicant has demonstrated their willingness to act safely and

responsibly by not engaging in commercial UAS operations. The applicant has worked

within FAA guidelines to obtain a legal authorization to conduct commercial operations.

Additionally, the fact that the applicant currently holds a FAA Private Pilot

Certificate demonstrates that the applicant has a high regard to safe operations, as well
as a necessary understanding of the NAS and FARs.

The experience of an FAA certificate serves to add significantly to the level of safety in any operation

performed by the applicant or the applicant's employees.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that

have the characteristics of UAS and that operate with the limitations listed herein.

These limitations provide for at least an equivalent or higher level of safety to operations

under the current regulatory structure as the proposed operations represent a safety

enhancement to the already safe aerial commercial photography and survey operations

conducted with conventional aircraft.

The UASs planned to be operated are the dJI Phantom 2 Vision

Plus aircraft (UA) is equipped with four rotors that are driven by electric motors , powered by batteries, 

and weigh less than 4 pounds, including payload . The UA would have a maximum airspeed

of 30 knots . The principal construction material of these UA is plastic. Operations will

be performed by a qualified UAS Pilot in Command (PIC) , as outlined below, to insure

that the UAS will "not create a hazard to users of the national airspace system or the

public." Given the small size of the UAS involved and the pre-planned environment

within which they will operate, the applicant believes that these operations fall squarely

within that zone of safety (an equivalent level of safety) in which Congress envisioned

that the FAA must, by exemption, allow commercial operations of UAS to commence

immediately. Also , operation in a researched (to include applicable NOTAMs) , predefined
area will prevent the possibility of a national security issue . The operation of

UASs by knowledgeable professionals with experience in the NAS will serve to enhance

safety, add to the public benefit and reduce environmental impacts related to current

methods of aerial photography and survey.

These limitations and conditions to which the operator, or its employees, acting as an

UAS PIC , agrees to be bound when conducting commercial operations under an FAA

issued exemption :

1 . Safety will be the first and foremost consideration in any UAS operation .

2 . The UAS pilot will be supervised by an FAA licensed airman with at

least a Recreational Pilot Certificate.

3 . The UAS Pilot, and observer will hold a current State Drivers license.

4 . The UAS airman will be considered PIC and will be responsible for safe operation of the flight.

5 . Flights will be conducted within line of sight of the PIC and an observer.

6 . Flights will be conducted in Class G airspace whenever possible. If an operation in

another airspace is required, the relevant controlling agency will be notified at least

48 hours prior to the operation and , if required , any necessary permission obtained .

7 . Flights will be conducted under visibility and cloud clearance requirements equivalent

to Visual Flight Rules (VFR).

8. The UAS will at all times give way to any aircraft, object, or persons.

9. Minimum crew for each operation will consist of the UAS PIC the,

PIC will at all times maintain visual line of site to the UAV.

10. Prior to a UAS flight, an area of operation will be established . This area of operation
will include a defined lateral and vertical area, where the UAS will operate (Appendix J).

Safety procedures will be established for persons, property and applicable airspace

within the area of operation .

11. Flight planning will include flight completion with at least 10% battery power

remaining as measured by the UAS or appropriate timing.

12. The UAS will utilize GPS navigation, failsafe , return-to-home (RTH) and/or flight abort safety 

features.

13. A briefing will be conducted in regard to the planned UAS operations prior to

operation at each new location. All personnel who will be

performing duties within the boundaries of the area of operation will be present for this

briefing .

14. All required permissions and permits will be obtained from appropriate state , county

or city jurisdictions, including local law enforcement , fire , or other appropriate

governmental agencies .

15. Written, to include electronic, and/or oral permission from the relevant property

owners will be obtained prior to an operation .

16. The UAS pilot will be trained in advance for the safe operation of the UAS to be

operated. This will include operation of the UAS both in normal and emergency modes

of operation as applicable, and will include familiarization with the operation manual (or

similar) if published by the UAS manufacturer. Training will also include types of

maneuvers to be performed and the safe operation in relation to persons, property and

applicable airspace.
Key points about the dji Phantom 2 Vision + (Documentation included in original 4-23-2015 primary 

document ID: FAA-2015-1156-0001) The UAV listed as primary aircraft, the dji Phantom 2 Vision +, 

(P2V+) is one of the leading UAV’s in the Ready to Fly (RTF) market. When the compass is calibrated with 

the GPS prior to take off, the return home point is set. In the application of commercial photography 

proposed by iFlyJax, this original location can be set a safe distance away from people and structures. 

On screen RADAR positioning and Return Home are key features about the P2V+ that make it a 

dependable and safe platform for this service. The flight RADAR displays the current position of the 

P2V+ in relation to the pilot in real time. In the event of communication loss between the controller and 

UAV, this technology automatically triggers the “return Home” feature. Home is the safe location where 

calibration took place, which is set prior to every flight. This feature is tested on a regular maintenance 

interval by iFlyJax in a controlled environment. When communication is severed the UAV climbs to a 

safe altitude then proceeds to fly directly to the take off point then descend at no more than 2 m/s. This 

is a key safety feature that makes the P2V+ a dependable and safe UAV. The total weight of 2.7lbs is well 

under the FAA 4.4lb limit. The Remote Control operating frequency is 5.728GHz – 5.85GHz separate 

from the 2412-2462MHz range of the video feed; another feature that provides an level of redundant 

safety to the P2V+ UAV platform.

Sincerely,

William Brady 

iFlyJax, LLC

P.O.Box 347 Ponte Vedra, FL 32082

Brady3@gmail.com

(253)222-1430