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 M odernization 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 exe mption 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. PI C 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 verificati on, 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 li fe 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 InspectionsInspections will be performed by the PIC relief is requested to the extent of anothe r 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 des cribed more fully, the requested exemption would permit t he 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. Operati ons 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 acc ess 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 engagi ng in commercial UAS operations . Th e applicant has worked within FAA guidelines to obtain a legal authorization to conduct commercial operations. Additionally, the fact that the appl icant currently holds a FAA Private Pilot Certificate demonstrates that the applicant has a high regard to sa fe operations, as wellas a necessary und erstanding of the NAS and FARs.

The experience of a n 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 pla nned to be operated are the d JI 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 t hat the FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also , operation in a researched (to include applicable NOTAMs) , predefinedarea 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 op erator, 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 . T he 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 al l 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 . T his area of operationwill 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 inc lude flight completion with at least 1 0% 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 o btained 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 communicat ion 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 di rectly 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 an d 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