1

Petition for Exemption Under 14 CFR § 11.81  to Allow Commercial 

Use of Unmanned Aircraft Vehicles 

Petitioner:

JJB Inspections

Owner: Jimmy Boles

Address: 204 Drake Apt B

Ripley,TN 38063

Email: lonewolf2765@bellsouth.net

Website: www. JJBinspectiondrones.com

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, 

JJB Inspections is a media company equipped to conduct aerial photography and videography, 

hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its UAV,s ( Unmanned Aerial Vehicle)

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

unmanned and relatively inexpensive UAV,s in airspace that is

limited,predetermined and controlled.

The proposed exemption, if granted, would allow JJB Inspections to conduct commercial 

operations of UAV,s meeting or exceeding all of the operational and safety requirements the 

FAA has set forth in Section 333.

JJB Inspections plans to use the capabilities of UAV,s to offer a multitude of services, including:

- Aerial surveying

- Agriculture and Livestock monitoring

- Real Estate Photography and presentation

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Emergency Search and Rescue.

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, 

provides a mechanism for seeking expedited FAA authorization of safe civil Unmanned Aircraft 

Systems (UAS) operations in the National Airspace System (“NAS”). Section 333(a) states that 

the FAA “shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the (comprehensive) plan and rule making

required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In 

Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited 

operation authorization” if several factors are met. Petitioner meets all requirements to permit 

FAA approval of commercial UAV operations.
2

Sections from which exemptions are sought:

14 C.F.R. Part 21 Subpart H

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121Page 3

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

UAV,s are oftentimes seen as superior to helicopters due to the lesser cost of equipment, the 

reduction of personnel needed to operate equipment, reduced noise levels and zero emissions 

into the environment. In addition to providing cost savings and having little to no impact on the 

environment.

These factors are beneficial for, and in the best interest of, the public. 

The Petitioner is requesting an exemption to enable JJB Inspections to operate a DJI Inspire 1 

UAV that is upgraded to latest version firmware, equipped with a 3 axis Zenmuse camera 

gimbal, which uses a High-Def video camera that can capture up to 4K (4096x2160p) video and 

12M pixel photos. This UAV has a built-in capability to limit the height it flies above the ground 

and the radius of the distance it flies from the operator. The DJI Inspire 1 also has the failsafe 

function of the autopilot system, which means, when the communication between the Main 

Controller and the transmitter is disconnected the system will automatically trigger Return to 

Home and will land safely. Please refer to Attachments DJI Inspire1 check list.

FCC Information

The DJI Inspire 1 transmitter used for controlling the UAV complies with part 15 of the FCC 

rules. Operation is subject to the following two conditions: (1) This device may not cause 

harmful interference, and (2) this device must accept any interference received, including 

interference that may cause undesired operation.

The DJI Inspire1 radio transmitter used for controlling the UAV is wireless technology which has 

been tested and found to be compliant with the applicable regulations governing a radio 

transmitter in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance
3

When operating the DJI Inspire 1 transmitter, the PIC will maintain a separation distance of at 

least 5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna 

to meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties

Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved by 

qualified personnel such as those authorized by DJI (or equivalent), and 

will require a test flight after such work. Records of all maintenance and repair 

work will be kept in a maintenance log for each aircraft. 

All flight operations will be conducted by at least two individuals (PIC and 

observer) who will maintain verbal communication capability with each other at 

all times during the flight, and who will remain stationary on the ground during 

the flight operations.

A Pilot In Command (PIC) who possess the following credentials: 

1.An Airman Certificate issued under 14 CFR 61 (private pilot 

license) screened by the TSA 

2.A Third Class medical certificate issued under 14 CFR 67. 

3.A bi-annual flight review under 14 CFR 61.56 

4. A certificate of competency for UAS issued by UMEX (or 

equivalent certification). 

5. At least 200 cycles and 25 hours of flight experience in a UAS 

rotorcraft (or UAS fixed-wing in the case of fixed-wing flight 

operations under this exemption). Such cycles and hours may be 

gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in 

make and model being flown in the prior 90 days. Such cycles and 

hours may be gained during flights under this exemption if a safe 

distance is maintained from persons in accordance with 14 CFR 

91.119.

i.A Visual Observer. 

ii.A Sensor Operator as necessary. 

All flight operations will be conducted in accordance with valid Certificates of 

Authorization. 

All flight operations will comply with the following: 

The manufacturers' Aircraft Flight Manuals and Operation Guidelines 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties 

include all preflight preparation and inspection, in flight operation, post flight requirements.
4

A pre-flight inspection will be performed by the PIC in accordance with the factory instruction 

manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make 

sure that the compass, gyro and acceleration values are within specs, positive GPS locks are

secure, battery health in each individual LiPo cells are balanced, and radio signals are locked in.

The sUAS will be maintained in accordance with the manufacturer’s instruction manual and 

only manufacturer's authorized replacement parts will be used.

Maximum flight time for each operational flight will be 18 minutes.

• Flights will be terminated at 30% battery power reserve should that occur prior to the 

18minute limit.

• The UAV will be programmed so that it will not be operated at an altitude of no more than 

200 feet AGL, and not more than 100 feet above an elevated platform from which filming is 

planned.

• Minimum crew for each operation will consist of the UAV Pilot, and Visual Observer.

• The UAV operated by the petitioner weighs less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbals).

• The UAV will operate at speeds of no more than 25 knots, can hover, and can simultaneously 

move vertically and horizontally.

The PIC will complete a risk evaluation of current weather conditions for safe flight.

The Observers duties are:

The Observer must have the visual acuity to observe the UAV and be able to communicate 

clearly with the PIC. 

 Warning the PIC of any impending obstacles in the flight path 

 Warning the PIC of any deviations in the planned flight path 

 Warning the PIC should any unauthorized personnel appear in the area of the planned

flight.

The Observer will have the authority to order the PIC to terminate the flight should he feel the 

flight cannot be conducted safely.

General Operating Standards:

• JJB Inspections will only operate its UAV,s in line of sight of a pilot and/or observer and will 

operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure 

that the UAV will "not create a hazard to users of the national airspace system or the public."

• No operation of a UAV within 5NM of an airport reference point . The PIC will give the 

position, altitude and the times the UAV will be operated. The UAV will not be operated at an 

altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot 

ceiling.

 Before an operation of a UAV within 5NM of airport a letter of agreement with the airport

management must be made available to any law enforcement official upon request.
5

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 200 ft AGL, at an airspeed 

of no more than 25 knots and no further than 1600 ft, or line of sight from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the 

property owner;

(e) All required permits or notifications will be obtained from state and local government prior 

to operation; 

(f) The UAV will not be operating over densely populated areas;

(g) The UAV will not be operating over any open-air assembly of people;

(h) The UAV will not be operating over heavily trafficked roads;

(i) The UAV will not be operating at night.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY:

JJB Inspections requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the UAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the DJI Inspire1 under either or both of the 

following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following 

purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. The aircraft will not carry persons or 

property, will not carry fuel, and will only fly under strict operational requirements. Combined 

with the UAV,s light weight, being constructed primarily of carbon fiber and plastic, we propose 

that the UAV will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not appropriate for 

this application, then we request an exemption of 

14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, 

citing the equivalent level of safety outlined in the previous paragraph.
6

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The UAV does not have an entrance in which the word "EXPERIMENTAL" can be 

placed We propose to apply for N-number AC Form 8050-1 to be acquired at area FAA Aircraft 

Registration Branch or Flight Standards Office and display the N- number in a way to be seen 

clearly on the the aircraft.

The PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft will be 

able to see the designation. Additionally we will display at the ground station a high contrast 

flag or banner.

Since the aircraft will operate within line of sight of the ground station, the banner should be 

visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in 

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command of an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. We recognize the FAA like other national 

airspace regulators are considering the issue that UAV operations by persons who hold no 

pilot’s license can still achieve the equivalent level of safety of current operations by manned 

aircraft with pilots holding any level of pilots license .

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, 

the documentation would not be available to the crew during flight operations. To obtain an 

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved 

UAV Flight Manual must be available to the crew at the ground station anytime the aircraft is 

in, or preparing for, flight, and ready for presentation for any governing official upon request.
7

14 CFR 91.109 Flight Instruction; 

Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. Although the DJI Inspire 1 is

capable of duel/linked controls the second control is used to control onboard camera 

movement JJB Inspections will be operating with a single remote controller and non 

electronically linked Observer.

91.119 Minimum safe altitudes:

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAV 

would be photography or survey of persons, vessels, vehicles or structures it would be 

necessary to operate closer than 500 feet to the items listed. Operations will only be flown over 

property or persons where permission has been obtained and careful pre- planned flight path 

has been performed. The aircraft will be operated at a low altitude allowing, if a power unit 

fails, an emergency landing without undue hazard to persons or property.

Therefore we maintain that due to the small size of the UAV, the hazard to persons, vehicles 

and structures is minimal compared to manned aircraft, which should be considered in granting 

the exemption.

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The UAV will always fly below 200 feet 

AGL and will not need to maintain cruising altitudes in order to prevent conflict with other 

aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted 

via radio from the UAV,s on-board computer to the display screen held by the PIC, providing a 

constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The UAV,s battery operated and the maximum 

duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the 

aircraft will never fly more than line of sight from the point of intended landing, a full battery 

charge at launch will ensure that we meet the reserve energy requirement of this paragraph. 
8

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.47 

pounds, the UAV is too small to carry FAA required documentation and does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of 

safety and meet the intent of 91.203, we propose that documents deemed appropriate for this 

aircraft by the FAA will be with the crew at the ground control station and available for 

inspection upon request. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance 

and inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 

addition conduct detailed inspections after every two hours of flight. Maintenance performed 

by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other 

maintenance will be performed by the manufacturer or their designated repair facility. 

The PIC will document work performed in accordance with 91.417. 

Promoting public good:

JJB Inspections will be using UAV’s in a variety of applications that generally require expensive 

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer more efficient 

and safer benefits over the use of full-sized manned aircraft for aerial photography, advanced 

agriculture monitoring, film and still photography, real estate marketing and search and rescue.

Due to flooding of the Mississippi river over the past few years, this would greatly supply safer, 

faster,more efficient information to our local officials who need this information about the river 

levels and safe water supply.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAV 

carrying no passengers or crew creates a much greater margin for public safety.

By granting JJB Inspections requested exemptions, the FAA will continue development of safe 

and successful commercial UAV operations and will advance the public knowledge base for 

such operations. 
9

Conclusion:

As pointed out in this application, the DJI Inspire1 which our company would use, under 

authorization by the FAA, is a small, light-weight device operated within the line of sight of the 

Pilot-in-Command (PIC), less than 200 feet above the ground and outside 5 miles from any 

airport, airfield other location with aviation activities, unless the air traffic control authorities 

(ATC) have been notified and have authorized each flight within a radius of this distance.

JJB Inspections is certain that the studies conducted until now by the FAA, about Section 332, 

Public Law 112-95, 2014, have already provided you with the assurances on the airworthiness 

of UAV,s.

For the foregoing reasons, the exemptions requested herein should be granted.

JJB Inspections should be permitted to conduct UAV operations in accordance with Section 

333 and all other operating parameters deemed necessary and appropriate by the FAA.

Signed

Jimmy Boles Owner JJB Inspections