Jackie E. Watson 2677 Spruce Creek Blvd. Port Orange, Florida 32128 April 

### 27, 2015
U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Ave., SE Washington DC 20590
Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14CFR 21 subpart H; 14 CFR 45.23(b); 14CFR 61.113(a); 14CFR 91.7(a); 14 CFR 91.9(b)(2); 14CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a}; 14CFR 91.203 (a) and (b); 14CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)
Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14CFR Part 11,Jackie E. Watson, operatorofSmall Unmanned Aircraft Systems ("sUAS"), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of his sUAS, so long as such operations are conducted within and underthe conditions outlined her-ein or as may be established bythe FAA as required by Section 333.
Commercial operation sUAS, as described herein, which are equipped with cameras and sensors, would operate inthe following manner:
1. Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photographyfor public and/or private use includingtelevision, public events, cinematography and news-gathering. 3. Aerial inspection/photographyofresidential/commercial structures under contractwith the property owners or local government authority. 4. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only when the local authorities orgovernment has requested by contract ordonation. 5. The abilityto offertrainingto persons individually or belonging to both private and/or public organizationsthat have interests in the use and application ofsUAS forthe purpose ofthe safe operation ofsUAS to enhance the safety ofthe National Airspace System (NAS) as well as forthe protection ofthe persons and property.U.S. Department ofTransportation April 30, 2015 Page 2
As described fully below, the requested exemption would permitthe operation ofsUAS under controlled conditions in the NAS that would be: a) limited b) controlled c) predetermined and will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administration's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraftsystems in the national airspace system."
The name, phone number, and address ofthe applicant is:
Attn: Jackie E. Watson Ph: 386-871-0269 Email:jackwatsonphotography@hotmail.com Address: 2677 Spruce Creek Blvd. Port Orange, Florida 32128 Regulations from which the exemption is requested:
14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 14 CFR 91.7 (a)
14 CFR 91.9 (b) (2) 14CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121
14CFR 91.151 (a) 14 CFR 91.203 (a) 

### & (b) 14CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b)
The applicant's sUAS are multi-rotor craft weighing no more than 551bs. including payload. Under normal conditions they operate at speeds of no morethan 50kts and have the abilityto hover and move along a vertical and horizontal plane simultaneously. They will be operated within line ofsight and within a closed offand predetermined area owned and/ operated bythe property representative or requesting agency. Given the small size ofthe sUAS and the controlled environment providedthe proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limitedto reduced emissions and noise, the grantofthe requested exemption by the Applicant is in the public interest. Accordingly theApplicant requests thatthe FAA grantthe requested exemption with minimum delay.

### U.S. Department ofTransportation April 30, 2015 Page3


### AIRCRAFTAND EQUIVALENT LEVEL OF SAFETY
The operation limitations proposed are for an equivalent or higher level ofsafety and will further enhance the safety ofthe persons and/or property using conventional aircraft.
The limitations and conditions to which theApplicant agrees to adhere to when conducting commercial operations underthe requested FAA issued exemption as setforth in the Flight Operations Manual (FOM) include:


### 1. The sUA$ will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlight timewhichever occurs first. 4. Flights will be operated at an altitude ofno more than 400feetAbove Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist ofthe sUAS Pilot, theVisual Observer (VO) which may include but not limited to a Camera Operator. 6. The sUAS pilotwill be a designated Pilot in Command (PIC) and hold a currentThird or higher Class Medical Certificate, along with avalid state driver's license. Ifthe PIC feels another operatorto be qualified with the necessary skills to be PIC and possess aThird or higher Class Medical and avalid state driver's license, that person may be designated PIC provided they have a minimum of20 hours ofoperational flight time with the sUAS. 7. A briefingwill be performed regarding the planned sUAS operations priorto each day's flight consisting ofall thedays' production activities. 8. The operatorwill file FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation. 9. The operatorwill obtain written and/orverbal consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100feet oftheflight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 10. The PIC and VO will have been trained in operation ofsUAS and receive up-to-date information forthe particular sUAS to be operated. 11. The PIC and VO will be able tocommunicate byvoice, radio, and/ortext at all times. 12. Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies for all flight operations. 13. Ifthe sUAS loses communications or loses GPS signal, the sUAS will have the capability to return to a pre-determined location within a designated location and land autonomously. 14. The sUAS will have the capabilityto abort aflight in case ofunpredicted obstacles, weather, or emergencies.U.S. Department ofTransportation April 30, 2015 Page4
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorizethe FAA to exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular sUAS. In all cases, an analysis ofthese criteria demonstrates that the sUA$ operated withoutan airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate without the restrictions and conditions proposed.
The sUA$ to be operated hereunder are less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. The FAA will have advance notice ofall commercial operations. These safety enhancements provide agreater degree ofsafety to the public and property ownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed bythesUAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load.
14C.F.R. § 45.23 (b). Marking oftheAircraft
The regulation requires: When marks include onlythe 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 morethan 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.
Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance tothe cabin, cockpit or pilot station on whichthe word "Experimental" can be placed. Given the size ofthe sUAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on thefuselage in compliance with §45.29 (f).
The equivalent level ofsafety will be provided by having the sUA$ marked on its fuselage as required by §45.29 (f) where the pilot, observer and othersworkingwith the sUA$ will see the identification ofthe sUAS as "Experimental."U.S. Department ofTransportation April 30, 2015 Page 5


### 14C.F.R. § 61.113 (a): 

### Private Pilot Privileges and Limitations: Pilot in Command.
Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carrying passengers or property for compensation or hire. The Applicant's sUAS do not carry any pilots or passengers nor propertytherefore Applicant is seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot's license will not ensure remote control piloting skills. The risks attendant tothe operation ofsUAS is far less than the risk levels inherent in the commercial activities outlined in 14CFR 61


### 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.
The regulation requires that no person may operate a civil aircraft unless it is in airworthycondition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety will be provided.


### 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.
Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis 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. The sUAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflyingthe sUAS will have immediate access to it.


### 14 C.F.R. § 91.103: Preflight Action.
This regulation requires each pilot in command to take certain actions beforeflightto insurethe safety of flight. As FAA approved rotorcraftflight manuals will not be provided forthe sUAS an exemption will be needed. The PIC will take all actions including reviewingweather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.


### 14 C.F.R. §91.109: Flight Instruction.
Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not have fullyfunctional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptionsforflight training withoutfullyfunctional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. Because ofthe size and speed ofthe sUAS an equivalent level ofsafety is provided bythefact that neithera pilot nor passengers will be carried in the sUAS.U.S. Department ofTransportation April 30, 2015 Page 6
14 C.F.R. §91.119: Minimum Safe Altitudes.
Section 91.119 establishes safe altitudesfor operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a multi-rotortype, the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the sUAS will not be operated higherthan 400 AGL with the exception that in circumstances where thesUAS is used to survey or photograph astructure whose height exceeds 400 feetAGL, the sUAS will not be operated morethan 100' above the highest point on the structure. Itwill however be operated in a restricted area with a security perimeter, where buildings and peoplewill not be exposed to operations without prior consent.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance noticeto the propertyowner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack of flammable fuel, any risk associated withthese operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small- UAS operations and the operations ofconventional aircraft that must comply with Section 91.119.
14 C.F.R. §91.121 Altimeter Settings.
This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure."As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by theoperator, pursuant to the safety check list and live flight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight.
14C.F.R. § 91.151(a}: Fuel Requirements for Flight in VFR Conditions
Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel toflyto the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes."
The battery powering the sUAS provides approximately 30 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame for flight in daylight ortwilight VFR conditions is reasonable.
The Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. Operatingthe small UAS, in atightly controlled area where only people and property owners or officialU.S. Department ofTransportation April30, 2015 Page7 representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender thetype of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 10 minuteswould greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety may be achieved by limitingflights to 30 minutes or25% ofbattery power- whichever occurs first. This restriction would be more than adequateto return the sUAS to its planned landing zone from anywhere in its limited line of sight operating area.


### 14 C.F.R. §91.203 (a) 

### and (b): Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person mayoperate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unlessthe 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.
The sUAS fully loaded weighs no morethan 55 lbs. and is operatedwithout an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS.
An equivalent level ofsafety will be achieved by keepingthese documents at the ground control point wherethe pilotflying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS.


### 14 C.F.R. §91.405 

### (a); 407 

### (a) (1); 409 

### (a) (2); 417(a) 

### &(b): Maintenance Inspections.
These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter.

..," and others shall inspect or maintain the aircraft in compliance with Part 43.
Given that these section and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applyto the applicant. Maintenance ofthe sUAS will be accomplished by the operator pursuantto guidelines specified in the sUAS manufacturer's flight manual and operating handbooks. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the sUAS can land immediately and will be operatingfrom no higherthan 400feet AGL. The operatorwill ensure the sUAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthycondition to provide the equivalent level ofsafety.
An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance withthe sUAS Manufacturer's Manual, as referenced in theAircraft Operations Manual {AOM).U.S. Department ofTransportation April 

### 30, 2015 Page8
As provided in the FOM, the operatorwill ensure thatthe sUAS is in working order priorto initiatingflight and perform required maintenance needed. 

### Additional Information
The applicant, Jackie E. Watson, has been involved in the building and piloting ofexperimental, certified and remotecontrolled aircraftfor more than 40 years. Also the primary pilot, Jackie E. Watson, is an FAA Licensed Airline Transport Pilot in both Multi-Engine and Rotorcraft-Helicopter aircraft. Additionally applicant has FAA Flight Engineer Rating's in both Turbojet and Turbo-propeller Aircraft and is a FAA licensed Airframe and Powerplant mechanic. Applicant will maintain avalid drive license and aThird Class FAA Medical Certificate or higher duringall periods when operating sUAS for commercial operations as outlined herein.
Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequate justification forthe grant ofthe requested exemptions allowing commercial operation ofthe Applicant's sUAS. Sincerely,

# /~~- 

# /. v;t:;::::s
r /**~a~.."ie** E. Watson