February 20, 2016

James J. Egger

President

J&L Aerial Productions and Photography LLC

290500 East 1780 Road

Duncan, OK 73533

(580)656-8859

U.S. Department of Transportation

Docket Operations, M-30

1200 New Jersey Ave., SE,

Washington, DC 10590

Re: J&L Aerial Productions and Photography LLC Petition for Exemption Pursuant to Section 

333 of the FAA Reform Act & 14 CFR Part 11

Dear Sir or Madam,

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

14 CFR Part 11, J&L Aerial Productions and Photography LLC (hereafter J&L Aerial Productions 

and Photography) hereby petitions the FAA for exemption from certain Federal Aviation 

Regulations (FARs) to conduct the following high quality imaging for various private, public and 

commercial uses; specifically targeting:

Description of Proposed Operations

High resolution aerial mapping, inspections and photography providing:

o Agricultural: Crop Health Monitoring, Mapping and Crop Health Inspections

o Utility Monitoring & Inspection: Power Line, Bridge, Wind Tower, Solar and 

Pipeline

o Cinematography & Videography

o Insurance: Crop, Construction, Roof and Building Inspections

o Marketing: Real Estate, Advertising and News gathering

o Geological: Land Surveying

J&L Aerial Productions and Photography, therefore, seeks exemption from the following FARs 

identified below, so long as such operations are in accordance with the conditions and 

limitations outlined by the FAA under Section 333:

o 14 CFR Part 21, Subpart H: Airworthiness Certificates

o 14 CFR 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

o 14 CFR 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, 

Recreational and Sport Pilot Medical Certificate, Privileges and Limitations
o 14 CFR 91.7(a): Civil Aircraft Airworthiness

o 14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 CFR 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

o 14 CFR 91.103: Preflight Action

o 14 CFR 91.109: Flight Instruction

o 14 CFR 91.119(c): Minimum Safe Altitudes Over Other Than Congested Areas

o 14 CFR 91.121: Altimeter Settings

o 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

o 14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417 (a) and (b): Maintenance Inspections

I. Petitioner’s Description

J&L Aerial Productions and Photography consists of a team of sUAS enthusiasts and 

entrepreneurs, founded to revolutionize the monitoring and inspection process by providing 

faster, safer and cost-effective aerial solutions for commercial, public and private markets.

This section responds to the specific requirements of 14 CFR Sec 11.81 to provide mailing 

address and other contact information such as fax number, telephone number or email address 

copy.

J&L Aerial Productions and Photography LLC

James J. Egger

290500 East 1780 Road

Duncan, OK 73533

Email: JandLAerialProductions@yahoo.com

Phone: (580)656-8859

II. Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the Reform 

Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned 

aircraft systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, 

the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS where it is 

safe to do so based on the following considerations:

o The UAS’s size, weight, speed and operational capability;

o Operation of the UAS in close proximity to airports and populated areas; and

o Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency’s safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 106(f)(defining the authority of 

the Administrator); 49 U.S.C. § 44701(f)(permitting exemptions from §§ 44701(a), (b) and §§ 

44702-44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (1)would benefit the public as a whole and (2)would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 CFR § 11.81 

(petitions for exemption).

III. Qualification for Approval Under Section 333

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant 

factors are satisfied. The requested exemption would permit J&L Aerial Productions and 
Photography to perform commercial operations under controlled conditions in airspace that is 

1) limited, 2) predetermined, 3) restricted, limited or controlled as to access and 4) would 

provide safety enhancements to the already safe operations in these industries presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation’s responsibilities to “...establish requirements for the safe 

operations of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act.

J&L Aerial Productions and Photography sUAS include:

DJI Phantom 3 Professional

The DJI Phantom 3 Professional weighs 55 lbs. or less, including payload. The DJI Phantom 3 

Professional operates under normal conditions at a speed of no more than 32 knots. J&L Aerial 

Productions and Photography sUAS operations will be conducted below an altitude of 400 ft. 

AGL, within unpopulated and secured areas, either within class G airspace or with the 

permission of ATC. sUAS operated by J&L Aerial Productions and Photography will also be 

conducted within visual line of sight of the operator and observer. Such operations will ensure 

the sUAS will “not create a hazard to users of the National Airspace System or the public” as per 

the FMRA 2012 Section 333. Given the size of the sUAS and the operating environment, this 

petition for exemption meets an equivalent level of safety, in which Congress envisioned the 

FAA must; by exemption allow commercial operations of UASs to commence immediately. Also 

due to the size and environment, approval of the application presents no national security 

issue.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit described herein, the grant of the requested 

exemption is also in the public interest.

The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in this petition, specifically exemptions no. 110662, 11109, 11112 and 11290; 

and J&L Aerial Productions and Photography therefore request our petition be granted without 

delay.

IV. Description of Proposed Operations

J&L Aerial Productions and Photography seeks an exemption pursuant to Section 333 of the 

Reform Act to use a sUAS for aerial data collection in support of its commercial operations.

The sUAS J&L Aerial Productions and Photography intend to use have been approved for 

commercial use in other grants of exemptions. The FAA has previously determined that the 

vehicle meets the criteria established in Section 333 of the Reform Act and is suitable for 

performing aerial data collection.

J&L Aerial Productions and Photography is committed to maintaining the highest standards of 

flight safety. All sUAS operations will occur in uncontrolled airspace, within visual line-of-sight 

(VLOS) of the pilot and visual observer and will be limited to daytime VFR conditions. The 

proposed operations in the petition for exemption are not new or novel to the FAA. The FAA 

has previously issued multiple grants of exemptions to use small UAS for aerial data collection 

in support of similar commercial and research activities. 

The low risk UAS operations proposed by J&L Aerial Productions and Photography in this 

Petition for Exemption fall squarely within the category of aerial data collection that has been 

subject to previous approval.

As a sUAS/drone service provider, J&L Aerial Productions and Photography needs to be able to 

conduct continuous research, development and training flights to better our products, services 

and troubleshoot any issues discovered through our operations.
o The sUAS will weigh less than 55 lbs.

o Flights will be operated within line of sight of a pilot and/or observer

o Flights will occur during daylight hours

o Flights will occur during Visual Flight Rules Meteorological Conditions (VMC)

o Flights will be operated at an altitude of no more than 400 feet AGL and within 

class G airspace. Operations in controlled B, C or D airspace will be conducted in 

coordination with the proper FSDO and ATC with prior permission.

o Flights will be terminated at 25% battery power reserve or when voltage is less 

than 10.6V should that occur during the operation, J&L Aerial Productions and 

Photography’s’ app will push notice and recommend returning at less than 30%.

o J&L Aerial Productions and Photography sUAS used by the company will be U.S. 

registered and display marks either in accordance with 14 CFR Part 45, Subpart C 

or approved alternate markings.

o Operations will only be conducted in confined areas and over property 

authorized for such use. Most operations will be conducted within the 

limitations of the blanket COA authorization, including below 200 feet AGL. 

o The operator will obtain the consent of all persons involved and ensure that only 

consenting persons will be allowed within close proximity to the flight operation.

o All required permissions and permits will be obtained from territorial, state, 

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

appropriate governmental agencies.

o A briefing will be conducted prior to each day’s activities for all personnel who 

will be performing duties for these operations.

o Minimum crew for each operation will consist of the sUAS pilot and a Visual 

Observer.

o sUAS Pilot will be the Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also present 

(i.e. the Visual Observer), that person can also be designated as the PIC.

o The PIC must have passed at least a sport pilot certificate and hold a valid U.S. 

driver’s license unless changed by future sUAS FAA regulations.

o PIC and VO will have been trained in operation of J&L Aerial Productions and 

Photography and have obtained all new required information on the particular 

UAS to be operated.

o Observer and PIC will at all times be able to maintain verbal communication, 

either directly or through electronic means.

o Operators will maintain the sUAS system in a condition safe for operating 

according to manuals, including pre-flight and post-flight inspections.

o If the sUAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined or safest location and land.

o The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. The J&L Aerial Productions and Photography drone is 

able to see real time flight data including settings, flight mode, Bluetooth, 

number of satellites, battery level, flight distance, altitude, speed and flying time 

allowing the pilot to have situational awareness of any issues. 

V. Regulations from which Exemption is Requested

14 CFR Part 21, Subpart H: Airworthiness Certificates

Given the size and limited operating area associated with the aircraft to be utilized, 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. The Federal Aviation Act (49 U.S.C. § 

44701(f)) 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 operated without an 

airworthiness certificate, in a restricted environment and under the conditions proposed will be 
at least safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated here is less than 55 lbs. fully loaded, carry neither a pilot nor 

passenger, carry no explosive materials or flammable liquid fuels, and operate within a 

controlled area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator 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 aircraft. These safety enhancements, which already apply to civil 

aircraft operated in connection with related applications, provide a greater degree of safety to 

the public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 CFR Part 21, subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the sUAS, 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.

14 CFR 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

J&L Aerial Productions and Photography seeks an exemption from the aircraft marking and 

identification requirements contained in 14 CFR §§ 91.9(c), 45.23(b) and 45.27(a).

o 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, marking and Placard 

Requirements, provides that: No person may operate a U.S. registered civil 

aircraft unless that aircraft is identified in accordance with part 45 of this 

chapter.

o 14 C.F.R. § 45.23(b), Marking of the aircraft, states: 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.

o 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must 

display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, 

boom or tail the marks required by § 45.23.

In prior grants of exemption under Section 333 of the Reform Act, the FAA determined that 

exemption from these requirements was warranted provided that the aircraft “have 

identification (NNumber) markings in accordance with 14 C.F.R. Part 45, subpart C if the 

markings are as large as practicable. (FAA Docket No. FAA-2014-0352) All UAS flown by UI will 

bear N-number marking that are as large as practicable in accordance with C.F.R. Part 45, 

subpart C (See, e.g., FAA Docket No. FAA-2014-0352, at 14).

14 CFR 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport 

Pilot Medical Certificate, Privileges and Limitations

J&L Aerial Productions and Photography seeks exemption from these sections, which restricts 

private, recreational or sport certificate holders from flying aircraft for compensation or hire, 

and would also require a second class medical certificate. The purpose of part 61 is to ensure 

that the skill and competency of any PIC matches the airspace in which the PIC will be 

operating, as well as requiring certifications if the private pilot is carrying passengers or cargo 

for hire. In this case, while the UAS will be operated as a part of a commercial operation, it 

carries neither passengers nor cargo.

In the grant of Exemption No. 11062 to Astraeus Aerial (FAA Docket No. FAA-2014-0352), the 

FAA determined that the unique characteristics of UAS operation outside of controlled airspace 

did not warrant the additional cost and restrictions attendant with requiring the PIC to have a 

Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment of the additional 
requirements for a private pilot to become qualified as a commercial pilot would not lead to 

any additional safety benefits when UAS operations are involved.

More recently, the FAA determined that holders of recreational and sport pilot certificates 

would also have adequate aeronautical knowledge to pilot a UAS. Accordingly, because these 

individuals would also be subject to security screening by the Department of Homeland Security 

(DHS), the FAA determined that holders of recreational and sport pilot certificates would be 

qualified to serve as the PIC for UAS operations (See Grant of Exemption No. 11213 to Aeryon 

Labs, Inc. (Docket No. FAA-2014-0642 at pages 8-9).

The restrictions Petitioner as placed on its UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial and other operators in more recently granted exemptions 

under Section 333 of the FAA Reform Act. J&L Aerial Productions and Photography will operate

away from persons and property that is not the subject matter of the flight. J&L Aerial 

Productions and Photography will also require all PICs to be thoroughly trained in the unique 

aspects of UAS flight. Pilots will have experience not only in UAS operations before they are 

permitted to participate in commercial flights on behalf of J&L Aerial Productions and 

Photography. The pilot qualification and training ensure that J&L Aerial Productions and 

Photography pilots are competent and proficient in the UAS they are operating. The 

petitioner’s training and qualification requirements are consistent with those contained in prior 

FAA issued grants of exemption, and will provide a higher level of competency and proficiency 

for its pilots and will ensure at lease an equivalent level of safety.

14 CFR 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UAS, J&L Aerial Productions 

and Photography seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in an airworthy condition to be operated. While the petitioner’s UAS will not have 

an airworthiness certificate, the FAA has determined that for the purpose of this exemption the 

pilot may determine the aircraft is in an airworthy condition prior to flight. The operating 

procedures will allow the PIC to determine whether the aircraft is in a condition safe for flight, 

and an exemption from § 91.7(a) is therefore warranted.

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 CFR 91.203(a) and (b): 

Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft onboard the aircraft.

Pursuant to 14 C.F.R. § 91.9(b)(2):

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

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a)Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) 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.
Given the small size and configuration of the UAS, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and 

the UAS has no cabin or cockpit.

In an FAA Office of Chief Counsel’s Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203 

(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, 

registration certificate and other required documents from the ground control station from 

which he or she is operating the aircraft (Memorandum from Mark Bury, FAA Assistant Chief 

Counsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards 

Service (August 8, 2014); see also Docket No. FAA-2014-0352 at 16-18). As this FAA office of 

Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these 

key documents during flight. Therefore, an equivalent level of safety will be achieved by 

ensuring that the pilot has access to the documents at the ground control station from which 

he or she is piloting the UAS. See also Exemption No. 11213 to Aeryon Labs, Inc. at page 11: 

The petitioner requested relief from 14 CFR § 91.9(b)(2): Civil aircraft flight manual, marking, 

and placard requirements and § 91.203(a) and (b): Civil aircraft: Certifications required. The 

FAA has previously determined that relief from these sections is not necessary. See Exemption 

No. 11062. Relevant materials may be kept in a location accessible to the PIC in compliance 

with the regulations.

14 CFR 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA 

approved Flight Manual on board the aircraft. While the PIC will be familiar with all information 

necessary to safely conduct the flight, an exemption is requested to the extent that an FAA 

approved Flight Manual is required.

Adherence to the requirements in the operating documents will ensure that the UAS is in an 

airworthy condition prior to flight. The PIC will perform a series of checklists designed to 

identify any defects or inoperable components, which cover pre-flight, take-off, landing and 

post-flight procedures. The PIC will also be required to review weather, flight requirements, 

battery charge, landing and takeoff distance, UA performance data and contingency landing 

areas before initiation of flight. Petitioner’s operating documents will be kept at the ground 

control station and will be accessible to the PIC at all times while operating the UAS.

14 CFR 91.109: Flight instruction

Petitioner seeks an exemption from 14C.F.R. §91.109(a), which provides in pertinent part that 

“[n]o 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 .” USA and remotely 

piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. Accordingly, an exemption will be required for the flight instruction 

requirements of 14C.F.R. §91.109(a).

Given the size and speed of the UAS that Petitioner intends to use, an equivalent level of safe 

training can still be achieved without dual controls because no pilot or passengers are aboard 

the UAS, and as required by the operating documents, all persons will be a safe distance away 

in the in the event that the UAS experiences any difficulties during flight instruction. Moreover, 

all flight training will be conducted in controlled and sterile environment. As a whole, the 

procedures provided for in the operating documents ensure that UAS flight instruction can be 

performed safely.

14 CFR91.119(c): Minimum safe Altitudes over other than congested areas 

UI requests an exemption from the minimum safe altitudes requirements of 

14C.F.R.§91.119(c).Section 91.119 prescribes the minimum safe altitudes under which aircraft 
may not operate, including 500 feet above the surface and away from any person, vessel, 

vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). 

An exemption is required because the proposed UAS operations will normally need to occur 

below 400 feet AGL. Additionally, due to the nature of the proposed operations, the PIC and /or 

observers may need to be less than 500 feet away from the UAS. Compared to flight operations 

with rotorcraft weighing far more than the maximum weight proposed herein, and given the 

lack of flammable fuel with the UAS, any risk associated with these operations is far less than 

those that presently exist with conventional aircraft.

An equivalent level of safety will be achieved given he size, weight, and speed of the UAS, as 

well the controlled location where the operations will occur, In order to avoid any risk to 

manned aircraft, flight operations will be restricted to below 400 feet AGL/ As set forth in the 

operating documents, the UAS will be operated in a controlled environment, and all flights will 

occur at a lateral distance of at least 500 feet from nonparticipating persons, unless that person 

is in a position where he or she is shielded from the UAS and any possible debris resulting from 

UAS failure. Procedures will be in place to ensure flight operations can be safely terminated if a 

nonparticipating person within 500 feet of the UAS leaves a shielded position. Further, UAS 

operations will occur at least 500 feet away from vehicles or structures unless the property 

owner/ controller has granted permission and the PIC has made a safety assessment of the risk 

of operating closer to those objects, and operations near the PIC or observer will not present 

an undue hazard per §91.119 (a). Adherence to these restrictions in J&L Aerial Productions and 

Photography operating documents will ensure the proposed operations can be conducted 

without compromising safety to persons or property on the ground. 

14 CFR 91.121: Altimeter Settings

To the extent necessary for J&L Aerial Productions and Photography to conduct the proposed 

operations, Petitioner requests an exemption from 14 C.F.R.§91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter 

that is set to the elevation of the departure airport or barometric pressure.

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 

can be achieved in circumstances where: (1) the UAS will be operated 400 feet AGL or below, 

(2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground- based onscreen display and, (4) where prior to each flight, a zero altitude initiation 

point is established for the PIC to confirm accuracy of the onboard GPS.

The UAS that petitioner intends to use performing the proposed operations meet all these 

operational characteristics. Moreover, the operating documents require the PIC to calibrate the 

aircraft’s GPS compass prior to each flight operation. As the FAA has determined in 

circumstances similar to this Petition for exemption, Petitioner’s UAS and the safety mitigation 

procedures contained in the operating documents, ensure that an equivalent level of safety 

will be achieved, and a grant of exemption to the requirements of §191.121 is therefore 

appropriate.

14 CFR 91.151(a) : Fuel Requirements for Flight in VFR Conditions

J&L Aerial Productions and Photography requests an exemption from 14 C.F.R. §91.151 (a)’s 

fuels requirements for flight in VFR conditions. Section 91.151 states:

(a)No person may begin a flight in an airplane under VFR conditions unless ( considering wind 

and forecast weather conditions) here 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.
Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption 

from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

The FAA Has previously granted relief from the fuel requirements of § 91.151(a) for flight in 

daytime VFR conditions in circumstances similar to those presented in this Petition for 

Exemption (See e.g., Exemption No. 8811, 10808 and 10673). In Exemption No. 11213 to 

Aeryon Labs, Inc., (Docket No. FAA-2014-0642) the FAA determined that a requirement 

prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast weather 

conditions) there was enough available power for UAS to operate for the intended operational 

time and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater, would ensure an equivalent level of safety to the 

fuel requirements of § 91.151(a) (Exemption No. 11213 at page 12). Petitioner’s operating 

documents impose this same requirement and an exemption from § 91.151(a)’s fuel 

requirements for flight in VFR conditions are therefore appropriate.

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): Maintenance Inspections

J&L Aerial Productions and Photography seeks an exemption from the maintenance inspection 

requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) 

and (b). These regulations specify maintenance and inspection standards in reference to 14 

C.F.R. Part 43-See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft 

“[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections...have discrepancies repaired in Part 43 of this chapter.”) An exemption 

from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the UAS to be operated under this grant of exemption will 

not have.

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the operating documents and any required manufacturer safety 

or service bulletins. Further, as required by the operating documents, the PIC will conduct a 

pre-flight inspection of the UAS and all associated equipment to account to account for all 

discrepancies and/or inoperable components. Maintenance will be performed and verified to 

address any conditions potentially affecting safe operation of the UAS and no flights will occur 

unless, and until, all flight critical components of the UAS have been found to be airworthy and 

in a condition safe for operation. A functional test flight will be conducted following the 

replacement of any flight-critical components. As required by the operating documents, the 

PIC who conducts the functional test flight will make an entry in the UAS aircraft records of the 

flight.

The operating documents also include requirements to follow the UAS manufacturer’s 

maintenance, overhaul, replacement, inspection and life limit requirements for the aircraft and 

aircraft components. Moreover, the operating documents also include procedure to document 

and maintain a record of the UAS maintenance, preventative maintenance, alterations, status 

of replacement/overhaul component parts and the total time in service of Petitioner’s UAS. As 

a whole, the maintenance and inspection procedures required by the Petitioner ensure that an 

equivalent or higher level of safety will be achieved.

VI. Public Interest

The public interest will be served by granting J&L Aerial Productions and Photography’s Petition 

for Exemption. Congress has established a national policy that favors early integration of UAS 

into the NAS in a controlled, safe working environment such as those proposed in this Petition. 

Granting this Petition for Exemption helps fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act-the FAA Administrator’s assessment of whether certain UAS may 

operate safely in the UAS before completion of the statutorily required rulemaking.

Beyond increased levels of safety, the public stands to benefit enormously from the 

commercial, programs supported by the proposed operation in the Petition for Exemption. 
Whether it is studying the best ways to monitor our aging infrastructure, or researching ways 

for farmers to produce better crops in a more sustainable and environmentally conscious 

manner, the public as a whole will benefit from the information gathered and studied as part of 

the education and research programs supported by the proposed operations in this Petition for 

Exemption.

VII. Privacy

The proposed operations will be conducted in accordance with applicable federal, state or local 

laws regarding privacy. All flights will occur over private, limited or controlled access areas with 

the property owner’s prior consent and knowledge. Operations will be conducted by trained 

personnel and all other individuals will either be a part of the operation or consent to be 

present at the time of operations.

VIII. Federal Register 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:

Petitioner seeks an exemption from the following rules in Title 41 of the Codes of Federal 

Regulations:

14 CFR Part 21, Subpart H: 14 CFR 91.9(c), 45.23(b) and 45.27(a): 14 CFR 61.23(a) and (c), 

61.113, 61.101(e)(4) and (5), 61.315; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); CFR 91.203(a) and (b); 

14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 

91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b)

IX. Conclusion

The proposed operations in this Petition for Exemption satisfy the criteria articulated in Section 

333 of the Reform Act and the FAA has issued grants of exemption in circumstances similar in 

all respects to those presented by J&L Aerial Productions and Photography in this Petition for 

Exemption. In consideration of the foregoing, J&L Aerial Productions and Photography 

respectfully submits that this Petition for Exemption qualifies for expedited approval via the 

FAA’s summary grant process.

I thank you for your prompt consideration of the requested exemptions. Should you have any 

questions or if you need additional information to support the requested exemptions, please do 

not hesitate to contact myself.

Very Respectfully Yours,

James J. Egger

President

J&L Aerial Productions and Photography LLC