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July 8th, 2015.

U.S. Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590-0001

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. Part 21 Subpart H; 14 C.F.R §§

61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a) and (b); 61.133(a); 91.7(a); 

91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.417(a) and (b)

Dear Mr. John S. Duncan:

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

“Reform Act”) and 14 C.F.R. Part 11 JMA Visuals, LLC (herein “the operator”). 

Operator of Small Unmanned Aircraft Systems (“sUAS’s”) equipped to conduct Aerial 

Photography and Cinematography for film, television, motion picture production, and 

commercial event video productions, hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so 

long as such operations are conducted with and under the conditions outlined herein or as 

may be established by the FAA in an exemption granted under section 333 or Section 49 

U.S.C.§44701(f). 1

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

small sUAS’s under controlled conditions as part of the NAS that would be 1) limited; 2) 

predetermined; 3) would provide safety enhancements in the fields in which it will 

operate, which now depend on commercial aircraft or humans on high structures. 

Approval of this exemption would be in the best interests of public safety and fulfill the 

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

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

Reform Act. 

 1

 The operator relies upon the following exemptions where specific reference to an 

exemption is not provided: Exemptions 11062 thru 11067, 11080, 11109 through 11112 

and 11114.
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The Name and Address of the applicant is:

JMA Visuals, LLC. 

John M. Antoniades

333 Meade Ter.

Union, NJ 07083

Tel: 973-309-6502

Regulations from which the exemption is requested:

14 C.F.R. Part 21 Subpart H 

14 C.F.R. § 61.23(a) and (c)

14 C.F.R. § 61.101(e) 4 and 5

14 C.F.R. § 61.113(a) and (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.417(a) and (b)

Aircraft the operator is requesting to operate:

DJI Phantom Series

DJI Inspire Series

DJI Spreading Wings Series

The Applicant

JMA Visuals, LLC is a Photography and Cinematography company that provides these 

services to private and commercial clients. JMA Visuals, LLC is a licensed and insured 

company doing business in the state of New Jersey. 

Commitment to Safety

The operator will operate sUAS’s in a manner that will be in the best interests of 

the public, the NAS, and non-participants during such flights. The operator will comply 
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all applicable FAR’s and requirements set forth by “the administrator” should an 

exemption be granted.

Expertise and Experience

The operator has been doing business for over ten years and is committed to 

offering the best possible services to its clients. In order to provide the best possible 

services it’s in the best interests of its clients to offer aerial photography and 

cinematography services. The owner of JMA Visuals, LLC. has a vast majority of 

experience in the aviation field. Said owner holds a BS of Aeronautical Science from the 

best aviation college in the country. Embry-Riddle Aeronautical University. Additionally 

said owner is an ATP rated pilot with over 6000 hours of 121 experience and rated in 

multiple transport category aircraft. The level of safety in which said sUAS’s will be 

operated will be of the utmost care in which he operates his aircraft. The operator will be 

able to commit to a level of safety, which far surpasses any other company in the same 

market. 

Statutory Authority

Section 333

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

provides a mechanism for seeking expedited FAA authorization of safe civil sUAS

operations in the 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 rulemaking 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 operational 

authorization.” The FAA has committed to complying with this mandate by granting 

several petitions almost identical to the one at hand. See, e.g., Exemption No. 11062, 

Regulatory Docket No. FAA-2014-0352 (granting regulatory exemptions to Astraeus 

Aerial for operation of unmanned aircraft systems for the purpose of filming for the 

motion picture and television industry).

Sections 333(b) identifies several factors that the FAA should consider in 

determining whether commercial sUAS operations should be approved. These include 

sUAS that, “as a result of their size, weight, speed, operational capability, proximity to 

airports and populated areas, and operation within visual line of sight do not create a 

hazard to the users of the [NAS] or the public or pose a threat to national security.” See 

Sections 333(b).
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Section 44701(f)

In addition to the specific authority conferred by section 333, the FAA 

Administrator has general authority to grant exemptions from the FAA’s safety 

regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See U.S.C. § 44701(f).

Requested Exemptions

The operator requests relief from the following regulations:

14 C.F.R. Part 21 Subpart H 

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and 

changing design approvals, production approvals, airworthiness certificates, and 

airworthiness approvals. Said sUAS’s being requested would not obtain an airworthiness 

certificate because no such parameters have been set for sUAS operations. 

14 C.F.R. § 61.23(a) and (c) Medical certificates: Requirement and Duration 

(a) Operations requiring a medical certificate. 

(c) Operations requiring either a medical certificate or U.S. driver’s license. 

Although established regulations require an airman to obtain a medical certificate 

when exercising the privileges of his or her certificate, no such FAR’s exist 

regarding UAS operations. Therefore the operator requests relief from this 

regulation and subparts.

14 C.F.R. § 61.101(e)(4) and (5) Recreational pilot privileges and limitations.

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational 

 pilot may not act as pilot in command of an aircraft–

(4) For compensation or hire;

(5) In furtherance of a business;

The operator seeks relief from said stated regulations as the operator will be 

conducting commercial aerial services for compensation and in furtherance of a 

business. The operator would like to use the Recreational certificate by the PIC to 

operate the sUAS’s. 
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14 C.F.R. § 61.113(a) Private Pilot privileges and limitations: Pilot in Command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as pilot in command of an aircraft.

The operator seeks relief from the above stated regulation as it will conduct 

commercial aerial services. The operator would like to use the Private Pilot 

Certification for its PIC’s of said sUAS’s stated earlier in this petition. 

14 C.F.R. § 61.315(a) What are the privileges and limits of my sport pilot 

certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a lightsport aircraft, except as specified in paragraph (c) of this section.

The operator seeks relief from the above stated regulation, as it will conduct 

commercial aerial services. The operator would like to use the Sport Pilot 

Certification for its PIC’s of said sUAS’s stated earlier in this petition. 

14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness

a) No person may operate a civil aircraft unless it is in an airworthy condition.

No standard of airworthiness will exist for the UAS. Given the size of the aircraft

and the requirements that the operator has agreed to as it relates to airworthiness, 

as contained in the “user manual” of the UA. An equivalent level of safety will be 

achieved by insuring a “pre-flight” inspection prior to each flight as determined 

by the operators Flight Operations Manual (“FOM”) and Motion Picture and 

Television Operations Manual (“MPTOM”) (collectively, “operations

manuals.”)

2

 2

 The FOM and MPTOM will be submitted separately and confidentially under 14 C.F.R. 

11.35(b), as the manuals contain proprietary information that the applicant has not and 

will not share with others. The operations manuals contain operating conditions and 

procedures that are not available to the public and are protected from release under the 

Freedom of Information Act, 5 U.S.C. §§ 552, et seq. 
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14 C.F.R. § 91.119(c) Minimum Safe Altitudes: General 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

The operator requests relief from said regulation as this pertains to manned 

aircraft. Manned aircraft possess a risk to public safety as they are of significant 

size and weight that can cause serious bodily injury. An equivalent level of safety 

will be achieved given the UA’s weight of less than 55lbs and do not contain 

flammable fuel, nor a conventional engine. In addition, the low-altitude of the 

UA’s will ensure separation with conventional that will have to comply with 

91.119. At times where the operator will operate the UA’s with less than 500’ as 

prescribed in the above regulation all flights will be in accordance with the 

operations manuals.

14 C.F.R. § 91.121 Altimeter Settings

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; 

or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92'' Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the 

area of operation as shown in the following table:

(c) To convert minimum altitude prescribed under Secs. 91.119 and 91.177 to the 

minimum flight level, the pilot shall take the flight level equivalent of the 

minimum altitude in feet and add the appropriate number of feet specified below, 

according to the current reported altimeter setting:

Said sUAS that the operator has petitioned to fly will not have a barometric 

altimeter display, but instead a GPS altitude display. An equivalent level of safety 
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will still be achieved. For further information regarding this will be dictated in the 

operations manuals. 

14 C.F.R. § 91.151(a)(1) Fuel Requirements for flight in VFR conditions

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

(considering wind and forecast weather conditions) there 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

Since the sUAS do not have fuel the operator can’t comply with this regulation.

Conversely the sUAS operate on battery power and have multiple fail-safes 

built into the sUAS. For a complete explanation on these safety features please 

refer to the operations manuals, which contain the user manual for the sUAS.

14 C.F.R. § 91.405(a) Maintenance Required

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter;

This regulation applies to part 43 aircraft, which have an airworthiness certificate.

Since the operator has already sought out relief from 14 C.F.R. § 91.7(a) it can 

not comply with above stated regulation. Should maintenance be required on the 

sUAS it will be in compliance with the user manual and documented per the 

operations manuals.

14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative maintenance, 

rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 

of this chapter; and

This regulation applies to part 43 aircraft, which have an airworthiness certificate.

Since the operator has already sought out relief from 14 C.F.R. § 91.7(a) it can 

not comply with above stated regulation. Should maintenance be required on the 

sUAS it will be in compliance with the user manual and documented per the 

operations manuals.
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14 C.F.R. § 91.409(a)(1) and (2) Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had--

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by Sec. 43.7 of this chapter; 

or

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.

This regulation applies to part 43 aircraft, which have an airworthiness certificate.

Since the operator has already sought out relief from 14 C.F.R. § 91.7(a) it can 

not comply with above stated regulation. Should maintenance be required on the 

sUAS it will be in compliance with the user manual and documented per the 

operations manuals.

14 C.F.R. § 91.417(a) and (b) Maintenance Records

(a) Except for work performed in accordance with §§91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

(b) The owner or operator shall retain the following records for the periods 

prescribed:

This regulation applies to part 43 aircraft, which have an airworthiness certificate.

Since the operator has already sought out relief from 14 C.F.R. § 91.7(a) it can 

not comply with above stated regulation. Should maintenance be required on the 

sUAS it will be in compliance with the user manual and documented per the 

operations manuals.

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:
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The operator seeks exemptions from the following regulations:

14 C.F.R. Part 21 Subpart H 

14 C.F.R. § 61.23(a) and (c)

14 C.F.R. § 61.101(e) 4 and 5

14 C.F.R. § 61.113(a) and (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F.R. § 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)(1)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.417(a) and (b)

To provide aerial photography and cinematography for commercial use and motion 

picture and television productions. 

Summary

The enhanced safety achieved by replacing manned aircraft with crew and 

flammable fuel with small unmanned UAS operated under the specific guidelines and 

procedures proposed by the operator gives the FAA good cause to find that UAS 

operations enabled by the instant petition are in the best interests of the public. Moreover, 

as the FAA has already recognized, “ UAS provide an additional tool for the filmmaking 

industry, adding a greater degree of flexibility, which supplements the current capabilities

offered by manned aircraft.” See Exemption No. 11062, Regulatory Docket No. FAA2014-0352, at. Pg. 22. 

In conclusion the regulatory exemptions requested herein should be granted and the 

operator should be permitted to conduct sUAS operations for the commercial and closedset photography and cinematography. 

Respectfully Submitted,

John M. Antoniades

JMA Visuals, LLC.

Owner/Operator