### UNITED STATES OFAMERICA DEPARTMENT OFTRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

JACKSON FAMILY VINEYARDS, DocketNo. FAA-2014- Petitioner.

PETITION OFJACKSONFAMILYVINEYARDS .. ._:

FORAN EXEMPTIONFROMTITLE 14 OFTHE CODE OFFEDERALREGULATIONS TO PERMITUNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS Tim B. Adelman LeclairRyan, P.C. 180 Admiral Cochrane Drive, Suite 370 Annapolis, MD 21401 Phone: 410-224-3000 Fax: 410-224-0098 tim.adelman@leclairryan.com Submitted on December 31, 2014 . f <..TABLE OF CONTENTS I. Petition for Exemption Summary II. Interests ofPetitioner III. Proposed Conditions and Limitations for Petitioner's Exemption IV. Information Required to Support a Petition for Exemption A. Contact Information ofCounsel B. Specific Sections of 14 CFRto beExempt C. The Extent ofReliefSought, and the Reason for SuchRelief D. Reasons Why an Exemption Would Furtherthe Public Interest E. Reasons Why an Exemption WouldNotAdversely Affect Safety F. Federal Register Summary 1. Exemptions Requested 2. Briefdescription ofthe nature ofthe exemption G. Additional Information Supporting an Exemption V. Conclusion Exhibit A- "Area ofOperations" Exhibit B - "Proposed Conditions and Limitations" Exhibit C- "Maintenance Manual" Exhibit D-"TrainingMaterials"

2I. Petition for Exemption Summary Jackson Family Vineyards ("Jackson") seeks exemption from the requirements of 14 C.F.R. §§ 61.56 (flight review), 61.113(a) and (b) (private pilot limitations), 91.7(a) (airworthiness), 91.119 (minimum safe altitudes), 91.121 (altimeter settings), 91.151 (VFRfuel requirements), 91.405(a) (maintenance inspections), 91.407(a)(l) (returnto service after maintenance), 91.409(a)(l) and (2) (annual inspection), and 91.417(a) and (b) (maintenance records). Jackson seeks these exemptions to permit it to conductUnmannedAircraft System ("UAS") operations over its private property in California and Washington. II. Interests ofPetitioner Jackson owns and operates over 35,000 acres onwhich it grows and harvests grapes and conducts its large scale wine productionbusiness. Forthe purposes ofthis Petition, Jackson is focused on its properties in California and Washington, as depicted inExhibitA "Areaof Operations." The vineyards are large areas offarm land that is vulnerable to trespass andillegal activities. Currently, to protectthe integrity oftheseproperties, Jackson contracts withprivate security companies using human ground surveillance teams with local sheriffs department's canine units integrated into the surveillanceteams. Whenthe surveilling security guard discovers signs oftrespassory use ofJacksonproperty-ofteninthe form ofusing Jackson irrigation and water systems for marijuanaplantharvesting-the security guard contacts local lawenforcementto request dispatch to these sites ofsuspected criminal activity. The UAS operation will compliment Jackson's current surveillance efforts. Itwill minimize the need to utilize potentially dangerous surveillance methods where security guards and canine partners directly confront trespassers and their illegal activities. When a canine team alerts onpotential illicit activity, highly trained UAS pilots will fly UAS equippedwith still and

3video photography over the Jacksonproperties to provide reliable birds-eye-view footage of what is occurring onthe ground. This ability to see the properties for a few hundred feet in the air will allow Jackson to significantly enhance the effectiveness ofits surveillance both in quality and quantity. Whenthe photography detects suspicious activity, the images will be available to local law enforcement for further investigation. Jackson's UAS operation will be conditioned and limited as described, in Section III of this Petition. Itwill not adversely affect safety; rather, it will minimize potential confrontations betweenJackson's private security guards, their caninepartners, and trespassers using Jackson's property for illicit operations. In furtherance ofthe goals of 14 C.F.R. § 11.81, the UAS operation utilizing still and video photographyto report to local law enforcement will be in the public interest and will provide a level ofincreased safetybyminimizing the potential dangerous situations for the Jackson agents and contractors currentlyproviding direct human surveillance. Moreover, Jackson will bemore effective atpreventingthe illegal marijuana grows and property theft. III. Proposed Conditions and Limitations for Petitioner's Exemption Jackson proposes that its UAS operationbe conductedpursuant to the Conditions and Operating Limitations set forth inExhibit B -"Proposed Conditions and Limitations." Each of the conditions and limitations set forth inExhibit B is consistent with previously granted small UAS Section 333 exemptions and FAA guidance. 1 IV. Information Required to Support a Petition for Exemption A. Contact Information ofCounsel Jackson Family Vineyards submits this ExemptionPetitionthrough counsel:

1 See Exemption No. 11110 (December 10, 2014; Docket FAA-2014-0367) ("Trimble Exemption"); Exemption No. 11109 (December 10, 2014; Docket FAA-2014-0507) ("C1ayco Exemption"); Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352) ("Astraeus Exemption"). 4Timothy B. Adelman LeclairRyan, P.C. 180 Admiral Cochrane Drive, Suite 370 Annapolis, MD 21401 Phone: 410-224-3000 Fax: 410-224-0098 tim.adelman@leclairryan.com B. Specific Sections of14 CFR to be Exempt 14 C.P.R. § 61.56- Flight Review 

### Id. at § 61.113 -PrivatePilot Privileges and Limitations: Pilot in Command 

### Id. at§ 91.7(a)- Civil Aircraft Airworthiness 

### Id. at § 91.119- Minimum Safe Altitudes: General. 

### Id. at § 91.121

- Altimeter Settings 

### Id. at § 91.151

- Fuel Requirements for Flight in VFR Conditions 

### Id. at§ 91.405(a)- Maintenance Required 

### Id. at§ 91.407(a)(l)- Operation After Maintenance, Preventive maintenance, Rebuilding, and Inspections 

### Id. at§ 91.409(a)(l), (2)- Inspections 

### I

d. at § 91.417(a), (b)

- Maintenance Records C. The Extent ofReliefSought, and the Reason for Such Relief i) When Jackson agents or contractors rely on UAS operations to conduct surveillance ofJackson's private property, Jackson will promote the safety, security, and wellbeing ofall people and property involved by strictly abiding by the Proposed Conditions and Limitations set forth in Exhibit B. In orderto conduct its proposed UAS operations withthe AirCover QR-425s, Jackson requests exemptions from

5certain Federal Aviation Regulations that were intended to promotethe safety of manned aircraft. To conduct its UAS operations, Jackson petitions the FAA for an exemption from the following federal regulations for the reasons noted: 14 C.F.R. § 61.56- Flight Review Jackson requests an exemption from this regulation to the extent necessary to permit Jacksonto conduct UAS operations over its private property with aircraft controlledbyPICs who have completed AirCover's training regimen and successfullypassed the FAA's Private Pilot Knowledge Exam. We respectfully submitthis request in good faith after considering the

numerous conditions and limitationsproposed bythis petition and the extensive nature ofthe AirCover'strainingprogram. A copy ofAirCover's proprietary training materials is provided for FAAreviewinExhibit D -"TrainingMaterials." However, recognizingthe FAA has denied

a similarrequest for an exemptionto the FAApilot certificate requirement, Jackson alternatively will agree to utilize airmen with at least a private pilot certificate for the pilots ofits UAS operation. 14 C.F.R. § 61.113- Private Pilot Privileges and Limitations: Pilot in Command Ifthe FAA determines that a private pilot certificate is necessary for UAS PICs, Jackson requests an exemption from§ 61.113 to the extent necessary to permitJackson to conductUAS operations with PICs holding FAAprivate pilot certificates. In most instances, the FAA would require a pilotto hold a commercial pilot certificate where there is compensation either to the pilot orfor the operation. Jackson seeks waiver from this requirement, consistent with previously granted Section 333 exemptions, because requiring the Jackson pilots operatingthe AirCover QR-425s to adhere to the commercial pilot certification requirements will not improve

6the safety ofoperations. Requiring airman "aeronautical knowledge," "aeronautical experience," and "flightproficiency" at the commercial certificate level for those individuals operating a remote-controlled, battery-powered UAS aircraft weighing less than 7 pounds and operated in accordance with the conditions and limitations set forth in Exhibit B would not bring the corresponding safety benefits contemplated in the manned commercial aircraft setting. Therefore, consistent withthe certificate requirements imposed onthe UAS pilots inrecently granted Section 333 exemptions (see Astraeus Exemption, TrimbleExemption, and Clayco Exemption), Jacksonrequests the FAA grant an exemption from 14 C.F.R. § 61.113 and allow Jackson's UAS pilots who hold a FAA privatepilot certificate or future FAA certificationto

serve as pilots for Jackson's UAS operations. 14 C.F.R. § 91.7(a)- Civil Aircraft Airworthiness Jacksonrequests an exemption from the airworthiness certificate requirement because the aircraft flown in Jackson's UAS operations will not have an airworthiness certificate pursuantto 14 C.F.R. Part 21, Subpart H. Jackson understands that without an airworthiness certificate, it must inspect each aircraft before each flight to determine that it is compliant with Jackson's UAS Operations Manual which is provided inExhibit C "Maintenance Manual." The AirCover Maintenance Manual was reviewed by the FAA in conjunction with an experimental airworthiness application submittedby AirCover. The Maintenance Manual was approved by Brook B. Stewart (SAC FSDO) on April3, 2014. Jackson bases this particular exemption request on the rationale that "[C]ompliance with [Jackson's] Manuals [is a] sufficient means for determining an airworthy condition." Trimble Exemption, at 16. 14 C.F.R. § 91.119- Minimum Safe Altitudes: General.

7Jacksonrequests an exemption from this regulation so that its UAS operations may fly at low altitudes to better capture reliable video and still photography ofits private property. Infact, only subpart (c) is relevant to Jackson's UAS operations because Jackson only intends to conduct UAS operations over its private vineyards which are not located near any populated areas and easily classified as "sparselypopulated areas" contemplated by subpart (c). Specifically withrespect to subpart (c), Jackson requests an exemption from the restriction that "aircraft may notbe operated closer than 500 feet to any person, vessel, vehicle,

or structure." Anexemption from subpart (c) will allow Jackson UAS operations' aircraft to optimally assess the conditions ofits property and any suspectedillicit activity occurring thereon. The lowerthe aircraft can fly for purposes ofcapturing video and still photography, the

more it alleviates the dangerto human and canine surveillanceteams. As the reliance onhuman and canine surveillanceteams diminishes, the potential for dangerous confrontations with trespassers also diminishes. Specifically, an exemptionwould allow Jacksonto operate within 500 feet ofvehicles and structures on its property as part ofits surveillance. However, Jackson will not operate within 500 feet ofpersons, vessels, vehicles or structures not located withinits private property. 14 C.F.R. § 91.121 -Altimeter Settings Jackson requests an exemption from this regulation. While the AirCover UAS does not

use abarometric altimeter, it determines altitude with a GPS signal. Jackson's UAS operations pilots will check the aircraft's altitude reading prior to each takeoff, and will effectively zero the aircraft's altitude at the point oftakeoff, to ensure that measurements ofthe aircraft's altitude are accurate relative to the local elevation. Jackson will also be conducting flights within visual line

8ofsight. Ifthis approach is deemed to not satisfy 14 C.P.R.§ 91.121, Jackson requests an exemption so that Jackson UAS operations can utilize this GPS signal methodology. 14 C.F.R. § 91.151- Fuel Requirements for Flight in VFR Conditions Jackson requests an exemption from this regulation to permit JacksonUAS pilots to plan for only 10 (ten) minutes ofoperating reserve time to be available atthe end ofeach UAS operation. Jackson's UAS operations will all occur withinthe boundaries ofits private property. The takeoffand landing will occur withinview ofthe pilot and at all times during the flight, the UAS aircraft will be less than 1 (one) mile from its takeoffand landing sight and on Jackson's private property. Jackson understands that the policybehindthis regulation is to account for unexpected weather conditions and logistical delays occurring during a flight orwhen an aircraft seeks to land at its first planned destination. Jackson requests an exemption from this regulationbecause these considerations are not applicable here where Jackson's UAS operations will be hyperlocalized and will notrealistically face the considerations undergirding the regulation'spolicy. Moreover, a shorterreserve will be an additional safety mechanismby limiting the ability ofthe UA to fly far from its initial launch location. 14 C.F.R. § 91.405(a)- Maintenance Required Jackson requests an exemption from this regulation's obligation to perform inspections and discrepancy repairs by FAA authorized mechanics. Jackson proposes Conditions and Limitations in Exhibit B, that will require a level ofmaintenance consistent with the FAA's standards communicated inthe Astraeus Exemption and the Trimble Exemption. Moreover, AirCover's maintenance and operations manual have beenreviewed by the FAA AIR-230 in connection with its application for experimental airworthiness and approved by Brook B. Stewart

9(SAC FSDO) on April4, 2014. A copy ofAirCover's proprietary Maintenance and Operations manual are provided for FAA review in Exhibit C- "Maintenance Manual." Jackson's exemptionrequest regarding this regulation is limited to subpart (a) because it will make appropriate logbook entries in aircraft maintenance records in compliance with subpart (b), appropriately mark any inoperative instrument or item ofequipment for whichmaintenance has beenproperly deferred in compliance with subpart (c), and appropriately placard listed discrepancies that include inoperative instruments or equipment in compliance with subpart (d).
14 C.F.R. § 91.407(a)(1)- OperationAfterMaintenance, Preventive maintenance, Rebuilding, and Inspections Jacksonrequests an exemption from this regulation to permitJackson to conduct its UAS operations without having to have the UAS approved for returnto service by a person authorized under 14 C.F.R. §43.7. AirCoverhas developed a comprehensive maintenance manual thathas beenreviewed byAIR-230 and approvedbyBrookB. Stewart (SAC FSDO) onApril 3, 2014, in conjunction with its application for experimental airworthiness certificate. Maintaining the UAS consistent withthe maintenance manual will provide an adequate level ofsafety and will not adversely affect safety withregard to the regulatory maintenance and alterationrequirements. Jackson has accounted for the requisite conditions and limitations described inthe Trimble Exemption and the Astraeus Exemption in crafting Jackson's own Conditions and Limitations. Jacksonproposes that its UAS operations be subject to scrutiny under its Conditions and Limitations in lieu oftherequirement that it satisfy 14 C.F.R. §91.407(a)(1). Related to this regulation, Jackson UAS operations will comply with subpart (a)(2) because Jackson UAS operations will require completion ofmaintenance record entries. 14 C.F.R. § 91.409(a)(1) and (2)- Inspections

10Jackson requests an exemption from this regulation so that Jackson will not be required to obtain annual inspections and airworthiness certificate inspections required by this regulation. Instead, Jacksonwill maintainthe UAS in accordance with the approved AirCover maintenance manual. Moreover, Jackson will adhere to the proposed Conditions and Limitations, whichwill provide a level ofsafety at least equivalentto that provided by this regulation and the requisite conditions and limitations described in the Trimble Exemption and the Astraeus Exemption. 14 C.F.R. § 91.417(a), (b)- Maintenance Records Jackson requests an exemption from this regulation so that Jackson will not be required to keep the maintenance records described by this regulation. Instead, Jackson will maintainthe UAS in accordance withthe approved AirCover maintenance manual. Moreover, Jackson will adhere to the proposed Conditions and Limitations, which will provide a level ofsafety at least equivalentto thatprovidedby this regulation and the requisite conditions and limitations described inthe Trimble Exemption and the Astraeus Exemption. D. Reasons Why an Exemption Would Further the Public Interest Withthe FAA grant ofJackson's exemption petition, Jackson will be better able to safely monitor its privateproperty. Using small UAS operations as an integrated part ofthe human and canine teams will reduce the potential for hostile confrontations between these teams and trespassers using Jackson's property. By providing the video and still photography capturedby the UAS operations to local law enforcement, Jackson UAS operations will effectuate a smarter,

more informed, and betterprepared response to any illicit activities taking place on Jackson's property. Providing additional securityto its properties, reducing the threat oftheft and preventing illegal marijuana grows. Jackson's UAS operations will protect the public interestby reducing crime and reducing the burden on local law enforcement.

11E. Reasons Why an Exemption Would Not Adversely Affect Safety Jackson's UAS operations will be conducted overits private property, allowing Jackson to maintain a sterile operating environment. As such, Jackson will be able to conduct its operations without adversely affecting safety. Every flight will be restricted to Class G airspace above its ownprivateproperty. Further, ifthe exceptionto 14 C.F.R. § 91.119 (the minimum safe altitudes provision) is granted, the UAS will be authorized to fly at low altitudes with little to no air traffic. Conducting its UAS operations at relatively lowaltitudes over its private propertythat is only frequented by (a) authorized Jackson agents or (b) unauthorized trespassers using Jackson's privateproperty for illicit purposes, will allowJackson to minimize safetyrisks createdbythe UAS aircraft. Concurrently, the UAS will eliminatetheriskto the safety ofthe surveillance teams and local lawenforcementthat would otherwise beprotectingthe integrity of Jackson'sproperty. F. Federal Register Summary 1. Exemptions Requested JacksonFamilyVineyards seeks exemption from the requirements of 14 C.F.R. 

### § § 61.56, 61.113(a) and (b), 91.7(a), 91.119, 91.121, 91.151, 91.405(a), 91.407(a)(l), 91.409(a)(1) and (2), and 91.417(a) and (b). 2. Briefdescription ofthe nature ofthe exemption The FAA exemption will permit Jackson Family Vineyards to operate anUnmanned Aircraft System ("UAS") over its private property located inthe States ofCalifornia and Washington as a means ofsurveilling its property with video and still photography equipment mounted on UAS aircraft being flown immediately above its property by pilots trainedpursuant

12to Jackson's Safety Conditions and Limitations provided to the FAA with Jackson's Exemption Petition. G. Additional Information Supporting an Exemption Jackson will readily provide additional information that the FAA might find helpful, or to

answer questions inresponse to any FAA requests. A confidential copy ofeach ofthe Manuals will be submitted to the FAA Assistant ChiefCounsel for International Law, Legislation, and Regulations as supporting documentation for this petition. The Manuals containproprietary information ofJackson and AirCover. Therefore, Jackson requests that the FAA treat the Manuals as confidential and not disclose them to the public. V. Conclusion As set forth above, Jackson seeks an exemptionpursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012. The exemption will permit safe operation ofthe AirCover UAS for the special purpose ofconducting aerial surveillance of Jackson uninhabited, private, agrarianproperty in the States ofCalifornia and Washington. By granting this petition, the FAA Administrator satisfies the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the public interest by allowing Jackson to conduct UAS operations overits privateproperty.
Respectfully Submitted,

Tim B. Adelman Leclair Ryan, P.C. COUNSEL FOR JACKSON FAMILY VINEYARDS

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