UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

JACKSON FAMILY VINEYARDS, 

Docket No. FAA-2014-

Petitioner. 

PETITION OF JACKSON FAMILY VINEYARDS 

.. ._: 

FOR AN EXEMPTION FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS 

Tim B. Adelman 

Leclair Ryan, 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 

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TABLE OF CONTENTS 

I. Petition for Exemption Summary 

II. Interests of Petitioner 

III. Proposed Conditions and Limitations for Petitioner's Exemption 

IV. Information Required to Support a Petition for Exemption 

A. Contact Information of Counsel 

B. Specific Sections of 14 CFR to be Exempt 

C. The Extent of Relief Sought, and the Reason for Such Relief 

D. Reasons Why an Exemption Would Further the Public Interest 

E. Reasons Why an Exemption Would Not Adversely Affect Safety 

F. Federal Register Summary 

1. Exemptions Requested 

2. Brief description of the nature of the exemption 

G. Additional Information Supporting an Exemption 

V. Conclusion 

Exhibit A- "Area of Operations" 

Exhibit B - "Proposed Conditions and Limitations" 

Exhibit C- "Maintenance Manual" 

Exhibit D -"Training Materials" 

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I. 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 (VFR fuel 

requirements), 91.405(a) (maintenance inspections), 91.407(a)(l) (return to 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 conduct Unmanned Aircraft System 

("UAS") operations over its private property in California and Washington. 

II. Interests of Petitioner 

Jackson owns and operates over 35,000 acres on which it grows and harvests grapes and 

conducts its large scale wine production business. For the purposes of this Petition, Jackson is 

focused on its properties in California and Washington, as depicted in Exhibit A "Area of 

Operations." The vineyards are large areas of farm land that is vulnerable to trespass and illegal 

activities. Currently, to protect the integrity of these properties, Jackson contracts with private 

security companies using human ground surveillance teams with local sheriffs department's 

canine units integrated into the surveillance teams. When the surveilling security guard 

discovers signs of trespassory use of Jackson property-often in the form of using Jackson 

irrigation and water systems for marijuana plant harvesting-the security guard contacts local 

law enforcement to request dispatch to these sites of suspected criminal activity. 

The UAS operation will compliment Jackson's current surveillance efforts. It will 

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 on potential illicit activity, highly trained UAS pilots will fly UAS equipped with still and 

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video photography over the Jackson properties to provide reliable birds-eye-view footage of 

what is occurring on the ground. This ability to see the properties for a few hundred feet in the 

air will allow Jackson to significantly enhance the effectiveness of its surveillance both in quality 

and quantity. When the 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. It will not adversely affect safety; rather, it will minimize potential confrontations 

between Jackson's private security guards, their canine partners, and trespassers using Jackson's 

property for illicit operations. In furtherance of the goals of 14 C.F.R. § 11.81, the UAS 

operation utilizing still and video photography to report to local law enforcement will be in the 

public interest and will provide a level of increased safety by minimizing the potential dangerous 

situations for the Jackson agents and contractors currently providing direct human surveillance. 

Moreover, Jackson will be more effective at preventing the illegal marijuana grows and property 

theft. 

III. Proposed Conditions and Limitations for Petitioner's Exemption 

Jackson proposes that its UAS operation be conducted pursuant to the Conditions and 

Operating Limitations set forth in Exhibit B -"Proposed Conditions and Limitations." Each of 

the conditions and limitations set forth in Exhibit 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 of Counsel 

Jackson Family Vineyards submits this Exemption Petition through 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"). 

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Timothy B. Adelman 

LeclairRyan, P.C. 

180 Admiral Cochrane Drive, Suite 370 

Annapolis, MD 21401 

Phone: 41 0-224-3 000 

Fax: 410-224-0098 

tim.adelman@leclairryan.com 

B. Specific Sections of 14 CFR to be Exempt 

14 C.P.R. § 61.56- Flight Review 

Id. at § 61.113 -Private Pilot 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 of Relief Sought, and the Reason for Such Relief 

i) When Jackson agents or contractors rely on UAS operations to conduct surveillance 

of Jackson's private property, Jackson will promote the safety, security, and wellbeing of all people and property involved by strictly abiding by the Proposed 

Conditions and Limitations set forth in Exhibit B. In order to conduct its proposed 

UAS operations with the AirCover QR-425s, Jackson requests exemptions from 

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certain Federal Aviation Regulations that were intended to promote the 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 

Jackson to conduct UAS operations over its private property with aircraft controlled by PICs 

who have completed AirCover's training regimen and successfully passed the FAA's Private 

Pilot Knowledge Exam. We respectfully submit this request in good faith after considering the 

numerous conditions and limitations proposed by this petition and the extensive nature of the 

AirCover's training program. A copy of AirCover's proprietary training materials is provided 

for FAA review in Exhibit D -"Training Materials." However, recognizing the FAA has denied 

a similar request for an exemption to the FAA pilot certificate requirement, Jackson alternatively 

will agree to utilize airmen with at least a private pilot certificate for the pilots of its UAS 

operation. 

14 C.F.R. § 61.113- Private Pilot Privileges and Limitations: Pilot in Command 

If the FAA determines that a private pilot certificate is necessary for UAS PICs, Jackson 

requests an exemption from§ 61.113 to the extent necessary to permit Jackson to conduct UAS 

operations with PICs holding FAA private pilot certificates. In most instances, the FAA would 

require a pilot to hold a commercial pilot certificate where there is compensation either to the 

pilot or for the operation. Jackson seeks waiver from this requirement, consistent with 

previously granted Section 333 exemptions, because requiring the Jackson pilots operating the 

AirCover QR-425s to adhere to the commercial pilot certification requirements will not improve 

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the safety of operations. Requiring airman "aeronautical knowledge," "aeronautical experience," 

and "flight proficiency" 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 with the certificate requirements imposed on the UAS pilots in recently 

granted Section 333 exemptions (see Astraeus Exemption, Trimble Exemption, and Clayco 

Exemption), Jackson requests the FAA grant an exemption from 14 C.F.R. § 61.113 and allow 

Jackson's U AS pilots who hold a FAA private pilot certificate or future FAA certification to 

serve as pilots for Jackson's UAS operations. 

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

Jackson requests an exemption from the airworthiness certificate requirement because the 

aircraft flown in Jackson's UAS operations will not have an airworthiness certificate pursuant to 

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 in Exhibit C "Maintenance Manual." The AirCover 

Maintenance Manual was reviewed by the FAA in conjunction with an experimental 

airworthiness application submitted by 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. 

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Jackson requests an exemption from this regulation so that its UAS operations may fly at 

low altitudes to better capture reliable video and still photography of its private property. In fact, 

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 "sparsely populated areas" contemplated by subpart (c). 

Specifically with respect to subpart (c), Jackson requests an exemption from the 

restriction that "aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, 

or structure." An exemption from subpart (c) will allow Jackson UAS operations' aircraft to 

optimally assess the conditions of its property and any suspected illicit activity occurring 

thereon. The lower the aircraft can fly for purposes of capturing video and still photography, the 

more it alleviates the danger to human and canine surveillance teams. As the reliance on human 

and canine surveillance teams diminishes, the potential for dangerous confrontations with 

trespassers also diminishes. Specifically, an exemption would allow Jackson to operate within 

500 feet ofvehicles and structures on its property as part of its surveillance. However, Jackson 

will not operate within 500 feet of persons, vessels, vehicles or structures not located within its 

private property. 

14 C.F.R. § 91.121 -Altimeter Settings 

Jackson requests an exemption from this regulation. While the AirCover UAS does not 

use a barometric 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 of takeoff, to ensure that measurements of the aircraft's altitude are 

accurate relative to the local elevation. Jackson will also be conducting flights within visual line 

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of sight. 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 Jackson UAS pilots to plan 

for only 10 (ten) minutes of operating reserve time to be available at the end of each UAS 

operation. Jackson's UAS operations will all occur within the boundaries of its private property. 

The takeoff and landing will occur within view of the pilot and at all times during the flight, the 

UAS aircraft will be less than 1 (one) mile from its takeoff and landing sight and on Jackson's 

private property. 

Jackson understands that the policy behind this regulation is to account for unexpected 

weather conditions and logistical delays occurring during a flight or when an aircraft seeks to 

land at its first planned destination. Jackson requests an exemption from this regulation because 

these considerations are not applicable here where Jackson's UAS operations will be hyperlocalized and will not realistically face the considerations undergirding the regulation's policy. 

Moreover, a shorter reserve will be an additional safety mechanism by limiting the ability of the 

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 of maintenance consistent with the FAA's 

standards communicated in the Astraeus Exemption and the Trimble Exemption. Moreover, 

AirCover's maintenance and operations manual have been reviewed by the FAA AIR-230 in 

connection with its application for experimental airworthiness and approved by Brook B. Stewart 

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(SAC FSDO) on April4, 2014. A copy of AirCover's proprietary Maintenance and Operations 

manual are provided for FAA review in Exhibit C- "Maintenance Manual." 

Jackson's exemption request 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 of equipment for which maintenance 

has been properly 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)- Operation After Maintenance, Preventive maintenance, Rebuilding, 

and Inspections 

Jackson requests an exemption from this regulation to permit Jackson to conduct its UAS 

operations without having to have the UAS approved for return to service by a person authorized 

under 14 C.F.R. § 43.7. AirCover has developed a comprehensive maintenance manual that has 

been reviewed by AIR-230 and approved by Brook B. Stewart (SAC FSDO) on April 3, 2014, in 

conjunction with its application for experimental airworthiness certificate. Maintaining the UAS 

consistent with the maintenance manual will provide an adequate level of safety and will not 

adversely affect safety with regard to the regulatory maintenance and alteration requirements. 

Jackson has accounted for the requisite conditions and limitations described in the 

Trimble Exemption and the Astraeus Exemption in crafting Jackson's own Conditions and 

Limitations. Jackson proposes that its UAS operations be subject to scrutiny under its 

Conditions and Limitations in lieu ofthe requirement 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 of maintenance record entries. 

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

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Jackson 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, Jackson will maintain the UAS in accordance with the approved AirCover maintenance 

manual. Moreover, Jackson will adhere to the proposed Conditions and Limitations, which will 

provide a level of safety at least equivalent to 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 maintain the 

UAS in accordance with the approved AirCover maintenance manual. Moreover, Jackson will 

adhere to the proposed Conditions and Limitations, which will provide a level of safety at least 

equivalent to that provided by this regulation and the requisite conditions and limitations 

described in the Trimble Exemption and the Astraeus Exemption. 

D. Reasons Why an Exemption Would Further the Public Interest 

With the FAA grant of Jackson's exemption petition, Jackson will be better able to safely 

monitor its private property. Using small UAS operations as an integrated part of the 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 captured by 

the UAS operations to local law enforcement, Jackson UAS operations will effectuate a smarter, 

more informed, and better prepared response to any illicit activities taking place on Jackson's 

property. Providing additional security to its properties, reducing the threat of theft and 

preventing illegal marijuana grows. Jackson's UAS operations will protect the public interest by 

reducing crime and reducing the burden on local law enforcement. 

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E. Reasons Why an Exemption Would Not Adversely Affect Safety 

Jackson's UAS operations will be conducted over its 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 own private property. Further, if the exception to 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 low altitudes over its private 

property that is only frequented by (a) authorized Jackson agents or (b) unauthorized trespassers 

using Jackson's private property for illicit purposes, will allow Jackson to minimize safety risks 

created by the UAS aircraft. Concurrently, the UAS will eliminate the risk to the safety of the 

surveillance teams and local law enforcement that would otherwise be protecting the integrity of 

Jackson's property. 

F. Federal Register Summary 

1. Exemptions Requested 

Jackson Family Vineyards 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. Brief description of the nature of the exemption 

The FAA exemption will permit Jackson Family Vineyards to operate an Unmanned 

Aircraft System ("UAS") over its private property located in the States of California and 

Washington as a means of surveilling its property with video and still photography equipment 

mounted on UAS aircraft being flown immediately above its property by pilots trained pursuant 

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to 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 in response to any FAA requests. A confidential copy of each of the Manuals 

will be submitted to the FAA Assistant Chief Counsel for International Law, Legislation, and 

Regulations as supporting documentation for this petition. The Manuals contain proprietary 

information of Jackson 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 exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 ofthe FAA Modernization and Reform Act of2012. The exemption will permit 

safe operation of the AirCover UAS for the special purpose of conducting aerial surveillance of 

Jackson uninhabited, private, agrarian property in the States of California and Washington. By 

granting this petition, the FAA Administrator satisfies the Congressional mandate of the FAA 

Modernization and Reform Act of2012, while also advancing the public interest by allowing 

Jackson to conduct UAS operations over its private property. 

Respectfully Submitted, 

Tim B. Adelman 

Leclair Ryan, P.C. 

COUNSEL FOR JACKSON FAMILY VINEYARDS 

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