UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF:

JL4, INC.,

 PETITIONER.

Re: Exemption Request Pursuant to Section 333 of

the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from: 14 CFR Part 21 

subpart H

14 CFR 45.23 (b); 14 CFR 61.113(a), (b); 14 CFR

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103(b)(2); 

14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119; 

14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203; 

14 CFR 91.405; 14 CFR 91.407; 14 CFR 91.409; 

and 14 CFR 91.417

FAA Docket No.: _______________

via Online Docketing System
PETITION FOR EXEMPTION

JL4, Inc., doing business as Georgia Land Surveying Company (“Petitioner”), by 

and through the undersigned counsel, submits this Petition for Exemption pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14

CFR § Part 11, requesting exemption from the Federal Aviation Regulations (“FARs”)

listed below to allow commercial operation of its small unmanned aircraft system (“UAS”),

because its proposed operations will be conducted within and under the conditions outlined 

herein or as my be established by the Federal Aviation Administration (“FAA”) from time 

to time. Petitioner’s request for relief based on the proposed operations outlined in this 

Petition would achieve a level of safety at least equal to that of the FARs from which 

exemption is sought, and in support thereof submits the following:

I. SUMMARY OF REQUESTED RELIEF

As described in more detail below, the requested exemption would permit the

operation of UAS under controlled conditions in the NAS that would be (a) limited (b)

controlled (c) predetermined and (d) will provide safety enhancements to the already safe

operations in the industry presently using conventional aircraft. Approval of this

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the

FAA Administrator’s) responsibilities to “....establish requirements for the safe operation

of such aircraft systems in the national airspace system.”

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a), (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103(b)(2)

14 CFR 91.105

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151

14 CFR 91.203

14 CFR 91.405

14 CFR 91.407

14 CFR 91.409

14 CFR 91.417

II. SUMMARY OF PROPOSED OPERATIONS SUPPORTING 

EXEMPTION

Commercial operation UAS, as described herein, which are equipped with

cameras and sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including

land surveying, building surveying and inspection, power line inspection, 
aerial photography, aerial videography, LIDAR based remote sensing, 

and other similar functions.

2. The UAS weighs less than 55 pounds.

3. Flights will be planned for a duration that will allow for a battery reserve 

equaling at least 25% of the battery’s capacity.

4. Flights will be operated at an altitude of no more than 400 feet Above

Ground Level (AGL).

5. The UAS operator, or pilot in command (PIC), will meet all minimum 

requirements imposed by relevant law.

6. The UAS will always be operated while in the PIC’s line of sight. A 

visual observer may be used when necessary.

7. The operator will file FAA Form 7711-1, or its equivalent, as modified in

light of the requested exemption, with the appropriate local Flight

Standards District Office (FSDO) no more than 72 hours but no less than

48 hours from planned operation. 8. A briefing will be performed regarding the planned UAS operations prior

to each flight.

9. The operator will coordinate with the appropriate FSDO per current FARs 

and other regulatory guidance provided by the FAA.

10. If the UAS loses communications or loses GPS signal, the UAS will have

the capability to return to a pre-determined location within a designated

location and land autonomously. 11. The UAS will have the capability to abort a flight in case of

unpredicted obstacles, weather, or emergencies.

III. UAS AND EQUIVALENT LEVEL OF SAFETY

Petitioner’s proposed operations with a grant of exemptions requested herein

will be conducted with an equivalent or higher level of safety as compared to 

manned aircraft operations in compliance with the same. FAA has granted 

exemptions under the Reform Act to petitioners operating the same or similar UAS

as Petitioner in: FAA Docket Numbers FAA-2015-2337 and FAA-2015-0965. The 

relevant UAS safety specifications are listed below and included in Schedule A 

(Description of UAS). The UAS: 

A. 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Petitioner requests exemption from the FARs concerning the requirement of

airworthiness certificates because UAS size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation within visual line of sight does 

not create a hazard to users of the national airspace system or the public or pose a threat 

to national security.

Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a)

(1). Given the size and limited operating area associated with the aircraft to be utilized by

Petitioner, 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 the restricted environment and
under the conditions proposed will be at least as safe, or safer, than a conventional aircraft

(fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed.

The UAS to be operated hereunder is less than 12 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates

exclusively within a secured and designated 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. The FAA

will have advance notice of all operations. These safety enhancements 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 UAS, 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. For 

these reasons, Petitioner requests an exemption from 14 CFR § 45.23(b). Furthermore, 

Petitioner would be required to coordinate flights with the local FSDO—an oversight 

mechanism that greatly reduces many of the concerns with national airspace system safety 

and security.

B. 14 CFR § 45.23(b). Marking of the Aircraft

The regulation requires: 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. Even though the UAS will have no

airworthiness certificate, an exemption may be needed as the UAS will have no entrance

to the cabin, cockpit or pilot station on which the word “Experimental” can be placed.

Given the size of the UAS, two- inch lettering will be impossible. The word

“Experimental” will be placed on the fuselage in compliance with § 45.29(f). The

equivalent level of safety will be provided by having the UAS marked on its fuselage as

required by § 45.29(f) where the pilot, observer and others working with the UAS will see

the identification of the UAS as “Experimental.” For these reasons, Petitioner requests an 

exemption from 14 CFR § 45.23(b).

C. 14 CFR § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command.

Petitioner’s proposed operations fall within the FAA’s policy for the commercial 

operation of UAS. Because the PIC or operator may lawfully operate a UAS for hire

pursuant to FAA policy, Petitioner requests an exemption from 14 CFR § 61.113(a).

D. 14 CFR § 91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. As there will be no airworthiness certificate issued for the aircraft,

should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft for maintenance and use of safety checklists

prior to each flight an equivalent level of safety will be provided. For these reasons, 

Petitioner requests an exemption from 14 CFR § 91.7(a).
E. 14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 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. The UAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because there

is no room or capacity to carry such an item on the aircraft. The equivalent level of safety

will be maintained by keeping the flight manual at the ground control point where the

pilot flying the UAS will have immediate access to it. For these reasons, Petitioner 

requests an exemption from 14 CFR § 91.9(b)(2).

F. 14 CFR § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight

to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be

provided for the aircraft an exemption will be needed. The PIC will take all actions

including reviewing weather, flight battery requirements, landing and takeoff distances

and aircraft performance data before initiation of flight. For these reasons, Petitioner 

requests an exemption from 14 CFR § 91.103.

G. 14 CFR §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a

manned free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls. UAS and remotely piloted aircraft, by their design do not have

fully functional dual controls. Flight control is accomplished through the use of a control

box that communicates with the aircraft via radio communications. The FAA has

approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. The equivalent level

of safety provided by the fact that neither a pilot nor passengers will be carried in the

aircraft and by the size and speed of the aircraft. For these reasons, Petitioner requests 

an exemption from 14 CFR § 91.109.

H. 14 CFR § 91.119: Minimum Safe Altitudes.

Because Petitioner intends to operate the UAS within the permissible altitudes 

specified in the blanked COA for UAS or any subsequent COA, Petitioner requests 

exemption from the minimum safe altitude regulations contained in 14 CFR § 91.119.

I. 14 CFR § 91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set “...to the elevation of the departure airport

or an appropriate altimeter setting available before departure.” As the UAS may not have

a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed.

An equivalent level of safety will be achieved by the operator, pursuant to the safety

check list and live flight data monitoring, confirming the altitude of the launch site

shown on the GPS altitude indicator before flight. For these reasons, Petitioner requests 

an exemption from 14 CFR § 91.121.
J. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane

under VFR conditions unless (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 (2) At night, to fly 

after that for at least 45 minutes.

The battery powering the UAS provides approximately 22 minutes of powered

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights

would be limited to approximately 10 minutes in length. Given the limitations on the

UAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or twilight VFR

conditions is reasonable.

Petitioner requests exemption from 14 CFR §91.151(a) because public safety and 

the safety of the national airspace system is not compromised under Petitioner’s proposed 

operations. This request has also been granted by the FAA under prior Section 333 

exemptions. Operating the small UAS, in a tightly controlled area where only people

and property owners or official representatives who have signed waivers will be

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks

that Section 91.151(a) was intended to alleviate given the size and speed of the small

UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility

for which the exemption will be granted. Petitioner believes that an equivalent level of

safety can be achieved by limiting flights to 17 minutes or 25% of battery power—

whichever happens first. This restriction would be more than adequate to return the

UAS to its planned landing zone from anywhere in its limited operating area. For these 

reasons, Petitioner requests an exemption from 14 CFR § 91.151(a).

K. 14 CFR § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person 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.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an

onboard pilot. As such, there is no ability or place to carry certification and registration

documents or to display them on the UAS. An equivalent level of safety will be achieved

by keeping these documents at the ground control point where the pilot flying the UAS

will have immediate access to them, to the extent they are applicable to the UAS. For 

these reasons, Petitioner requests an exemption from 14 CFR § 91.203(a) and (b).
L. 14 CFR §§ 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): Maintenance

Inspections.

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in

compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the Petitioner. Maintenance will be

accomplished by the operator pursuant to the flight manual and operating handbook. An

equivalent level of safety will be achieved because these small UASs are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods

of time. If mechanical issues arise the UAS can land immediately and will be operating

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working

order prior to initiating flight, perform required maintenance, and keep a log of any

maintenance performed. Moreover, the operator is the person most familiar with the

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and

inspections will be performed in accordance with the UAS Manufacturer’s Manual, as

referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the

operator will ensure that the UAS is in working order prior to initiating flight and

perform required maintenance needed. For these reasons, Petitioner requests an 

exemption from 14 CFR §§ 91.405(a); 407(a)(1); 409 (a)(2); 417(a) and (b).

IV. REGARDING THE UAS PILOT IN COMMAND

Petitioner is committed making safety of the national airspace and public safety a 

priority. Petitioner will only utilize the services of UAS operators for its commercial 

flights that have demonstrated proficiency in UAS operations and meet the minimum 

qualifications required by law. The relief requested in this section is bifurcated with the 

relief in section B being requested in anticipation of possible PIC requirements the FAA 

may include in its order. 

Petitioner’s proposed operations can be carried out by a PIC holding a Student 

Certificate without compromising public safety and the safety of the national airspace 

system.1 The Student Certificate is the most appropriate certificate for Petitioner’s 

proposed UAS operations due to: 

(1) the minimal imposition on navigable airspace; 

(2) cooperation with FSDO prior to operations; 

(3) the lack of any people onboard the UAS; 

 1 Petitioner asserts, as many other petitioners have, that its proposed operations can be carried out safely 

without using an operator that possesses an FAA-issued airman certificate; however, the FAA’s policy 

interpretation that it is not permitted to authorize an operator to control an aircraft in the national airspace 

without an airman certificate gives rise to this request for the airman certificate that bears the closest 

resemblance to the degree of aeronautical knowledge and proficiency necessary for Petitioner to operate a 

UAS with the same degree of safety as a traditional aircraft. It is Petitioner’s position that the foregoing 

statement is consistent with the policy outlined in the Notice of Proposed Rulemaking for UAS regulations.
(4) the majority of operations being conducted over uninhabited and unimproved 

land; 

(5) the UAS being battery powered rather than combustible fuel propelled; 

(6) the widely accepted practice of the public operating the same or similar UASs 

in the same application for non-commercial purposes with no formal training or 

certificate; 

(7) the relative ease of familiarization with UAS technology as contrasted with 

traditional aircraft; and

(8) the greatly reduced implications of a UAS incident as contrasted with a 

traditional aircraft. 

The level of aeronautical knowledge experience, and training attributable to a 

student pilot of a traditional aircraft operating in a variety of controlled airspaces with 

advanced technological systems is adequate to facilitate Petitioner’s safe operation of 

UAS while adhering to the United States legislature’s mandate that all aircraft operators 

in the national airspace must be certificated. Should a more advanced degree of 

certification be required, the result would cause undue economic hardship given the 

Petitioner’s options would be limited to hiring a licensed pilot or sending Petitioner’s 

agents through a more advanced level of flight training than would be required. A 

requirement that a certificate more advanced than a Student Certificate could arguably be 

arbitrary and capricious as the proposed regulations for UAS operation in the UAS Notice 

of Proposed Rulemaking is substantially less burdensome than even a Light Sport or 

Recreational Certificate. Requiring such certificates could diminish Petitioner’s ability to 

engage in the very types of operations supported by the legislature by making it either 

economically impracticable or causing Petitioner’s employees to spend more time on 

airman certification than will likely be required by the permanent UAS regulations. The 

current regulatory framework governing the oversight of commercial civil UAS operation 

provides an adequate level of accountability as the requests of this Section are applied to 

Petitioner’s proposed operations. Petitioner also submits the foregoing in support of 

requiring a valid driver’s license with self-certification of medical fitness as an alternative 

to a Medical Certificate.

V. PUBLIC SAFETY AND PUBLIC BENEFIT

Public safety is dramatically improved by Petitioner’s proposed operations because 

the UAS can perform inspections and surveying functions in dangerous environments 

including, but not limited to, hazardous waste accidents; natural disasters; and areas 

where ongoing hostile or criminal events are occurring. These types of dangerous 

environments typically put emergency response personnel in danger of physical harm. 

Petitioner’s proposed operations benefit the public by gather information despite these 

harms and improves public safety by mitigating the need for personnel to be on the 

scene. 

Petitioner’s proposed operations will improve public safety and provide a public 

benefit because the UAS will not emit pollutants like larger aircraft. The public will 

also benefit from reduction in noise pollution because Petitioner’s use of a UAS over a 

traditional manned aircraft. 

VI. CONCLUSION
Petitioner respectfully requests that this exemption be grated due to its satisfaction

of the criteria provided in Section 333 of the Reform Act of 2012. The extent of relief 

requested by Petitioner is for exemption from all regulations listed above in full subject to 

conditions or partial denials, if any, prescribed by the FAA as it has done for the substantially 

similar petitions for exemption noted above.

Respectfully submitted,

HARDY LAW, LLC

By: /s/

 Jason Kemp

 Attorney for Petitioner

 
SCHEDULE A 

Schedule 1 - UAS Description 

Item Description

Full Legal Name of UA Manufacturer or Builder Turbo Ace

sUA Model Designation Matrix-S

Serial No. JL4-1

Class (Airplane, Airship, Rotorcraft, Gyroplane, Ducted Fan) Rotorcraft

sUA Maximum Takeoff Weight 11 lbs

Category (Land, Sea, or Both) Land

Name of Engine Manufacturer Turbo Ace

Engine Model Designation TA-MAT-13

Engine Serial-Numbers (if none shown, enter 'none') None

Number of Engines 4

Engine Power Output (given in HP or Lbs. Thrust) 7.4 pounds of thrust

Engine Type (2 or 4 Cycle Reciprocating, Electric,

Turbo - Fan/Prop/Shaft/Jet) Electric

FAA Registration No. To be determined:

Application submitted 

to FAA Registration 

Division