Justin Robinson

JR Aeronautics LLC

9911 Winands Road

Randallstown,MD

21133

Glossary of Abbreviations

❏ AGL Above Ground Level

❏ ATC Air Traffic Control

❏ CFR Code of Federal Regulations

❏ FAA Federal Aviation Administration

❏ FAR Federal Aviation Regulation

❏ FPV First Person View

❏ GS Ground Speed

❏ GPS Global Positioning System

❏ NAS National Air Space

❏ NOTAM Notices to Airmen

❏ PIC Pilot In Command

❏ UAV Unmanned Aerial Vehicle

❏ VFR Visual Flight Rules

❏ VO Visual Observer

Justin Robinson, owner JR Aeronautics LLC, respectfully submits this petition for

exemption. I, Justin Robinson, am writing pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012. I request exemptions from the following FAA regulations so that my

business may operate UAVs in the NAS commercially.

The specific sections of 14CFR from which JR Aeronautics LLC seeks exemptions

JR Aeronautics LLC kindly requests exemptions from the following regulations.

14 C.F.R. Part 21;

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113 (a) & !(b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b)

14 CFR 91.103 (b)

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (1) and (2)

14 CFR 91.417 (a) & (b)

The extent of relief JR Aeronautics LLC requests

JR Aeronautics LLC requests relief from the previously stated regulations to fly commercial

UAVs in the NAS. Should this exemption be granted, JR Aeronautics LLC will offer aerial imagery

to the American public. We believe our company can safely integrate UAVs into the NAS. Our

goal is to provide the world with valuable examples guiding the way for other UAV operators.

This exemption will help us demonstrate to other pilots the safest way to operate commercial

UAVs in NAS. Our objective is to provide the public with safe low level

aerial platforms.

JR Aeronautics LLC wishes to safely offer aerial imagery in the following fields:

Real Estate

Sports

Surveying

Inspections

Marketing

Public Events

How this exemption will benefit the public as a whole

Should this exemption be granted, JR Aeronautics LLC will fly UAVs in the NAS

commercially. Aerial imagery creates many valuable benefits for the public. It helps potential

property buyers see surrounding terrain. Realtors can utilize the unique footage to honestly

portray property. Realtors are not the only people to benefit from commercial UAVs. JR Aeronautics also 

plans to help local farmers. Our aerial services can help farmers monitor their

crops. We have the capability to fly over fields giving different perspectives of the ground.

Abnormal growing problems can be detected from the air. By offering our aerial services, the

local agricultural community will save money. If granted, this exemption will also be used to offer

aerial inspections for industrial companies. As of now, industrial companies located in

mountainous terrain must cope with dangerous and adverse flight conditions. Helicopter pilots

must fly low and slow to gain proper inspection information. Experienced helicopter pilots die

every year from the unnecessary risks associated with aerial inspections. The high risk

connected to aerial inspections often forces companies to abandon manned inspection flights all

together. This puts the public at risk and endangers workers. By offering unmanned aerial

inspections, JR Aeronautics LLC will make the public safer. Our UAVs are much smaller and

lighter than manned helicopters. This allows us to fly much slower and lower. By offering a safer

alternative to manned aerial inspections, companies will more willingly inspect their property.

Tourism is another area that will benefit from aerial imagery. Unique aerial footage can highlight key 

attractions for potential tourists. One effective way to attract potential tourists is sharing appealing videos 

on the internet. Mountain bike videos, ski movies, and other sport production films help bring travelers

to Maryland. High quality video captured by JR Aeronautics LLC UAVs will promote

local tourist attractions. Aerial footage makes the simplest advertisement videos look

professional. Local businesses can promote their products much easier. This will benefit local

our economy and increase the tax base. More people will become aware of the beautiful

scenery Maryland has to offer. JR Aeronautics LLC can offer useful aerial footage without

endangering citizens. We can fly missions without polluting the air with unnecessary C02. Our

UAVs operate with low noise levels thus reducing noise impacts to wildlife and humans.

JR Aeronautics LLC will also benefit the UAV community as a whole. Our goal is to provide this

region with examples of safe UAV operation.
Reasons why this exemption will not adversely affect safety

14 C.F.R. Part 21

JR Aeronautics LLC wishes to be relieved from 14 C.F.R Part 21. If operated according to

flight rules and procedures mentioned in part 1, the DJI PHANTOM 3 PROFESSIONAL do not put 

persons or property at risk. Based on the UAVs operating parameters

(depicted at the end of the document), we believe an airworthiness certificate is unnecessary.

The airworthiness of our UAVs will be determined by the PIC and VO prior to every flight. A

thorough checklist will guide the PIC and VO in approving the UAV for flight. If the PIC and VO

agree that the UAV is safe for flight, the UAV will become airworthy. If something with the UAV

is found amiss during the preflight checklist, the flight will be cancelled. The problem will be

fixed and the UAV must pass a preflight inspection to become airworthy again. The PIC for

JR Aeronautics LLC will hold a sport pilot certificate of higher class rating. Because JR Aeronautics LLC 

PIC will hold a sport pilot certificate or higher class rating, similar pilot judgment used

in scale aircraft will be implemented into the operation of our UAVs. For example, a PIC holding

a sport pilot certificate is very familiar with the importance of a preflight checklist. Completion

of the specific UAV checklist will take place before each flight. Our UAVs are small, lightweight,

and fly at speeds well below 50 mph. Due to JR Aeronautics LLC flight procedures and operating

limitations, our flight rules will make us safer compared to manned aircraft operating in

accordance with 14 C.F.R. Part 21.

14 C.F.R. 45.23 (b)

The 14 C.F.R. 45.23 (b) regulations: When marks include only the Roman capital letter

“N” and the registration number is displayed on limited, restricted or lightsport

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,” “lightsport,”

“experimental,” or

“provisional,” as applicable (FAA regulations 14 C.F.R. 45.23 (b) ). JR Aeronautics LLC UAVs

(DJI PHANTOM 3 PROFESSIONAL) are not big enough to display large text

on the body. We request to be exempt from this regulation because an equal amount of safety

can be achieved by placing the identification letters elsewhere. UAVs do not have an interior

cabin or cockpit. The PIC and VO remain stationary on earth. The PIC and VO operate the UAV

using a ground station. The words “ground station” refers to the UAVs control equipment on the

ground. Such equipment can include the UAV controller, video receivers, and LCD telemetry

monitors. Instead of placing the large “N” numbers and aircraft type on the UAV, the letters will

be placed on the ground equipment. The N number and aircraft type will be displayed viewable

to ground personnel. This will allow all bystanders (bystanders must remain 150 feet away from

the UAV at all times) to familiarize themselves with the aircraft type and identification numbers.

Small “N” numbers will be place on the UAV for extra precaution. Due to the size of the UAV,

the small “N” numbers may not be visible at all times.

14 C.F.R. 61.113 (a) & (b)

This regulation states: “no person who holds a sport 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” (FAA

Regulation 14 C.F.R. 61.113 (a) & (b) ). JR Aeronautics LLC wishes to be relieved from this rule

because an adequate amount of safety will be provided. Our UAVs (DJI PHANTOM 3 PROFESSIONAL

and DJI Inspire 1) will not carry passengers or cargo. Our companies flight limitations

and procedures (depicted at the end of the document) will prohibit the UAVs from operating in a
dangerous manner. JR Aeronautics LLC PIC will hold a sport pilot certificate or better. Holding a

commercial pilot's license does not specifically prove a pilot's ability to operate a UAV. A PIC

must successfully prove his or her ability to fly a UAV by completing the necessary pilot

milestones. Necessary PIC requirements can be found at the end of this document. JR Aeronautics LLC

wishes to be relieved from 14 C.F.R. 61.113 (a) & (B) so that a PIC holding a sport

pilot license can act as PIC for a commercial UAV.

14 C.F.R. 91.7 (a)

This regulation states: “ No person may operate a civil aircraft unless it is in an airworthy

condition” (FAA Regulation 14 C.F.R. 91.7). JR Aeronautics LLC UAVs do not carry passengers or

cargo. The UAVs are small enough to fit inside backpacks and small carrying cases. Should

JR Aeronautics LLC receive an exception, no existing FAA regulation exists to guide operators in

determining airworthiness. Due to the UAV size, operating limitations, and PIC experience,

JR Aeronautics LLC can offer the equivalent or higher level of safety.

14 C.F.R. 91.9 (b) (2)

This regulation states: “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 (FAA Regulation 14 C.F.R. 91.9 (b) (2)). JR Aeronautics LLC wishes to be

exempt from 14 C.F.R. 91.9 (b) (2) because an equal amount of safety can be provided by

having such paperwork on the the ground. To begin with, the UAV is not designed to carry its

own manual. If extra paperwork is stored on the UAV, the unnecessary weight could infringe on

control response. Secondly, JR Aeronautics LLC UAVs will not carry passengers. If an in flight

crisis occurs, no humans will be present aboard the UAV to read the manual and solve the

problem. An equal amount of safety can be provided by keeping the appropriate manual and

paperwork on the ground. This will allow the paperwork to be easily accessible by the PIC and

VO at all times.

14 C.F.R. 91.103 (b)

The regulation 14 C.F.R. 91.103 (b) states: “For any flight, runway lengths at airports of

intended use, and the following takeoff and landing distance information” (FAA Regulation 14

C.F.R. 91.103 (b)). All UAVs in the JR Aeronautics LLC fleet have incredible vertical takeoff and

landing capabilities. This eliminates the need for a long, hard surface runway. JR Aeronautics LLC

UAVs will not operate within 5 miles of an airport. Due to this important limitation, attaining

airport information such as runway lengths is not necessary. JR Aeronautics LLC request to be

exempt from 14 C.F.R. 91.103 (b) because an equal amount of safety can be met by following

the preceding rules. JR Aeronautics LLC PIC will become familiar with local weather prior to every

flight. The PIC will also review the local airspace below 400 feet in which the UAV will fly in. Due

to these alternative flight precautions, the desired level of safety can be met. Requiring specific

airport data will not enhance safety or help the PIC.
14 C.F.R. 91.119

JR Aeronautics LLC requests relief from 14 C.F.R. 91.119 because we wish to operate the DJI Inspire 1 

and DJI PHANTOM 3 PROFESSIONAL under 400 feet. It is in the public's best interest that all UAVs 

stay clear of class E airspace and fly under 400 feet. JR Aeronautics LLC wishes to fly low level

missions. Following the flight minimums stated in 14 C.F.R. 91.119 could endanger manned aircraft. 

Operating our UAVs at lower altitudes guarantees the separation between manned and unmanned aircraft. 

By operating our UAVs below 400 feet and within

VLOS, JR Aeronautics LLC will not endanger the public. JR Aeronautics LLC PIC and VO will

thoroughly review the flight area prior to takeoff. By following our flight plan (thoroughly depicted

in section 1), JR Aeronautics LLC UAVs will not endanger ground personnel should a power

failure occur. Due to JR Aeronautics LLC preflight procedures and thorough flight planning, we

believe an equal level of safety can be met. Operating our UAVs below 400 feet AGL

guarantees the highest level of safety.

14 C.F.R. 91.121

JR Aeronautics LLC wishes to be exempt from 14 C.F.R. 91.121. A barometric pressure

altimeter will not be needed to maintain flight levels. Flight levels will not separate UAVs from

aircrafts because the UAVs will not fly above 400 AGL. JR Aeronautics LLC will operate below

400 feet clear of all manned aircraft. GPS altimeter data will be transmitted within a live

telemetry feed back to the PIC and VO. The GPS altimeter aboard the DJI Inspire 1, and DJI PHANTOM 

3 PROFESSIONAL will prevent the UAVs from flying above 400 feet AGL. The PIC and

VO will be able to see live altimeter readings at all times. The altimeters aboard the UAVs will

only be used to remain below 400 AGL.

14 C.F.R. 91.151 (a)

This regulation states “ ( 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

(2) At night, to fly after that for at least 45 minutes.” (FAA Regulation 14 C.F.R. 91.151 (a)).

JR Aeronautics LLC DJI Inspire 1 and DJI PHANTOM 3 PROFESSIONAL use electrical energy

stored in batteries. JR Aeronautics LLC requests relief from 14 C.F.R. 91.151 (a) because no

liquid fuel is used. The maximum duration of flight will be 15 minutes with 5 minutes reserve. We

believe this regulation exists to protect civil aviation pilots from running out of fuel. Should a civil

aviation pilot became lost, this regulation provides pilots with enough time to acquire their

location and land safely. Civil aircraft must also carry extra fuel in case unpredictable weather

impedes their intended destination. This problem does not exist for UAVs operating under

electrical battery power. The live telemetry allows our PIC to closely monitor voltage, current

draw, and time to prevent a loss of power. Should a power loss occur, the UAV will harmlessly

descend to the ground. An immediate loss of power is always considered while creating a flight

plan. We believe our flight procedure and limitations guarantees a level of safety greater than 14

C.F.R. 91.151 (a).

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.203 (b) states: “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” (FAA Regulation 14 C.F.R. 91.203 (a) & (b)). JR Aeronautics LLC requests

relief from 14 C.F.R. 91.203 (a) & (b) because this regulation does not enhance the safety of our

UAVs. We believe our proposed strategies mentioned in this paragraph will satisfy the desired
level of safety. Carrying documents on board the UAV adds weight and decreases stability. We

propose that such documents required by the FAA be stored on the ground available to the PIC

and VO. JR Aeronautics LLC suggests that all onboard UAV identification information required by

the FAA be displayed on a small information card. This card, permanently attached to the UAV,

will contain a copy of the PIC and VOs valid US driver's license. Most importantly, the onboard

information card will display the word “experimental” in bold letters. Other onboard information

required by the FAA will be displayed alongside the PIC and VOs IDs. JR Aeronautics LLC

proposes that the information card be permanently attached to the exterior of the UAV. No

interior exists to hold such information and documents.

14 CFR 91.405 (a); 91.407 (a) (1)

Compared to manned aircraft, lightweight UAVs are much simpler to safely maintain. We

propose that simple maintenance be done by the PIC. Simple maintenance includes: propeller

replacements, exterior cleaning, and software updates. The PIC will only complete the required

maintenance specifically allowed by the UAV manufacture. If the UAV needs extensive care, it

will be sent in to its appropriate manufacturer. All maintenance will be thoroughly logged and

sent to the FAA upon request. The UAV will undergo thorough test flights before returning to

service.

A summary the FAA can publish

JR Aeronautics LLC request exemptions from the following regulations: 14 C.F.R. Part 21;

45.23 (b); 61.113 (a) & (b); 91.7 (a); 91.9 (b); 91.103 (b); 91.119; 91.121; 91.151 (a); 91.203 (a)

& (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) & (b). If granted, this

exemption will allow JR Aeronautics LLC to operate commercial UAVs in the NAS. Our company

will use lightweight UAVs to capture aerial imagery for local businesses. Aerial imagery will help

attract more tourists with the intention of improving Baltimore, Maryland's economy. Our PIC

and VO must undergo extensive preflight checklist before flying the UAV. We believe our safety

procedures will be above public expectations. Before every flight, JR Aeronautics LLC will receive

permission from the appropriate landowner whose land directly underlies the intended flight path

of the UAV. Without a landowner's full consent, a flight will not take place over his or her

property. Our thorough preflight checklist and extensive flight procedures makes our UAVs very

safe. JR Aeronautics LLC will provide valuable aerial imagery while improving the local economy.

Additional Information

JR Aeronautics LLC proposes the following PIC requirements.

JR Aeronautics LLC PICs must meet the following qualifications.

1) A PIC will be required to have 25 hours of total logged UAV air time and 10 hours logged

 airtime with the specific UAV he/she intends to fly.

2) A PIC operating under JR Aeronautics LLC exemption must hold a sport pilot certificate or 

higher class rating

If a PIC candidate meets the previously stated requirements, he or she will become PIC.

JR Aeronautics LLC will not have more than 1 PIC at all times. All PIC log entries and

qualifications will be sent to the FAA upon request.

Flight limitations and procedures

1) UAV must not exceed 50 mph ground speed.

2) UAV must remain under 400 feet AGL.

3) It will be required that the PIC and VO maintain unassisted eye contact with the UAV at

all times.
4) The UAV must land with 20% reserved power.

5) All UAV flights, maintenance, and reports will be carefully logged and presented to the

FAA upon request.

6) UAV will operate in accordance with VFR weather minimums.

7) UAVs must have attitude hold, GPS hold, and GPS return to launch capabilities.

Preflight checklist (Openpilot) This checklist will be used before every flight.

Environmental:

□ Check for people, animals, property in the flight vicinity.

□ Check aerial sectional charts, local notams, and local weather before flying.

□ Notify any bystanders or nearby property owner of your intentions.

□ If flying FPV, discuss flight plan with your check-pilot.

□ First Aid / Safety Kit on hand, stocked, readily accessible, and visible to anyone in the area

Hardware/Equipment:

== VISUALLY INSPECT THE AIRFRAME ==

□ Cracks (especially in high stress areas like joints)

□ Loose or damaged screws / fasteners / bands / straps / ties

□ Loose or damaged wiring

□ Loose or damaged connections (solder, plugs, etc)

□ Inspect prop mounts & screws & apply slight counter pressure on arms to check for loosened

construction

□ For FPV, inspect/clean FPV and/or GoPro camera lens and ensure that cameras are secured

□ Battery/batteries fully charged, properly seated and secured

□ Remove props and test fail-safe behavior (if applicable)

□ Props are smooth and free of damage/defect (check blade, surface, & hub)

□ Tighten prop adapters (careful not to over tighten which may damage prop)

□ Ensure voltage alarm is connected

□ Ensure arming/idle timeout is properly configured (6-15 seconds is generally acceptable)

□ Check whether the right model is selected in the transmitter (if applicable)

□ Check your RC transmitter shows the right range and centering for all sticks

□ If desired, perform range test

Preflight

== POWER UP ==

□ Batteries charged & secured

□ Position UAV in a level, safe location for takeoff

□ For FPV, power up ground station, video receiver, goggles, etc

□ If using onboard video recorder (i.e., Gopro), turn on camera

□ All transmitter controls move freely in all directions

□ All transmitter trims in its neutral position

□ All transmitter switches in correct position (typically away)

□ Transmitter throttle to zero

□ Radio transmitter on

□ Connect/power on battery to airframe

□ Ensure led indicators & audible tones are all correct

□ Timer on (if applicable)

□ For FPV, check video in goggles
□ Scan for nearby people or animals

□ Stand clear - audibly, loudly announce the word "CLEAR!"

□ Arm flight controller

Takeoff

□ Increase throttle slightly listening for any abnormalities

□ Short 20-30 second hover at 3-5 feet (listen for any unusual vibrations, anything loose, or anything out 

of the ordinary)

□ Test GPS hold before continuing flight
Sincerely,

Justin Robinson

Owner, JR Aeronautics LLC

UAV Manuals:

DJI Phantom 3 Professional

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v

1.0_en.pdf

DJI Inspire 1

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf