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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

East Coast Jib and Aerial, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS.

PURSUANT TO SECTION 333 OFTHE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on August 27, 2015

East Coast Jib and Aerial, LLC. 

6000 Deerfield Lane

Hickory, NC 28602

East Coast Jib and Aerial, LLC

Joshua Lee Bumgarner - Owner/Chief Operator

6000 Deerfield Lane

Hickory, NC 28602

www.EastCoastJibandAerial.com

JoshBum@EastCoastJib.com 

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602		

www.EastCoastJibandAerial.com 704-996-9415

704-996-9415
East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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Table of Contents

GLOSSARY	OF	ABBREVIATIONS...........................................................................................3

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER..............................................3

Executive	Summary .................................................................................................................4

Expeditious	Summary	Grant	Approval	Request......................................................................4

Description of Type, Make and Models of sUAV/UAS Requested:.............................................5

Commercial (Mission, Operation) Purpose:........................................................................................5

Regulations from which the Exemption Relief is requested:.......................................................6

The name and address of the Petitioner: .............................................................................................6

Background...........................................................................................................................................7

Commitment to Safety..................................................................................................................................7

Expertise & Experience................................................................................................................................7

The	Exemption	Request .........................................................................................................8

Operator	Requirements ................................................................................................................ 10

Aircraft	and	Equivalent	Level	of	Safety.................................................................................... 13

Specific	Uses	Public	Benefits ....................................................................................................... 17

Equivalent	Level	of	Safety............................................................................................................. 18

14 C.F.R. § 91.7(a): Civil aircraft airworthiness..............................................................................19

14 C.F.R. §91.119: Minimum safe altitudes ......................................................................................20

14 C.F.R. §91.121 Altimeter Settings...................................................................................................20

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ..............................20

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections.....................................................................................................................................................21

Federal	Register	Publication............................................................................................. 22

Privacy	and	National	Security........................................................................................... 22

Summary................................................................................................................................... 23

APPENDIX	A - TECHNICAL MANUALS AND SPECIFICATIONS........................................... 25

APPENDIX	B - MAINTENANCE AND INSPECTION MANUAL................................................ 26

APPENDIX	C - MOTION PICTURE AND TELEVISION OPERATIONS MANUAL................27

APPENDIX	D - AIRCRAFT FLIGHT OPERATIONS MANUAL................................................ 28
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control.

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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INTRODUCTION AND INTERESTS OF THE PETITIONER 

Dear Sir or Madam:

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

“Reform Act”) and 14 C.F.R. Part 11, East Coast Jib and Aerial, LLC., (“East Coast 

Jib and Aerial”) Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped 

to offer on-demand commercial UAS operations for a host of industries 

and applications and to perform the purposes listed below, hereby applies 

for an exemption from the listed Federal Aviation Regulations (“FARs”) to 

allow commercial operation of its sUAV’s/UAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be 

established by the FAA in an exemption granted under either Section 333 or

Section 49 U.S.C. §44701(f)

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

operation of a UAS under controlled conditions in airspace that is 1) limited; 2) 

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

will operate, which now depend upon conventional aircraft or humans climbing 

high on dangerous structures, walking in insect laden swamps, and working 

adjacent to treacherous infrastructure. 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.” Section 333(c) of the 

Reform Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this 

application. Petitioner has provided in a confidential document attachment labeled 

as petitioner proprietary information, specific exemption numbers whereby the FAA 

has already granted a previous exemption similar or identical to each and every 

request, herein. 

1 East Coast Jib and Aerial, LLC. relies upon the following exemptions when a specific 

reference to an exemption is not provided: Exemptions 11062 thru 11067, 11080, 11109 

through 11112, 11114, 11213, 11062 and as recent as 11857.

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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Petitioner has identified four previous approved exemptions for each of the 

Petitioners FAA submission requests:

 Commercial (mission/operation) purposes;

 Type of sUAV’s (UAS);

 Title 14 Exemptions 

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAV’s makes and 

modes as follows: 

1.) DJI - Inspire 1, 2.) Aeronavix Droidworx SkyJib 8

Each separately weighs 55 lbs. or less, with imaging payload and applicable 

equipment.

Equipment operation manuals for each sUAV are included for your reference and 

are considered confidential information for each respective company’s UAS and are 

affixed separately in these documents labeled Appendix A.

Commercial (Mission, Operation)Purpose: 

This exemption request, once granted would allow the petitioner to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge 

Inspections, flare stack inspection, utility-power generation system inspections 

and patrolling, aerial inspection, photography and videography of residential 

and commercial real estate, weddings, aerial inspection, photography and 

videography of utility infrastructure including but not limited to electrical 

power lines, wind turbines and cell towers, pipeline inspection and 

patrolling, film making, cinematography, and videography, precision 

agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, 

2 Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they 

contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 

Reform Act Section 333 (b). 

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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construction site inspection and monitoring, public entity support operations, Aerial 

imaging for safety, monitoring and comparing work efforts and completion 

percentages, and security of controlled environment of various sites, aerial video 

and live video feed to assist with search and rescue operations under the authority 

and support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and 

live newsgathering, training to persons individually or belonging to both private and 

public organizations to increase awareness and improve safety for current and 

future UAS operations within the NAS, special events: including high schools. 

colleges, professional sports, open air events and fairs, research, risk management 

and assessment, motion picture production3, surface mining, closed set filming4,

disaster and catastrophe events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

The name and address of the Petitioner:

East Coast Jib and Aerial, LLC.

Attn: Joshua Lee Bumgarner

6000 Deerfield Lane

Hickory, NC 28602

JoshBum@EastCoastJib.com

Please direct any question or comment regarding this petition to the Petitioner 

3 Motion Picture and Television Flight Operations Manual is herein attached as 

Appendix C.

4 Motion Picture and Television Flight Operations Manual for closed set filming is 

herein attached as Appendix C.

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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Background

The Petitioner, East Coast Jib and Aerial, LLC. is under Josh Bumgarner’s

direction. Josh Bumgarner is a highly accomplished, capable and 

experienced TV production professional with over 20 years of experience in the 

Television and Motion Picture industries.

East Coast Jib and Aerial, LLC. is a local North Carolina small business seeking 

relief to conduct commercial videography and photography with the use of 

unmanned aircraft. We provide image acquisition services to television, motion 

picture and a number of other professionals, with the purpose of marketing, news 

and entertainment.

East Coast Jib and Aerial, LLC. under Josh Bumgarner’s guidance and vast 

experience is prepared to provide safe and professional services to many industries. 

Josh Bumgarner, as of the filing of this petition has 18.4 hrs logged in a Remos GX 

LSA flying out of HKY as a part of a flight training program for a Sport Pilot 

Certificate and also currently holds a 3rd Class Medical.

Commitment to Safety

As part of its commitment to safety and innovation, East Coast Jib and Aerial, 

LLC. is asking for this exemption in part, to reduce the risk of injury to its 

employees and contractors who participate in the proposed activities the 

petitioner requests, including but not limited to damage to agriculture, natural 

habitat, buildings and other structures within the United States. 

Expertise & Experience

East Coast Jib and Aerial, LLC. and Josh Bumgarner due to these experiences is 

extremely qualified and is considered an expert in the North Carolina film and 

television industries. 

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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The Exemption Request

East Coast Jib and Aerial, LLC. proposes the use of the sUAV’s will be for capture of 

high resolution imagery and video of residential or commercial applications 

and purposes to a level of quality that allows the Petitioner to use the 

imagery to identify, record, memorialize events and objects according to the 

purposes noted. 

The imagery and video will be used to identify the condition of landscapes, 

agriculture, events, disasters and infrastructure to conduct bridge inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection, photography and videography of residential and commercial real estate, 

weddings, aerial inspection, photography and videography of utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, 

pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial imaging for safety, monitoring 

and comparing work efforts and completion percentages, and security of controlled 

environment of various sites, aerial video and live video feed to assist with search 

and rescue operations under the authority and support of local authority officials, 

aerial video and photography for public and private use including television, public 

events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within the 

NAS, special events: including high schools, colleges, professional sports, open air 

events and fairs research, risk management and assessment, motion picture 

production, surface mining, closed set filming, disaster and catastrophe events.

The UAS will be operated by East Coast Jib and Aerial, LLC. and or 

contracting operators on occasion to capture high-resolution imagery/video of 

large structures (wide and tall such as warehouses, high rise buildings, bridges, 

and construction sites, as well as “birds eye” views of fire and explosion sites.

Given the small size of the sUAV’s involved, no more than 55 lbs., majority of the 

speed of operation be between 5-15 mph and the restricted environment within 

which they will operate, the Petitioner falls squarely within that zone of safety (an 

equivalent level of safety in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing

Sections 333(a through (c of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not 

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the following:

 The UAS’s size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added).5

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under §40101 of the Act: The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 

of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to 

grant exemptions reaches such issues as authorization of commercial operation of aircraft without an 

FAA issued pilot’s license.

East Coast Jib and Aerial, LLC. in filing this application is requesting that the 

FAA combine the grant of the Section 333 exemption with a standard 

Certificate of Operation (COA) that will allow commercial operations of East 

Coast Jib and Aerial, LLC.'s sUAV without the necessity of filing for a COA for 

each flight, unless such flight is to be conducted in an area not approved in the 

exemption. Compliance with the conditions agreed to herein and that may be 

imposed by the FAA, as set forth in prior Section 333 exemptions, provide the 

separation needed from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no 

closer than 5 nautical miles of the geographic center of an airport as denoted on a 

current FAA published aeronautical chart, unless a letter of agreement with that 

airport’s management is obtained, East Coast Jib and Aerial, LLC. requests 

that operations over congested or densely populated areas be allowed. The 

sUAS operated by the petioner do have GPS geo-fencing, they will operate at a 

very low altitude, within confined areas, at low speed and weighs no more 

than 55 lbs.. Such operations will only be under-taken with the approval of the 

land or homeowner, as set forth herein, and will comply with the requirements that 

operations be no closer than 500 feet to the adjacent building unless the 

land owner has provided permission, and the Operator has made a safety 

assessment of the risk from such operations. 

5 Applicant interprets this provision to place a duty on the Administrator to not only 

process applications for exemptions under section 333, but for the Administrator to 

craft conditions for the safe operation of the UAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval.

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Operator Requirements

Given the sUAV proposed by East Coast Jib and Aerial, LLC., Operators should not 

be required to hold a private pilot license. East Coast Jib and Aerial, LLC. believes 

that 1 the operator, instead of understanding how to operate a passenger carrying 

aircraft, should have knowledge and experience that enables the safe operation of 

a small, remotely piloted sUAV should understand airspace restrictions and know 

how to ensure separation from other aircraft as well as non-participants and 

property; 2 the sUAV has built-in technical capabilities that limit the 

potential for unsafe operation and 3 there are other security screening 

mechanisms already in existence that East Coast Jib and Aerial, LLC. will utilize 

to ensure the operators are acting consistently with national security interests. 

Given the sUAV safety features outlined below, East Coast Jib and Aerial, LLC.

proposes that its operations under this Exemption request should not be required 

to hold a commercial or private pilot certification. Instead, Operators should be 

required to: have successfully completed, at a minimum, FAA sport pilot ground 

instruction and passed the FAA sport pilot written examination or FAArecognized equivalents; have completed East Coast Jib and Aerial, LLC.

training program for operation of the UAS.

East Coast Jib and Aerial, LLC. notes that 1 the FAA has found that safety

factors permitted operation of sUAV’s by Operators with these qualifications in the 

case of operations pursuant to public COAs when the mandatory operating 

conditions specified above were present; and 2 that the Notice of Proposed 

Rulemaking entitled Operation and Certification of Small Unmanned Aircraft

Systems, 80 F.R. 9544 (February 23, 2015 (“NPRM”, does not require the operator 

to hold a private pilot license or a third class medical.

Advanced sUAV’s has a navigation and control system and auto-pilot that allows it to

execute very accurate pre-programed flights. Flights are pre-programmed with GPS 

waypoint to establish perimeters beyond which the aircraft will not operate. Flights 

under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto-pilot. In the case of 

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the 

control unit, and the autopilot executes those maneuvers. Pre-programmed 

Operator interventions include: initiation of holding at present position; suspension 

of mission; fly back to launch point; abort mission and land immediately; and 

emergency power cut off and land (flight termination system. Additional 

automated safety functions and safety enhancing features of the Advanced sUAV’s

may include the following:

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an

immediate landing,

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels. Low power below 10% triggers an immediate landing,

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold

position at its current location for 5 seconds and if the signal is not restored,

execute a return to home and land,

4) Redundant “kill switches” that enable completely shutting the aircraft down

in flight in the event of a loss of control or un-commanded deviation from the

flight path,

5) The aircraft, weighs less than 55 lbs., fully loaded,

6) The motors are driven by pulse width modulated signals, not analog signals,

7) The aircraft will operate for the Purposes at no more than 50 mph (while

imaging) nor above a maximum of 400 feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft 

Systems (UAS Operational Approval, at 20-21 (July 30, 2013; As the FAA has 

determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”, 

in comparing the requirements for private pilot knowledge and the knowledge 

required for a commercial pilot, that knowledge associated with a private pilot 

license, and therefore private pilot ground school, was sufficient to allow private 

pilots to operate sUAV’s under those exemptions. 

Based upon that analysis, East Coast Jib and Aerial LLC., believes successful

completion of FAA Sport pilot ground school is a suitable predicate to operating 

the sUAV under this exemption. East Coast Jib and Aerial, LLC. proposes that the 

Operator accumulate required sUAV flight training hours through the operation 

of sUAV’s rather than flight hours in conventional aircraft. Those hours are more 

relevant to the operations proposed herein than hours gained in obtaining a

private pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders 

of magnitude heavier than the sUAS and carry not only the pilot himself, but also 

passengers and fuel, none of which is carried in the sUAS. These conventional 

aircraft fly over all sorts of airspace without the permission or knowledge of the 

landowner. 

A handheld radio controller controls the sUAV and the vehicle is operated within the 

line of sight. The requirements of Part 61.127 (commercial flight proficiency) and 

§61.107 (private flight proficiency), to the extent they are relevant to UAS

operations, can be taught in the training of company operators. As a review of

the requirements of part 61.127 and 107 demonstrate, the issues presented as

they relate to a 55 pound aircraft, operating at less than 50 mph during

filming operations are those taught in ground school and in flight training

with the particular UAS and not gained from accumulating flight hours in a

fixed wing or rotorcraft gas or jet A powered aircraft completing cross country

flights and take offs and landings at controlled and uncontrolled airports.

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As to national security review of pilots, each of East Coast Jib and Aerial, LLC.

pilots/operators will obtain internally provided training (Ground and 

Practical) from the Chief Operator to operate the sUAV. Alongside a Sport Pilot 

Certificate, this review and training could reasonably vet the Operators against 

any known terrorist or no fly listings that are relevant and publicly available.

East Coast Jib and Aerial, LLC. additionally asks that the exemption be 

issued without the requirement for a visual observer. As set forth herein, an 

equivalent level of safety is provided by the size, speed and control capabilities of 

the aircraft, as well as the operational procedures that will be applicable 

to all flight hereunder. These obviate the need for the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she will 

walk and follow the aircraft around the inspection area so that while it is flying its 

pre-programed and at times, manual flight path, the UAS will always be directly in 

his or her line of sight. The Operator will not be distracted by viewing the pictures 

taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty 

will be to watch the flight of the UAS over the structure and intervene to address 

flight path deviations or other issues that arise during the flight. The functions that 

an observer performs where the aircraft is flown at long distances from the launch 

area will not be necessary as the Operator will always have the aircraft in his or her 

direct sight. The observer also will not be necessary because the Operator will 

conduct a pre-flight inspection of the area, will and if needed, cordon off the area 

and will perform frequent visual scans of the area while the vehicle is operating.

East Coast Jib and Aerial, LLC. again notes that the NPRM does not require the use 

of a visual observer. Given the clear direction in Section 333 of the Reform Act; 

the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing battery powered

sUAV’s for these functions instead of turbine or gas power aircraft/rotorcraft 

and operations with pilots having at least a private pilot license, the grant of the 

requested exemptions is in the public interest. 6

6 Should the FAA determine that it cannot grant such an exemption for operations 

without a FAA licensed sport pilot, despite the showing made herein, under the 

statutory authority the FAA already has, East Coast Jib and Aerial, LLC. will 

operate its aircraft with pilots holding at least a sport pilot certificate issued by 

the FAA. In that event, East Coast Jib and Aerial, LLC. requests that the exemption 

be granted with conditions similar to those contained in numbered paragraphs 

14-15 in Exemption 11136

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Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the operations conducted with conventional 

aircraft or with humans climbing up and around structures. These conditions are 

drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 

11112, and 11213 and as recent as 11857.

These limitations and conditions to which East Coast Jib and Aerial, LLC. (referred 

to as “Operator”) agrees to be bound when conducting commercial operations 

under an FAA issued exemption include:

1) Operations authorized by this grant of exemption are limited to

the aircraft described in the Operator’s manual, which is a multirotor weighing up to 55 pounds: Proposed operations of any

other aircraft will require a new petition or a petition to amend

this grant.

2) The UA may not be flown at an indicated airspeed exceeding 30

mph (10 mph during inspections).

3) The UA must be operated at an altitude of no more than 400 feet

above ground level (AGL), as indicated by the procedures

specified in the Operator’s manual. All altitudes reported to ATC

must be in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the

Aircraft Operator at all times. This requires the Aircraft Operator to

be able to use human vision unaided by any device other than

corrective lenses..

5) The Exemption Holder’s Manuals must be amended to include all

conditions and limitations required by the FAA. The Manuals

must be maintained and made available to the Administrator

upon request. If a discrepancy exists between the conditions and

limitations in the exemption and the procedures outlined in the

Exemption Holder’s Operator’s manual, the conditions and

limitations in the exemption take precedence and must be

followed. Otherwise, the Aircraft Operator must follow the

procedures as outlined in its Aircraft’s manual. The Exemption

Holder may update or revise its Manuals. It is the Exemption

Holder’s responsibility to track such revisions and present

updated and revised documents to the Administrator upon
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request. The Exemption Holder must also present updated and 

revised documents if it petitions for an extension or amendment 

of this exemption. If the Exemption Holder determines that any

update or revision would affect the basis upon which the FAA 

granted this exemption, then the Exemption Holder must 

petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to

ensure it is in a condition for safe flight. If the inspection reveals

a condition that affects the safe operation of the UAS, the aircraft

is prohibited from operating until the necessary maintenance

has been performed, and the UAS is found to be in a condition for

safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be

properly documented in the aircraft records.

7) Any UAS that has undergone maintenance or alterations that

affect the UAS operation or flight characteristics, e.g.,

replacement of a flight critical component, must undergo a

functional test flight in accordance with the Exemption holder’s

Manuals. The Aircraft Operator who conducts the functional test

flight must make an entry in the UAS aircraft records of the

flight. The requirements and procedures for a functional test

flight and aircraft record entry must be added to the Exemption

Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement,

inspection, and life limit requirements, with particular attention

to flight critical components that may not be addressed in the

manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance,

inspections, and record keeping requirements in accordance

with the Operator’s Manuals. Maintenance, inspection, and

alterations must be noted in the aircraft logbook, including total

flight hours, description of work accomplished, and the signature

of the authorized technician returning the UAS to service.

10) The authorized technicians must receive and document training

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a

record entry in the UAS logbook or equivalent document of the
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corrective action taken against discrepancies discovered 

between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have

logged at least 25 hours of total time as a UA rotorcraft pilot and

at least ten hours logged as a UA pilot with a similar UA type and

5 hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the UA

must return to a pre-determined location within the private or

controlled-access property and land or be recovered in

accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of

unpredicted obstacles or emergencies, including unauthorized

people entering the flight area, in accordance with the

Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight

unless (considering wind and forecast weather conditions) there

is enough power to fly to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 10

minutes.

17) All aircraft operated in accordance with the exemption must be

identified by serial number, registered in accordance with 14

CFR part 47, and have identification (N- Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as

large as practicable.

18) Before conducting operations, the radio frequency spectrum

used for operation and control of the UA must comply with the

Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be

available to the Operator at the Ground Control Station of the

UAS any time the aircraft is operating. These documents must be

made available to the Administrator or any law enforcement

official upon request.

20) The UA must remain clear and yield the right of way to all other

manned operations and activities at all times (including, but not

limited to, ultra-light vehicles, parachute activities, parasailing

activities, hang gliders, etc.).
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21) The UA may not be operated by the Aircraft Operator from any

moving device or vehicle.

22) UAS operations may not be conducted during night, as defined in

14 CFR 1.1.

23) All operations must be conducted under visual meteorological

conditions (VMC). The UA may not be operated less than 500

feet below or less than 2,000 feet horizontally from a cloud or

when visibility is less than 3 statute miles from the Operator.

24) During operations the UA may not operate within 5 nautical

miles of the geographic center of an airport as denoted on a

current FAA-published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the

operation is conducted in accordance with a NOTAM, if as

required by the Operator’s COA. The letter of agreement with the

airport management must be made available to the

Administrator upon request.

25) The UA may not be operated over congested or densely

populated areas unless the conditions set for in #26 are satisfied.

These populated areas include but are not limited to the yellow

areas depicted on World Aeronautical Charts (WAC), Sectional

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC).

However, aeronautical charts may not reflect pertinent local

information. Ultimately, it is the Operator’s responsibility to

maintain the minimum safe altitudes required by § 91.119 (d)

(1).

26) Flight operations must be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles, and structures

unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from debris in the event of an

accident. The Aircraft Operator must ensure that

nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such

protection and are within 30 feet of the UA, flight

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures

where the land owner/controller has granted permission

and/or the Aircraft Operator has made a safety assessment

of the risk of operating closer to those objects and;
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c. Operations near the Aircraft Operator do not present an

undue hazard to the Operator per § 91.119(a).

27) All operations shall be conducted over private or controlledaccess property with permission from the land owner/controller

or authorized representative. Permission from land

owner/controller or authorized representative will be obtained

for each flight to be conducted.

28) Any incident, accident, or flight operation that transgresses the

lateral or vertical boundaries of the operational area as defined

by the applicable COA must be reported to the FAA’s UAS

Integration Office (AFS-80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB)

per instructions contained on the NTSB Web site: www.ntsb.gov.

Specific Uses Public Benefits

East Coast Jib and Aerial, LLC. proposes use of its sUAV provided 

equivalent or augmented levels of safety for each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting 

the roofs, agriculture land, buildings and large structures site surveys, wild life 

monitoring, mosquito and insect control are now conducted by either humans 

wading through swamps, climbing on the roofs and structures that are steep, tall,

slippery, weakened or otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must 

climb on the roofs or require the use of aircraft that are orders of magnitude greater 

in size than the sUAV. Either method, manual inspection or large conventional 

aircraft, results in increased risk of injury due to personnel falling off roofs or 

ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or 

increased risk from low altitude flyovers with helicopters or fixed wing aircraft 

inspecting buildings after damage from storms or other disasters, such as 

earthquakes or fires. Such flights are, of course, significantly more expensive than 

those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, but 

those who are along the path of flight associated with the arrival and departure of 

the conventional aircraft at the inspection site because the aircraft must be flown to 

and from the site. By contrast, the sUAV is carried to the site and transits no other

property. Conventional aircraft carry flammable fuels that are not carried by the 

UAS and emit pollutants associated with internal combustion engines. The sUAV’s 

proposed herein are battery powered and have no emissions.

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Equivalent Level of Safety

14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and	Limitations;	Pilot	in	

Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the East Coast Jib and 

Aerial, LLC. sUAV is remotely controlled with no passengers or property of others on 

board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot 

in command of an aircraft for compensation or hire. 

East Coast Jib and Aerial, LLC. respectfully proposes that Operator requirements should 

take into account the characteristics of the particular UAS. East Coast Jib and Aerial, 

LLC. sUAV's have a high degree of pre-programmed control and various built-in 

technical capabilities that strictly limit the potential for operation outside of the 

operating conditions set forth in the exemption application. East Coast Jib and Aerial, LLC.

sUAV's have navigation and control system comprised of a Ground Control Station

(GCS) and auto-pilot system that can be pre-programmed to set operational boundaries. All

flights are pre-programmed with precision GPS guidance.. In the case of unplanned 

events, the Operator may input pre-programmed evasive maneuvers from the 

control unit, and the onboard autopilot executes those maneuvers. Pre-programmed 

Operator interventions include initiation of holding at present position; suspension of 

mission; fly back to launch point; abort mission and land immediately; and emergency 

power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the 

East Coast Jib and Aerial, LLC. sUAV’s may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 

10% levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will 

hold position at its current location for 5 seconds and if the signal is not 

restored, execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft 

down in flight in the event of a loss of control or un-commanded 

deviation from the flight path.

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog 

signals.
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1.7. The aircraft will operate for the Purposes at no more than 50 mph

(while imaging) nor above 200 feet above the structure (imaging 

altitude) or a maximum of 400 AGL.

Given these safety features, East Coast Jib and Aerial, LLC. proposes that 

Operators of the company owned sUAV should not be required to hold a 

commercial or private pilot certification. 

Instead, Operators should be required to: have successfully completed, at a 

minimum, FAA Sport pilot ground instruction and passed the FAA Sport Pilot 

written examination or FAA-recognized equivalents; have completed the 

manufacturer’s or East Coast Jib and Aerial, LLC.'s developed training program 

for operation of the UAS.

Given these conditions and restrictions, an equivalent level of safety will be 

provided by allowing operation of the East Coast Jib and Aerial, LLC.'s sUAV

without a private pilot’s certificate or a commercial pilot’s certificate, under the 

conditions set forth herein.

The risks associated with the operation of the East Coast Jib and Aerial, LLC.

sUAV (given its size, speed, operational capabilities, and lack of combustible fuel 

are so diminished from the level of risk associated with private pilot 

operations or commercial operations contemplated by Part 61 with conventional 

aircraft (fixed wing or rotorcraft, that allowing operations of the UAS as set forth

above meets or exceeds the present level of safety provided under 14 C.F.R. § 

61.113(a & (b and does not rise to the level of requiring a commercial pilot to 

operate the aircraft under § 61.133(a.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

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

airworthy condition. Should the exemption be granted allowing commercial 

operation of the UAS without an airworthiness certificate, no standard will exist for 

airworthiness of the UA. Given the size of the aircraft and the requirements that the 

Operator has agreed to as it relates to airworthiness, as contained in the manual, an 

equivalent level of safety will be achieved by insuring compliance with the manuals 

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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prior to each flight. The FAA has granted exemptions to conduct similar operations 

in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and speed of 

the UAS as well as the location where it is operated. No flight will be taken without 

the permission of the property owner, facility owner, and/or local officials. Because 

of the advance notice to the property owner and participants, all affected individuals 

will be aware of the planned flight operations as set forth in the Manuals. Compared 

to flight operations with aircraft or rotorcraft weighing far more than the maximum 

55 lbs. and the lack of flammable fuel, any risk associated with these operations is 

far less than those presently presented by conventional aircraft operating at or 

below 500 AGL in the aerial photography industry. In addition, the low-altitude

operations of the sUAS will ensure separation between these small-UAS operations 

and the operations of conventional aircraft that must comply with Section 91.119. 

The FAA has granted exemptions to conduct similar operations in Exemptions 

11062 through 11067, 11080 and 11110.

14 C.F.R. §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 East 

Coast Jib and Aerial, LLC. sUAV, in manual or emergency mode, will not 

have a barometric altimeter display, but instead a GPS altitude display, an

exemption will be needed. The Operator, pursuant to the procedures set forth in 

the Manuals as indicated before flight, will achieve an equivalent level of 

safety. The FAA has granted exemptions to conduct similar operations in 

Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. § 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) 

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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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 sUAS provides up to 40 minutes of powered flight. To

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS 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 is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation 

to operate without compliance with FAR 91.151 (a. 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.

Petitioner believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25% of remaining battery power whichever happens first. 

This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 

and Exemptions 11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (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 sections 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 or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits.

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 defined 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. As provided in the Aircraft 

Flight Operations Manual the Operator will ensure that the UAS is in working order

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

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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maintenance performed. Moreover, the Operator and manufacturer are most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. The FAA has granted exemptions 

for similar operations in Exemptions 11062 through 11067, 11080 and 11110.

*********

Federal Register Publication

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:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a & (b; 91.7(a; 91.119; 91.121; 91.151(a; 91.405(a;

91.407(a(1; 91.409(a(2 and 91.417 (a & (b to operate commercially a small 

unmanned vehicle (55 lbs. or less for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections 

and patrolling, aerial inspection and photography of residential and commercial 

utility infrastructure including but not limited to electrical power lines, wind 

turbines and cell towers, pipeline inspection and patrolling, filmmaking, 

cinematography, and videography, precision agriculture with on board sensors, 

wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, public entity support 

operations, aerial video and live video feed to assist with search and rescue 

operations under the authority and support of local authority officials, aerial 

video and photography for public and private use including television, public 

events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within 

the NAS, special events: including high schools. colleges, professional sports, 

open air events and fairs, research, risk management and assessment, motion 

picture production, surface mining, closed set filming, disaster and catastrophe 

events.

Privacy and National Security

All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Inspection will be of inanimate objects in 

areas where the owners will have consented to the inspections or otherwise have 

agreed to allow the UAS and the Operator to be in the area where operations will 

take place.The size of the UAS, its speed and restricted area of operation do not raise 

national security issues.

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Summary

Approval of exemptions allowing commercial operations of sUAV’s for petitioner to 

operate an unmanned aircraft system (UAS to conduct bridge Inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection and photography of residential and commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, 

pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial video and live video feed to 

assist with search and rescue operations under the authority and support of local 

authority officials, aerial video and photography for public and private use including 

television, public events, and cinematography live feed and live newsgathering, 

training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events: including high schools. colleges, 

professional sports, open air events and fairs, research, risk management and 

assessment, motion picture production, surface mining, closed set filming, disaster 

and catastrophe events, will enhance safety by reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing 

people in swamps, on roofs or tall, hazardous or weakened structures, exposes them 

to higher risks than those created by use of a sUAV’S. Conventional aircraft that 

operate at extremely low altitudes just feet from the subject being inspected and in 

extreme proximity to people and structures present the risks associated with 

vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other 

fuel (140 gallons for jet helicopters. Such aircraft must fly to and from the project 

location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible 

fuel carried on board. The sUAV is carried to the target area and not flown. The 

sUAV will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein. These lightweight aircraft operate at slow 

speeds, close to the ground, and in areas that are under the control of the customer 

for the operations and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and 

people or the use of individuals to climb the structures to conduct the operations.

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Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than 

adequate justification for the grant of the requested exemptions allowing 

commercial operation of Petitioner’s UAS for the Purposes outlined herein and 

are consistent with exemptions already granted, including Exemptions number 

11171 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as 

recent as 11857.

Sincerely,

Joshua Bumgarner, Owner/Chief Operator

East Coast Jib and Aerial, LLC.

6000 Deerfield Lane

Hickory, NC 28602

East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

www.EastCoastJibandAerial.com 704-996-9415
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APPENDIX A - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 

333 (b). 

Submitted under separate cover.
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APPENDIX B - MONTHLY MAINTENANCE AND REPAIR LOG

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they 

contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 

Reform Act Section 333 (b). 

Submitted under separate cover.
East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602 

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APPENDIX C – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS 

MANUAL VERSION 1.0

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they 

contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 

Reform Act Section 333 (b). 

Submitted under separate cover.
APPENDIX D – AIRCRAFT FLIGHT OPERATIONS MANUAL VERSION 1.0

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is protected 

under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b). 

Submitted under separate cover.

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