Page 1 UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WA SHINGTON, DC 20590

IN THE M AT TER OF THE PETITION FOR EXEMPTION OF:



## East Coast Jib and Aerial, LLC.

FOR A N EXEMPTION SE EKING RELIEF FROM

THE REQUIREMENTS OF THE FAA REFORM A CT AND

PA RT 11 OF THE FEDER AL A VIA TION REGULA

TI ONS FROM

TI TLE 14 OF THE CODE OF FEDERA L REGUL AT IONS

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 COMMERCIA L OPERA TION OF UNM AN NED AIR CRA FT SYSTEMS

. PURSUA NT TO SECTION 333 OF THE F AA M ODERNIZ AT ION

AN D REFORM A CT OF 2012 (PUBLIC L AW 112

- 95)

Submitted on August 2 7 , 2015

East Coast Jib and Aerial, LLC.

6000 Deerfield Lane

H ickory, NC 2 8602

East Coast Jib and Aerial, LLC

Joshua Lee Bumgarner - Owner/Chief Operator

60 00 Deerfield Lane

H ickory, NC 28602

www. EastCoastJibandAerial .com

JoshBum@EastCoastJib.com

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

www. EastCoastJibandAerial .com 7 04-996-9415 704- 996-9415East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602

www.EastCoastJibandAerial.com 704-996-9415 Page 2 

### 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	Exemptio n	Request** 

**......................................................................................................... 8** 

**Operator	Requirements**

**................................................................................................................ 10** 

**Aircraft	and	Equivalent	Level	of	Safety**

**.................................................................................... 13** 

**Specific	Uses	Public	Benefits**

**....................................................................................................... 17** 

**Equivalent	Level	of	Saf ety** 

**............................................................................................................. 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	Registe r	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** Page 3



## GL **OSSARY OF ABBREVIA TIONS** 

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 Certifi cate o f 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

Sec tion 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

U AV 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 Sec tion 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 Airc raft Systems (“sUASs”) equipped

to offer on -de mand commercial UAS ope rations 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/UA S

, so long as such operations ar e

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

operat ion 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 climbin g

high on da ngerous str uctures, 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 re quirements for the safe operation

of such aircraft systems in the national airspace system.” Section 333(c) of the

Reform Act. 1



## Ex **ecutive 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

requ est, 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 exempt ions 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 pe titioner is seeking an exempt ion to commercially operate sUAV ’s makes and

modes as follows:

1.) DJI

- Inspire 1, 2.) Aeronavix Droidwor x SkyJib 8

Each separatel y weighs 55 lbs. or less, with im aging payload and app licable

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 -pow er 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, aeri al surveying,

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

contain proprie tary 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 sit e inspection and monitoring, public entity support operations, Ae rial

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 wit h 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 pe rsons individually or belonging to both private and

public organizations to increase awareness and improve safety for current and

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

colleges, professional sports, open air events a nd fairs

, research, risk management

and assessment, motion picture production 3

, surface mining, closed set filming 4

, disaster and catastrophe events.



### Regulations from **which the E xemption**  **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

www.EastCoastJibandAerial.com 704-996-9415Page 7



### Background

The Petitioner

, East C oast Jib and A erial, LLC. is under Josh Bumgarner ’s

direction

. Josh Bumgarner is a hi ghly accompl ished, 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 service s t o 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 prepar ed 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 co ntractors 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

tele vision industries.

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

www.EastCoastJibandAerial.com 704-996-9415Page 8



## The Ex **emp tion 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 t he

purposes noted.

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

agriculture, events, disasters and infrastructure to conduct bridge ins pections, flare

stack inspection, utility -po wer generation system inspections and patrol ling, 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 tow ers,

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

monito ring, public entity support operations, aer ial 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 be longing to both private and public organizations to increase

awareness and improve safety for current and futur e 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 U A S will be operated by East Coast Jib and Aerial, LLC. and or

contracting operators on occasion to capture high -re solution 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 th e

speed of operation be between 5-1 5 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, al low commercial operations of UASs to commence im mediately.

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 wh ether 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 ty pes 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 f or 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 ai rcraft, 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 -4 4716

of this title if the Administrator fi nds 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 issue d 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 pri or 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 FA A 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 -f encin g, 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 -t aken with t he approval of the

land or home owner , 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 dut y on the Adm inistrator 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 st atutory requirements for approval.

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

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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

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

aircraft, should have knowledge and experience that enab les the safe operati on of

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

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

property; 2 the sUAV has built -i n 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 A erial, LLC. will utilize

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

Given the sUAV safety fe atures 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 FAA

recognized 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 Pro posed

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 -pi lot that allow s it to

execute very accurate pre -pr ogramed flights. Flights are pr e -pr ogrammed with GPS

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

under auto -p ilot are not directed by pos itive manual input, but through pre

programmed flight parameters that are executed by the auto -p ilot. In the case of

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the

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

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

auto mated safety functions and safety enh ancing features of the Advanced sUAV’s

may include the following:

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

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

immediate landing,

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

levels. Low power be low 10 % triggers an immediate landing,

3) If the auto -p ilot detects a lost -l ink to the ground controller, the UAS will hold

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

ex ecute 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 -c ommanded devi ation 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 5 0 mph (while

imaging) nor above a maximum of 400 fe et AGL.

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

Systems (UAS Operational Appr oval, at 20

- 21 (July 30, 2013; As the FAA has

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

in com paring the requirements for private pi lot knowledge and the knowledge

required for a com mercial pilot, that knowledge associated with a private pilot

license, and therefore private pilot ground school, was sufficient to allo w private

pilots to operate sUAV’ s under th ose exemptions.

Based upon that analysis, East Coast Jib and A erial 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

Op erator ac cumulate required sUAV flight training hou rs 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 m agnitude 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 airspac e without the permission or knowl edge 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 profi ciency), to the extent they are relevant to UAS

operations, can be taught in the training of com pany 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 5 0 mph during

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

with the par ticular 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.

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

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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 (G round and

Practical) from the Chief Operator to op erate the sUAV

. Alongside a Sport Pilot

Certificate, t his 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

is sue d 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 here under. 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 -p rogramed and at ti mes, 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 th e flight. Rather, once the sUAV is launched, the Operator’s only duty

will be to watch the flig ht 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-f

light 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 Aviati on 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 pow ered

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

be granted with conditions similar to those contained in num bered paragraphs

14 -1 5 in Exem ption 11136

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

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### Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested here in 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 saf ety 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 oper ation s

under an FAA issued exemption include:

1) Operations authorized by this grant of exem pt ion are limited to

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

other aircraft will requ ire a new petition or a petition to amend

this grant.

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

mph (1 0 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

m ust be in feet AGL.

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

Air craft Operator at all ti mes. 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 req uest. If a discrepancy exists between the conditions and

limitations in the exemption and the procedures outlined in the

Exemption Holder’s Oper ator’s manual, the conditions and

limitations in the exemption take precedence and must be

followed. Otherwise, the Aircraft Operator must follow the

procedur es 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 th e Administrator uponEast Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602

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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 condi tion 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

pre flight 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 co mponent, 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 fo r 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 requi rements, 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 Ma nuals. 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 theEast Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602

www.EastCoastJibandA erial.com 704-996-9415 Page 15

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

Exempt ion 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, Su bpart 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 ag ency 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 enf orcement

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

www.EastCoastJibandA erial.com 704-996-9415 Page 16

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 U A 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 agr eement 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 r esponsibility 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 assessmen t

of the risk of operating closer to those objects and;Page 17 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 controlled

access 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 vertic al 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 o n the NTSB Web site: www.ntsb.gov

.



### Specific Uses Public Benefits

East C oast 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 in specting

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 wit h confined and dangerous spaces, or

i ncreased 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 t han

those undertaken with a sUAV

.

The present system exposes those not only in the im mediate 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 wi th inter nal combustion engines. The sUAV’ s

proposed herein are battery powered and have no emissions.

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

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

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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 pri vate pilots to non -c ommercial 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 ha ve a high degree of pre -p rogrammed control and various built -i n

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 ha ve navigation and control system comprised of a Ground Control Station

(GCS) and auto -p ilot system that can be pre -p rogramme d to set operational boundaries

. All

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

events, the Operator may input pre -p rogrammed evasive maneuvers from the

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

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 i nclude t he following:

1.1. Auto

- pilot detection of lost GPS or of insuf ficient satellites initiates an

immediate landing.

1.2. Low power on the aircraft triggers escalati ng 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 groun d 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 s hutt ing the aircraft

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

deviation from the flight path.

1.5. T he aircraft, weighs less than 5 5 lbs., fully loaded.

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

signal s.Page 19 1.7. The aircraft will operate for the Purposes at no more than 5 0 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 -rec ognized 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 equ ivalent leve l 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.

sU A V (giv en 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

air craft (fixed wing or rotorcraf t

, that allowing operations of the UAS as set forth

above m eets 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 air craft unless it is in

airworthy condition. Should the exemption be granted allowing comm ercial

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

www.EastCoastJibandA erial.com 704-996-9415Page 20

prior to each flight. The FAA has granted exem ptions 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 4 00

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 flam mable fuel, any ris k associated with these operations is

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

below 500 A GL in the aerial photography industry. In addition, the low

- altitude

operations of the sUAS will ensure separation between the se small

- UAS operations

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

The FA A ha s 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 t o m aintain 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. sUA V

, 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 exem ptions 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 prohibi ts 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

www.EastCoastJibandAerial.com 704-996-9415Page 21

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 -mi nute 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 ar ea 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 saf ety can be achieved by limiting

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

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

landing zone from anywhere in its limited operating area. Sim ilar 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); 91.4 **07 (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 aircra ft with an airworthiness

certificate, these sections will not apply to the Petitioner

. Maintenance will be

accom plished by the Operator or manufacturer pursuant to the flight manual and

operating handbook as referenced in the Manuals attached as confidenti al 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

lim ited periods of time. If mechanical issues arise, the UAS can land immediate ly and

will be operating from no higher than 400 feet AGL. A s 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

www.EastCoastJibandA erial.com 704-996-9415Page 22

maint enance performed. Moreover, the Operator and manufacturer are most

familiar with the aircraft and best suited to m aintain 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.

*********



## Fede **ra l R**  **egister Publication**

Pursuant to 14 C .F.R. Part 11, the following summary is provided for publication in

the Fed eral Register, should it be determined that publication is needed:

Pe titioner 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 operat e comm ercially a small

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

in spections, flare stack inspection, utility -po wer generation system inspections

and patrolling, aerial inspection and photography of residential and commercial

utility infrastructure including but not limited to elect rical 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

surveyi ng, 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 futur e UAS operations within

the NA S, spec ial events: including high schools. colleges, professional sports,

open air events and fairs

, research, risk m anagement and assessment, motion

picture production, surface mining, closed set filming, disaster and ca tastrophe

events.



## Priv **acy 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 ob jects 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.

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

www.EastCoastJibandAerial.com 704-996-9415Page 23



## Summary

Approval of exemptions allowi ng commercial operations of sUAV’ s for petitioner to

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

stack inspection, utility -po wer generation system inspections and patrolling, aerial

inspection and phot ography 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 un der 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 futur e 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 enhanc e 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 airc raft 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 proje ct

location. In contrast, a sUAV wei ghing 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. Th e

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

risks associated with manned aircraft flights.

The operation of sm all U ASs, weighing less than 55 lbs., conducted under the strict

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

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

con ducted 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

.

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

www.EastCoastJibandA erial.com 704-996-9415Page 24

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

weigh t, speed, operating capabilities, proximity to airports and populated areas and

operation within visual line of sight and nation al 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

11 171 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.EastCoastJibandA erial.com 704-996-9415East Coast Jib and Aerial, LLC. 6000 Deerfield Lane, Hickory, NC 28602

www.EastCoastJibandA erial.com 704-996-9415 Page 2 5 

### APPENDIX A

- TECHNICAL MANUALS AN D 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 I nformation 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

www.EastCoastJibandA erial.com 704-996-9415 Page 26 

### APPENDIX B

- MONTHLY MAINTENAN CE 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

www.EastCoastJibandA erial.com 704-996-9415 Page 27 

### 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 relea sed 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

www.EastCoastJibandAerial.com 704-996-9415 Page 28