Date: May 30, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington DC 20590

Jarad Wright – Owner

JCeezer Marketing, LLC

1511 Melody Ridge Court NE

Conyers, GA 30012

678-672-7813

RE: Petition of JCeezer Marketing, LLC Exemption Pursuant to Section 333 of the 

FAA Reform Act

Attn: To whom it may concern

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

Reform Act) and14 C.F.R. Part 11, JCeezer Marketing, LLC, operator of Small 

Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography and 

videography, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333.1

JCeezer Marketing, LLC has been in business since 2015. In recent history we have 

been bidding on jobs that have been bid by drone operators in our area and we find 

it difficult to compete with them. Therefore, we would like to add drone aircraft. As 

described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is

1. Limited 2. Predetermined and 3. Controlled. The proposed exemption, if 

granted, would allow JCeezer Marketing, LLC to conduct commercial 

operations of small, unmanned aircraft systems ("UAS") meeting or 

exceeding all of the operational and safety requirements Congress has set 

forth in Section 333.

2. JCeezer Marketing, LLC is a media/technology company that plans to exploit 

the capabilities of Unmanned Aerial Systems to offer a multitude of services, 

including: 

a. Aerial surveying

b. Remote sensing

c. Agricultural support 

d. Real Estate Photography

e. Aerial film making and photography
f. Construction site inspections and monitoring Wildlife and forestry 

monitoring 

g. Educational and research operations

Statutory Authority Section 333, titled "Special Rules for Certain Unmanned 

Aircraft Systems", provides a mechanism for seeking expedited FAA authorization of 

safe civil UAS operations in the NAS. Section 333(a) states that the FAA "shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the (comprehensive) plan and rule making 

required by section 332(b)(1) of this Act or the guidance required by section 334 of 

this Act." In Section 332(b)(1 ), Congress made it clear that Section 333 provides a 

mechanism for "expedited operation authorization" if several factors are met. 

Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations.

The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

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

14 C.F.R. 91.7 (a)

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

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

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

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14C.F.R. (91.401-91.417)

Unmanned Aircraft System

sUAVs are oftentimes seen as superior to helicopters due to the smaller devices 

cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety. 

We are petitioning for exemption to enable JCeezer Marketing, LLC to operate a DJI 

Phantom 3 Professional equipped with a three-axis gimbals and using High-Def 

cameras. This sUAV has a built-in capability to limit the height it flies above the 

ground, to limit the radius of the distance it flies from the operator and to exclude it 

from Class 8, C and D airspace including a no-fly zone feature. The DJI Phantom 3 

Professional also has the fail safe function of the Naza-M autopilot system which 

means when the communication between the Main Controller and the transmitter is 

disconnected, the outputs of all command sticks from controller will go to the center 

position. If the GPS signal is good enough, the system will automatically trigger 

Return to Home and will land safely.
The above specifications meet with the Model Aircraft Operating Standards as 

set below:

 JCeezer Marketing, LLC will only operate its sUAS in line of sight of a pilot 

and/or observer and will operate at sites that are a 'sufficient distance' from 

populated areas within the sterile area described in the FOPM. Such 

operations will insure that the sUAS will "not create a hazard to users of the 

national airspace system or the public."

 When flying sUAV within 5 miles of an airport, airport operators will be 

notified and the operator will give the right of way to avoid flying in the 

proximity of full-scale aircraft. 

 Maximum flight time for each operational flight will be 20 minutes.

 Flights will be terminated at 25% battery power reserve should that occur 

prior to the 20 minute limit.

 The sUAV will be programmed so that it will not be operated at an altitude of 

no more than 400 feet AGL, and not more than 200 feet above an elevated 

platform from which filming is planned.

 Minimum crew for each operation will consist of the sUAS Pilot, and Visual 

Observer.

 The sUAS operated by the petitioner weighs less than 55 pounds, including 

the payload (i.e. camera, lens, and gimbal).

 The sUAV will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

 Given the small size of the sUAS and the restricted sterile environment 

within which they will operate, our sUAS operations adhere to the Reform 

Act's safety requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable than 

larger aircraft running on combustible fuel, it operates at lower altitudes with no 

people on board and will thereby reduce current risk levels and thereby enhance 

safety and diminish the likelihood of death or serious bodily injury. With a small 

payload and maximum flight time of only 20 minutes, this is offers little or no risk to 

national security. Low level oblique photos and video from several angles are far 

more effective than ground based imagery for displaying the characteristics of large, 

complex properties with several buildings and large trees. The applicants in the past 

have chartered 2-seat full-sized helicopters for this purpose, which has proven more 

costly than many potential clients have been able to afford. The benefits of reduced 

cost and improved quality of presentation from the UA will be valuable to and 

benefit many buyers and sellers of real property. Additionally, we request that we 

be allowed to use our system to benefit first responders nearby who might require 

assistance, including fire fighters, the police, the sheriff, et al., while remaining 

subject to all limitations cited in this application as we do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b)AII operations must occur in FAA Class G airspace at no more than 400 ft AGL, at

an airspeed of no more than 25 knots and no further than 1/8th NM from the PIC;
(c)AII operations must utilize a visual observer (VO). The VO and PIC must be able

to communicate by voice at all times during a flight operation;

(d)Operations will be restricted to flights over private property with the permission 

of the property owner;

(e) All required permits will be obtained from state and local government prior to 

operation;

(f) JCeezer Marketing, LLC, will not be operate over densely populated areas;

(g) JCeezer Marketing, LLC, will not be operating over any open-air assembly of

people;

(h) JCeezer Marketing, LLC, will not be operating over heavily tracked roads;

(i) JCeezer Marketing, LLC, will not be operating within 5 NM of an airport or 

heliport without prior permission.

We respectfully request exemption under Section 333 to enable JCeezer Marketing, 

LLC, to operate efficient, limited, low-risk commercial sUAV operations for the 

activities stated respecting at all times the space and privacy of citizens and 

property whilst keeping our skies safe.

Sincerely, 

Jarad Wright 

JCeezer Marketing, LLC
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

JCeezer Marketing, LLC requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of the 

sUAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for Unmanned 

Aerial Systems, we request an experimental certificate be issued for the DJI 

Phantom 3 Professional under either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the 

following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including flights 

to show compliance for issuance of type and supplemental type certificates, flights 

to substantiate major design changes, and flights to show compliance with the 

function and reliability requirements of the regulations. Since the experimental 

certificate can be used for commercial purposes such as market surveys, sales 

demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. The aircraft will not carry 

persons or property, will not carry fuel, and will only fly under strict operational 

requirements. Combined with the UA's lightweight, being constructed primarily of 

carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, 

than a conventionally certificated aircraft performing the same mission. If an 

experimental airworthiness certificate is not appropriate for this application, then 

we request an exemption of 14 CFR Part 21, Subpart H. and the requirement for 

airworthiness certificate in general. Citing the equivalent level of safety outlined in 

the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must 

display the word "EXPERIMENTAL" in letters at least 2 inches high near the 

entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance 

in which the word "EXPERIMENTAL" can be placed, and may not have a registration 

number assigned to it by the FAA. We propose to achieve an equivalent level of 

safety by including the word "EXPERIMENTAL" in the placard on the top of the 

aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and 

others in the vicinity of the aircraft while it is preparing for launch will be able to 

see the designation. Additionally, we feel that the permanent placard discussed in 

the previous paragraph will provide the aircraft's registration information at the 

ground station. Finally, we will display at the ground station a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 
inches high or greater. Since the aircraft will operate within 3/4 NM of the ground 

station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations Pilot in Command and 

61.133 Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act 

as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) 

allows a private pilot to act as pilot in command of an aircraft in connection with 

any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. Our proposed operations require that the PIC must hold at 

least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry 

passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even

though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. We assume that the intent of this 

requirement is to ensure that flight manual information is available to the aircrew 

while operating the aircraft. We request an exemption to this requirement since the 

aircraft is not only too small to carry documentation, the documentation would not 

be available to the crew during flight operations. To obtain an equivalent level of 

safety and meet the intent of 91.9, we propose that a current, approved sUAS

Flight Manual must be available to the crew at the ground station anytime the 

aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain 

flight tests The regulation states that "No person may operate a civil aircraft that is 

being used for flight instruction unless that aircraft has fully functioning dual 

controls." The sUAS System ground based control station consists of a small handheld radio transmitter and while it does not offer a second set of "controls", both the 

student and instructor can, and will, operate the single set of controls 

simultaneously. With both student and instructor having "hands-on" the controls 

during flight, we feel that this technique meets the intent 91.109 and provides an 

equivalent level of safety. 

91.119 Minimum safe altitudes:

General. The regulation states that over sparsely populated areas the aircraft cannot 

be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since 

the typical mission of the sUAS would be photography or survey of persons, vessels, 
vehicles or structures it would be necessary to operate closer than 500 feet to the 

items listed. Operations will only be flown over property or persons where 

permission has been obtained and careful pre-planned has been performed. The 

aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. 

Therefore we maintain that due to the small size of the UAS, the hazard to persons, 

vehicles and structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to 

an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly 

below 400 feet AGL and will not need to maintain cruising altitudes in order to 

prevent conflict with other aircraft. An Above Ground Level altimeter measurement 

above the takeoff point is transmitted via radio from the sUAS on-board computer to 

the d1splay screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended 

landing and to fly after that for at least 30 minutes. We feel the intention of this 

paragraph is to provide an energy reserve as a safety buffer for delays to landing. 

The sUAV is battery operated and the maximum duration of flight from a single 

battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly 

more than 1/8 NM from the point of intended landing, a full battery charge at launch 

will ensure that we meet the reserve energy requirement of this paragraph. We 

request an exemption to the word "fuel" and ask for an equivalent interpretation 

with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration 

number assigned to the aircraft and a registration certificate must be aboard the 

aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate 

be "displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry 

documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and· meet the intent of 

91.203, we propose that documents deemed appropriate for this aircraft by the FAA 

will be colocated with the crew at the ground control station and available for 

inspection upon request. In order to identify the aircraft, we propose that the 

information found on airworthiness and registration certificates be permanently 

affixed to the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations The regulation provides that the operator is primarily responsible for 
maintaining the aircraft in an airworthy condition, including compliance with part 

39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for 

return to service by a person authorized under 43. 7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and inspection of 

the aircraft and "be authorized to approve the aircraft for return to service." The 

Page 10 PIC will ensure that the aircraft is in an airworthy condition prior to every 

flight and in addition conduct detailed inspections after every two hours of flight. 

Maintenance performed by the PIC is limited to repairing small cracks, replacing a 

propeller, checking electrical connections and updating software and firmware for 

the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety

Safety and Benefits of the UAS

JCeezer Marketing, LLC will be using the UAS in a variety of applications that 

generally require expensive full-size manned aircraft to complete. Small, light, 

unmanned aerial vehicles offer myriad benefits over the use of full-sized manned 

aircraft for electric power line inspection, oil/gas pipeline inspection, advanced 

agriculture, film and still photography, just to name a few. Replacing significantly 

larger manned aircraft carrying crew and flammable fuel with small UAS carrying no 

passengers or crew creates a much greater margin of safety for the pilots and crew. 

By granting Toledo JCeezer Marketing, LLC's requested exemptions, the FAA will 

help Drive development of safe and successful commercial UAS operations and will 

advance the public knowledge base for such operations. JCeezer Marketing, LLC is 

committed to promoting the UAS research efforts of policymakers including the 

FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations 

and serving as a resource for future UAS research operations. Thus, the FAA has 

good cause to grant this Petition.

Conclusion

As pointed out in this application, all the SUAs which our company would use, under

authorization by the US DOT-FAA, are small, light-weight devices operated within 

the line of sight of the Pilot-in-Command (PIC), less than 400 feet above the ground 

and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other 

location with aviation activities, unless the air traffic control authorities (ATC) have 

been notified and have authorized each flight within a radius of this distance.

Page II

All our SUAs have proven capability for controlled flight. They are devices offered 

for general sale on the market around the world and have often been used as Model 

Aircraft in the USA.

We a re certain that the studies conducted until now by the FAA, about Section 332, 

Public Law 112 -95, 2014, have already provided you with the assurances on the 

airworthiness of SUAs such as ours. For the foregoing reasons, the exemptions 

requested herein should be granted and Aerial Associates Photography should be 

permitted to conduct small UAS operations in accordance with its manuals and all 
other operating parameters deemed necessary and appropriate by the FAA. The 

submission of this application and its contents is the best demonstration that indeed 

it is possible to pursue the authorization process so that some SUAs may be used for 

legitimate commercial activities and under reasonably safe conditions.