John M Jenkins

3138 Diablo View Rd.

Lafayette Ca, 94549

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal

Aviation Regulations from 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2);

91.109;119.121; 91.151(a); 91.405(a); 91.407(a) (1); 91.409(a) (2);

91.417(a)&(b)

Attached:

Inspire_1_Maintenance_ManualV1.0_en.pdf

Inspire_1_Safety_Guidelines_en.pdf

To Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for

Exemption under section 333 of the FAA Modernization and Reform Act of

2012, I John Jenkins, request exemption from the following sections of Title 14,

Code of Federal Regulations §§ 61.113(a); 61.113(b); 91.119(c); 91.121;

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

In order to operate small unmanned aircraft systems (UAS) commercially in

airspace regulated by the Federal Aviation Administration (FAA) for the

purposes of aerial photography, cinematography, videography, Real Estate Aerial

Photography and other flight operations that could be performed safely and more

cost effectively with the use of small UAS at low altitude within the U.S. national

airspace system as compared to a manned aircraft. Operations will be performed
only at the request of and with the authorization and permission of clients or their

authorized agents in order to facilitate commerce and raise awareness of the

beneficial uses of small unmanned air systems. 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. My exemption request would

permit operation of an ultra lightweight, unmanned (piloted by remote control)

UAS in controlled and limited airspace . Predetermined in areas away from

general public, airports, heliports and vehicular traffic for community photos and

videos, and within property boundaries for individual property owner’s, real

estate listing videos/photos. I, John Jenkins, have personally instilled safety

protocols and controls to avoid and prevent public hazard. This will act to further

safety protocols exclusive to lightweight UAS specific to real estate video and

photography usage as I, John Jenkins, record flight data and other information

gained through permitted flight operations to share with the FAA through any

required FAA reports to assist with future protocol and safety regulation.

UAV/UAS/UA.

The UAV/UAS/UA which I John Jenkins, will be operating is the

DJI​Inspire 1​. The inherent safety features, sophistication, programmability,

GPS navigation, return home capability, airport vicinity no­fly feature and

restricted altitude feature, as well as differentiating radio frequency (rf) for

aircraft controller/receiver and for the camera make the Inspire 1 a much safer

UAV for the purposes of this petition. This is a professional grade radio

controlled UAV that has the capacity for software upgrades. It is light, less than

6.5 pounds including battery and camera. Incorporated into the programming of

the Inspire is an automatic return home feature that automatically directs the craft

back to point of take off should communication with the transmitter be lost. The

Inspire has a cruising speed of 22m/s, with a maximum flight time of about 20

minutes. The Inspire has an additional communication link between the camera

and craft on a different rf for a smart phone connection. Allowing the operator or

Pilot In Command (PIC) to monitor battery level, altitude (AGL), distance from

PIC, camera imagery, and control camera angle. The DJI Inspire’s 2.4 ghz

transmitter/controller/receiver rf for managing flight with a 5.8 ghz rf
transmitter/receiver for video/photography functions eliminates possible rf

conflict. The software for the Inspire allows the operator or PIC to set maximum

altitude AGL for each flight, allowing customization of flights to no higher than

100 feet, 150 feet, or 200 feet AGL as an examples. The 400 foot maximum AGL

can be programmed into the UAV's software pre­flight to insure compliance with

FAA standards. Adding to the safety capabilities of this UAV. This UAV is

programmed to remain in position when controls are released. Maintaining

altitude and GPS location. The Inspire has an altitude and radar monitoring

function that allows the operator more precise determination of height, direction

of flight and distance from the operator PIC. The operator or PIC can monitor

GPS lock status while UAV is in flight, with the ability to anticipate loss of GPS

locking so the operator or PIC can land the UAV as a precaution.

The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions

and Limitations section and believes that the procedures specified therein are

reasonable and will be utilized in order to manage and mitigate risk and ensure

public safety. A preflight checklist will be developed and employed to ensure that

the UA airworthiness will be verified before launch. Airworthiness will be

maintained by performance of routine inspections before each flight, maintaining

flight and maintenance logs to record time on failure prone components. The

petitioner will only operate the UAS over designated properties with the owner’s

consent. Flight plans will be predetermined to limit the UASs flight time and

limit safety concerns. The petitioner will take into account distance from persons

and potential flight obstacles prior to operating the UAS. UAS operation will

always be within VLOS of the PIC and the observer.

Public interest.

The use of the UAS in order to facilitate commerce could lead to economic

growth. Operations for this petition will enable service for property owners or

their designees seeking an enhanced perspective for characteristics, amenities,

and benefits of their desired photographic subjects that cannot be displayed

through ground level videography/photography. Aerial photography is a valuable

marketing tool that can lead to increased commerce and enhance personal

photography. The petitioner will provide clients with photographic data for these
purposes on a ‘for hire’ basis acting as an independent contractor. A visual

observer will be utilized. Flight data including UA flight time, Control Unit

operation time, incident, accident, and details concerning any deviations from

normal operations will be available to FAA for use in collecting data regarding

the use of UAS as part of this application. This data may be submitted to FAA via

traditional means or other means as required.

Pilot.

I began piloting a UAV/UAS/UA in 2014 with my purchase of a DJI

Phantom. I honed my skills with this UAS and have since graduated to the DJI

Inspire 1. With a photograph and videography background I have approached the

piloting of these craft with the same passion and commitment. Each flight has a

well thought out plan and purpose. Being an essential tool used in my business to

support my family, I take every precaution necessary to insure the safety of my

clients and all involved.

Conclusion.

The petitioner is requesting this exemption for the purposes of “aerial

photography, cinematography, videography, Real Estate photography and other

flight operations”. The reason for such a general and broad based request is that

the petitioner wishes to utilize a business strategy that enables a flexibility and

speed at which he can adapt to future client needs and without the long

turnaround time associated with additional exemptions. The primary purpose of

seeking this exemption is to obtain the capability to offer those services while

remaining in compliance.

Respectfully submitted,

John M Jenkins