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James Bassett­Cann

T: 1 (609) 477 8027

bassettcannj@gmail.com

August 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

RE: Request for exemption from regulatory provisions of small unmanned aerial

systems (sUAS) in civil operation on client possessed properties and public property (state,

county, regional properties where permissible) as stipulated by Title 14 Aeronautics and Space,

sections: 45.23(b);14 CFR Part 21;14 CFR 61.113; 91.7; 91.9; 91.103; 91.109; 91.119; 91.121;

91.151; 91.203; 91.405; 91.407; 91.409; 91.417

JOI Photography LLC

2320 Turk RD, Doylestown, PA, 18901

JOI Photography LLC (Applicant) seeks exemption from a number of provisions listed in

Title 14 Aeronautics and Space Code of Federal Regulations (C.F.R.) for operation and use of

small unmanned aerial system (“sUAS”) to establish accurate images and videos for real­estate

clients, planned events, surveillance of monuments, buildings, and utilities, as well as

videography and cinematography of non­navigable airspace. For the purposes of this request,

“small” is defined as any device weighing less than fifty­five (55) pounds. For the stated intent

and attention to safety, Applicant has submitted this application for exemption and requests the

allowance of civil operations of its sUAS within the non­exhaustive conditions enumerated

herein or as may be established by the Federal Aviation Administration(“FAA”) as required by

section 333.

Applicant’s requested exemption would permit the operation of an sUAS under a

controlled environment that would be limited to: 1. Continuous visual Line of sight (VLOS) of

the sUAS operator; 2. from a dedicated remote for the control of the sUAS; 3. a safe distance
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from both the operators of the sUAS as well as persons or wildlife who would be photographed

and/or filmed; 4. access to the equipment required to operate the sUAS as well as the sUAS itself

will only be accessible to JOI personnel, and; 5. the most local Flight Standards District Office

(FSDO) or Air Traffic Control (ATC) governing body has been given advanced notice of aerial

operations and objectives.

I. DESCRIPTION AND BACKGROUND OF JOI PHOTOGRAPHY, LLC.

JOI Photography, LLC (JOI) is a collaboration of two photographers, James Bassett­Cann

and Ian Mason, who worked cooperatively and individually for the past eighteen years. Since the

company’s founding on April 1, 2015, JOI has established itself as a multi­purpose photography

solutions company. JOI has been founded with the philosophy to take advantage of the many

different industries that depend on photography to promote and catalogue their activities. Aerial

photography with sUAS’s is the next challenge to responsibly add to its repository of solutions

that aligns with this philosophy and goal.

Appendix A will provide the manufacturers information in regard to the The sUAS’s design,

performance, safety features, and required maintenance procedures. If a device is added to JOI’s

Fleet that deviates from what is listed in Appendix A JOI, will submit an update to the appendix

to accurately represent its fleet of UAS devices. Additionally should JOI develop a device that is

defined as experimental or special beyond the regulators norms then an additional document

will be filed with the FAA to specifically address this device.
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Appendix B will include the Preflight checklist and procedure for operations of a UAS operated

by JOI.

The following are the sections of 14 CFR from which JOI Photography LLC(JOI) seeks relief or

to establish an alternative self imposed regulation:

14 CFR 21;specifically Subpart H Certification Procedures for products and parts,

airworthiness certificates.

Applicant seeks relief since the sUAS’s established in Appendix A are all in a weight

class of less the 55 pounds and cannot travel at any speed in excess of 40 miles per hour (mph).

All areas of flight will be limited to the criteria established in the pre­flight checklist and relevant

permissions established by the local FSDO or ATC governing body. The certification of this

petition will also bestow a Certificate of Authorization allowing Applicant to operate at a

maximum height of 200 feet from ground level. Applicant seeks a conditional height increase in

instances where the subject that requires photographs or video is permanently installed and is

only viewable at an altitude between 200 and 500 feet from ground level. Currently, JOI does not

seek permission to pilot its sUASs over 500 feet from ground level, but reserves the right to

re­submit an amended request for such an authorization if necessary to remain current with

industry standards and practice.

14 C.F.R. 45.23(b);Display of identifying markings
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Applicant believes that due to the size and design of the sUAS Applicant seeks to pilot

there is not sufficient space to place two­inch lettering detailing the UAS’s federally registered

N­number or serial code. In an effort to comply, the N­number or serial number will be applied

to the top of the device defined by the following criteria: the identification marks are clearly

visible; the functional elements of the UAV are unaffected; that the lettering be applied at a size

of no less than .5 inches tall. If the FAA should later determine there to be a need to mark the

device in a more identifiable manner Applicant will comply.

14 CFR 61.113 (a) & (b);Private Pilot Privileges and Limitations: Pilot in Command

Applicant has determined that its pilots are currently limited to its founders, James

Bassett­Cann and Ian Mason. Both individuals are able to comply with FAA’s sUAS piloting

standards, outlined below. The following are the standards met by both members of JOI. These

criteria will be required of any potential new hire or member, at which time an updated petition

stating the names of the individuals seeking permission will be submitted. Only an accepted

petition will permit those who are listed the ability to operate a sUAS in a civil operation.

Currently, this petition only applies to the two member previously listed. In addition, Applicant

requires its potential pilots:

1. be citizens of the United States.

2. maintain a state­issued license without restrictions of mobility.

3. maintain all safety procedures listed in the JOI Operational Guidelines for Aerial media

and Maneuvers (listed bellow).
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4. not be prescribed to any medication or have consumed any drug that might cause loss in

visual contact or impaired ability to operate the sUAS.

Applicant’s pilots will be held to an acceptable standard provided by their Certificate of

Authorization (COA) or Waiver (COW) as provided by the acceptance of this petition. All

devices piloted by Applicant will be sUAS devices weighing less then fifty­five (55) pounds.

Should an Applicant pilot engage in operations with a sUAS weighing more than 55 pounds, use

any sUAS in a terroristic manner, or use a sUAS unrecognized by the FAA they will be

discharged and removed from their position as PIC and will turn over operational control of the

sUAS to the appropriate FAA authorities or Applicant personnel. In order to prevent the actions

of a JOI pilots as those listed above it is mandatory to adhere to the outlined operational

guideline as well as the pre­flight checklist.

In addition, Applicant will maintain regular contact with any Flight Standards District

Office (FSDO) flight facility as well as the most local ATC governing bodies within the region it

should wish to pilot its sUAS’s. Applicant will comply with the operational procedure

established by the FSDO to provide both culpability for their actions as well as conscious

understanding of what Applicant’s pilots’ flight parameters are meant to be. The PIC will be

whoever is engaged in both the interaction and operation of any of Applicant’s equipment that

relates to its sUAS’s. Only one pilot will be able to direct a sUAS;s directional movement. An

additional remote is permitted for the purpose of altering or modifying the angle established by

the camera.
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For the purpose of clarity, Ian Mason and James Bassett­Cann seek the acceptance of this

petition on behalf of JOI Photography, LLC as they are the only personnel seeking civil

clearance of sUAS in the NAS.

14 C.F.R. 91.9 (b) (2);Requires an aircraft flight manual in the aircraft.

Applicant’s sUAS’s will not hold or bear passage to an onboard manual or operational

guideline for the operation of the vehicle. Since these sUAS’s will not be used to carry a

passenger or cargo – and since Applicant does not intend to fit them for that use – the

establishment of an onboard manual is not applicable.

14 C.F.R. 91.103;Preflight Actions

Applicant has determined that any activity involving one its sUASs necessitates all

personnel to complete a pre­flight inspection of its sUASs as well as maintain a continuous

VLOS with the sUAS. Any scheduled or non scheduled use of a sUAS where a member of

Applicant’s company is the PIC will require a self­imposed pre­flight and post­flight checklist

(see Appendix B). The following are guidelines for all operations Applicant is involved in that

use a sUAS authorized by this petition:

1. JOI, will not operate a sUAS within 5 nautical miles (NM) from an airport having an

operational control tower; or
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2. 3 NM from an airport with a published instrument flight procedure, but not an operational

tower; or

3. 2 NM from an airport without a published instrument flight procedure or an operational

tower; or

4. 2 NM from a heliport with a published instrument flight procedure

5. No flights will be conducted within restricted airspace or the airspace listed above; unless

specific certification or permission is granted. examples include: cities, highly

populated/congested areas, designated no fly zones, international boundaries and

regulations

6. All flights will be conducted after a pre­trip inspection of the UAS which will include:

the verification of an established takeoff and landing zone, all forms of identification and

registration are available on request, the UAS is clearly marked with identifying

information provided by the Aircraft registration Branch after the submission of AC form

8050­1, the calibration of the UAS with all instruments required to operate the UAS

safely and effectively, weather and climate is in compliance with safe operation of the

UAS and continuously maintained visual line of sight(VLOS).

7. All media generated by a device operated by JOI Photography is the property of JOI

Photography until a current contract or future contract is established clearly stating the

transfer of ownership.

8. No flights will be conducted outside of an altitude between 200­500 feet or greater until

permission from a petitioned request has been granted by the FAA (Federal Aviation

Administration).
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*Per the terms accepted in this exemption if a height ceiling is placed on the applicant of 200

feet, the applicant reserves the right to resubmit an application for exhemption from the

200 feet height ceiling.

14 C.F.R. 91.109;Flight instruction; Simulated instrument flight and certain flight tests

Applicant seeks permission to operate its sUAS’s in a safe and controlled environment

and for no reason seeks to use a device for the purpose of instruction. All JOI personnel will be

certified through a formal submission of a petitioned request. All of the sUAS’s piloted by JOI

will only have one PIC who will conduct all piloting operations based off of the corresponding

remote of the UAS as established in Appendix A. At no point will a PIC ever hand control of the

sUAS over to an unauthorized person.

14 C.F.R. 91.119;Minimum safe altitudes: General

Applicant requests a maximum altitude ceiling of 500 feet from ground level. In the case

that the FAA permits Aplicant’s petition, we are entitled to the issuance of a blanket COA for all

operations between 500 feet and ground level. Every objective will hold an independent

Certificate of Authoriztion for the period required to photograph and film the objective to its

completion. The purpose of a requested height ceiling of 500 feet is to photograph various

subject matter that is only properly visible within a height between 200 to 500 feet. For example,
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the William Penn statue above City Hall in Philadelphia Pennsylvania is presently installed at an

altitude above 200 feet. In operations meant for the purpose of conservation and refurbishment,

visual confirmation of damage is required by conservators as well as insurance companies to

validate the purposeful restoration of this monument and others like it. The altitude of the sUAS

is established at launch and monitored by the PIC.

14 C.F.R. 91.121;Altimeter settings

Applicant requests authorization to operate the device within the vicinity of a human or

animal, but at a distance no shorter than ten feet. In regard to flying a sUAS within the vicinity of

a human, no person filmed or photographed by JOI will be unaware of the operations JOI is

engaged in while piloting one of it’s sUAS’s. In instances where a person is unaware of JOI’s

operations with its sUAS, a minimum safe distance of 100 feet from unaware audience will be

observed. It is not in the interest of JOI to engage in any act that might invade a person’s privacy.

The only instance a person may be within 100 feet of one of JOI’s UASs will be in instances of

lightly populated environments, for example, a park bench or a beach open to the public.

14 C.F.R. 91.151 (a);Fuel requirements for flights in Visual Flight Rules (VFR) conditions

Applicant has determined that no flight from take off to landing will result in a flight time

longer then 25 minutes. By exchanging the battery­powered elements, a new pre­flight procedure

will be required before take­off can occur(listed in apendix B). Currently all sUAS’s operated by
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JOI will be powered using non­combustable battery components. See Appendix A for further

details outlining the power sources for each of Applicant’s sUAS’s.

14 C.F.R. 91.203 (a) & (b);Civil aircraft: certification required

Applicant finds that a COA is the most necessary basic level of certification and is

required by all JOI Pilots who engage in any operation of a sUAS. A self­imposed flight program

and certification process will be established as an added level of precaution. All certificates of

authorization or waiver will be awarded through the acknowledgment and understanding of the

FAA. All self certiftied procedures will be held in record by the applicant.

14 C.F.R. 91.405, 91.407, 91.409, 91.417 Vehicle Maintenance

Applicant seeks to use its pre­flight checklist. Should a sUAS require maintenance that

would require elements that would in some way change the device’s operation or purpose, the

sUAS will no longer be authorized for flight. Only in the case that all of the following criteria are

met will a sUAS operated by JOI be permitted to conduct aerial operations: all documentation of

changes made will be submitted before the FAA for inspection, confirmation or recognition of

the intentional repairs and alterations that satisfy the FAA, and; a preliminary flight to be

conducted at an altitude lower than 100 feet to verify functionality of the sUAS. Should the

FAA determine there to be a requirement beyond JOI’s submitted procedure, Applicant will

comply.
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(d) The reasons why granting your request would be in the public interest; that is, how it would

benefit the public as a whole;

Applicant has determined that in creating a safe and responsible photography solutions

company with sUASs, it will ultimately make a safer environment. The current cost­prohibitive

nature of aerial photography and manned aircrafts makes civil operations of an sUAS more

cost­effective in garnering the same result. As an example, Applicant has outlined a number of

purposes for which it will use its sUAS’s and the benefits its operations pose to the public at

large:

Civil operations as they pertain to the use of sUAS devices under the control of JOI

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● Real Estate photography and cinematography

● Weddings and event photography and cinematography

● Surveying for conservation of monuments, buildings, and utilities photography and

cinematography

● Videography and cinematography of non­navigable air space (in unpopulated areas)

Operations conducted by JOI in the benefit of the public:

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Applicant operates its business at its core as a solutions company using the medium of

photography and cinematography to supply the demand of its clients. Applicant’s business

1 Should a person be identified as being involved in a criminal act while JOI is operating a sUAV, JOI will contact

the appropriate authorities and make copies of all footage or images available by request or subpoena.

2 49 U.S.C. §44701(f)
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mission and plan provides a new and innovative solution in conveying a property, wedding or

event, wildlife in its habitat, damage to monuments, and explores areas and views that otherwise

would not be possible without the use of a sUAS.

In regards to Real Estate, accurate images of property listings are necessary to accurately

advertise a property. The current industry norm involves either a plane or helicopter to pass over

a residential area. This process is cost­prohibitive and in most cases much more dangerous than

piloting a sUAS that weighs less then fifty­five pounds and has a maximum travel speed varying

between ten and twenty miles per hour (DJI PHANTOM 3, specifications of maximum travel

speeds and weights are established in Appendix A).

In regards to contractors, in most cases builders or roofers need accurate images and

videos of their work for general advertising purposes, as well as for insurance. Having images of

progress from above the operational area in this case indicates progress of a project in its

entirety. It can also indicate where potential issues may arise in the future, such as high damage

areas, problem areas, and non­functioning areas.

In regards to weddings and events, the demand for photographs and cinematography for

both weddings and events is the best practice for establishing a lasting memory. There is no

reason for a photographer blocking the observable view of an event attendee when a sUAV can

capture the same image and maintain a much less prominent profile. It is also another way to

make an event more unique and special.

In regard to surveillance of surveying monuments, all monuments age in ways that are

not visible from the limited viewpoint on the ground. Getting an indepth view of weather

damage, load stresses, or a need for repair could mean systemic changes in preventing something
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unexpected. Since the subject of the footage is non­human and in most cases, an item that

currently serves the public interest, whether aesthetically or functionality, it is naturally

beneficial to observe required maintenance from the best vantage point possible.

In regards to the use of sUAS’s in currently non­navigable airspace, these are areas where

– due to natural formations, trees, or other obstacles – a manned aircraft is unable to pilot

through. All of the sUASs the applicant seeks to operate maintain a small profile with easier

access to these areas.

(e) The reasons why granting the exemption would not adversely affect safety, or how the

exemption would provide a level of safety at least equal to that provided by the rule from which

you seek the exemption;

Applicant believes in all situations where a sUAS is being operated, the level of safety,

communication with appropriate authorities, and certification improve the level of safety

currently observed in the NAS(National Airspace System). The pre­flight checklist established in

Appendix B serves the purpose of guaranteeing each operation is effective to its purpose and at

all times maintains the operational parameters listed above. By regularly communicating with the

FSDO and maintaining continuous logs of planned and performed flights, Applicant seeks all

responsibility for it actions. For these reasons, JOI feels that it will not adversely affect the safety

of the general populace.

The sUAS’s Applicant seeks to operate has several safety protocols listed bellow:
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1. Should the sUAS lose connection with its controller while airborne the device will

automatically descend until connection with the remote can be reestablished. If

connection cannot be achieved the sUAS will seek to land in the same location it

took off from and will automatically power down.

2. Should the sUAS lose connection with its minimum required 6 satellites the device

will begin to descend. If connection cannot be achieved thes UAS will seek to land

in the same location it took off from and will automatically power down.

3. Should the UAS fly into restricted airspace it is programed to land immediately as

seen in safesty protocols 1 and 2

Summary of petition for the Public Registry:

Petitioner:

JOI Photography LLC

Background:

A photography and cinematography solutions company with a passion for finding new and

innovative ways to solve clients’ problems.

Sections of title 14 Aeronatics and Space Code of Federal Regulations (CFR) enumerated in this

petition:
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Title 14 Aeronatics and Space. sections: 45.23(b);14 CFR Part 21;14 CFR 61.113; 91.7; 91.9;

91.103; 91.109; 91.119; 91.121; 91.151; 91.203; 91.405; 91.407; 91.409; 91.417

Description of the relief sought by the petitioner:

Pursuant of the petition seeks relief from Title 14 Aeronatics and Space, sections: 45.23(b);14

CFR Part 21;14 CFR 61.113; 91.7; 91.9; 91.103; 91.109; 91.119; 91.121; 91.151; 91.203;

91.405; 91.407; 91.409; 91.417 for the purpose in engaging in aerial photography and

cinematography in the following fields of focus: real­estate, events public and private, surveying

wildlife, surveying damage to: monuments, buildings and utilities; and images and videos of non

navigable air space.

(h) If you want to exercise the privileges of your exemption outside the United States, the reason

why you need to do so.

Applicant believes that both the safety procedures and desire to operate within the

guidelines established by the FAA should also permit the use of a UAS outside of the NAS

established by the United States(U.S). Out of both respect and recognition of JOI’s procedure, no

operations with a sUAS piloted by a JOI representative will ever take place where permission is

not previously granted. It Applicant’s the wish to maintain a safe and secure future in aerial

photography.
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Appendix A

DJI Phantom 3 Professional

3

General Information:

Weight (Including Battery and Propellers): 1280 g

Diagonal Size (Including Propellers): 590 mm

Max Ascent Speed: 5 m/s

Max Descent Speed: 3 m/s

Hover Accuracy Vertical: +/­ 0.1 m (when Vision Positioning is active) or +/­ 0.5 m

Horizontal: +/­ 1.5 m

Max Speed: 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level: 6000 m

Operating Temperature: 0°C to 40°C

GPS Mode: GPS/GLONASS

Camera on the DJI Phantom 3 professional:

Sensor: Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range: 100­3200 (video) 100­1600 (photo)

Shutter Speed: 8s ­1/8000s

Image Max Size: 4000 x 3000

3 Exact specifications from manufacturer’s website can be found at: Phantom 3 ­ Specs | DJI. (n.d.). Retrieved July

7, 2015, from http://www.dji.com/product/phantom­3/spec
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Still Photography Modes: Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time­lapse

Video Recording Modes

Phantom 3 Professional

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types: Micro SD

Max capacity: 64 GB. Class 10 or UHS­1 rating required

Max Bitrate Of Video Storage

Phantom 3 Professional: 60 Mbps

Supported File Formats: FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG­4 AVC/H.264)

Operating Temperature0°C to 40°C

Gimbal arm:

Controlable Range: Pitch ­90° to +30°
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Stabilization: 3­axis (pitch, roll, yaw)

Controller:

Operating Frequency: 2.400 GHz­2.483 GHz

Max Distance: 2000m (outdoors and unobstructed)

Video Output Port: USB

Operating Temperature: 0°C­ 40°C

Battery: 6000 mAh LiPo 2S

For tablet or phone:

Receiver Sensitivity (1%PER): ­101 dBm ±2 dBm

Transmitter Power (EIRP):

FCC: 20 dBm/CE: 16 dBm

Working Voltage: 1.2 A @7.4 V

Flight Battery

Capacity: 4480 mAh

Voltage: 15.2 V

Battery Type: LiPo 4S

Energy: 68 Wh

Net Weight:365 g

Max Flight Time: Approximately 23 minutes

Operating Temperature: ­10°C to 40°C
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Max Charging Power: 100 W

Apendix B
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Pre­flight Checklist for JOI Pilot in Comand who is to be defined as the (PIC)

Name of PIC:_________________________________________________________________

Address of temporary sUAS Airport:________________________________________________

Descrition of the sUAS objective: __________________________________________________

______________________________________________________________________________

Has the PIC toured the area around the airport to validate possible flight paths: Yes/No_______

Date of aerial operations:_________________Time of aerial operations:__________________

Are weather conditions satisfactory for flight of a sUAS: Yes/No ________________________

The battery of the sUAS registers 90%­100% of charge: Yes/No _________________________

The battery of the remote registers 90%­100% of charge: Yes/No _______________________

The sUAS has been calibrated in relation to the take off zone: Yes/No_____________________

The sUAS specified take off and landing area has been established: Yes/No________________
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The sUAS has fully functioning lights indicating front from back: Yes/No __________________

The sUAS is clearly displaying its N­Number or serial number: Yes/No ____________________

No persons are within a vicinity of 10 feet of the sUAS during pre­flight: Yes/No ____________

The camera is responding to the PIC Yes/No________________________________________

Printed Acknowledgments of flight activity provided by the regional FSDO: Yes/No__________

SUBJECT OF FLIGHT:

What is the target objective of this flight: ____________________________________________

To what altitude (estimated) is it anticipated that the sUAS will be

piloted:___________________

How many take­offs and landings will be required:______/flights actually taken:_____

Post­flight Checklist:
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Were there any hazards, issues, or equipment malfunctions during the operation of the UAS?

_____________________________________________________________________________

Was the flight objective achieved?:________________________________________________

Has the raw footage been archived?:________________________________________________