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 625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 

 www.jirehcom.com 

July 14, 2015 

Carl J. Ulbrich 

Jireh Communications Inc. 

625 W. Deer Valley Rd., #103204 

Phoenix, AZ 85027 

(602) 674-5675 

carl@jirehcom.com

Petition of Jireh Communications

For Exemption Pursuant to Section 333 

Of the FAA Modernization and Reform Act of 2012 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR 

Part 11, Jireh Communications, hereby applies for an exemption from Federal Aviation 

Regulations (FARs) identified below, to allow commercial operations of small unmanned 

aerial system (i.e., sUAS). 

This exemption is in accordance with protocols outlined in this petition for exemption, 

and any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act. 

This exemption would permit commercial operation by Jireh Communications Inc., which 

uses DJI Phantoms, Inspire 1, and 3DR Solos to conduct sUAS education, real estate 

photography, videography, film and movie production, demonstration flights and 

inspections. Jireh Communication’ operation under the exemption will be subject to 

strict operating requirements and conditions to ensure an equivalent level of safety to 

currently authorized operations using manned aircraft and under conditions as may be 

modified by the FAA as required by Section 333. 

Jireh Communications will be operated under controlled VFR conditions at low altitude in 

airspace that is permitted in accordance with Jireh Communications’ approved Certificate 

of Authorization (COA). They will operate the sUAS’s with pilots who have 

comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and 

Part 107 commercial compliance requirements. Finally, the FAA ATC will approve the 

airspace in which the sUAS will operate in advance. 

Jireh Communications respectfully submits this request for an exemption because it 

operates sUAS's. The FAA can have confidence that the operations will be conducted at 

an equivalent level or greater level of safety. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities under Section 333(c) of the Reform Act to “establish requirements for the 

safe operation of such aircraft systems in the national airspace system.” 
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For your convenience, Jireh Communications has organized this Exemption request as 

follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations 

V. Regulations From Which Exemption is Requested 

VI. Public Interest 

VII. Privacy 

VIII. Federal Registry Summary 

IX. Conclusion 

I. Petitioner's Description: 

Jireh Communications Inc. , headquartered in Phoenix, Arizona, is a company that 

provides sUAS support to news services, real estate photography, film and movie 

production, education, demonstration flights and inspections in a compliant and safe 

environment. Jireh Communications plan on providing a wide range of services as the 

sUAS market expands. 

Jireh Communications’ goal is to operate in an accident-free environment by: 

• Demonstrating a commitment by management and all employee’s to operator in 

a compliant manner. 

• Identify hazard and risk while eliminating or controlling all these risk. 

• They will use steps to intervene and report when unsafe work practices appear to 

exist. 

• Train all employees involved in flight operations to operate at the highest 

standard level. 

The contact information for Petitioner is as follows: 

Jireh Communications Inc. 

625 W. Deer Valley Rd., #103204 

Phoenix, AZ 85027 

Carl Ulbrich 

(602) 674-5675 

carl@jirehcom.com

 

II. Relevant Statutory Authority: 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether 

certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") 

before completion of the formal UAS rulemaking, based on the following considerations: 
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• 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 the visual line of sight of the operator. 

If the Secretary determines that such vehicles "may operate safely in the National 

Airspace System, the Secretary shall establish requirements for the safe operation of 

such aircraft in the National Airspace System". 

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. A party requesting an exemption must explain the 

reasons why the exemption: (1) would benefit the public as a whole, and (2) would not 

adversely affect safety (or how it would provide a level of safety at least equal to the 

existing rules). 

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

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

under 40101 of the Act, from the requirement that all civil aircraft must have a current 

airworthiness certificate and those regulations requiring commercial pilots to operate 

aircraft in commercial service: 

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. 

III. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied. 

The proposed operations would permit Jireh Communications the use of small UAS under 

controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; 

and that (3) provides an increased level of safety beyond that existing when fixed or 

rotor wing aircraft are used to accomplish the same purpose. 

Jireh Communications uses UASs that are multirotor, weighing less than 25 pounds 

including payload. They operate, under normal conditions, at speeds not to exceed 45 

mph and have the capability to hover, and move in the vertical and horizontal plane. 

Jireh Communications’ UASs will operate in line of sight, during daylight hours, and will 

only operate within a sterile area. Jireh Communications will operate at or below 400 

feet AGL and will file a NOTAM for each flight operated in controlled airspace. All 

required permissions and permits would be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies prior to operating a sUAS. 

Given the small size of the sUAS’s involved and the restricted sterile environment within 

which they will operate, this Jireh Communications’ exemption falls within the zone of 
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safety and demonstrate an equivalent level of safety, in which Congress desired the FAA 

to permit commercial UAS operations by exemption pending completion of formal 

rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s 

will operate, approval of the application presents no hazard in the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, the grant of the requested 

exemptions is also in the public interest. 

IV. Description of Proposed Operations 

To assist the FAA in its safety assessment of Jireh Communications' proposed sUAS 

operations, below is a summary of operational limitations and conditions that will ensure 

an equivalent or higher level of safety to operations conducted under current regulatory 

guidelines: 

1. The sUAS will weigh less than 25 pounds. 

2. Flights will be operated within line of sight of the PIC and observer. 

3. Maximum total flight time for each operational flight will be limited to the amount 

of time the sUAS can be flown and still maintain a reserve battery power of no less 

than 25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or 

who have not signed a waiver in advance of the operation. 

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a 

Visual Observer. Additional crewmembers consist of a Pilot and a Camera Operator. 

7. The sUAS Pilot in Command will have undergone comprehensive UAV / UAS / Drone 

flight training for competency and new FAA 333 and Part 107 commercial 

compliance requirements. 

8. Jireh Communications will designate a Pilot in Command ("PIC") for each mission. 

9. The sUAS will operate only within a confined "Sterile Area". 

10. Prior to the operations at a particular location, a site inspection will have been 

conducted. On the day of the mission the management person with operational 

control and the PIC will concur on dispatching of the mission. 

11. A briefing will be conducted in regard to the planned sUAS operations prior to each 

day's missions. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the sterile area be present for this briefing. 

12. Jireh Communications crew will use the checklist and callouts required in the 

Operations Manual. 

13. All sUAS’s will be maintained in accordance with inspection program specified in the 

manufacturer’s guidelines. 

14. In the event of an accident involving an Jireh Communications sUAS, they will cease 

operations and report the accident to the NTSB and AFS-80. 

15. Pilot in Command and Visual Observer will at all times be able to communicate by 

voice. 
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16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational 

Personnel will have been trained and tested in accordance to FAA, NTSB, and AFS-80 

best practices. 

17. All required permissions and permits would be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies. 

18. Jireh Communications management will submit a written “Plan of Activities” to the 

local Flight Standards District Office (FSDO) having jurisdiction over the area of 

proposed filming three days in advanced of operations during film or movie 

productions. 

19. If the sUAS loses communications signal, the sUAS will have the capability to return 

to a pre-determined location within the Sterile Area and land. 

20. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

21. The sUAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

22. Jireh Communications, by following FAA, NTSB, and AFS-80 best practices, will 

assure no individuals’ privacy is violated. 

V. Regulations From Which Exemption is Requested 

A. 14 CFR § 91.103: Preflight Action 

B. 14 CFR § 91.113: Right-of-Way Rules 

C. 14 CFR § 91.119 (c): Minimum Safe Altitudes 

D. 14 CFR § 91.121: Altimeter Settings 

E. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions 

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

A. 14 CFR § 91.103: Preflight Action 

Jireh Communications requests an exemption from the preflight actions requirements of 

14 CFR 91.113 that prescribes the preflight actions under which aircraft may operate: 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. 

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been 

advised by ATC; 

b. For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

i. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; 

and 

ii. For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance 
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under expected values of airport elevation and runway slope, aircraft gross weight, 

and wind and temperature. 

Jireh Communications will not operate sUAS’s under IFR conditions or when the ceilings 

are below 1000 feet and the visibility is below 3 statute miles. DJI’s sUAS’s do not have 

published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing 

distance data. 

Equivalent Level of Safety 

In adherence to FAA, NTSB, and AFS-80 best practices, the PIC along with the person 

having operational control must follow to assure that the weather will be adequate to 

complete the mission in VFR condition. 

B. 14 CFR 91.113: Right-of-Way Rules 

Jireh Communications request an exemption from 14 CFR 91.113 Right-of-way rules, 

requiring vigilance by each person operating an aircraft so as to see and avoid other 

aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot 

shall give way to that aircraft and may not pass over, under, or ahead of it unless well 

clear. 

Jireh Communications operates small pilotless UAS’s and cannot comply with these 

rules as they have been written. 

Equivalent Level of Safety 

Jireh Communications operates sUAS’s at or below an altitude of 400 feet AGL, well 

below the normal operating altitude of other aircraft. Jireh Communications 

management require that a Pilot in Command with experience will oversee each mission 

and has knowledge of the avoid rules. A Visual Observer will assist the PIC in looking for 

aircraft entering the operations area. It’s the responsibility of the PIC to cease 

operations and land the UAS immediately whenever and aircraft comes into the vicinity 

creating a potential threat. Operations cannot recommence until the threat is clear. 

C. 14 CFR. § 91.119: Minimum Safe Altitudes 

Jireh Communications requests an exemption from the minimum safe altitude 

requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which 

aircraft may operate: 

• Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. 

• Over other than congested areas at an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

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

Section 91.119 (d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes 

or altitudes specifically prescribed for helicopters by the FAA." 
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To provide the intended operations, the sUAS is normally operated below 400 feet AGL. 

Additionally, due to the nature of the proposed operations, the sUAS will maintain a 

lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and 

vessels, and from people not associated with the operation. 

Equivalent Level of Safety 

Compared to flight normal aircraft, Jireh Communications’ multi-rotor aircraft weigh a 

maximum of 25 pounds, and given the lack of flammable fuel, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. An 

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. As set forth in the FAA, NTSB, and AFS-80 

best practices, the sUAS will be operated in a sterile area, where buildings and people 

will not be exposed to operations without their preobtained consent. Because of the 

advance notice to the property owners and participants, all affected individuals will be 

well aware of the planned flight operations prior to commencement of operations. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with 

aircraft that are subject to the minimum safe altitude regulations. Finally, the successful 

safety record of the DJI sUAS’s demonstrates that the sUAS can be safely used at these 

lower altitudes and closer operating environments. 

D. 14 C.F.R. § 91.121: Altimeter Settings 

Jireh Communications seeks an exemption from 14 CFR 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required because the sUAS does not have a barometric altimeter, but 

rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in 

the FAA, NTSB, and AFS-80 best practices. Jireh Communications will confirm the 

altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, 

the PIC will use the GPS altitude indicator to constantly monitor the sUAS's height, thus 

ensuring operation at safe altitudes. 

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Jireh Communications requests an exemption from 14 CFR § 91.151(a)'s fuel 

requirements for flight in VFR conditions. Section 91.151 states: 

a. No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and assuming normal cruising speed – 

i. During the day, to fly after that for at least 25 minutes; or 

ii. At night, to fly after that for at least 45 minutes. 

The batteries powering Jireh Communications’ UAS’s provide approximately 10-25 

minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 

91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's 
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proposed flight area and the location of its proposed operations within a predetermined 

area, a safety margin based on a reserve amount of battery life is needed. Jireh 

Communications will not be conducting any sUAS flights at night. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted 

on-site without significant transit time by the sUAS. All flights will be planned to 

terminate with no less than 25% reserve battery power still available. This restriction 

would be more than adequate to return the sUAS safely to its planned landing zone 

from anywhere in its confined area of operation even in the event of an unexpected 

occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not 

include the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS, and the proximity of the flight operation to the landing 

zone. Moreover, operation will be limited to controlled areas where only people and 

property owners, or official representatives who have signed waivers will be allowed. 

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

 Maintenance Inspections 

Jireh Communications also seeks an exemption from the maintenance inspection 

requirements contained in 14 CFR 91.405(a), 91.407(a) (1), 91.409(a) (2), 91.417(a) and 

(b). These regulations specify maintenance and inspection standards in reference to 14 

CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator of an aircraft "shall 

have the aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections ...have discrepancies repaired as prescribed in part 43 of this 

chapter"). An exemption to these regulations is needed because Part 43 and these 

sections only apply to aircraft with an airworthiness certificate, which the sUAS will not 

have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with FAA, NTSB, and AFS-80 best practices. The operator 

will ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. The operator is the person 

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

condition to provide the equivalent level of safety. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time during 

daylight hours, creates less risk than that associated with conventional rotorcraft 

performing the same operation. 

VI. PUBLIC INTEREST 

Granting Jireh Communications an exemption furthers the public interest. National 

policy set by Congress favors early integration of UAS into the national airspace in 

controlled, safe working environments such as those propose in this petition. The one 

vision of Jireh Communications is to help facilitate safe integration of sUAS’s into 

mainstream USA in the following areas: 
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Movies and Videography 

Whether the shot requires unique views and expansive panning or extreme altitude 

with radical views, the UAS is designed to hold up under demanding conditions. Because 

of the autopilot feature with pre-designed mission management and R/C control 

interrupt, the pilot and camera operator can easily create the ultimate shot with HD 

video or HD still photos. When working close in on a closed set the hazards to the actors 

are greatly reduced due to the size of the sUAS. 

News Gathering 

Similar to movies and videography, each news assignment may require a completely 

different shot or view of a scene. With budgets for traditional helicopter use being 

greatly reduced, the UAS is the perfect solution to allow for easy news gathering for a 

fraction of the cost. The sUAS can and will be operated in a sterile area away from the 

public, while the traditional helicopter must hover over persons and property increasing 

the danger to individuals. 

Real Estate 

The sUAS can be used in all areas of real estate, including commercial, residential and 

industrial properties. Using a sUAS, real estate professionals can create promotional 

videos, photos and unique shots that normal camera aspects cannot capture. Jireh 

Communications’ easy-to-use video and photo platform enables properties to stand out, 

providing dazzling views that are typically shown via expensive computer animation or 

costly helicopter rentals. Imagine shooting a view from a high-rise condo in stunning 

high definition that shows your potential customer the actual view from the residence. 

The remote platform is great for new planning, zoning and large developments. Simple 

and easy-to-use video and photos allow for multiple height pictures and elevation views. 

VII. Privacy 

Jireh Communications is deeply committed to protecting public privacy. Jireh 

Communications knows that many individual have concerns about privacy from the 

operations of sUAS’s. Jireh Communications has created a privacy notice that informs 

residents, commercial property owners, churches, schools, and governmental 

organizations of our intent to conduct commercial drone operations in proximity to 

their property. 

VIII. Federal Registry Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Jireh Communications seeks an exemption from the following rules: 

14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 

91.151(b); 14 CFR § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b). 

Approval of this exemption request allows Jireh Communications to conduct commercial 

operations with small and lightweight unmanned aerial systems. Jireh Communications’ 

singular vision is to enhance safety of sUAS operations in the NAS while reducing risk to 

the general public and property owners. 
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The DJI sUAS, weighing less than 25 pounds and powered by batteries, eliminates 

virtually all of that risk given the reduced mass and lack of combustible fuel carried on 

board. The sUAS is transported to the designated mission area and set up there. The 

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

associated with manned aircraft flights. 

The operation of this small UAS will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the 

requirements of several regulations and allowing commercial operations. These 

lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile 

environment. As a result, they are far safer than conventional aerial survey and 

inspection operations conducted with fixed wing aircraft or helicopters. 

If additional information is required, or if you have any questions regarding this Petition 

for Exemption, please contact the undersigned at: 

With Best Regards, 

Carl Ulbrich, President 

Jireh Communications Inc. 

(602) 674-5675 

Email: carl@jirehcom.com