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Section 333 Exemption Request, Stacy Johnson Inc. February 26, 2016

Travis Johnson Stacy Johnson Inc. 3606 W. 109 th St. S. Jenks, OK 74037

FAA Section 333 Petitions Shell Docket U.S. Department of Transportation 1200 New Jersey Avenue S.E. Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of th e FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 9 1.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b) ; 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

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Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Stacy Johnson Inc. operator of an U nmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation R egulations (FARs) to allow commercial operation of its UAS, so long as such operations are conducte d within and under the conditions outlined herein or as may be established by the FAA as requi red by Section 333.

Commercial operation of an UAS, as described herein , which are equipped with camera(s) and sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or p rivate use including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or p rivate use including television, public events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commer cial under contract with the owners or local government authority.

4. Aerial video/photography or providing live video fe ed to assist with search and rescue operations in cases of an emergency or natural disa ster only when the local authorities of government has requested it by contract or donation

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5. The ability to offer training to persons individual ly or belonging to both private and/or public organizations that have interest in the use and app lication of a UAS for the purpose of the safe operations of a UAS to enhance the safety of t he National Airspace System (NAS) as well as for the protection of the persons and property.
As described fully below, the requested exemption w ould permit the operation of a UAS under controlled conditions in the NAS that would be a) l imited b) controlled c) predetermined and d) will provide safety enhancements to the already saf e operations in the industry presently using2 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrato r’s) responsibilities to “....establish requirements for the safe operation of such aircraf t systems in the national airspace system.”

The name and address of applicant is:

Stacy Johnson Inc. Attn: Travis Johnson Address: 3606 West 109 th Street South, Jenks, OK 74037 Email: travisj@cox.net Phone: 918.633.6717

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 14 CFR 91.109 14 CFR 91.407 (a) (1) 14 CFR 45.23 (b) 14 CFR 91.119 (c) 14 CFR 91.4 09 (a) (2) 14 CFR 61.113 (a) & (b) 14 CFR 91.121 14 CFR 9 1.417 (a)&(b) 14 CFR 91.7 (a) 14 CFR 91.151 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.203 (a) & (b) 14 CFR 91.103 14 CFR 91.405 (a)

Stacy Johnson Inc. will operate the DJI Phantom 3 UAS, with a total weight of 2.82 lbs. The dimensions are 23.23 inches x 23.23 inches x 9.45 i nches. Under still air the maximum speed will not exceed more than 35 mph. The DJI Phantom 3 ha s the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Phantom 3 has four motors with four counter rotating propellers, powered by a 4480 mAh 15.2v Lithium Polymer battery. The DJI Phantom 3 will be controlled with a remote controll er with an operating frequency of 2.4GHz – 2.483GHz. The applicant will operate the UAS in li ne of sight within a closed off and predetermined area owned and/operated by the proper ty representative.

Stacy Johnson Inc. will operate the DJI Inspire 1 UAS, with a total weight of 6.47 lbs. The dimensions are 17.24 inches x 17.76 inches x 11.85 inches. Under still air the maximum speed will not exceed more than 49 mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors with four counter rotating propellers powered by a 4500 mAh 22.2v Lit hium Polymer battery. The DJI Inspire 1 will be controlled with a remote controller with an oper ating frequency of 5.725GHz – 5.825GHz. The applicant will operate the UAS in line of sight wit hin a closed off and predetermined area owned and/operated by the property representative.

Given the small size of the UASs outlined above and the controlled environment provided, the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reducti on in environmental impacts, including but not limited to reduced emissions and noise, the gra nt of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.3 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. Aircraft and Equivalent Level of Safety

The operation limitations proposed below are for an equivalent or higher level of safety. Because of these limitations, the operations of UAS by Stacy Johnson Inc. will further enhance the safety of the persons and/or property from thos e flying conventional manned aircraft.

These limitations and conditions to which the appli cant agrees to adhere to when conducting commercial operations of UAS under the FAA issued e xemption include:

1. The UAS will weigh less than 55 lbs.

2. The UAS will have a maximum operating speed of no m ore than 50mph.

3. A Visual Observer (VO) may be utilized when the Pil ot in Command (PIC) deems necessary to assist with the safe operation of the flight.

4. Flights will be operated within line of sight of th e Pilot in Command (PIC) and/or Visual Observer (VO).

5. Maximum flight time for each operational flight wil l be 30 minutes. Flights will be terminated at 30 minutes of flight time, or 25% bat tery power reserve, whichever occurs first.

6. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platfo rm from which filming is planned.

7. Minimum crew for each operation will consist of the UAS Pilot, and may include a Visual Observer (VO).

8. The UAS pilot will be a designated Pilot in Command (PIC) and at least hold a satisfactory Sport Pilot’s written exam along with a meeting and complying with the medical requirements for a Sport Pilot’s Certificate. If the PIC feels another operator to be qualified with the necessary skills to be PIC & pos sess the satisfactory Sport Pilot written exam, able to meet and comply with medical requirem ents of the Sport Pilot Certificate, that person may be designated PIC provided they hav e a minimum of 20 hours of flight time with the UAS.

9. A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ flying/filming activiti es.

10. All flights will occur under Day Visual Meteorologi cal Conditions (DVMC) only.

11. The flights will occur no closer than a 5 mile radi us of the geographic center/Airport Reference Point (ARP) of a tower con trolled or uncontrolled airport.

12. If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled a irport the respective airports will be contacted advising them of the estimated flight tim e, flight duration, elevation of flight and other pertinent information. If requested by the airport manager or ATC facility, a Flight Service Station will be contacted for approp riate filing of a Notice to Airmen (NOTAM) of authorized UAS activities, location in r elation to the closest published VHF4 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. Omnidirectional Range (VOR), radial, distance, and altitude block of the UAS activity.

13. The operator will attempt to obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting p ersons will be allowed within 50 feet of the flight operation, and the radius may be redu ced to 20 feet based upon an equivalent level of safety determination, with the exception of one person standing next to the PIC for observation of photo/video performan ce, so long as the flight is not conducted over the PIC. With the advanced permissio n of the FSDO, operations at closer range of additional persons may be approved.

14. The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the particular UAS to be operated.

15. The PIC and VO will be able to communicate by voice , radio, and/or text at all times.

16. When necessary, written and/or verbal permission an d permits will be obtained from territorial, state, county or city jurisdictions, i ncluding law enforcement, fire or other appropriate governmental agencies.

17. If the UAS loses communications with the remote con troller, the UAS will have the capability to return to a pre-determined location w ithin a designated location and land autonomously.

18. The PIC will abort a flight in case of unpredicted obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates 14 C.F.R. §91.203 (a) ( 1)
Subpart H, entitled Airworthiness Certificates, est ablishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be u tilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalen t level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S .C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, oper ational capability, and proximity to airports and populated areas of the particular UAS. In all cases , an analysis of these criteria demonstrates that the UAS operated without an airworthiness certifica te, in the restricted environment and under the conditions proposed will be at least as safe, or sa fer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certifi cate without the restrictions and conditions proposed.
The UAS to be operated hereunder is less than 55 lb s. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flamma ble liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil a ircraft, operations under this exemption will be tightly controlled and monitored by both the operat or and under the requirements and in compliance with local public safety requirements. T hese safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. P art 21, Subpart H. Lastly, application of these sam e criteria demonstrates that there is no credible thr eat to national security posed by the UAS, due to its size, speed of operation, location of operation , lack of explosive materials or flammable liquid fuels, and inability to carry a substantial externa l load.5 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. 14 C.F.R. § 45.23 (b). Marking of the Aircraft
The regulation requires:
When marks include only the Roman capital letter "N " and the registration number is displayed on limited, restricted or light-sport category aircraf t or experimental or provisionally certificated
aircraft, the operator must also display on that ai rcraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches no r more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "pr ovisional," as applicable.
Even though the UAS will have no airworthiness cert ificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible.
14 C.F.R. § 61.113 (a) and (b): Private Pilot Privi leges and Limitations: Pilot in Command.
Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilo t in command of an aircraft that is carrying passenge rs or property for compensation or hire. Stacy Johnson Inc. may achieve an equivalent level of saf ety as achieved by current regulations because the applicant’s UAS do not carry any pilots or pass engers nor property. The risks attendant to the operation of UAS is far less than the risk levels i nherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS has satisfactorily com pleted a Private Pilot Written Exam, maintains current Private Pilot Certificate #3799827 along wi th a current Third Class or higher Medical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the safe operation of the UAS.
14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.
The regulation requires that no person may operate a civil aircraft unless it is in airworthy conditio n. As there will be no airworthiness certificate issue d for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check li sts prior to each flight an equivalent level of saf ety will be provided.
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Man ual in the Aircraft.
Section 91.9 (b) (2) provides: No person may operat e a U.S.-registered civil aircraft ... (2) For whic h an Airplane or Rotorcraft Flight Manual is not requ ired by §21.5 of this chapter, unless there is available in the aircraft a current approved airpla ne or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinatio n thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be ma intained by keeping the flight manual at the ground control point where the pilot flying the UAS will h ave immediate access to it.
14 C.F.R. § 91.103: Preflight Action.
This regulation requires each pilot in command to t ake certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all act ions as stated in the FOM in Section 4 under Normal Procedures including but not limited to revi ewing weather, flight battery requirements, landing and takeoff distances and aircraft performa nce data before initiation of flight.6 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. 14 C.F.R. §91.109: Flight Instruction.
Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless th at aircraft has fully functioning dual controls. UA S and remotely piloted aircraft, by their design do n ot have fully functional dual controls. Flight control is accomplished through the use of a contro l box that communicates with the aircraft via radio communications. The FAA has approved exemptio ns for flight training without fully functional dual controls for a number of aircraft and for flig ht instruction in experimental aircraft. The equivalent level of safety provided by the fact tha t neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircr aft.
14 C.F.R. §91.119: Minimum Safe Altitudes.
Section 91.119 establishes safe altitudes for opera tion of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimum s prescribed, provided the person operating the helicopter complies with any route or altitudes pre scribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such o perations. As set forth herein, the UAS will never operate at higher than 400 AGL with the excep tion that in circumstances where the UAS is used to survey or photograph a structure whose heig ht exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. At times, however, it will be operated on private property. Buildings and people will not be exposed to operations without their pre-obtained (written or oral) consent.
The equivalent level of safety will be achieved giv en the size, weight, speed of the UAS as well as th e location where it is operated. No flight will be ta ken without the permission of the property owner or local officials. Because of the advance notice t o the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weigh ting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk ass ociated with these operations is far less than those presently presented with conventional aircraf t operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure sepa ration between these UAS operations and the operations of conventional aircraft that must compl y with Section 91.119.
14 C.F.R. §91.121 Altimeter Settings.
This regulation requires each person operating an a ircraft to maintain 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 UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitu de indicator before flight.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
Section 91.151 (a) prohibits an individual from beg inning “a flight in an airplane under VFR conditions unless (considering wind and forecast we ather conditions) 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 UAS provides approximately 25-30 minutes of powered flight. To meet the7 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. 30 minute reserve requirement in 14 CFR §91.151, UA S 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 in daylight or twilight VFR conditions is reasonable.
Applicant believes that an exemption from 14 CFR §9 1.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly control led area 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 t hat Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Addition ally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limit ing flights to 25 minutes or 25% of battery power— whichever happens first. This restriction wo uld be more than adequate to return the UAS to its planned landing zone from anywhere in its li mited operating area.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircr aft Certification and Registration
The regulation provides in pertinent part:
(a) Except as provided in § 91.715, no person may o perate a civil aircraft unless it has within it the following:
(1) An appropriate and current airworthiness certif icate. . . .
(b) No person may operate a civil aircraft unless t he airworthiness certificate required by paragraph
(a) of this section or a special flight authorizati on issued under §91.715 is displayed at the cabin o r cockpit entrance so that it is legible to passenger s or crew. The UAS fully loaded weighs no more than 55 lbs. an d is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS.
An equivalent level of safety will be achieved by k eeping these documents at the ground control
point where the pilot flying the UAS will have imme diate access to them, to the extent they are applicable to the UAS.
14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 41 7(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 betw een required inspections, except as provided in paragraph (c) of this section, have discrepancies r epaired as prescribed in part 43 of this chapter... ,” and others shall inspect or maintain the aircraft i n compliance with Part 43.
Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenan ce will be accomplished by the operator pursuant to the flight manual and operating handbook. An equ ivalent level of safety will be achieved because the UAS is very limited in size and will carry a sm all payload and operate only in restricted areas fo r a limited period of time. If mechanical issues aris e the UAS can land immediately and will be operating from no higher than 400 feet AGL. The ope rator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance8 | P a g e o f 8

Section 333 Exemption Request, Stacy Johnson Inc. performed. Moreover, the operator is the person mos t familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.
An equivalent level of safety will be achieved beca use maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working ord er prior to initiating flight and perform required maintenance needed.

Additional Information
The applicant, Travis Johnson, has been involved in operating remote controlled aircraft for many years. Also the primary pilot, Travis Johnson hol ds a Private Pilot Certificate #3799827 for Single Engine Land, as well as holds a current third class medical.
Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the request ed exemptions allowing the commercial operation of the applicant’s UAS platforms.

Sincerely,

Travis Johnson
Stacy Johnson Inc.