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5440 South Lakeshore Drive, Suite 102, Tempe, Arizona, 85283

January 10, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

REF: DOT/FAA Petition for Exemption

Dear Sir or Madam:

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

("Reform Act") and 14 CFR Part 11, Just 1 UAV, ("Petitioner"), for the purpose of 

creating a UAV educational and pilot training program, hereby applies for an exemption 

from Federal Aviation Regulations ("FARs") identified below, to allow commercial 

operation of small unmanned aerial systems (“sUAS") so long as such operations are 

conducted within an under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.1

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

exemption, protocols defined in the following proprietary and confidential documents:

Exhibit A – Flight and Maintenance Information Manual 

Exhibit B - Standard Operating Procedures

Exhibit C – Pilots Operating Handbook

Petitioner submits Exhibits A-C, its Manuals, as a Confidential documents under 

14 CFR § 11.35(b), as the Manuals contain confidential commercial and proprietary 

information that the Petitioner has not and will not share with others. The Manuals 

contain operating conditions and procedures that are not available to the public and are

protected from release under the Freedom of information Act 5 U.S.C. § 552 et.seq. Just 

1 UAV manuals will be hand delivered with appropriate reference to content, contained 

in this document. 
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For your convenience, this Petition is organized as follows:

1. Description of Petitioner

2. Description of Proposed Operation

3. Relevant Statutory Authority

4. Just 1 UAV Proposed UAS Operations Meet the Requirements of Section 333 of 

the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

 Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth 

in the Just 1 UAV Ops/Flight Manual

5. Regulations from which the exemption isrequested: 

14C.F.R. Part 21

14C.F.R. 45.23(b)

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

14C.F.R. 91.7 (a)

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

14C.F.R. 91.103

14 C.F.R. 91.109

14C.F.R. 91.119

14C.F.R. 91.121

14C.F.R. 91.151 (a)

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

14C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14C.F.R. 409 (a) (2)

14C.F.R. 417 (a) & (b)

6. Public Interest

7. Privacy

8. Conclusion
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1.		Petitioner's Description

The name and address of the applicant is:

Just 1 UAV

5440 South Lakeshore Drive, Suite 102

 Tempe, Arizona, 85283

Business Partners

Justin Harvey

jharvey@just1uav.com

480-359-9795

Gary North

gnorth@just1uav.com

916-749-9120

Document prepared by Gary North

The partners of Just 1 UAV have combined aviation experience and successful 

business development expertise. Experience includes an FAA licensed Airline Transport 

Pilot, holding a current First Class Medial Certificate. Having over 30 years of extensive

Federal Aviation Regulations knowledge and flight experience within the National 

Airspace System. Each partner has experience in successful business development and 

business ownership.

2.		Description	of	Proposed	Operations	

Just 1 UAV intends to establish a UAS Flight Instruction Program. This program 

will introduce students to the elements of UAS operation from a commercial and 

noncommercial perspective and how these operations must fit into the National Air Space 

System "NAS"). All UAS training and instruction activities will occur under tightly 

controlled conditions on property that is more than five miles from any airport. Upon 

completion of Just 1 UAV’s Program, students will be provided with a Certificate of 

Completion. This "Certificate of Completion" does not permit the student to engage in 

commercial UAS activities that are not in accordance with the FARs, but rather, is 

intended to be an acknowledgement that the student has successfully demonstrated a 

complete understanding of UAS operations from a NAS perspective. This exemption 

request is an opportunity to not only prepare UAS pilots for aviation and aerospace 

careers in the UAS industry, but also to collaborate with the FAA to study and address 

training and qualification needs specific to the UAS industry. Furthermore, Just 1 UAV

will coordinate and continuously update its curriculum to take advantage of new guidance 
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and regulations proposed and implemented by the FAA. Just 1 UAV is committed to 

ensuring that its instruction program not only is compliant, but always reflects best 

practices in the UAS industry.

3.		Relevant	Statutory	Authority

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

Reform Act) and 14 C.F.R. Part 11, Just 1 UAV, developer and operator of Small

Unmanned Aircraft Systems (“sUASs”) for the purpose of creating a UAS educational

and pilot training program, 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.

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 3) controlled as to access and

4) would provide safety enhancements to the already safe educational and pilot training 

programs presently using conventional aircraft. Approval of this exemption would

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

Administrator’s) responsibilities to “...establish requirements for the safe operation of

such aircraft systems in the national airspace system.” Section 333(c) of the Reform 

Act.

4.		Qualification	for	Approval	Under	Section	333	of	the	Reform	Act

1. The UAS weighs 55 pounds or less.

2. Flights will be operated within the visual-line-of sight of a pilot and an observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit. 

 

4. Flights will be operated at an altitude of no more than 400 feet AGL and will not 

be conducted within navigable controlled airspace without prior written 

authorization from the FAA.
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5. Flights will be operated at a lateral distance of at least 500 feet from any persons, 

inhabited structures, vehicles or vessels that are not involved in the operation

unless permission has been received and appropriate waivers have been signed 

by the persons or property owners in advance.

6. Flights will be limited to a speed of 35 mph and vertical ascent will be limited to 

15 mph.

7. The UAS will be operated and maintained in accordance with the requirements of 

the Manufacturer's Manuals and any manufacturer Safety Bulletins.

8. Prior to the operation, the flights will be fully preplanned and briefed, including 

possible contingencies and emergency procedures.

9. If required, Just 1 UAV will file FAA Form 7711-1, or its equivalent with the 

appropriate Flight Standards District Office and/or air traffic control ("ATC") 

facility between 72 and 48 hours before the flight.

10. All required permissions and permits will be obtained from territorial, state, 

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

appropriate governmental agencies.

11. If the UAS loses communication with the pilot, it will have the capability to 

return to the sterile area home launch location or a pre-determined safe abort 

location.

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

communication between the pilot and the observer.

13. The UAS will have the capability to abort flight in the case of unpredicted 

obstacles or emergencies.

14. UAS pilot will be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical. The observer will hold at least a third class 

medical. 

15. All UAS operations will occur in daylight, Visual Flight Recognition ("VFR") 

conditions. IFR flights are prohibited and no flights will occur at night, or in 

adverse weather conditions.

16. The UAS will be controlled by the Phantom 2 2.4GHz Remote Control System 

and the radio frequency spectrum used for operation and control of the UA shall 
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comply with the Federal Communications Commission ("FCC") or other 

appropriate government oversight agency requirements.

5.		Petitioner	Requests	Exemption	From	the	Following	Regulations

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(l)

Subpart H, entitled Airworthiness Certificates, establishes 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 

utilized by the Just 1 UAV, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent 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, operational 

capability, and proximity to airports and populated areas of the particular UAS. Our 

small UAS will be operated at low speed in a controlled environment, at least five miles 

from an airport and more than three miles from any city or densely populated area. An 

analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating 

with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, 

and operates exclusively within a secured area as set out in the Manual. Like other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by the 

operator, pursuant to the Manual's requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of 

operation as is currently done on active construction sites. The FAA will have advance 

notice of all operations.

These safety enhancements, which already apply to civil aircraft operated in 

connection with flight training, 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. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat 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 ability to carry an external load no greater than two lbs.
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14 C.F.R. 45.23(b): Marking of the Aircraft

This regulation requires certain experimental, provisionally certificated aircraft, 

or light- sport category aircraft to be marked with letters between 2 inches and 6 inches 

high "limited," "restricted," "light-sport," "experimental," or "provisional," near each 

entrance to a cabin, cockpit, or pilot station.

Even though the UAS will have no airworthiness certificate, 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 sUAS, two-inch 

lettering will be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer and others working with 

the sUAS will see the identification of the UAS as "Experimental." The FAA has issued 

the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and 

10167A.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the pilot 

operating the aircraft to have completed a UAS flight training course before flying a 

UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is 

remotely controlled with no living thing or cargo on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set

forth in the Manual. The risks associated with the operation of the sUAS are so 

diminished from the level of risk associated with commercial operations contemplated 

by Part 61 when drafted, that allowing operations of the sUAS as requested with a pilot 

who has met the minimum requirements stated in the Manual exceeds the present level 

of safety achieved by 14 C.F.R. §61.113 (a) & (b).

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 condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 
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airworthiness. Given the size of the aircraft and the requirements contained in the 

Manual for maintenance and use of safety checklists prior to each flight, an equivalent 

level of safety will be provided.

14 CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard

requirements

The sUAS, 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 maintained by keeping the flight manual 

at the ground control point where the pilot flying the sUAS will have immediate access 

to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 

10700.

14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight 

to ensure the safety of flight. An exemption is needed from this requirement, as the pilot 

will take separate preflight actions, including checking for weather conditions, checking 

flight battery requirements, checking takeoff and landing distances, and all other actions 

in the Preflight Checklist in the Manual. These actions will provide an equivalent level 

of safety.

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 that aircraft has fully 

functioning dual controls.

By design, sUASs and remotely piloted aircraft do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has previously 

approved exemptions for aircraft without fully functional dual controls. The equivalent 

level of safety provided by the fact that neither a pilot nor passengers will be carried in 

the aircraft, the ability to control the sUAS via radio signals from the controller, and by 
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the size and speed of the aircraft.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. This exemption is for a multirotor craft that flies 

similarly to a helicopter, with vertical take off and vertical landing, which will typically 

operate at altitudes of 200 AGL, so an exemption, may be needed to allow such 

operations. The UAS will never operate at altitude higher than 400 AGL and will be in a 

restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre-obtained consent. See Manual for detailed procedures.

The equivalent level of safety will be achieved given the size, weight, speed of 

the UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and any onsite personnel as outlined in the Manual, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighting far more than the maximum 55 lbs. proposed herein 

and carrying flammable fuel, any risk associated with our operations is far less than 

those presently presented with helicopters and other conventional aircraft operating at or 

below 500 AGL in the flight training industry. In addition, the low-altitude operations 

of the sUAS will ensure separation between these small- UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. 91.121: Altimeter Settings

This regulation requires each person operating an aircraft 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 sUAS 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 

Manual and Safety Check list, confirming the altitude of the launch site shown on the 

GPS altitude indicator before flight.
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14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR 

conditions. Our UAS is limited to operations in sterile and controlled environments as 

outlined in the Manual, and has a limited range and flight time which require an 

exemption from 14 CFR 91.151(a).

The battery powering the sUAS provides approximately 35 minutes of powered 

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights 

would be limited to approximately 5 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 night VFR conditions is 

reasonable.

Just 1 UAV believes that an exemption from 14 CFR §91.15l(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small 

UAS, in a tightly controlled 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 that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights 

to 10 minutes would greatly reduce the utility for which the exemption will be granted.

An equivalent level of safety can be achieved by limiting flights to 30 minutes, 

or enough battery reserve to ensure that the sUAS lands at the ground station with at 

least 25% of battery power (as determined by the onboard monitoring system and the 

pilot), whichever happens first. This restriction would be more than adequate to return 

the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673, and 10808.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The regulation provides in part:

(a) Except as provided in § 91.715, no person may operate a civil 

aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .
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(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55lbs and is operated without an 

onboard pilot. Therefore there is no ability or place to carry certification and registration 

documents or to display them on the sUAS.

An industry enhances safety while reducing risk. Manned aircraft monitoring 

and surveying creates a greater risk because the craft are much larger, have combustible 

fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 55 lbs. 

and powered by batteries eliminates virtually all of that risk given the reduced mass and 

lack of combustible fuel carried on board. 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 small UASs, weighting less than 55 lbs., conducted in the 

strict conditions outlined above, will provide an equivalent level of safety supporting the 

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

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a result, 

are far safer than conventional operations conducted with turbine helicopters operating 

in close proximity to the ground and people.

An equivalent level of safety will be achieved by keeping these documents at 

the ground flight control point where the pilot flying the sUAS will have immediate 

access to them, to the extent they are applicable to the sUAS. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions 

includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR 91.405 (a); 407 (a)(l); 409 (a)(2); 417 (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 between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter ...," and others shall inspect or maintain 

the aircraft in 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 Just 1 UAV. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook as 
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referenced in the Manual. An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. As provided in 

the Manual, the operator will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, 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.

6.		Public	Interest

The public as a whole will benefit from a collaborative relationship between the 

FAA and Just 1 UAV that focuses on the safe promotion of best practices for training and 

qualification needs specific to the UAS industry. The proposed UAS operations in this 

Petition for Exemption will also improve safety and reduce risk by alleviating the public's 

exposure to danger associated with student flight training utilizing full size fixed-wing 

aircraft and rotorcraft. The UASs Petitioner intends to use are battery powered and create 

no emissions. Moreover, in the unlikely event that one of Petitioner's UASs crash, there is 

no fuel to ignite and explode. Any accident involving Petitioner's lightweight UASs will 

present significantly less danger to the pilot and other individuals on the ground than one 

involving a full size helicopter.

7.		Privacy

All Just 1 UAV operations shall be conducted in accordance with applicable 

federal, state, or local laws regarding privacy. Just 1 UAV will not conduct flight 

operations over property that it does not own or control without the prior consent and 

knowledge of the property owner. Moreover, Just 1 UAV will not capture or use images 

from neighboring properties within the vicinity of UAS flight operations.

8.		Conclusion

Just 1 UAV’s Petition for Exemption satisfies the criteria articulated in Section

333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity 

to airports and populated areas, operation within visual line-of-sight and national 

security. The proposed UAS operations will benefit the public as a whole by fostering a 

collaborative relationship between the FAA and Just 1 UAV which focuses on UAS 
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training, qualifications, and processes involving the safe and efficient operation of UAS 

in the NAS.

If additional information is required, or if you have any questions, please contact Just 1 

UAV Business Partner, Gary North at 916-749-9120 or gnorth@just1uav.com

Sincerely,

Gary North

 Just 1 UAV

Business Partner