JimmyC LTD

176 Trails End Ranch
Cedar Creek, TEXAS 78612 JimmyClark@USA.com

512

- 417

- 4677 cell phone

June 1 , 2015

US D epartment Of Transportation

Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or M adam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, JimmyC LTD , owner and operator of Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that JimmyC LTD may operate UASs commercially in airspace regulated by the FAA., as long as suc h operations are conducted with in and under the conditions outlined herein or as maybe established by the FAA as required by Section 333.
Jimmy C LTD is co

- owned by James (Jimmy) Clark and Michelle Clark . Both are licensed insurance adjusters

. Jimmy Clark is on the board of directors for the National Association of Catastrophe Adjusters. Both have Texas Drivers licenses. All operations will be performed with the public’s safety and right to privacy safe guarded at all times. As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for

c ommercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for safe operation of such aircraft systems in national airspace systems.” Section 333(c) , o f the Reform Act.
JimmyC LTD UAS is The DJI Phantom 3 Professional Quad Copter rotorcraft weighing less than 55 pounds including payload. They operate at a speed le ss than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The DJI Phantom 3 Professional Quad Copter has an auto return to launch point when battery power is under 25%. The UAS will operate within the l ine ofsight with in a protected flight area as described be low and at 200 feet AGL or less with

an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public no r the environment.
JimmyC LTD respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b) , 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).
JimmyC LTD submits this application in accordance with the Reform Act ,112 P.L. 95 331

- 334, seeking relief from any currently applicable FAR’S operating to prevent JimmyC LTD future commercial use of small UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace system as it is in the public’s interest to do

so. JimmyC LTD UASs meet the definition of “small unmanned aircraft” as defined in Section 331 and therefor the integration of these UASs are expressly contemplated by the Reform Act. JimmyC LTD would like to operate its light weight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary of Transportation to consider whether certain

un manned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following: The UASs size, speed, weight and operational capability Operation of the UASs in close proximity to airports and po pulated areas Operation of the UASs within visual line of sight of the operator Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace System, the secretary shall establish requirements for the safe operation in national airspace.
JimmyC LTD are rotorcraft weighing less than 55 lbs. and the y operate at speeds less than 50 knots and have the capability to operate in the vertical and horizontal plane simultaneously. The UASs will operate onl y within the lin e of sight of the operator with in a protected flight area and at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public.The very small nature of these UASs combined with the safe guards presented below,

will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence imme diately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management proces s. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verse s traditional aircraft as well a s th e economic impact of greatly reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay. The following will be considered as binding limitation on operations of JimmyC LTD , 1. Flights will only occur in the day time hours, 2. Flights will be operated in th e line of sight of the operator ( PIC ) and Observer, (VSO) 3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by manufacturers recommendations, 4. The UASs will weigh less that 55 lbs., 5. Flights will be operated at 200 feet AGL or less. 6. Crew w ill be at a minimum of operator (PIC) and an observer and/or came ra operator (VSO) , 7. Operator and crew will remain in contact during the flight operation, 8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area, 9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of violating anyone’s privacy. 10. All required FAA clearances, will be obtained and distances from airports strictly observed. 11. All UASs will have the capability to return automatically to the operator in a safe manner with the auto return function checked and working. 12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned to operate the UASs at a safe distance from the main fishing boat. 13. Flights will only operate in VFR conditions. 14. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining. 15. Flight team will communicate by voice and the use of two

- way radio if the area is too big to hear voice fr om all team members. 16. UASs will be used to photograph and video structures to determine extent of damage from various natural disasters and catastrophes. 17. When operating over or near water the UASs will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table.14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for JimmyC LTD UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is a uthorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of w eight, size, speed, maneuverability and proximity to areas such as airports and dense populations. JimmyC LTD meets or exceeds each of these elements
As of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” COA for flights at or under 200 AGL to any UASs operator with a section 333 exemption. 14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of safety wi ll be achieved by maintaining such certifications and registrations at JimmyC LTD operations center. 14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form conte mplated by FAR’s this regulation is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. A s there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at JimmyC LTD operations center. The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be o perated at lower altitudes in certain conditions. JimmyC LTD will only operate its UASs at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential fo r these operations. Flights will only be over private property that the owner has consented and all persons with in this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weig hing far more than 50 lbs. , operating below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public.Approval of these 333 Exemption s allowing commercial operations of small UASs in the

service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general. With the use of sma ll UASs of 55 lbs. or less, battery operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by JimmyC LTD will give the people another avenue t o express themselves and to have a video record to share with family and friends forever.
Granting JimmyC LTD the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the m asses. JimmyC LTD respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by JimmyC LTD pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely

Jimmy Clark
JimmyC LTD

176 Trails End Ranch , Cedar Creek, TEXAS 78612 JimmyClark@USA.com