JRS Concepts Aerial Video and Photography 

Owners: Jeffrey R. Snyder 

12113 Still Meadow Dr, Clermont, FL 34711 

407-409-0100 

U.S. Department of Transportation Federal Aviation Administration 

October 25, 2015 

Re: Exemption request pursuant to Section 333 of the 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 91.109; 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) 

Dear Sir or Madam, 

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 

2012 (the “Reform Act”) and 14 CFR Part 11, Jeffrey Snyder, owner of JRS Concepts which owns and 

operates an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal 

Aviation Regulations (FARs) to allow commercial operation of its UAS, 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. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner: 

- Aerial photography and/or video for public and/or private use including real estate, architecture, 

surveying, engineering and other related professional activities. 

- Aerial video and/or photography for public and/or private use including television, public events, 

private events, cinematography and news gathering. 

- Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

- Aerial inspection/photography or residential/commercial utility infrastructure including but not limited 

to electrical power lines, wind turbines and cell towers. 

- Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of emergency or natural disaster only when the local authorities or government has requested it 

by contract or donation. 

JRS Concepts operates a DJI Phantom 3 (4) blade quad copter weighing 6 pounds, 7.5 ounces. The UAS 

has a maximum airspeed of 40 miles per hour and uses a remote controller operating on frequency 

range of 2.400-2.483 GHZ. The Phantom 3 is equipped with built-in ground support technology that 

allows it to fly utilizing global positioning system (GPS) for stability, tracking, safe flight mode and a 

return-to-home feature in the event of loss of remote control signal or critical low battery. All flights 
start with a pre-flight safety check and all flight data are recorded. The Phantom 3 is equipped with a 

gimbal mounted camera that sends a live video signal to the controller allowing the person in control 

(PIC) to monitor real-time video. Flight data, speed height, distance, battery level and general aircraft 

conditions are also displayed during operation. The Phantom 3 battery has a flight time of 15-20 minutes 

and is, therefore, always returned to original takeoff point and always flown utilizing visual line of sight 

(VLOS). I have been training on the DJI Phantom for seven months and have become proficient in all 

aspects of flight and safety of this UAS. 

My request for exemption would allow us to offer unique aerial photography and videography services 

to my clientele. 

UAS Safety Operating Parameters I

will abide by the following additional operating conditions under this exemption, which ensures a level 

of safety during UAS flight including operating the UAS below 400 feet and within a radius of 1,000 feet 

from PIC always maintaining VLOS and obtaining permission from the owner/controller of any vessels, 

vehicles and structures when operations may be conducted closer than 500 feet to any such vessels, 

vehicles or structures. 

I will conduct a safety assessment of the risk of operating closer to those objects and determine that it 

does not present an undue hazard. 

Other safety operating parameters include:

- Operate the UAS for 15-20 minutes per flight. 

- Land UAS prior to the manufacturers recommended minimum level of battery power. 

- Operate the UAS during daylight hours only within VLOS. 

- Utilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands if communication 

with the PIC is lost or battery becomes critically low. 

- Always obtain all necessary permissions prior to operation. 

- Have procedures in place to abort flights in the event of safety breaches or potential danger. 

- Review weather reports prior to flight and never operate UAS in unsafe conditions, high wind, low 

clouds or conditions that hinder visibility. 

- Only operate in safe environments that are strictly controlled, are away from power lines, elevated 

lights, airports and densely populated areas. 

- Conduct extensive preflight inspections and protocols during which safety carries primary importance. 

3 The PIC will also have a minimum of five hours logged on this craft and 10 hours minimum flying UAS 

quad copters under varying conditions and environments and will follow all safety protocol of JRS 

Concepts as well as guidelines of 14 CFR §61.51(b) having the ability to safely operate the UAS in a 

manner consistent with the operating documents, including evasive and emergency maneuvers and 

maintaining appropriate distances from people. Specific Exemptions Requested Given the size, weight, 

speed and limited operating area associated with the UAS, I feel an exemption from 14 CFR Part 21, 
Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a) and (b) (certifications required), subject to 

certain conditions and limitations, is warranted and meets the requirements for an equivalent level of 

safety under 14 CFR Part 11 and Section 333 of P.L. 112-95 (Section 333). 

I request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is 

difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the 

word “Experimental” on its fuselage as required by 14 CFR 45.29(f) so that anyone will see the markings. 

I request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in 

Command. The applicant’s UAS do not carry any pilots or passengers nor property. The Risks attendant 

to the operation of the UAS is far less than the risk levels inherent in the commercial activities outlined 

in 14 CFR §61. The operation and limitations in the flight operation manual (FOM) will equate to the safe 

operations of the UAS. We request an exemption from 14 CFR 91.7(a) which prohibits the operation of 

an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our 

operation, this regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14 CFR 

91.407(a)(1), 14 CFR 91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections since they only 

apply to aircraft with an airworthiness certificate. However, as a safety precaution, we will perform a 

preflight inspection of the UAS before each flight as outlined in the attached operating documents. I

request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft, however, 

since there are no pilots or passengers on board the aircraft, and given its size, this regulation is 

inapplicable. 

I believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the 

UAS ground station. We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated 

Instrument Flight and Certain Flight Tests. The regulation states that “no person may operate a civil 

aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

Although the DJI Inspire 1 is capable of dual/linked controls, we will be operating with a single remote 

controller. 

4 I request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation of civil 

aircraft, but allows helicopters to be operated at lower altitudes in certain conditions. We will not 

operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in 

safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or 

below those in relation to minimum safe altitudes.” Given the size, weight and maneuverability and 

speed of the UAS, an equivalent or higher level of safety will be achieved. We request an exemption 

from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the UAS utilizes electronic GPS with a 

barometric sensor. We request an exemption from 14 CFR 91.151(a) Fuel Requirements for Flight in 

visual flight rules (VFR) conditions. The UAS is 100 percent electric and two low battery alerts are issued 

– per the operating documents, the UAS will be landed at the first alert. Also, our flights will last only 15-

20 minutes each and the UAS has an automated function, which results in immediate landing when a 

low battery is detected. The PIC will not begin a flight unless, considering wind an forecast weather 

conditions, there is enough power to fly to the first point of intended landing and, assuming normal 

cruising speed, land the UAS with 30 percent battery power remaining. 

Summary 
I will comply with all of the following conditions and limitations should this grant of exemption be 

provided: 

1. Operations will be limited to the following aircraft described in the operating documents which is a 

quad-rotor aircraft weighing less than seven pounds: DJI Inspire 1 Aircraft System. 

2. The UAS will not be flown at an indicated airspeed exceeding 40 mph. 

3. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by the procedures 

specified in the operating documents. 

4. The UAS will be operated within VLOS of the PIC at all times. 

5. All operations may utilize a visual observer (VO. The UAS will be operated within the VLOS of the VO 

at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated 

before the flight and will not transfer his or her designation for the duration of the flight. The PIC will 

ensure that the VO can perform the functions prescribed in the operating documents. 

6. The operating documents will be accessible during the UAS operations and made available to the 

Administrator upon request. Any revisions to the operating documents will be presented to the 

Administrator upon request. 

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated 

until the necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The Ground Control Station will be included in the preflight inspection. All maintenance and 

alterations will be properly documents in the aircraft records. 

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts 

the functional test flight will make an entry into the aircraft records. 5 

9. The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. 

inoperable components, items or equipment not already covered in the relevant sections of the 

operating documents. 

10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, 

inspection and life limit requirements. 

11. We will carry out maintenance, inspections and record-keeping requirements, in accordance with 

the operating documents. Maintenance, inspection and alterations will be noted in the aircraft records, 

including total flight hours, description of work accomplished and the signature of the authorized person 

returning the UAS to service. 

12. Each UAS operated will comply with all manufacturer Safety Bulletins. 

13. An authorized person will make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which 

the PIC is rated on. 
15. Prior to operations conducted for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot operating the 

make and model of the UAS to be used in operations. 

16. The PIC will not operate the UAS for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated and 

logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner 

consistent with the operating documents, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

17. UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1 All operations will 

be conducted under visual meteorological conditions (VMC). 

18. The UAS will not operate within five nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart. 

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than three statute miles from the PIC. 

20. If a UAS loses communications or loses its GPS signal, it will return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents. 

21. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents. 

22. The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is 

enough power to fly at a normal cruising speed to the intended landing point and land the UAS with 30 

percent battery power remaining. 

23. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UAS will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to the PIC at the 

Ground Control Station of the UAS at any time the UAS is operating. These documents will be made 

available to the Administrator or any law enforcement official upon request. 6 

25. The UAS will remain clear and yield the right of way to all manned aviation operations and activities 

at all times. 

26. The UAS will not be operated by the PIC from any moving device or vehicle. 

27. The UAS will not be operated over congested or densely populated areas unless contracted out to do 

events. 

28. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles and structures unless: a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UAS and/or debris in the event of an accident. We will ensure that 
nonparticipating persons remain under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the UAS, flight operations must cease 

immediately. b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an undue 

hazard. c. Operations near to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per 14 CFR 91.119(a). 29. All operations will be conducted over private 

or controlled-access property with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized representative will be obtained for 

each flight to be conducted. 30. Any incident, accident or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable certificate of authorization 

(COA) will be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be 

reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

website: www.ntsb.gov. 

On behalf of B2 Aerial Video and Photography, I would like to thank you for your consideration in 

granting this exemption.

Signed, Jeffrey Snyder

JRS Concepts