JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

May 21, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, D.C. 20590 

Subject Matter: 

Exemption Request; Section 333 of the FAA Modernization & Reform Act and Part 11 of the 

Federal Aviation Regulations from; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.119 (c); 91.121; 91.151 

(a)(1); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

To whom it may concern: 

In accordance with Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012, JOSA Industries, LLC respectfully petitions the Secretary of Transportation 

and the Federal Aviation Administration for an exemption of the above mentioned Federal Aviation 

Regulations, for the purpose of business operations of small-unmanned aerial systems (UAS). 

Furthermore, the details of this petition will describe in a more detail the manner in which JOSA 

Industries, LLC is seeking the exemption request. 

A. Summary of the Petition 

JOSA Industries, LLC formally requests exemption from the following Federal Aviation Regulations 

(FARs) that are found under Title 14 of the Code of Federal Regulations (CFR): 14 CFR 61.113 (a) 

& (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a)(1); 91.405 (a); 91.407(a) (1 ); 91.409 (a) (2); 91.417 

(a) & (b). JOSA Industries, LLC seeks approval and exemption from the above listed CFRs to 

operate the DJI Phantom 2 Vision+ for the purpose of providing high resolution aerial imagery for 

compensation/hire to companies and individuals. The operation of the DJI Phantom 2 Vision+ by 

JOSA Industries, LLC will abide by all manufacturer approved operation limitations, Advisory 

Circular 91-57, other limitations stated in this document, and all recommendations by the FAA and 

other government agencies. 

B. Petition for Exemption 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR 

Part 11, JOSA Industries, LLC, operator of small unmanned aerial systems, conducting aerial 

photography/ aerial inspection for business purposes over the following areas; (1) over land, 

waterways, and oceans; (2) operation over and/or in non-restricted National Parks, National 

Forests, and non-navigable airspace using nonintrusive recording devices; and (3) operation in 

otherwise unrestricted U.S. States and Territories. All proposed operations would be conducted 

under controlled conditions in airspace that is: (1) limited, (2) predetermined, and (3) access 

controlled. 

Aviation using commercial grade photography/ remote sensing imaging devices, is formally 

requesting for exemption to the above mentioned Federal Aviation Regulations for commercial 

operation of its unmanned aerial system in accordance with limitations described within this 

document or as established by the Federal Aviation Administration required by Section 333. 

JOSA Industries, LLC is requesting exemption that would allow the operation of their UAS for aerial 

photography and inspection limited, predetermined and access controlled airspace. The use of 

aerial photography by small unmanned aerial systems/vehicles will improve aviation safety by 

reducing the hazard of low flying manned aerial photography in traditional small aircraft as well as 

increase the capacity of National Airspace System by allowing aerial photography to be conducted 

without utilization of limited airport/airspace resources. 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

If the exemption is approved, JOSA Industries, LLC would enhance safety and meet the 

requirement of the Secretary of Transportations responsibilities described in Section 333(c) of the 

FAA Modernization and Reform Act of 2012. 

C. Name and Address of the Petitioner 

JOSA Industries, LLC

Attn: Jorge Sosa

Phone: 337-962-7611

Email: aerials@josaindustries.com

Address: 163 Rue du Belier Apt 104 Lafayette LA 70506

D. Petitioner Petitions for Exemption of the Following Regulations 

 14 CFR 91.405 (a)

 14 C.F.R. 91.119 (c)

 14 CFR 407 (a) (1)

 14 CFR 61.113 (a) & (b)

 14 C.F.R. 91.121

 14 CFR 409 (a) (2)

 14 C.F.R. 91.7 (a)

 14 CFR 91.151 (a)

 14 CFR 417 (a) & (b)

JOSA Industries, LLC operates unmanned aerial systems that are multi-rotorcraft equipped with 

precision flight and stable hovering, radar positioning, return home, onscreen real-time flight 

parameters, on-board NAZA computer stabilization controller and GPS, the UAS will weigh less 

than 55 lbs. or less and most typically include camera/payload. Normal UAS operations are 

conducted at speeds well below 100 KIAS utilizing the functions of rotorcraft; it has the ability to 

hover. JOSA Industries, LLC will only operate in line of sight and will operate in airspace described 

in this document or as specified by the FAA. All UAS operations will be vetted by JOSA Industries, 

LLC operator/ qualified personnel to confirm that there are no hazards to users of the National 

Airspace System or innocent bystanders or general public. 

E. How the request benefits the public as a whole 

JOSA Industries, LLC believes that the safe, limited, and controlled operations of its unmanned 

aerial systems (UAS) described in this document will meet and exceed the strict safety and 

security standards of the FAA and/or national security issues. Moreover, JOSA Industries, LLC

believes that the utilization of UAS described in this document will benefit the public as a whole in 

five ways; 

1) JOSA Industries, LLC continued commitment to keep the highest level of safety during its UAS 

operations and set industry standards for safe UAS operations for future operators

2) Reduce the risk to life and property

3) Reducing National Airspace System (NAS) congestion through utilization of small (less than 

55lbs.) UAS instead of conventional aircraft during aerial photography/ inspection operations. 

4) Reducing noise and air pollution created by conventional fixed wing/rotor wing aircraft, and 

5) Increase aerial photography/inspection industry economic growth. 

JOSA Industries, LLC utilization of UAS (DJI Phantom 2 Vision +) for the purposes of aerial 

photography/ inspection will be a leader in using and setting industry best practices for safe UAS 

operations in the NAS. Additionally, utilization of UAS will reduce the risk to life and property by 

limiting the use of conventional aircraft such as fixed-wing and rotor-wing aircraft with weights in 

excess of 1000lbs and carrying hundreds of gallons of flammable fuels flying at low altitudes. The 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

UAS described in this document is less than 55 lbs. carries a small battery as a power source and 

can effectively do the same job as conventional aircraft with reduced likelihood and severity of risk. 

Moreover, the utilization of UAS will reduce UAS congestion by reduced usage of conventional 

aircraft requiring access to UAS. An additional benefit will be reductions in noise and air pollution 

from conventional aircraft by utilization of small UAS using batteries as the main source of power 

instead of fossil fuels used by conventional aircraft. Finally, the utilization of UAS for aerial 

photography/ inspection will allow for positive economic growth in the aerial photography/

inspection industry, as well as peripheral industries that rely on aerial photography/ inspection, i.e., 

building construction, real estate, and inspection services.

F. Limitations and Conditions 

JOSA Industries, LLC will describe in this document the proposed limitations and conditions of its 

UAS operations. These operations and conditions are intended to provide safe operations up and 

beyond current regulatory framework that apply to similar operations. Moreover, the limitations and 

conditions described below JOSA Industries, LLC will accept to be held accountable when 

conducting business/commercial UAS operations from the FAA issued exemption: 

1. The UAS maximum take-off weight (MTOW) will be less than 55 lbs. JOSA Industries, LLC: 

I. DJI Phantom DJI Phantom 2 Vision +

II. Other DJI manufactured UAS 

2. The pilot in command (PIC) of the UAS will possess at least a JOSA Industries, LLC training 

session, which includes and not limited to ground station, UAS operation, emergency procedure, 

maintenance tracking and pre-flight checklist.

3. Operator PIC qualifications criteria and demonstrated ability to operate UAS 

I. Completed initial and or recurrent training prior to UAS operations. Follow training guidance in 

accordance with manufacturer. 

II. All training will be documented and recorded 

III. PIC will demonstrate evasive and emergency maneuvers 

IV. Maintaining appropriate distances from persons, vessels, vehicles, and structures as per FAA 

regulations 

V. PIC qualification flight hours will be logged in a manner consistent with 14 CFR 61.51. 

4. The Visual Observer (VO) qualifications and demonstrated ability 

I. Completed initial training prior to UAS operations 

II. All training will be documented and recorded 

5. Training operations for PIC and VO (training, proficiency, and experience building) will only be 

conducted during dedicated training sessions. During training, proficiency, and experience building 

flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC 

will operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR 

91.119. 

6. All UAS operations will remain below 400 feet above ground level. UAS operations will utilize no 

less than two qualified people. The first person will be operator of the UAS flight controls “pilot in 

command” (PIC). The second person, visual observer (VO), will be used to assisting the PIC with 

seeing and avoiding other air traffic and other ground based obstacles/obstructions and will not 

permitted to operate the UAS camera or other instruments. 

7. The UAS will be operated within the line of sight (LOS) of the PIC at all times. The PIC will be 

able to use human vision unaided by any device other than corrective lenses. The PIC will have an 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

FAA-issued airman medial certificate. First person view (FPV) will not be used by the PIC or visual 

observer (VO). The UAS will not be operated by the PIC from any moving device or vehicle. 

UAS operations will not be permitted unless there is enough power to fly to the UAS to the 

intended landing point at a normal cruise speed and land the UAS with 30% battery power 

remaining. 

9. The PIC will be designated before flight and will not transfer controls for the duration of flight. 

The PIC will ensure that the VO can perform all of their essential functions. All operations will 

utilize a VO. The VO will not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to 

operate the camera or other instruments. The UAS will remain clear and yield the right of way to all 

manned aviation operations at all times 

10. Pre-flight operations will include the use of a Preflight Checklist as stated by DJI. Additionally, 

prior to each flight the PIC will conduct and preflight inspection of the UAS and Ground Control 

Station to ensure it’s in a condition for safe flight. All discrepancies found during the preflight 

inspection will prohibit flight operations until the necessary maintenance has been performed and 

the UAS is found to be in a condition for safe flight. All discrepancies, maintenance, alterations will 

be properly documented in the aircraft records. 

11. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics there will be a functional flight test by the PIC and the PIC will make and entry in the 

aircraft records. All maintenance will follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limited requirements. 

12. Each UAS will comply with all manufacturers Safety Bulletins. 

13. The operator will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the manufacturers operating documents. All Maintenance, inspection, alterations, 

and status of replacement/overhaul component parts must be noted in the aircraft records, 

including total time in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

14. Authorized persons will make entry in the aircraft record of corrective action taken against 

discrepancies discovered between inspections. 

15. The UAS will not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as required 

by the operator’s Certificate of Waiver. All UAS operations will not be operated less than 500 feet 

below or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC. Controlled airspace will be utilized with prior permission from Air Traffic Control or 

the Federal Aviation Administration. At all times, in all situations, without exception, the PIC will 

maintain visual line of sight with the UAS. 

16. The UAS will not be operated over congested or densely populated areas. 

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

times. The UAS will not be flown at an indicated airspeed exceeding 30 knots. 

18. All operating documents will be accessible during UAS operations. JOSA Industries, LLC may 

update or revise operating documents, however; it will track revisions and present updated revised 

documents the administrator upon request. 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

19. All documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the 

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

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

20. Prior to all UAS flight operations, the pilot in command will conduct a visual inspection of the 

property and attempt to inform all persons on the property of the UAS operations. Flight operation 

will be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, 

VO, operator trainees or essential persons), vessels, vehicles and structures unless: 

I. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator 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 UA, flight 

operations will cease immediately and/or; 

II. 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, and; 

III. Operations nearer to the PIC, VO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a). 

21. The PIC of the UAS and VO involved with each UAS flight operation will have received initial 

training, and recurrent training on a periodic basis to keep up-to-date on, applicable government 

regulations, airspace regulations, manufacturer updates, and other information regarding UAS 

operations in the NAS. 

22. The PIC and VO will be able to verbally communicate at all times. Electronic messaging or 

texting will not be permitted during flight operations. 

23. If the UAS loses communications or loses its GPS signal, it will return to a pre-determined 

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

operating documents. 

24. The PIC will abort the flight in the event of unpredicted obstacles or emergencies 

25. The visual observer will carry and utilize fire extinguishing equipment in case of an emergency. 

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

will be conducted under visual meteorological conditions (VMC). Flights under special visual flight 

rules (SVFR) are not authorized. 

27. UAS operations will be identified by serial number, registered in accordance with 14 CFR part 

47, and identification (N-Number) marking in accordance with 14 CFR part 45, Subpart C. The 

markings will be a large as practical. 

28. UAS operations, if required by controlled airspace, will request a Notice to Airman (NOTAM) no 

more than 72 hours in advance, but not less than 48 hours prior to the operation. 

29. All UAS operations will comply with Federal Communications Commission or other appropriate 

government oversight agency requirements 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

30. All operations shall 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. 

31. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable 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 Web site: 

www.ntsb.gov. 

32. Unless otherwise specified the UAS, the UAS PIC, and the UAS operations will comply with all 

applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. 

G. Specific Sections of 14 CFR from which JOSA Industries, LLC Seeks Exemption 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

The proposed UAS operations by JOSA Industries, LLC would employ All UAS Pilot in Commands

(PICs) to go through a JOSA Industries, LLC ground school and flight lessons in accordance with 

manufactures and industry guidance prior to operations. All JOSA Industries, LLC PIC’s will only 

operate the UAS as stated in this document and/or as recommended by the FAA. All JOSA Industries, 

LLC UAS operations will be controlled and limited, all flights will be coordinated ahead of time. JOSA 

Industries, LLC feels that the level of safety will be equivalent or in excess that of a commercial pilot 

operations. JOSA Industries, LLC objective is to safety operate UAS in a controlled manner at a 

reduced risk level that would not require a commercial pilot certificate. 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

JOSA Industries, LLC would like to request and exemption to operate their UAS without an 

airworthiness certificate. Instead, JOSA Industries, LLC will verify the airworthiness of the UAS prior to 

each flight to ensure that the UAS is airworthy prior to each and every flight. All record keeping of 

maintenance actions will be documented in the same manner as a conventional aircraft. In order to 

meet or exceed level of safety as described in 14 C.F.R. §91.7(a). JOSA Industries, LLC operations 

will include: 

Pre-flight operations prior to each flight the PIC will conduct and preflight inspection of the UAS and 

Ground Control Station to ensure it’s in a condition for safe flight. All discrepancies found during the 

preflight inspection will prohibit flight operations until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. All discrepancies, maintenance, alterations will 

be properly documented in the aircraft records. 

If the UAS has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics there will be a functional flight test by the PIC and the PIC will make and entry in the 

aircraft records. All maintenance will follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limited requirements. 

Each UAS will comply with all manufacturers Safety Bulletins. 

The operator will carry out its maintenance, inspections, and record keeping requirements, in

accordance with the manufacturers operating documents. All Maintenance, inspection, alterations, and 

status of replacement/overhaul component parts must be noted in the aircraft records, including total 

time in service, description of work accomplished, and the signature of the authorized person returning 

the UAS to service. 

Authorized persons will make entry in the aircraft record of corrective action taken against 

discrepancies discovered between inspections. 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

14 C.F.R. §91.119 (c): Minimum safe altitudes 

JOSA Industries, LLC would like to request an exemption to 91.119 paragraph (c) Over other than 

congested areas. 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. 

All flights will be conducted with within visual line of sight and with prior permission from the owner 

of the property or local municipality. Additionally, all persons, vessels, vehicles, not directly 

involved with the operation will be notified and cleared of the area where the proposed UAS 

operations will be conducted. The advance notice and access restricted area will maintain an 

equivalent level of safety of that described in 14 C.F.R. §91.119 (c): Minimum safe altitudes. 

14 C.F.R. §91.121 Altimeter Settings 

JOSA Industries, LLC is requesting an exemption from 14 CFR 91.121 requiring each person 

operating an aircraft shall maintain the cruising altitude by reference to an altimeter that is se when 

operating below 18,000 feet mean sea level to the elevation of the departure airport or an 

appropriate altimeter setting available before departure. 

To meet the equivalent level of safety, the UAS operated by JOSA Industries, LLC has GPS 

altitude readout instead of a barometric altimeter. The JOSA Industries, LLC qualified PIC will 

maintain the equivalent level of safety by confirming the altitude of the launch site shown on the 

GPS altitude indicator prior to each flight. The operating documents will require confirmation of the 

launching site altitude on the UAS GPS altitude indicator before each flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

JOSA Industries, LLC believes that an equivalent level of safety can be achieved by following the 

UAS manufacturer’s operating documents with regard to battery voltage. In order to achieve or 

exceed the level of safety, the JOSA Industries, LLC PIC will not begin a flight unless (considering 

wind and forecast weather conditions) there is enough power to fly to the intended landing point at 

normal cruising speed and land the UAS with no less than 30% of battery power. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

JOSA Industries, LLC UAS operations will keep an equivalent level of safety as described below. 

JOSA Industries, LLC will perform preventative and required maintenance on its UAS as required 

by the manufacturer and/or FAA safety/service bulletins. If a mechanical event occurs the UAS will 

land immediately. The operator will make sure that the UAS is in an airworthy condition prior to 

each flight operation. The operator will perform maintenance on its UAS and will maintain thorough 

record keeping of any maintenance performed. In order to meet or exceed level of safety as 

described in 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b). JOSA Industries, LLC

operations will include: 

Pre-flight operations: prior to each flight the PIC will conduct and preflight inspection of the UAS 

and Ground Control Station to ensure it’s in a condition for safe flight. All discrepancies found 

during the preflight inspection will prohibit flight operations until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. All discrepancies, 

maintenance, alterations will be properly documented in the aircraft records. 

If the UAS has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics there will be a functional flight test by the PIC and the PIC will make and entry in the 

aircraft records. All maintenance will follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limited requirements. 

Each UAS will comply with all manufacturers Safety Bulletins. 

The operator will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the manufacturers operating documents. All Maintenance, inspection, alterations, 

and status of replacement/overhaul component parts must be noted in the aircraft records, 

including total time in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 
JOSA	Industries,	LLC________________________________________________________________________

1630 Rue du Belier Apt 104 Lafayette LA 70506 Jorge Sosa (337)-962-7611

Authorized persons will make entry in the aircraft record of corrective action taken against 

discrepancies discovered between inspections. 

H. Publication Summary

The following summary is provided for publication in the Federal Register. Pursuant with Section 

333 of the FAA Modernization and Reform Act of 2012, JOSA Industries, LLC requests an 

exemption from the following rules: 

14 CFR 61.113 (a) & (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a)(1); 91.405 (a); 91.407(a) (1); 

91.409 (a) (2); 91.417 (a) & (b).

Exemption from these regulations will allow JOSA Industries, LLC` to operate commercially a UAS, 

DJI Phantom 2 Vision+ (55lbs or less), for Aerial Photography/ Inspection Operations. 

If approval of the exemption is granted, JOSA Industries, LLC would conduct commercial 

operations of the approved UAS for aerial photography/inspection for business operations over 

land, water-ways, and oceans; operation over/in non-restricted National Parks, National Forests, 

flight in non-navigable airspace, using non-intrusive recording devices, operation in otherwise 

unrestricted US States/Territories. 

The use of UAS of less than 55 lbs. with power source is a safer and more economical mechanism

than utilization of conventional aircraft. JOSA Industries, LLC proposed commercial operations of 

UAS would be conducted under controlled conditions in airspace that is: limited, predetermined, 

and access controlled