JBK Unmanned Systems

8 Sentinel Trail

Palm Coast, Fl 32164

386.559.4831

jbkunmannedsystems@gmail.com

May 26th, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Exemption per PL 112-95 §333 from 14 CFR 61.113(a) and (b), 

14 CFR 91.103, 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 

91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 

91.409(a)(2), 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

JBK Unmanned Systems respectfully requests an exemption of the above 

applicable sections of title 14 CFR for the purpose of conducting commercial 

operations including, but not limited to, aerial photography, videography, survey

and mapping, inspections as well as providing services for search and 

rescue/recovery and firefighting operations. JBK will use its small Unmanned 

Aircraft System(sUAS) within controlled access airspace, using licensed airmen, 

and will employ a comprehensive safety, training, and planning program. The 

employment of sUAS platforms for these missions should provide the FAA with 

good cause to find that these operations enhance safety by eliminating the need 

to use conventional aircraft in the sometimes unique environments where a

sUAS would be particularly adept, but a conventional aircraft may pose a hazard 

to its crew and those on the ground.
JBK Unmanned Systems requests exemption from the following applicable 

regulations, pursuant to the Administrator’s authority to grant exemptions 

contained in 49 U.S.C. § 106(f), 40113, and 44701:

14 CFR 21 Part H - Airworthiness Certificates,

14 CFR 61.113(a) and (b) – Pilot in Command,

14 CFR 91.103 – Preflight action,

14 CFR 91.105 – Flight crewmembers at stations,

14 CFR 91.109 – Flight instructions,

14 CFR 91.119 - Minimum Safe Altitudes,

14 CFR 91.121 - Altimeter settings,

14 CFR 91.151(a) - Fuel requirements,

14 CFR 91.405(a) - Maintenance required,

14 CFR 91.407(a)(1) - Operations after maintenance,

14 CFR 91.409(a)(2) - Inspections,

14 CFR 91.417(a) and (b) – Maintenance records

OPERATIONS OVERVIEW

Our operations utilize sUAS in a manner that provides services not offered by

manned aircraft or enhances the level of safety at which the tasks can be

completed in manned aircraft. Examples of the proposed aerial photography 

operations include real estate, insurance damage assessment and various 

inspection services. These types of operations restrict the use of the sUAS to a 

small area typically encompassing a limited number of residential and 

commercial properties at a time. The areas in which the flight takes place can 

readily be protected with secured access. The structures on these properties 

provide sufficient protection from the sUAS and can be completed with much less 

risk than that of a manned operation at low altitudes.

JBK’s survey, mapping and inspection operations will include mapping and 

inspections of both agriculture and construction sites utilizing a sUAS rotorcraft 

flying pre-programmed grids that can be interrupted and returned to a safe 

landing zone. Currently these operations are executed by general aviation 

aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudes 

and speeds. Our operation would greatly increase the level of safety, replacing 

large aircraft with a sUAS under 35 pounds and restricted to speeds no greater 

than 50 knots. These sites are areas that can readily be secured by JBK 

personnel and would not provide any additional risk to the general public.

JBK Unmanned Systems will offer services to local public safety agencies where 

FAA rules and local laws permit. These services could include search and rescue 

of missing persons, evidence search, structural and wildland firefighting 

operations and other operations where permitted.
Any operations under this exemption would be conducted in accordance with the 

strict parameters specified in the confidential Flight Operations Manual and 

confidential Pilot Operating Handbooks.

The limitations and conditions that JBK Unmanned Systems agrees to be bound 

to include:

1. The sUAS will weigh less than 35 lbs.

2. Flights will be operated within VLOS of a pilot and/or observer and will be 

conducted during daylight hours only.

3. Flights will be terminated at 25% battery power reserve.

4. Flights will be operated at an altitude of no more than 400 feet AGL and 

ground speed will not exceed 50 knots.

5. Preflight inspections of all components of the system and a safety risk 

assessment will be conducted and a separate log/checklist will be filed for each 

flight.

6. Minimum crew for each operation will consist of the sUAS Pilot, the Visual

Observer and based on results of the safety assessment may include a security 

coordinator. A sensor operator may also be used when necessary.

7. Observer and pilot will at all times be able to communicate by voice.

8. Pilot and observer will be trained in the operation of the UAS to be used and 

will receive up-to-date information on the particular UAS to be operated as 

required in the Flight Operations Manual (FOM will be provided upon request).

9. sUAS pilot will be an FAA licensed airman with at least a sport pilot

certificate and drivers license as required in the current FAA policy.

10. The UAS will only operate within a confined “Safety Perimeter” as defined in 

the FOM.

11. A briefing will be conducted in regard to the planned sUAS operations prior to

each day’s activities. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for this 

briefing.

12. Written and/or oral permission from the relevant property holders will be

obtained.

13. 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.

14. If the sUAS loses communications or loses its GPS signal, the UAS will have

the capability to return to a pre-determined location within the Safety Perimeter

and land.
AIRCRAFT TO BE UTILIZED

JBK Unmanned Systems will utilize a DJI Inspire 1 and DJI Phantom 3 for its

operations. The sUAS are rotocopter configuration and will weigh no more than 

35 pounds. They will operate no faster than 50 knots groundspeed. The aircraft 

are agile, having the ability to hover, and move about its three axes 

simultaneously. The aircraft will be operated below 400 feet Above Ground Level 

(AGL) and continuously within the Pilot in Command’s (PIC) line of sight, so as to 

not create a hazard to users of the national airspace system or public. 

The above aircraft are equipped with the following safety features:

1) Both units have a “Return to Home” feature that is automatically activated 

when controller signal is lost and can be activated manually when 

problems occur or a preset battery level indicator is activated.

2) Both units have GPS capability that provides stability and allows the PIC 

more control in various conditions.

3) Both units have programming such as “No Fly Zone” (preprogrammed no 

fly zones around certain airports) and “Flight Limitations” that provide the 

ability to manually program height and distance limitations to meet FAA 

rules.

4) The Inspire 1 has dual controllers so the camera can be controlled by a 

second operator, thus allowing the PIC complete concentration on flight 

operations only.

5) The Phantom 3 has a “Waypoint System” allowing preprogrammed flight 

operations in certain circumstance.

Because of the sUAS’ specifications and flight characteristics, it poses no threat 

to national security.

FLIGHT CREW

All of JBK Unmanned Systems operations will be performed by FAA licensed 

pilots with trained Visual Observers and, where necessary, Site Security 

Coordinators. These operations will be in controlled and secured environments

and only after a safety assessment has been completed. Prior to flight, the PIC 

and Visual Observer (VO) will complete the qualification process as outlined in 

the company’s FOM. The Pilot in Charge will possess, at a minimum, a sport 

pilot’s certificate, meet applicable recent flight experience requirements and hold 

a state driver’s license. The Visual Observer will be trained in accordance with 

the company’s FOM.
PREFLIGHT ACTION

In accordance with 14 CFR 91.103, the PIC will, at minimum, receive a weather

briefing, survey the launch and recovery environments and review takeoff and

landing distances and other applicable aircraft performance data, check the 

aircraft and ground station/transmitter battery levels, and brief the Visual 

Observer (VO) and any other supporting crew on the mission, safety, and 

contingencies. All flights will be conducted in Day VMC conditions. Minimum 

flight crew shall include the PIC, Visual Observer to assist with seeing-andavoiding other aircraft, a Site Security Coordinator as determined by preflight risk 

analysis.

FUEL REQUIREMENTS

All JBK Unmanned Systems PICs will terminate flights when remaining battery 

power level reaches 25%.

sUAS MAINTENANCE

JBK Unmanned Systems will conduct all maintenance on the sUAS in

accordance with the FOM, POH and Manufacturer user manuals. All

maintenance will be conducted by trained JBK Unmanned Systems personnel. 

Repairs will be conducted by same or authorized manufacturer representative

and will require a test flight after completion. Maintenance, repair and software 

update logs will be strictly maintained and available for inspection by the proper 

authorities.

FLIGHT SAFETY AND SECURITY

Because of the relatively small operating perimeter, any mechanical issues that 

may arise during a flight could be quickly mitigated by terminating the flight.

Security of flight operations will follow procedures outlined in earlier sections.

FOM and POH include sections on limitations of safe operations as well as 

emergency and abnormal operating procedures. Requirements for basic training 

and continuing education have been established.

Several principals of JBK Unmanned are current or former law enforcement 

and/or fire service personnel, including FEMA and USAR operations. Safety and 

security of all flights is of the utmost importance to JBK. The safety and security 

of flight operations personnel and the public will not be adversely affected during 

these activities.
PUBLIC BENEFIT

Use of sUAS technology to obtain imagery, information and data currently

obtained by use of manned flight or manual methods:

1) Reduces statistical risk to human life due to manned aircraft accidents

or due to other dangerous activities that can be avoided.

2) Reduces the cost of obtaining such information, which benefits

consumers and the economy.

3) Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft.

CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of

2012 (size, weight, speed, operating capabilities, proximity to airports and

populated areas and operation within visual line of sight and national security) 

provide more than adequate justification to grant JBK Unmanned Systems

requested exemption, allowing for JBK Unmanned Systems commercial 

operations for the purpose of photography, videography, inspections and survey

pursuant to the company’s FOM and POH. Confidential Manuals are available on 

request.

Sincerely,

James P. Gilbert Jr.

President, JBK Unmanned Systems