### April 22, 2015

Exemption No. 11404 Regulatory Docket No. FAA

– 20 15

– 0120

Mr. Gary North

Business Partner

Just 1 UAV

5440 South Lakeshore D rive

Suite 102 Tempe, AZ 85283

Dear Mr. North :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 10, 2015 , you petitioned the Federal Aviation Administration (FAA)

on behalf of Ju st 1 UAV ( hereinafter petitioner or operator ) for an exemption

. The exemption

would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to conduct a UAS Flight Instruction Program to introduce students to the elements of UAS operation from a

commercial and noncommercial perspective and how these operations must fit into the

National Air s pace System

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operatio ns and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in a cting on this petition would be detrimental to the petitioner

.

### 2

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision Plus.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products

and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification procedures for products and pa rts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global , LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passeng ers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authori ty contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Just 1 UAV is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

### 3

Conditions and Limit ations

In this grant of exemption, Just 1 UAV is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

Vision Plus when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 f eet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than

corrective lense s, as specified on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designa ted before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operati ons in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and

### 4

limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must foll ow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enf orcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which th e FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS tha t has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption.

Functio nal test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspecti on must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance ha s been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS ope rated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia , Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights f or the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonpa rticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual mete orological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airp orts not denoted with an ARP, the center of the airport symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption

holde r. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at le ast five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption hol der may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

### 6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents re quired under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipati ng persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must 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 must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

### 7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Stand ards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and p hone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certifica te number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise s pecified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017 , unless sooner supersed ed or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

### 1 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

D ear 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 Av iation Regulations ("FARs") identified below, to allow commercial
operation of small unmanned aerial systems (“sUAS") so long as such operations are

conducted within a n 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

- Stan dard Operating Procedures

Exhibit C

– Pilots Operating Handbook

Pe titioner 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 h as 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.

### 2 For your convenience, this Petition is organized as follows:

1. Description of Petitioner

2. Description of Proposed Operation

3. Relevan t 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 Ope rational Restrictions Set Forth

in t he Just 1 UAV Ops/Flight Manual

5. Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

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

14 C.F.R. 91.7 (a)

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

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

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

14 C.F.R. 91.405 (a)

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

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

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

6. Public Interest

7. Privacy

8. Conclusion

### 3 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

Ju stin Harvey
jharve y@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 dev elopment expertise. E xperience includes an FAA licensed Airline Transport
Pilot, holding a current Firs t Class Medial Certificate. Having over 30 years of extensive
Federal Aviation Regula tions knowledge and flight experience with in the National
Airspace System

. Each partner has experience in successfu l business developm ent 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 U AS 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 "Cert ificate 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 need s specific to the UAS industry. Furthermore, Just 1 UAV
will coordinate and continuously update its curriculum to take advantage of new guidance

### 4 and regulations proposed and implemented by the FAA. Just 1 UAV is committed to
ensuring that its instruction p rogram not only is compliant, but always refl ects 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”) f or the purpose of creating a UAS education al
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.

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

inhabited structures, vehicles or vessels that are n ot 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 wi ll 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 Fl ight Standards District Office and/or air traffic control ("ATC")
facility between 72 and 48 hours before the flight.

10. All required permissions and pe rmits 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 ste rile 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 spect rum us ed for operation and control of the UA shall

### 6 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 Avia tion 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 airpor ts 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 demo nstrates 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 op erated 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 w ithin 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 loc al 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 i n
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 crit eria
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 th an two lbs.

### 7 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 U AS 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

th e 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

oper ating 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

wh o 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 dete rmining

### 8 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 action s 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

communica tes 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 a ircraft, the ability to control the sUAS via radio signals from the controller, and by

### 9 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 U AS 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 af fected
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 o perations 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 s afety 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.

### 10 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 fr om 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) fall s 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

re presentatives 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 fl ights
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 wi th 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 are a.

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) A n appropriate and current airworthiness certificate. . . .

### 11 (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 55 lbs 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.

A n industry enhances safety while reducing risk. Manned aircraft monitoring
and surveying creates a greater risk because the craft ar e much larger, have combustible
fuel, and carry an onboard human pilot. In contras t, 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 sm all 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 groun d, 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.

A n equivalent level of safety will be achieved by keeping these document s 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

i ncludes 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

t he 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 man ual and operating handbook as

### 12 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 po wered 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 i ndividuals 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 rega rding 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 flig ht 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 vi sual 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

### 13 training, qualifications, and processes involving the saf e 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

S incerely,

Gary North

Just 1 UAV

Business Partner