Jessica Carlisle Photography 104PoplarLoop Calem, AL 35040 Telephone:205-669-9250, Cell:205-283-4599



### July 14, 2015 U.S. Department ofTransportation Docket Management System Email:jcphotos@att.net



### West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE Washington DC 20590

RE: Exemption RequestSection 333 ofthe FAA ReformAct 

### Dear Sir or Madam: We respectfully request exemption under Section 333 ofthe FAA Reform ACT and Part 11 ofthe Federal Aviation Regulations. Petitioner: 

### Jessica Carlisle Photography (JCP) 104 Poplar Loop Calera, AL 35040 Telephone: 205-669-9250 Cell: 205-283-4599 Email:jcphotos@att.net JCP intends to incorporatethe use of (UAS) for avarietyofprojects which may include but not be limited to projectand construction management, inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; educational and research projects; remote sensing projects; wildlife and forestry monitoring projects; aerial filmmaking; photographyand real estate purposes; search and rescue, etc.U. S. Department ofTransportation Docket Management System July 14, 2015 Page Two

Specific Section(s) seeking exemption: 14C.F.R Part 21 14C.F.R. 45.23(b) 14C.F.R. 61.113(a) and (b) 14C.F.R. 91.7(a) 14C.F.R. 91.9(b)(2) 14C.F.R. 91.109 14C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14C.F.R. 91.203{a) and (b) 14C.F.R. 91.215 14C.F.R. 91.104 through 91.417 Extend ofrelief requested: To permit commercial operation of Small Unmanned Aircraft Systems (UAS) for operations conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. Said exemption would permittheoperation of (UAS) undercontrolled conditions in limited, predetermined and controlled airspace. Upon granting ofthis proposed exemption request, JCP would conduct commercial operations of (UAS) meetingor exceeding all operational and safety requirements per Section 333.U.S. DepartmentofTransportation Docket Management System July 14,2015 Page Three

Public Benefit: 1. Project and construction management, inspections and monitoring.The use of (UAS) on construction sites may improvethe safety ofworkers, local residents and general public byassessing potential dangerous situations. Falls and injuries may be reduced or eliminated through a more thorough review ofthe construction sites. In some cases, (UAS) may reduce the reliance of helicopters orsmall aircraftto monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy usage. 2. Environmental Review projects. The use of (UAS) duringthe process of reviewing projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental Review ofthe project site as well as surrounding areas. Reliance of helicopters or small aircraft may be eliminated. 3. Aerial surveying. The use of (UAS) in connection with aerial surveying ofsmallerareas may eliminatethe use of helicopters or aircraft. This could provide a more cost effective, safer and moreenergy efficient product. 4. Agricultural projects. Wildlife and Forestry projects. The use of (UAS) could assist with surveying agricultural projects as well as wildlife and forestry projects by providing information when problems occur, vermin infestation, fire hazards, etc. 5. Remote Sensing projects. The use of (UAS) could provideviews and information for remote and inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and aircraft. 6. Educational and Research projects. The use of (UAS) could provide information for said projects in a more cost effective and efficient mannerthan other available options. 7. Aerial filmmaking, photography and real estate purposes. The use of (UAS) may provide a pointofview previously unavailablethrough other means. This would be more cost effective, efficient and saferthan helicopters and aircraft. 8. Search and rescue. The use of (UAS) may provide assistance to local laworganizations during search and rescue missions. (UAS) may reach areas unattainable orviewable with helicopters and aircraft. (UAS) may be implemented quicker as time is ofthe essence during search and rescue operations.

### U. S. Department ofTransportation Docket Management System July 14, 

### 2015 Page Four

Reasons whythe exemption would notadversely affectsafety or howthe exemption would provide a level of safetyat least equal tothe existing rule. Proposed operations using (UAS) provide increased safety enhancement especially when compared with helicopters and aircraft forthe following reasons: 1. The (UAS) will weigh less than ten (10) pounds. 2. Flights will be operated within thevisual line ofsight ofthe pilot. 3. Maximum total flighttimefor each operational flightwill be thirty (30) minutes. Flighttimes may be less than thirty (30) minutes as the (UAS) will continuously monitor battery reserve and return to the ground station with at least 20% battery power reserved. 4. Flights will never exceed 400 feetAGL. 5. Minimum crewfor each operation will consist ofthe (UAS) pilotand aVisual Observer. 6. A briefing will be conducted daily by all personnel working with said (UAS). 7. All onsite personnel and client employees will be required to execute awaiver. Verbal/written consent will be required ofall persons within 100feet offlightoperation. 8. Written and/ororal permission from relative property owners will be obtained priorto operating the (UAS). 9. All permits, permissions, etc. will be obtained from local government offices as required. 10. The (UAS) operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.). 11. The (UAS) will operate atspeeds less than 50 knots, hover and simultaneously movevertically and horizontally. 12. The (UAS) will have the capabilityto return and land atthe pre-determined location with the Security Perimeter should the (UAS) lose communication orGPS signal during any operations. 13. The (UAS) will have the capability to abort aflight in case of unpredicted obstacles or emergencies. 14. Operations will not be conducted over densely populated areas or heavilytraffic highways.U. S. Department ofTransportation Docket Management System July 14, 2015 Page Five

15. Operations will not be conducted within five (5) NM ofan airportor heliport. JCP will abide by all regulations including thefollowing: 1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates. 2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks. 3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. 4. 14 C.F.R. 91.7 Civil aircraft airworthiness. 5. 14 C.F.R. 91.9 Civil aircraftflight manual, marking and placard requirements. 6. 14 C.F.R. 91.109 Flight instruction; Simulated instrumentflight and certain flighttests. 7. 14 C.F.R. 91.119 Minimum safe altitudes: general. 8. 14 C.F.R. 91.121 Altimeter settings. 9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions. 10. 14 C.F.R. 91.203 Civil aircraft: Certifications required. 11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements. 12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use. 13. 14 C.F.R. 91.401 Applicability. 14. 14 C.F.R. 91.403 General. 15. 14 C.F.R. 91.405 Maintenance required. 16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration. 17. 14 C.F.R. 91.409 Inspections.U. S. Department ofTransportation Docket Management System July 14, 2015 Page Six

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipmenttests and inspections. 19. 14C.F.R. 91.413 ATC transpondertests and inspections. 20. 14C.F.R. 91.415 Changes to aircraft inspection programs. 21. 14C.F.R. 91.417 Maintenance records. 

### Equipment and Specifications. DJI Phantom 3 Professional Quadcopter with 4K Camera and 3-Axis Gimbal Specifications: Up to 23 minutes offlighttime, HD video streaming to mobile Top speed: 12 mph MaxAltitude: 400ft, per FAA rules Weight: 2.8 lb including battery and propellers Communication Distance: up to 6500 feet Detached Controller with colorscreen and live flight dataU.S. Department ofTransportation Docket Management System July 14, 2015 Page Seven

Plug and playwith 3-axis Solo Gimbal Please feel free to contact our office should you have any additional questions orcomments. Thank you foryour cooperation with this matter. Sincerely, JESSICA CARLISLE PHOTOGRAPHY