Jessica Carlisle Photography 

104 Poplar Loop 

Calem, AL 35040 

Telephone: 205-669-9250, Cell: 205-283-4599 

July 14, 2015 

U.S. Department of Transportation 

Docket Management System 

Email: jcphotos@att.net 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the 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 incorporate the use of (UAS) for a variety of projects which may include but not be limited to 

project and 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; photography and real estate purposes; search and rescue, etc. 
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Docket Management System 

July 14, 2015 

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Specific Section(s) seeking exemption: 

14 C.F.R Part 21 

14 C.F.R. 45.23(b) 

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

14 C.F.R. 91.7(a) 

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

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) and (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417 

Extend of relief requested: 

To permit commercial operation of Small Unmanned Aircraft Systems (UAS) for operations conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by Section 333. 

Said exemption would permit the operation of (UAS) under controlled conditions in limited, predetermined and 

controlled airspace. Upon granting of this proposed exemption request, JCP would conduct commercial 

operations of (UAS) meeting or exceeding all operational and safety requirements per Section 333. 
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Docket Management System 

July 14,2015 

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Public Benefit: 

1. Project and construction management, inspections and monitoring. The use of (UAS) on construction sites 

may improve the safety of workers, local residents and general public by assessing potential dangerous 

situations. Falls and injuries may be reduced or eliminated through a more thorough review of the construction 

sites. In some cases, (UAS) may reduce the reliance of helicopters or small aircraft to 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) during the 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 of the 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 of smaller areas may eliminate the use 

of helicopters or aircraft. This could provide a more cost effective, safer and more energy 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 provide views 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 manner than other available options. 

7. Aerial filmmaking, photography and real estate purposes. The use of (UAS) may provide a point of view 

previously unavailable through other means. This would be more cost effective, efficient and safer than 

helicopters and aircraft. 

8. Search and rescue. The use of (UAS) may provide assistance to local law organizations during search and 

rescue missions. (UAS) may reach areas unattainable or viewable with helicopters and aircraft. (UAS) may be 

implemented quicker as time is of the essence during search and rescue operations. 
U. S. Department of Transportation 

Docket Management System 

July 14, 2015 

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Reasons why the exemption would not adversely affect safety or how the exemption would provide a level of 

safety at least equal to the existing rule. 

Proposed operations using (UAS) provide increased safety enhancement especially when compared with 

helicopters and aircraft for the following reasons: 

1. The (UAS) will weigh less than ten (10) pounds. 

2. Flights will be operated within the visual line of sight of the pilot. 

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight times 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 feet AGL. 

5. Minimum crew for each operation will consist of the (UAS) pilot and a Visual 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 a waiver. Verbal/written consent will be 

required of all persons within 100 feet of flight operation. 

8. Written and/or oral permission from relative property owners will be obtained prior to 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 at speeds less than 50 knots, hover and simultaneously move vertically and 

horizontally. 

12. The (UAS) will have the capability to return and land at the pre-determined location with the Security 

Perimeter should the (UAS) lose communication or GPS signal during any operations. 

13. The (UAS) will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

14. Operations will not be conducted over densely populated areas or heavily traffic highways. 
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Docket Management System 

July 14, 2015 

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15. Operations will not be conducted within five (5) NM of an airport or heliport. 

JCP will abide by all regulations including the following: 

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 aircraft flight manual, marking and placard requirements. 

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests. 

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. 
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July 14, 2015 

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18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and inspections. 

19. 14 C.F.R. 91.413 ATC transponder tests and inspections. 

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs. 

21. 14 C.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 of flight time, 

HD video streaming to mobile 

Top speed: 12 mph 

Max Altitude: 400ft, per FAA rules 

Weight: 2.8 lb including battery and propellers 

Communication Distance: up to 6500 feet 

Detached Controller with color screen and live flight data 
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Docket Management System 

July 14, 2015 

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Plug and play with 3-axis Solo Gimbal 

Please feel free to contact our office should you have any additional questions or comments. Thank you for your 

cooperation with this matter. 

Sincerely, 

JESSICA CARLISLE PHOTOGRAPHY