Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(the “Reform Act”) and 14 C.F.R. Part 11, Jackson R Campbell, an operator

of the “Phantom 3 Pro” Unmanned Aircraft System (“UAS”) seeks

exemption from the Federal Aviation Regulations (“FARs”) as described

below.

The exemption request will permit Jackson R Campbell to operate UASs

commercially for the purpose of filming and photographing property, people,

and events. Jackson R Campbell will provide a service that is beneficial to

an industry that is already using, and seeking to use, UASs for these

purposes with a legal and safe option while providing relevant experience

and information to the FAA and the UAS community. This will benefit the

public with the controlled operation of UASs by Jackson R Campbell and

increased integration into the National Airspace System (“NAS”).

All operations by Jackson R Campbell will strictly adhere to safety,

applicable FARs, Operator’s Handbook, applicable Airworthiness Directives,

and all other guidelines from the FAA. Jackson R Campbell will, at all times,

conduct operations in a manner as to maintain the same level of safety as

current manned aircraft operations.

Jackson R Campbell will operate exclusively in controlled conditions, within

visual line of sight (“VLOS”), at low altitudes of 400 feet above ground level

(“AGL”), or no higher than 200 feet above the highest obstacle (“AHO”) with

prior Flight Safety District Office (“FSDO”) approval. Any UAS in operation

by Jackson R Campbell will not exceed 55 lbs. weight.

At all times Jackson R Campbell will, maintain safe operations, ensure

current requirements are met, and consistently assure an open line of

communication with the FAA. Jackson R Campbell will maintain the highest

of standards in all UASs operations. A thorough understanding of the

importance of safety guidelines in the NAS, and a desire to promote the

appropriate integration of UASs for the furtherance of aviation as a whole is

the foundation upon which this Jackson R Campbell will operate.

The name and address of the applicant are: Jackson R Campbell 
Phone: 417-234-3826 Email: jacksoncampbell@gmail.com

Address: 201 W Kennedy Strafford, Mo 65757

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 91.7(a) ;

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

14 C.F.R. 91.109(a) ;

14 C.F.R. 91.119;

14 C.F.R. 91.105

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. 91.407(a) (1) ; 14 C.F.R. 91.409(a) (2) ; 14 C.F.R. 91.417(a).

Appendix A discusses each rule listed above and explains why exemptions

pursuant to the proposal set forth in this letter are appropriate, provide an

equivalent level of safety, and are in the public interest.

The Applicable Legal Standard Under Section 333

Jackson R Campbell submits that grant of this exemption application

advances the Congressional mandate in Section 333 of the Reform Act to

accelerate the introduction of UASs into the NAS if it can be accomplished

safely. This law directs the Secretary of Transportation to consider whether

certain UASs may operate safely in the NAS before completion of the rule

making required under Section 332 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UASs

do not create a hazard to users of the NAS, the public, or pose a threat to

national security in light of the following:

● The UAS’s size, weight, speed, and operational capability; 2

● Operation of the UAS in close proximity to airports and populated areas;

And ● Operation of the UAS within visual line of sight of the operator.

Reform Act § 333(a) (1). If the Secretary determines that such vehicles

“may operate safely in the national airspace system, the Secretary shall
establish requirements for the safe operation of such aircraft in the national

airspace system.” Id. §333(c) (emphasis added).1

The Federal Aviation Act expressly grants the FAA the authority to issue

exemptions. This statutory authority, by its terms, includes exempting civil

aircraft, as the term is defined under §40101 of the Act, from the

requirement that all civil aircraft must have current airworthiness certificate

and those regulations requiring commercial pilots to operate aircraft in

commercial service:

The Administrator may grant an exemption from a requirement of a

regulation prescribed under subsection (a) or (b) of this section or any of

sections 44702-44716 of this title if the Administrator finds the exemption is

in the public interest.

The grant of the requested exemption is in the public interest based on the

clear direction in Section 333 of the Reform Act; The additional authority in

the Federal Aviation Act, as amended; The strong equivalent level of safety

surrounding the proposed operations; And the significant public benefit,

including enhanced safety and cost savings associated with use of UASs for

aerial videography/photography, the reduction or elimination of unregulated

operators, and the safe integration of UASs. Accordingly, the applicant

respectfully requests that the FAA grant the requested exemption without

delay.

Airworthiness

Grant of the exemption to Jackson R Campbell will be subject to the

following mandatory airworthiness conditions:

● The UAS will never exceed a gross takeoff weight (GTOW) of 55

lbs., or in excess of the Operator Handbook/Manufacturer

recommendations, whichever is more restrictive.

● The Manufacturer checklist and Jackson R Campbell preflight

checklist will be followed prior to each flight.
• The aircraft registration number will be displayed on the aircraft in accordance with current

regulations.

The POH, registration, copy of exemption, checklist, and copy of maintenance

records will be mandatory documents for operation and must be located with or in

the base station and accessible to the PIC at all times.

Any FAA or manufacturer required placards are placed and clearly visible

on the base station or controlling device.

All equipment installed on the UAS will be operational for flight.

PIC will be the determining authority on the airworthiness of the UAS prior,

during, and after each flight, and will cease operations upon deeming the

UAS not airworthy until proper maintenance or action has been taken.

In adherence to 14 C.F.R. §43.9 each person who maintains, performs

preventative maintenance, rebuilds, or alters the UAS, airframe, motor,

propeller, appliance, or component part will make an entry in the

maintenance record of that equipment containing the following information:

○ Description of work performed.

○ Date of completion of work performed.

○ Name of the person performing the work.

○ Signature of the person performing the work.

In addition to the information above, the following will be included on

any maintenance records for record keeping and reporting to the FAA

upon request:

○ Aircraft total time.

○ Time in service of part by method of Time since New (TSN) or

Time since

Overhaul (TSO).

○ Manufacturer,model,serialand/orpartnumberwhenavailable.

Any maintenance action that may affect flight characteristics or

airworthiness will a maintenance operational check and test flight
performed by the PIC

Mandatory Operating Conditions

Grant of the exemption to Jackson R Campbell will be subject to the

following mandatory operating conditions:

● All operations are required to remain at, or below, 400 feet AGL

unless prior approval is received from the FAA Flight Standards District

Office having jurisdiction, and no flight exceeding 400 feet AGL may go

above 200 feet above the highest obstacle, or outside visible range, or

beyond the capability of the UAS (whichever is lower in altitude).

● Operations are to be conducted over private or controlled-access

property.

● Permission from land owner/controller required before commencing

any flight.

● Operations to occur under Visual Flight Rules during Visual

Meteorological

Conditions (VMC).

● Aircraft to remain within Visual Line of Sight (VLOS).

● Operations to be conducted in a controlled environment with only

the

necessary persons present, any person present, not employed by

Jackson R Campbell, will sign a waiver acknowledging UAS

operations, proper safety procedures, and a statement acknowledging

risks.
● Operations will be conducted with a visual observer (VO), in addition

to the UAS pilot, who will remain in VLOS with the UAS pilot, the UAS,

and the area of operations at all times. VO will assist in maintaining a

controlled environment, spotting hazards to persons or property,

monitoring and communicating on appropriate ATC, CTAF, or other

appropriate radio frequencies.

● UAS will not be operated below 25% battery capacity, or a battery power

reserve of less than 10% flight time, whichever is the greater of the two.

Operator Requirements

Jackson R Campbell understands and upholds the stance that necessary

precautions are required to protect aircraft already operating in the NAS,

and the safety and security of the flight crew members, passengers as well

as the public and property. For this reason Jackson R Campbell will require

all pilots of the UAS to be a trained in the operation of the UASs.

The PIC and the Visual Observer will, at all times, be aware that UASs

currently cannot adhere to the standard “see and avoid” requirements due

to the size of the UAS impacting the distance at which it can be identified by

pilots of manned aircraft. Jackson R Campbell maintains a zero tolerance

policy for any pilot that fails to give complete right of way, and wide berth to

any aircraft that comes within 1 statute mile horizontally or 2000 feet

vertically of operations.

The PIC will adhere to appropriate FARs as well as follow the included UAS

user Manual. The PIC will, while the exemption is in place, log all flights

conducted, or any flight to meet the requirements.

The visual observer will be trained according to the Operating Manual. The

VO will be required to exhibit proficiency in operating the UAS. The VO will

not, at any time during operations conducted under this exemption, operate

or control any portion of the flight of the UAS unless they meet the PIC

requirements of this exemption.

Privacy

All flights will occur over private or controlled access property with the

property owner’s or controlling authority’s prior consent and knowledge.
Filming will be of people who have also consented to being filmed or

otherwise have agreed to be in the area where filming will take place.

***

In summary, applicant seeks an exemption from the FARs set forth above

and in Appendix A to allow commercial operations of UASs conducting

aerial flights as described.

Approval of the exemption allowing commercial operations of Jackson R

Campbell UASs will increase safety by permitting an operator to conduct a

service safely that is already occurring without FAA knowledge, exemption,

or adhering to prescribed safety guidelines. The exemption will also

encourage the education of UAS operators and the adoption of FAA

guidelines and approval for commercial UAS operations. It benefits the

public through a higher level of safety of UAS operations and a service that

benefits the local public and business. It also benefits the public through a

smooth and well approached integration of UASs into the NAS, and

continual communication with the FAA and the information gained.

The UASs operated by Jackson R Campbell satisfies the criteria set forth in

Section 333 of the Reform Act–size, weight, speed, operating capabilities,

operation within visual line of sight, and national security–and showing an

equivalent level of safety to manned aircraft flights and safety focused

standards of operation, providing more than adequate justification for the

grant of the requested exemptions allowing commercial operations.

Best Regards, Jackson R Campbell