December 21, 2015 

Jason Jones

Destin Property Sales, LLC 

33 Private Ct

Miramar Beach, Fl 32550

(850) 797-6227

jason@destinpropertysales.com

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. §§ Part 21; 45.23(b); 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 91.119; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (1) 

(2); 91.417(a)&(b) 

Dear Sir or Madam: 

I, Jason Jones, am writing pursuant to the FAA Modernization and Reform Act of 2012 and 

the procedures contained within 14 C.F.R. 11, to request that I, Jason Jones, an owner and 

operator of small unmanned aircrafts, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I, Jason Jones may operate my small light-weight unmanned 

aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”). 

I, Jason Jones, have over ten years of digital photography experience as well as over 12

years in the field of Real Estate Sales & Marketing. Using the DJI Phantom 3, I, Jason 

Jones, intend to provide videography, cinematography and photography services in the 

areas of building inspections, real estate, site surveys, aerial mapping, business marketing, 

special events to include but not limited to weddings, private or public parties/events, 

geological surveying, environmental studies, wineries, outdoor recreational facilities and 

landscapes.

I, Jason Jones, am committed to safety with each flight. My, Jason Jones, exemption 

request would permit operation of a UAS(s) in areas away from the general public, airports, 

heliports and vehicular traffic for community videos, and within property boundaries for 

individual homeowner real estate listing videos/photos. 

I. Contact Information: 

Jason Jones 

Destin Property Sales, LLC 

33 Private Ct 

Miramar Beach, Fl 32550 

(850) 797-6227

jason@destinpropertysales.com 
II. The Specific Sections of Title 14 of the Code of Federal Regulations from Which 

Jason Jones Requests Exemption are: 

• 14 CFR Part 21; 

• 14 C.F.R. 45.23(b); 

• 14 CFR 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(b); 

• 14 C.F. R. 91.109; 

• 14 C.F.R. 91.119; 

• 14 C.F.R. 91.121; 

• 14 C.F.R. 91.203(a) & (b); 

• 14 C.F.R. 91.151(a); 

• 14 C.F.R. 91.405(a); 

• 14 CFR 407(a) (1); 

• 14 CFR 409(a) (1) & (a) (2); 

• 14 CFR 417(a) & (b) 

III. The Extent of Relief Jason Jones Seeks and the Reason He Seeks Such Relief:

I, Jason Jones, am writing pursuant to the FAA Modernization and Reform Act of 2012 and 

the procedures contained within 14 C.F.R. 11, to request that I, Jason Jones, an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I may operate my small light weight unmanned aircraft system 

(“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). 

The Reform Act in Section 332 provides for such integration of civil unmanned aircraft 

systems into our national airspace system as it is in the public’s interest to do so. My, Jason 

Jones, light-weight UAS meets the definition of “small unmanned aircraft” as defined in 

Section 331 and therefore the integration of my light-weight UAS is expressly contemplated 

by the Reform Act. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system. Considerations include: The 

weight, size, speed and overall capabilities of the UAS's, whether the UAS will be operated 

near airports or heavily populated areas; and, whether the UAS will be operated by line of 

sight 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, 

Jason Jones. My UAS utilizes four (4) counter-rotating propellers for balance, control and 

stability and is equipped with a GPS and auto return safety technology. Weighing less than 

five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. 

I, Jason Jones, will operate the Phantom 3 in a safe manner, using the following checklists 

as well as operating procedures to determine that the aircraft is physically and electronically 

ready for safe flight and that permission from the property owner/representative is received:

Pre-flight Checklist: 

• Survey the property for hazards, such as trees, utility poles and other elements that 

might compromise the flight then make a judgment as to whether to proceed. 

• Check the weather for wind speed, cloud cover and any forecast changes that might 
adversely affect flight safety and performance. 

• Examine the aircraft- looking at connections and searching for cracks and loose 

parts. 

• Determine that the electronic elements are performing correctly (receiving more than 

6 GPS signals along with calibration of the magnetic compass). 

• Determine that the barometric altimeter reflects approximately 0 feet AGL. 

• Following takeoff, hover at an altitude of approximately 10 feet to assure that the 

Home Point is solid. Then exercise all controls to confirm their functionality, if one of 

the controls is not functioning, the flight will be terminated immediately. 

• Not fly over dense traffic or crowds. 

• Give right-of-way to any manned aircraft. 

• Stay clear of FAA controlled airspace at airports (generally a five nautical mile 

radius) as well as restricted and prohibited zones. 

• Fly no higher than 400' and no further than 1000' from the Home Point, recognizing 

that the primary responsibility is to safely keep the aircraft safely within VLOS. 

• Stay clear of clouds and fog (500' vertically and 2,000' horizontally). 

Post-flight Checklist: 

• Inspect the Phantom 3 to determine its physical and electronic condition. 

• Examine the aircraft- looking at connections and searching for cracks and loose 

parts. 

IV. How Jason Jones Request Will Benefit the Public as A Whole: 

Aerial videography and photography has been around for a long time through manned fixed 

wing aircraft and helicopters. For small budget companies and individuals, the expense of 

such aerial videography and photography is cost prohibitive. Only large companies and 

high-income individuals can afford to absorb such expense. Manned aircraft pose a threat 

to the public through potential catastrophic crashes resulting in a potential loss of life. My, 

Jason Jones, UAS poses no such threat since size and lack of combustible fuel alleviates 

any potential threat to the public. Congress has already proclaimed that it is in the public’s 

interest to integrate commercially flown UAS’ into the national airspace system, hence the 

passing of the Reform Act. My, Jason Jones, light- weight UAS is battery powered and 

creates no emissions that can harm the environment.

V. Reasons Why Jason Jones Exemption Will Not Adversely Affect Safety 

Or How the Exemption Will Provide a Level of Safety At Least Equal To Existing 

Rule: 

My, Jason Jones, exemption will not adversely affect safety. 

• My UAS weighs less than 5 pounds complete with a small light- weight high definition (HD) 

camera. 

• I only operate my UAS below 400 feet (well within the 400 foot permissible ceiling set by 

the FAA Modernization and Reform Act of 2012). 

• I land my UAS prior to manufacturer recommended minimum level of battery power. 

• I pilot my UAS through remote control/FPV only by line of sight. 

• My UAS has GPS with a flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost. 
• I only operate in reasonably safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas. 

• I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance. 

• I always obtain all necessary permissions prior to operation.

VI. A Summary the FAA May Publish in the Federal Register:

A. 14 C.F.R. § 21, 14 C.F.R. § 91 and 91.151: Airworthiness Certificates, Manuals and the 

Like

14 C.F.R. § 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a) (1). The 

size, weight and enclosed operational area of my, Jason Jones, UAS permits exemption 

from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant 

to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My, Jason 

Jones, current and projected UAS’ meet or exceed each of the elements.

14 C.F.R. § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size of the UAS, this Regulation is inapplicable. 

An equivalent level of safety will be achieved by maintaining a safety/flight manual 

delineating areas of where safety can be defined. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.151(a) with the condition that the PIC does not begin a flight unless 

(considering wind and forecast weather conditions) there is enough power to fly to the first 

point of intended landing and, assuming normal cruising speed, land the UA with 30% 

battery power remaining.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required certifications and 

registrations by me, Jason Jones.

B. 14 C.F.R. § 45.23: Marking of the Aircraft

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. My, Jason Jones, UAS is, by definition, unmanned. Therefore, does not have 

a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch 

lettering is difficult to place on such small aircraft with dimensions smaller that minimal 

lettering requirement. Regardless, I, Jason Jones, will mark the UAS in the largest possible 

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. § 

45.29 (f) so that I, Jason Jones, the pilot, will see the markings. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700.
C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC

Pursuant to 14 C.F.R. § 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Jason Jones, can achieve an equivalent level of safety as achieved by current 

Regulations because my UAS does not carry any pilots or passengers. Further, while 

helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the 

operation of my UAS is far less than the risk levels inherent in the commercial activities 

outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Jason Jones, to operate my UAS in a 

manner that meets and exceeds current safety levels in relation to 14 C.F.R. § 61.113 (a) & 

(b). 

D. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. My UAS will never 

operate at an altitude greater than 400 AGL; safely below the standard of 400 AGL. I, Jason 

Jones, will however operate my UAS in safe areas away from public and traffic, providing a 

level of safety at least equivalent to or below those in relation to minimum safe altitudes. 

Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level 

of safety will be achieved. 

E. 14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417 (a) & (b): Maintenance 

Inspections 

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

have the 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. 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my, Jason Jones, UAS. However, as a safety precaution, I, Jason Jones, 

inspect my UAS before and after each flight.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 

91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed 

operational area of my UAS permit exemption from Part 21 because my, Jason Jones, UAS 

meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under both the 

Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UAS’ from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as 

airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 

§ 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As 

there are no pilots or passengers, and given the size of the UAS’, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The 

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular 

software updates and curative measures for any damaged hardware. Therefore, an 

equivalent level of safety will be achieved. 

In summary, Jason Jones seeks an exemption from the following Regulations: 
14 C.F.R. § 21, Subpart H; 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 (b); 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. § 91.405 (a); 14 

C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a) (1); and, 14 

C.F.R. § 91.417 (a) & (b) 

I, Jason Jones, am requesting this exemption for the purposes of aerial photography, 

cinematography, videography, inspections and other flight operations. The reason for such 

a general and broad based request is that I, Jason Jones, wish to utilize a business strategy 

that capitalizes on opportunities as they may arise in the future. My, Jason Jones, business 

model is based on the idea of offering ad hoc small UAS services to individuals or 

companies who wish to employ these services as a safe, effective, and legal option to 

enhance their business or hobby.

Granting my, Jason Jones, request for exemption will reduce current risk levels and thereby 

enhance safety. My UAS craft does not contain potentially explosive fuel, is smaller, lighter 

and more maneuverable than conventional video and photographic aircraft. Further, I 

operate at lower altitudes and in controlled airspace eliminating potential public risk flying to 

and from established air fields. There are no personnel on board my, Jason Jones, UAS 

and therefore the likelihood of death or serious bodily injury is significantly diminished. My, 

Jason Jones, operation of my UAS, weighing less than 5 pounds and travelling at lower 

speeds within limited areas will provide an equivalent level of safety as that achieved under 

current FARs. Accordingly I, Jason Jones, respectfully request that the FAA grant my 

exemption. 

Respectfully submitted, 

Jason Jones 

Destin Property Sales, LLC 

33 Private Ct 

Miramar Beach, Fl 32550 

(850) 797-6227

jason@destinpropertysales.com 

DJI Phantom 3 Professional Specifications