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 air crafts, 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 recrea tional 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.comII. 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 t he 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 t he 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, spee d 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,

J ason 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 wi th 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 prope rty 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 mightadversely affect flight safety and performance.

• Examine the aircraft

- looking at connections and searching for cracks and loose parts.

• Determine that the electronic element s 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 ai rcraft.

• 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 responsibili ty 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

- lookin g 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 b udget 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 c atastrophic 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 c ontrol 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 whic h 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

Lik e 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 per mits 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 conte mplated 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 flig ht 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 Jone s

. 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

le ttering 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, 10167 A 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 cu rrent 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 Altitude s 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 m y 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 t o 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

ai rworthiness 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. T he 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 air worthiness 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, 1 0167, 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. § 91.40 5 (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 id ea 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 leve ls 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 eliminati ng 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, weigh ing 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 subm itted,

Jason Jones Destin Property Sales, LLC

33 Private Ct Miramar Beach, Fl 32550 (850) 797

- 6227 jason@destinpropertysales.com

DJI Phantom 3 Professional Specifications