September 21

, 2015

Exemption No. 12934 Regulatory Docket No. FAA

− 20 15

− 2659

Mr. Carl J. Ulbrich
Jireh Communications Inc.
625 W est Deer Valley R oa d
Phoenix

, AZ 85027

Dear Mr. Ulbrich :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter posted to the public docket on July 1, 2015, and by letter dated July 14, 2015 , you petitioned the Federal Aviation Administration (FA A) on behalf of Jireh Communications
Inc. ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate

an unmanned ai rcraft system (UAS) to conduct sUAS education, real estate photography, videography, film and movie producti on, demonstration flights and inspections

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and
the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the p etitioner are the DJI Phantom, DJI Inspire 1, and 3D Robotics
Solo

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited2

operating area associated with the aircraft and its operation, the Secretary of Transportation
has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA
finds that relief from 14 CFR part 21

, C ertification procedures for pr oducts and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1 and closed set motion picture and filming

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No.
FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and
11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the s pecifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled b y this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The rea sons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and
11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Jireh Communications Inc. is granted an exemption
from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection and closed set motion picture and filming

. This exemption is subject to the
conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by
instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Jireh Communications Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom, DJI Inspire 1, and 3D Robotics Solo when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming

are permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determ ine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than
corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO m ay be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC
must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating
documents must be accessible during UAS operations and made available to the
Administrato r upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator m ust follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. An y UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption

. Functional test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight insp ection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintena nce has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and
aircraft components.

12. Each U AS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

curre nt FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in
14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with
14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During
traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are conside red nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under v isual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exem ption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a clo ud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in t he event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after tha t for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The

ex emption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon r equest.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons
from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensurin g the safety of nonparticipating persons ; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property w ith permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported
to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTS B) per instructions
contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditi ons and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities
must include at least the f ollowing:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;
d. Make, model, and ser ial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;
f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list o f those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and
h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption termin ates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/
John S. Duncan Director, Flight Standards Service

EnclosuresPage 1 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com July 14, 2015

Carl J. Ulbrich
Jireh Communications Inc. 625 W. Deer Valley Rd., #103204 Phoenix, AZ 85027 (602) 674-5675 carl@jirehcom.com

Petition of Jireh Communications For Exemption Pursuant to Section 333 Of the FAA Modernization and Reform Act of 2012

To Whom It May Concern:
Pursuant to Section 333 of the FAA Moderniz ation and Reform Act of 2012 and 14 CFR Part 11, Jireh Communications, hereby applie s for an exemption from Federal Aviation Regulations (FARs) identified below, to a llow commercial operations of small unmanned aerial system ( i.e. , sUAS).

This exemption is in accordance with protocol s outlined in this petition for exemption, and any other requirements established by the FAA pursuant to Section 333 of the
Reform Act.

This exemption would permit commercial operation by Jireh Communications Inc., which uses DJI Phantoms, Inspire 1, and 3DR Solo s to conduct sUAS education, real estate photography, videography, film and movie production, demonstration flights and inspections. Jireh Communication’ operat ion under the exemption will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manne d aircraft and under conditions as may be modified by the FAA as required by Section 333.

Jireh Communications will be operated under co ntrolled VFR conditions at low altitude in airspace that is permitted in accordance wi th Jireh Communications’ approved Certificate of Authorization (COA). They will operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight tr aining for competency and new FAA 333 and Part 107 commercial compliance requirements. Finally, the FAA ATC will approve the airspace in which the sUAS will operate in advance.

Jireh Communications respectfully submits th is request for an exemption because it operates sUAS's. The FAA can have confidence that the operations will be conducted at an equivalent level or greate r level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Re form Act to “establish requirements for the safe operation of such aircraft system s in the national airspace system.”Page 2 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com For your convenience, Jireh Communications has organized this Exemption request as
follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Unde r Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest

VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

I. Petitioner's Description: Jireh Communications Inc. , headquartered in Phoenix, Arizona, is a company that provides sUAS support to news services, real estate photography, film and movie production, education, demonstration flight s and inspections in a compliant and safe environment. Jireh Communications plan on pr oviding a wide range of services as the sUAS market expands.

Jireh Communications’ goal is to operat e in an accident-free environment by:

• Demonstrating a commitment by management and all employee’s to operator in a compliant manner.

• Identify hazard and risk while eliminating or controlling all these risk.

• They will use steps to intervene and report when unsafe work practices appear to

exist.

• Train all employees involved in flight operations to operate at the highest
standard level.

The contact information for Petitioner is as follows:
Jireh Communications Inc. 625 W. Deer Valley Rd., #103204 Phoenix, AZ 85027

Carl Ulbrich (602) 674-5675 carl@jirehcom.com

II. Relevant Statutory Authority: This petition for exemption is submitted to fu lfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft syst ems into the national airspace system." Pursuant to Section 333 of the Reform Act, th e FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of the formal UAS rulema king, based on the following considerations:Page 3 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com • The UAS's size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall estab lish requirements for the safe operation of such aircraft in the National Airspace System".

Additionally, the FAA Administrator has genera l authority to grant exemptions from its safety regulations and minimum standards wh en the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefi t the public as a whole, and (2) would not adversely affect safety (or how it would prov ide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exem pting civil aircraft, as the term is defined under 40101 of the Act, from the requirement th at all civil aircraft must have a current airworthiness certificate and those regulati ons requiring commercial pilots to operate
aircraft in commercial service:

The Administrator may grant an exem ption from a requirement of a regulation prescribed under subsection (a ) or (b) of this section or any of sections.

III. Qualifications for Approval Under Section 333 of the Reform Act The proposed operations in this petition for exemption qualify for expedited approval
under Section 333 of the Reform Act. Each of the statutory criteria and other relevant
factors are satisfied.

The proposed operations would permit Jireh Communications the use of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) cont rolled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

Jireh Communications uses UASs that are multirotor, weighing less than 25 pounds including payload. They operate, under norm al conditions, at speeds not to exceed 45 mph and have the capability to hover, and mo ve in the vertical and horizontal plane. Jireh Communications’ UASs will operate in lin e of sight, during daylight hours, and will only operate within a sterile area. Jireh Communications will operate at or below 400
feet AGL and will file a NOTAM for each f light operated in controlled airspace. All required permissions and permit s would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS.

Given the small size of the sUAS’s involved and the restricted sterile environment within which they will operate, this Jireh Communicati ons’ exemption falls within the zone ofPage 4 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com safety and demonstrate an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will operate, approval of the applicat ion presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, th e equivalent level of safety surrounding the proposed operations, and the significant pub lic benefit, the grant of the requested exemptions is also in the public interest.

IV. Description of Proposed Operations To assist the FAA in its safety assessment of Jireh Communications' proposed sUAS operations, below is a summary of operationa l limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operatio nal flight will be limited to the amount
of time the sUAS can be flown and still main tain a reserve battery power of no less
than 25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flights will be operated at a lateral distan ce of least 100 feet from any inhabited structures, buildings, vehicles, vessels, peop le not associated with the operation or who have not signed a waiver in advance of the operation.

6. Minimum crew for each operation will cons ist of the sUAS Pilot in Command and a
Visual Observer. Additional crewmembers co nsist of a Pilot and a Camera Operator.

7. The sUAS Pilot in Command will have undergone comprehensive UAV / UAS / Drone flight training for competency a nd new FAA 333 and Part 107 commercial compliance requirements.

8. Jireh Communications will designate a Pilo t in Command ("PIC") for each mission.

9. The sUAS will operate only within a confined "Sterile Area".

10. Prior to the operations at a particular lo cation, a site inspection will have been conducted. On the day of the mission the management person with operational
control and the PIC will concur on dispatching of the mission.

11. A briefing will be conducted in regard to th e planned sUAS operations prior to each day's missions. It will be mandatory that all personnel who will be performing duties within the boundaries of the sterile area be present for this briefing.

12. Jireh Communications crew will use the checklist and callouts required in the Operations Manual.

13. All sUAS’s will be maintained in accordance with inspection program specified in the manufacturer’s guidelines.

14. In the event of an accident involving an Jireh Communications sUAS, they will cease operations and report the accident to the NTSB and AFS-80.

15. Pilot in Command and Visual Observer will at all times be able to communicate by

voice.Page 5 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com 16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational
Personnel will have been trained and tested in accordance to FAA, NTSB, and AFS-80 best practices.

17. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

18. Jireh Communications management will submit a written “Plan of Activities” to the local Flight Standards District Office (FSDO) having jurisdiction over the area of proposed filming three days in advanced of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to return to a pre-determined location within the Sterile Area and land.

20. Contingency plans will be in place to safely terminate flight if there is a loss of communication between the pilot and the observer.

21. The sUAS has the capability to abort a f light in case of unpredicted obstacles or emergencies.

22. Jireh Communications, by following FAA, NTSB, and AFS-80 best practices, will assure no individuals’ privacy is violated.

V. Regulations From Whic h Exemption is Requested A. 14 CFR § 91.103: Preflight Action B. 14 CFR § 91.113: Right-of-Way Rules C. 14 CFR § 91.119 (c): Mi nimum Safe Altitudes D. 14 CFR § 91.121: Altimeter Settings E. 14 CFR § 91.151(b): Fuel Requireme nts for Flight in VFR Conditions F. 14 CFR § 91.405(a), 91.407(a)(1 ), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

A. 14 CFR § 91.103: Preflight Action Jireh Communications requests an exemption fr om the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight.

a. Flight under IFR or a flight not in the vici nity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;
b. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

i. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance da ta is required, the takeoff and landing distance data contained therein;
and

ii. For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performancePage 6 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Jireh Communications will not operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. DJI’s sUAS’s do not have published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing
distance data.

Equivalent Level of Safety In adherence to FAA, NTSB, and AFS-80 best practices, the PIC along with the person having operational control must follow to as sure that the weather will be adequate to complete the mission in VFR condition.

B. 14 CFR 91.113: Right-of-Way Rules Jireh Communications request an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may no t pass over, under, or ahead of it unless well
clear.

Jireh Communications operates small pilotl ess UAS’s and cannot comply with these rules as they have been written.

Equivalent Level of Safety Jireh Communications operates sUAS’s at or below an altitude of 400 feet AGL, well below the normal operating altitude of other aircraft. Jireh Communications management require that a Pilot in Command with experience will oversee each mission and has knowledge of the avoid rules. A Visual Observer will assist the PIC in looking for aircraft entering the operations area. It ’s the responsibility of the PIC to cease operations and land the UAS immediately whenev er and aircraft comes into the vicinity creating a potential threat. Operations ca nnot recommence until the threat is clear.

C. 14 CFR. § 91.119: Mi nimum Safe Altitudes Jireh Communications requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescrib es the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town , or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

• Over other than congested areas at an altit ude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operat ing the helicopter complies with any routes or altitudes specifically prescrib ed for helicopters by the FAA."Page 7 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com To provide the intended operations, the sUAS is normally operated below 400 feet AGL. Additionally, due to the nature of the prop osed operations, the sUAS will maintain a
lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation.

Equivalent Level of Safety Compared to flight normal aircraft, Jireh Communications’ multi-rotor aircraft weigh a maximum of 25 pounds, and given the lack of flammable fuel, any risk associated with these operations is far less than those that pr esently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As set forth in the FAA, NTSB, and AFS-80 best practices, the sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their preobtained consent. Because of the advance notice to the property owners and pa rticipants, all affected individuals will be well aware of the planned flight operations prior to commencement of operations.

Furthermore, by operating at such lower al titudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments.

D. 14 C.F.R. § 91.121: Altimeter Settings Jireh Communications seeks an exemption fr om 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising al titude or flight level by reference to an
altimeter that is set to the elevation of the departure airport or ba rometric pressure. An exemption is required because the sUAS does not have a barometric altimeter, but
rather a GPS altitude read out.

Equivalent Level of Safety An equivalent level of safety will be achiev ed by following the procedures set forth in the FAA, NTSB, and AFS-80 best practice s. Jireh Communications will confirm the
altitude of the launch site shown on the GPS altitude indicator before flight. Moreover,
the PIC will use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe altitudes.

E. 14 CFR 91.151(a): Fuel Requirement s for Flight in VFR Conditions Jireh Communications requests an exempt ion from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states:

a. No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather condi tions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed –

i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes.

The batteries powering Jireh Communicati ons’ UAS’s provide approximately 10-25 minutes of powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flights could not be conducte d. Given the limitations on the sUAS'sPage 8 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com proposed flight area and the location of it s proposed operations within a predetermined area, a safety margin based on a reserve amount of battery life is needed. Jireh Communications will not be conducting any sUAS flights at night.

Equivalent Level of Safety An equivalent level of safety will be achi eved because the operations will be conducted on-site without significant transit time by the sUAS. All flights will be planned to
terminate with no less than 25% reserve batte ry power still available. This restriction would be more than adequate to return th e sUAS safely to its planned landing zone from anywhere in its confined area of op eration even in the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151( a) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled areas where only people and property owners, or official representative s who have signed waivers will be allowed.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections
Jireh Communications also seeks an exem ption from the maintenance inspection requirements contained in 14 CFR 91.405(a), 91. 407(a) (1), 91.409(a) (2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating that ea ch owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repa ired as prescribed in part 43 of this chapter"). An exemption to these regulati ons is needed because Part 43 and these sections only apply to aircraft with an airw orthiness certificate, which the sUAS will not
have.

Equivalent Level of Safety An equivalent level of safety will be achi eved because maintenance and inspections will be performed in accordance with FAA, NTSB , and AFS-80 best practices. The operator will ensure that the sUAS is in working orde r prior to initiating flight, perform required maintenance, and keep a log of any maintena nce performed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the e quivalent level of safety.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will only take place in restrict ed areas for limited periods of time during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation.

VI. PUBLIC INTEREST Granting Jireh Communications an exemption furthers the public interest. National policy set by Congress favors early integratio n of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. The one vision of Jireh Communications is to help facilitate safe integration of sUAS’s into mainstream USA in the following areas:Page 9 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com Movies and Videography Whether the shot requires unique views and expansive panning or extreme altitude with radical views, the UAS is designed to hold up under demanding conditions. Because of the autopilot feature with pre-design ed mission management and R/C control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD still photos. When working close in on a closed set the hazards to the actors are greatly reduced due to the size of the sUAS.

News Gathering Similar to movies and videography, each ne ws assignment may require a completely
different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the UAS is the perfect soluti on to allow for easy news gathering for a
fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, while the traditional helicopter must ho ver over persons and property increasing the danger to individuals.

Real Estate
The sUAS can be used in all areas of real estate, including commercial, residential and industrial properties. Using a sUAS, real es tate professionals ca n create promotional videos, photos and unique shots that normal camera aspects cannot capture. Jireh Communications’ easy-to-use vi deo and photo platform enable s properties to stand out, providing dazzling views that are typically shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high-rise condo in stunning high definition that shows your potential cu stomer the actual view from the residence. The remote platform is great for new pla nning, zoning and large developments. Simple and easy-to-use video and photos allow for mult iple height pictures and elevation views.

VII. Privacy Jireh Communications is deeply committe d to protecting public privacy. Jireh Communications knows that many individual have concerns about privacy from the operations of sUAS’s. Jireh Communications has created a privacy notice that informs residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct co mmercial drone operations in proximity to their property.

VIII. Federal Registry Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be dete rmined that publication is needed:
Jireh Communications seeks an exem ption from the following rules: 14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.405(a), 91.407(a) (1 ), 91.409(a) (2); 91.417(a) and (b).

Approval of this exemption request allows Jireh Communications to conduct commercial operations with small and lightweight unma nned aerial systems. Jireh Communications’ singular vision is to enhance safety of sUAS operations in the NAS while reducing risk to the general public and property owners.Page 10 of 10

625 W. Deer Valley Rd., # 103204 • Phoenix, AZ 85027 • (602) 674-5675 www.jirehcom.com The DJI sUAS, weighing less than 25 pounds and powered by batteries, eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far sa fer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for Exemption, please contact the undersigned at:

With Best Regards,

Carl Ulbrich, President
Jireh Communications Inc. (602) 674-5675 Email: carl@jirehcom.com