July 8, 2015

Jacob Jones 1351 Grand Canyon Cir Franklin, IN 46131 Cell (219) 669-7622

Email: jjones1986@gmail.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 2012

Attachments: 1) Phantom 2 Vision+ User Manual V1.6 2) 3DR Solo User Manual 3) Flight Log

References: 1) FAA Exemption No. 11138, Regulatory Docket No. F AA20140481 in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. F AA–2014–0508 in the matter of the petition of ADVANCED AVIATION SOL UTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FA A20140355 in the matter of the petition of FLYING CAM INC

4) FAA Exemption No. 11437 Regulatory Docket No. FA A20150221 in the matter of the petition of MARCUS D MELHUS

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012 , I Jacob N. Jones, referred to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b); In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (F AA) for the purposes of aerial photography, cinematography, videography, and other flight opera tions that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be in support of local firedepartments and related emergency service agencies, focusing on pre-incident planning and

imaging that would form the basis for incident acti on plans in the event of a real emergency. Operations will be performed only at the request of and with the authorization and permission of clients (municipalities) or their authorized age nts in order to improve incident pre-planning

and raise awareness of the beneficial uses of small unmanned air systems for use within the fire service to improve their ability to respond in the event of a real incident. So long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as requi red by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1-3.

The FARs The petitioner seeks exemption from the above menti oned FARs for the following

reasons; 61.113(a) & (b) ; The petitioner requests relief in order to facilita te the utilization of an experienced UAS operator with the addition of a trained observer. A ll pre-flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civi l UAS operation in the National Airspace System. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be pos sible without additional relief. The petitioner requests modification, waiver or exemption and clar ification concerning the terms “congested areas” and “densely populated”. The petitioner requ ests waiver for this condition to allow reasonable and responsible operations in areas of s ubdivisions and neighborhoods if required. The petitioner will primarily operate the UAS betwe en ground level and 200 feet. The UAS will be operated over designated properties with the con sent of the local municipality or their designated agent and while maintaining a safe dista nce from persons. The petitioner will compile flight data from the logs. This data may as sist the FAA in development of regulations for commercial operations in low-risk, controlled e nvironments.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) i s inapplicable since the

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for

altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytim e, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power manage ment. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches aspecified level. Given the limitations on proposed operations and the location of those

proposed operations, The FAA found that a reduced m inimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.41 7(a) & (b) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition f or safe flight in accordance with the operating documents. The FAA found that adherence to the peti tioner’s operating documents and the conditions and limitations specified, describing th e requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that s afety would not be adversely affected.

The UAS The DJI Phantom 2 vision plus & 3DR SOLO are highly successful consumer grade small rotorcrafts in the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry aloft a high de finition camera. It has an advertised maximum speed of less than 30 knots (15m/s) and a m aximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm). It utilizes an interna l inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primaril y through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control came ra angle. It has failsafe modes of operation for either loss of RC or GPS signal. Alti tude can be limited by the onboard flight controller and maximum altitude can be preprogramme d by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flig ht controller will warn the pilot via telemetry and external lighting cues before reachin g a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usua lly last less than 12 minutes. More information is

available in attachments.

Risk mitigation The petitioner has reviewed FAA exemptions referenc e’s 1-3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure that the UA airwor thiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record t ime on failure prone components. These

documents will be made available to the FAA and SoT to assist in future implementation of safety standards and regulations. The petitioner wi ll only operate the UAS over designated properties with the clients consent. Flight plans w ill be predetermined to limit the UASs flight time and limit safety concerns. The petitioner will take into account distance from persons and potential flight obstacles prior to operating the U AS. UAS operation will always be within VLOS

of the PIC and the observer.Public interest

Use of the UAS in lieu of a manned aircraft would e nhance safety and reduce the environmental impact as compared to similar operati ons conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. With the ability to easily and cost effectively gain a perspective of complex and possi bly high risk environments, fire departments can more effectively develop pre-plans to mitigate any situations that arise. Moreover, the ability to periodically review building roof modifi cations and loads significantly improves situational awareness and improves the safety of bo th firefighters and occupants. Additionally, effective use of this technology will allow smaller fire departments to maximize their resources on mitigating actual issues as opposed to wasting p recious time getting a “big picture” perspective in a real incident. Operations for this petition will enable fire departments to gain an enhanced perspective for characteristics, exposu res and hazards associated with a particular property that cannot be gained through ground level inspection. Aerial surveying and inspections can increase planning efficiency, impro ve resource estimations, and reduce risks to personnel and property. The petitioner will provide clients with photograph ic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control Unit operation ti me, incident, accident, and details concerning any deviations from normal operations will be avail able to FAA for use in collecting data regarding the use of UAS as part of this applicatio n. This data may be submitted to FAA via traditional means or other means as required.

Conclusion The petitioner is 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 the petitio ner wishes to provide services to fire departments and other emergency service providers t hat can only be provided through the quick deployment and cost effective operations prov ided by a UAS. It is believed that these services will allow clients to significantly improv e their pre-planning and situational awareness which in turn will lead to more efficient mitigatio n of incidents, thereby reducing property loss and improved the safety of both building occupants and emergency services personnel. The petitioner's business model is based on the idea of offering ad hoc small UAS services to clients who wish to employ these services as a safe, effect ive, and legal option to enhance their operations. By providing this service to multiple c lients, the petitioner can ensure adherence to standards and protocols and can develop and refine generally applicable safety guidelines and processes. The petitioner has refrained from engagi ng in commercial use of the UAS. The primary purpose of seeking this exemption is to obt ain the capability to offer those services while remaining in compliance. The petitioner has 4 years of experience in the radio control model aircraft hobby.

Respectfully submitted

Jacob N. Jones