FAA-2015-0150

Andy Hawley

JTV

152 W. Michigan Ave.

Jackson, MI 49201

517-787-8817 – Office

517-783-5060 – FAX 

ahawley@jtv.tv

Petition for Exemption 14 CFR § 11.81 – DRONE EXEMPTION

FAA-2015-0150

RE: SECTION 333 

My name is Andy Hawley, Director at JTV in Jackson, Michigan. We operate a local 

TV channel and full service Media Company. Over the past year we have seen many 

UAS’s enter the marketplace. Our specific commercial use is aerial shots for video 

production, corporate video and golf courses. There is a market for this type of 

work and we would like to proceed under the legal guidelines of the FAA in this 

section. 

We intend to use a DJI Phantom II drone in our operations. The design and 

operational requirements are included in this petition as an attachment (operations 

manual).

1. Safety Operations. At all times, our operator will observe all safety requirements 

before, during and after every flight. We will minimize risk to the UAS in every way. 

We will ensure the safety of any persons on the ground in the vicinity of the drone 

operation.

Our operation of the drone will be in strict accordance of our safety procedures and 

the operator will be required to conduct a pre-flight safety checklist.

2. Procedures

The rules we have implemented include:

No operation above 200 feet

No operation within 6 miles of any airport or flight path

Operations will be during daylight hours

Drone must be operated so the drone is within sight range of the operator at all 

times

Drone will not be operated anywhere near the public, including public events, 

sporting activities, populated public places, events, parades, etc. 
No person, other than the drone operator and his or her assistant may be in the 

vicinity of the drone operation

The drone may not be operated by anyone other than a trained operator

An assistant will be required in order to operate the drone

Every operation will require a trained operator and an assistant

The assistant will be trained

The assistant will have safety as their primary responsibility and will warn the drone 

operator if any persons enter the immediate area of the operation

The drone will be completely inspected before and after each use

Drone operators will be completely trained and tested before operating the drone

Drone operators will be required to perform drone operations in a testing scenario 

before being permitted to operate the drone

Drone operator will be required to read the drone operation manual completely 

before operating drone

3. Frequency The drone will be operated remotely, using the manufacturer’s 

supplied transmitter and receiver. They operate on a frequency of 5.728 to 5.85 

GHz. The working frequency is 2.4ghz wi-fi for mobile device link.

The transmitter and receiver devices comply with all FCC regulations and rules

The weight of the drone is 2.9 lbs. The drone has a built in video and still camera 

provided by manufacturer and housed within the drone.

4. Qualifications of PIC operators

PIC operators will undergo a vigorous training period which will include classroom 

and field instruction. All PIC operators will be required to serve as an observer on a 

minimum of 15 flights before assuming PIC command. All PIC operators will be 

required to perform a safety checklist before each flight. An observer/assistant will 

be required on all flights.

Observers will be required to undergo the same training as a PIC operator, with the 

exception of actual drone operation

5. Basic first aid training will be required of all PIC operators and observors

6. Intended use – JTV will use the drone to create videos and stills to be used in a 

variety of applications: Golf course layout videos, farm observation/recording 

videos, segments for television commercials. No persons will be allowed present 

during flight in the vicinity of the flight. We will provide the highest level of safety 

at a minimum equivalent to the rule we seek exemption. At no time will our 

operation adversely affect safety or property.

7. The maximum operating speed will be 20 feet/second. The maximum altitude 

will be 190 feet. The area of intended operation will be completely scrutinized 

immediately before flight to ensure there are no persons in the vicinity and no 
hazards to operation.

8. The area of intended operation is primarily flatland, in non-populated areas. The 

drone will not be operated over water or over any street, highway or railway.

9. Airport proximity: We will not operate the drone within 6 miles of any airport or 

in accordance with statutory mandate under section 333.

10. Line of Sight: The drone will be operated at all times and without exception in 

line of sight of the operator. We will comply with this mandate by thorough training 

of operators and observers. Operators and Observers will be required to cease flight 

should the drone not be visible at any time. The drone will only be operated on 

clear days and in broad daylight.

11. The drone will undergo a pre-flight safety check, with all systems being tested 

before flight. The drone pre-flight safety check will be followed by a visual 

observation test where the drone will be raised to 7 to 10 feet for final testing. The 

operator will perform the pre-flight safety check before each operation. The testing 

will ensure that the entire flight can be conducted safely.

12. We don’t intend to use the drone outside of any rules, regulations or guidelines

We respect the FAA Guidelines and would never use UAS near crowds, public events, 

highways, airports or above the heights currently prohibited.

I humbly request the FAA grant us exemption for use of commercial UAS under 

guidelines and regulations currently listed. I also support the FAA’s proposal to 

eliminate the requirement for a pilot’s license to be obtained for commercial use.

Thank you for your swift response.

Cordially,

Andy Hawley

Director

JTV, Inc.

152 West Michigan Avenue

Jackson, MI 49201

517-787-8817

ahawley@jtv.tv

www.jtv.tv