August 7, 2015

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Pursuant to section 333 of the FAA and 14 C.F.R. part 11.81.

IN THE MATTER OF A PETITION FOR 333 EXEMPTION OF:

Name and Address of Petitioner:

James C. Carter

DBA - Jimmy Carter’s Flight School

2450 Montecito Rd. Ste. 216

Ramona CA. 92065

flyjcfs@yahoo.com

I am submitting my Petition for a 333 Exemption to Operate sUAS (small Unmanned 

Aircraft System) for the following activities:

Aerial photography and/or video capture, coverage of events, flight

instruction, structural inspections of buildings, bridges, pipelines, and cell 

towers, real estate marketing, surveys and mapping, and wind turbine 

inspections. Additionally, can provide assist with search & rescue operations if 

requested by appropriate agencies.

I hereby petition for exemption from the following 14 CFR Parts:

14 CFR FAR part 21, subpart H Part 36

61.101 (e) (4) & (5) 61.113 (a) & (b) 

91.7 (a) 91.119 (c)

91.121 91.151(a)

91.405 (a) 91.407 (a)

91.409 (a) (1) & (2) 91.417 (a) & (b)
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Relief Sought: 

Jimmy Carter’s Flight School requests a 333 Exemption to operate sUAS for the 

commercial purposes as stated above. This relief is sought because the commercial 

use of a sUAS is currently prohibited unless performed under a 333 Exemption.

Owner operator: James C. Carter, Commercial Pilot, Airplane Single & Multiengine 

Land, Instrument Rated, Current 2nd Class Medical. 

Gold Seal Flight Instructor: over 5000 hrs. instruction given and 5600 hrs. as PIC 

(350 hrs. twin), taught Part 141 for over 5 years, Jimmy Carter’s Flight School 

opened June 1996. Military service E4 U.S.M.C. Honorable Discharge.

As a long time and current CFI II with thousands of flight hours in both SEL and 

MEL aircraft, and a constant advocate for aviation safety, I’m certain I can 

successfully and safely operate a sUAS commercially under a 333 Exemption. I have 

flown radio controlled aircraft since childhood. Because of my keen interest in 

aviation safety, over the years I have served as a FAA Aviation Safety Counselor,

conducted many safety trainings & meetings, helped organize and execute area air 

shows, and have become a reliable source of ‘safety-first’ flight instruction in the 

Southern California area. Additionally, I will be able to contribute to the overall safe 

integration of sUAS aircraft into the NAS by teaching safe and prudent sUAS 

operations to the anticipated newcomers to these aircraft; I could be a great addition 

to the San Diego FAST team.

Description of sUAS:

If the exemption is granted, I will be flying N8494C a DJI Phantom 3 Professional 

sUAS, and it is described below:

a. 4 motor Quad-copter weighing less than 3 pounds

b. HD/UHD camera for video and/or still images

c. Operates on a rechargeable battery, no flammable fuels

d. GPS, compass and related sensors that provide extremely stable and accurate 

flight and positioning controls

e. Features a number of fail-safe features including automatic return-to-home, 

flight distance & altitude limiter, and no-fly zone capabilities

f. Remote Control provides full access and control of all flight aspects, plus a live 

HD video feed allowing operator to see exactly where aircraft is and all related 

flight telemetry 
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Public Benefits:

 

a. Reduces risk to human life versus manned aircraft flights with flammable 

fuels

b. Dangerous activities that can be avoided (scaffolding or rigging failures during 

bridge/tower/construction inspections)

c. Reduces the cost of obtaining such information, which benefits consumers and 

the economy

d. Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft

e. Allows me to help the public learn safe sUAS operations and assist the local 

San Diego FSDO with a growing new industry

f. Can assist with search & rescue and/or fire operations activities, if requested

 

Safety Not Adversely Affected:

a. All sUAS operations will be conducted safely while complying with all current 

and future FAA rules and regulations, as well as ‘safety first’ procedures such 

as:

a. Complying with all manufacturer pre-flight & post-flight check lists

along with evaluations of current flight and location conditions 

b. Utilizing the manufacturer’s Flight and Operations Manuals

c. Flights will be conducted in VFR conditions during daylight hours and 

will not exceed 400 AGL 

d. No operations over densely populated areas or within 5 miles of an 

airport

e. Flights will be conducted by a current CFI or Private Pilot with a 

Visual Observer (VO) in light of sight and with verbal communication 

capability

f. Aircraft N8494C will be marked in accordance with section 47.3. The 

above mentioned aircraft are so small that the markings will have 

alternative marking procedure. See 14 CFR 45.22(d); 45.29(f)

Suggested Public Federal Register Summary:

“The petitioner is seeking an exemption to operate small unmanned aircraft systems 

(sUAS) weighing less than 55 pounds to offer affordable aerial photography and 

video services to businesses and individuals. Services may include: event coverage,

structural inspections of buildings, bridges, pipelines, cell and wind tower inspections, 

real estate surveys, mapping and marketing, sUAS flight instruction, and search & 

rescue operations.”
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Overall Summary:

Based on my significant aviation experience and ‘safety-first’ perspective, coupled 

with my operational goals and protocols outlined above, I believe I am uniquely 

suited to be awarded the requested 333 Exemption so I can begin safe sUAS 

commercial operations and assist with the successful integration of sUAS aircraft by 

instructing newcomers on how to fly safely within the NAS.

Regards,

James C. Carter