August 7 , 2015

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., S E

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 P etitioner:

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 Syste m ) for the following activities:

A erial p hotography and /or video capture

, coverage of events

, f light

instruction, s tructural inspections of b uildings, bridges, pipelines, and cell

towers

, r eal estate marketing

, surveys and mapping

, and wind turbine

inspections

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

requested by appropriate agencies.

I h ereby 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)2

Relief S ought:

Jimmy Carter ’ s Flight School request s a 333 Exemption to operate s UAS for the

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

use of a s UAS is currently prohibited unless performed under a 333 E xemption.

Owner operator: James C

. Carter

, Commercial Pilot

, Airplane S ingle & Multiengine

L and , I nstrument Rated

, C urrent 2nd C lass Medical

. Gold Seal Flight Instructor: over 5000 h rs

. instruction given and 5600 hrs. as PIC

( 350 hrs. t win ), t aught P art 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 C ounselor,

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

S outhern 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 anticipa ted 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 r echargeable battery , no flammable fuels

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

flight and positioning controls

e. F eatures 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 acces s and control of all flight aspects

, plus a live

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

flight telemetry3

Public B enefits :

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 ben efits consumers and

the economy

d. Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft

e. Allows m e to help the public learn safe s UAS operations and assis t the local

San Diego FSDO with a growing new industry

f. C an assist with search & rescue and/or fire o perations activities

, if requested

Safety N ot A dversely A ffected :

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 ex ceed 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

. T he

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 exemp tion 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,

re al estat e surveys, mapping and marketing, sUAS flight instruction, and search &

rescue operations.”4

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

instruc ting newcomers on how to fly safely within the NAS.

Regards,

James C. Carter