J and J Studio, LLC

4705 Sea Ridge Court

Fort Worth, TX 76133

817-673-1743

jason@jandjstudio.com

J and J Studio, LLC is petitioning the Federal Aviation Administration (FAA) for an exemption to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR part 11. 

J and J Studio, LLC is a Texas based limited liability company desiring to supply sUAS aerial photography and 

videography to local businesses. The exemption would allow J and J Studio, LLC to operate commercially a sUAS 

(small unmanned aircraft system), identified as a DJI Phantom 3 Professonal with a small integrated camera safely 

and securely mounted using a mechanical stabilizer for the purpose of aerial videography and photography for:

1: Real estate

2: Constructions site processes

3: Landscape imagery

4: Insurance claims due to natural disasters

5: Private and public events while operated away from the population, 

6: Aerial mapping

7: Business advertising

8: Cinematography

9: Search and Rescue Operations

J and J Studio, LLC agrees to operate within the boundaries set forth by this exemption and to provide a 

professional and safe service in the aerial photography and videography field.

The ability to provide these services to local businesses and individuals in our community will benefit 

them by opening up opportunities they otherwise could not have. Traditional methods of aerial 

photography/videography are simply not viable options for the average consumer as they are not cost 

effective and involve great risks to everyone involved. A sUAS drone operation is much more affordable 

& safer to the community and better for the environment than the traditional aerial option for instance 

the sUAS does not use flammable fuel, it does not emit carbon dioxide, it does not hold a pilot, or cargo, 

it is small and l 

The safe operation of the sUAS will be the first priority before, during and after every operation, flight operator 

and spotter will inspect all aspects of the drone, the batteries and the controller to ensure safe and proper 

operation, before take off the internal GPS locks in coordinates in case the return to home function is enabled. If 

for any reason these safety protocols fail or the weather is not in agreement the drone will not be operated.

A post flight check will also take place at the change of each battery.

The DJI Phantom 3 has numerous safety features such as: 

FPV. Pilot can clearly see where drone is flying and what is in front of the drone, the FPV combined with line of 

sight ensures flight safety.

Failsafe mode. Engages the UAS to safely return home and automatically land should signal between controller and 

UAS be interrupted, return home GPS point is set before each flight
Low battery alerts. If the battery lowers to 20% the phantom will alert user but can also utilize GPS to return home 

(starting GPS point) should battery levels begin to reach a critical point. 

No fly zones. The Phantom 3 Pro includes a no fly zone feature in which it will not function if in the region of a class 

A or B fly zone

The UAS to be used meets all operational limitations of the Major Provisions of Proposed Part 107:

The sUAS DJI Phantom 3 Pro has a weight of less than 4 pounds making it below the 55 pound limit, a length of 16 

inches and a width of 16 inches, height of 8 inches, and has a max speed of 20m/s mph putting it far below the 

100mph limit.

The UAS has readable markings of red, blue and black to identify the device.

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, the petitioner 

will:

a. Only operate its sUAS in direct visual line of sight of the pilot and observer without use of a

visual aid other than corrective lenses.

b. Operate at an altitude no greater than 400 feet above ground level.

c. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid

any conflicts with manned or other UAS aircraft that may enter the sUAS operating area. The

UAS flight will be immediately terminated if a potential conflict may exist. The sUAS will yield to all manned 

aircraft at all times.

d. Operate over private or public sites only with prior permission from property owner or

owner’s agent or legal authorities as allowed by law.

e. Terminate flight when any unsafe condition exists.

f. Terminate flight when battery voltage drops to 20% of battery capacity or when the low

battery alert occurs per the Instruction Manual.

g. Operate at a ground speed of 0 to 40 knots during on site missions, current sUAS maximum speed is 

13 knots.

h. Operate in accordance with the guidance and standards set forth by the sUAS manufacturer and

the administrator.

h. Operate with a minimum crew for each operation consisting of the PIC and a visual observer in

direct communication utilizing appropriate verbal, radio or cell phone as needed.

i. No UAS operations will be conducted within 5 miles of an airport.

j. Will not "create a hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b)

All sUAS operations shall take place during daylight hours under proper conditions equivalent to Visual Flight Rules 

(VFR) with the sUAS no more than 1/2 mile from the PIC.

At no time shall the sUAS be operated with missing or manufacturer unapproved parts, or in any condition that 

could pose a hazard to any other aircraft or structure or person on the ground.

The requests of this petition are similar to those of Mr. Jase W. Robak, Mr. Todd Thomas Drone Pics, and 

Mr. Mike Lloyd Lloyd & Associates, all of whom have received Section 333 exemptions for comparable 

aircraft for similar operations.

Regulations from which the exemption is requested:

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 
14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b)

Included in this petition is the operating manual of the sUAS DJI Phantom 3 Pro, the smart battery instructions and 

the safety guidelines document from DJI.

Summary:

J and J Studio, LLC is requesting an exemption for the purpose of operating a sUAS to provide aerial videography 

and photography for real estate, constructions site processes, landscape imagery, insurance claims due to natural 

disasters, private and public events while operated away from the population, aerial mapping, business 

advertising, and cinematography . 

The use of a sUAS will provide a benefit to the general public and serve the public interest by providing the service 

of aerial photographic images and video to numerous businesses and individuals for considerably less than the 

previously only available option of utilizing manned aircraft at a greater level of safety. With the market in high 

demand of this service, J and J Studio, LLC desires to provide this service with safety and quality in mind while 

abiding by local and governmental laws. 
Appendix 

Section Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on vehicle 

Insufficient space on vehicle

14 CFR Part 21 Aircraft certification 

requirements and procedures 

Designed for manned aircraft; 

not suitable for off-the-shelf 

UAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements designed 

for manned aircraft, not UAS; 

petition describes training for 

UAS operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; 

not suitable for off-the-shelf 

UAS 

14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls 

during flight instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read