To	the	Federal	Aviation	Authority	(FAA),

Jay	Gee	Holdings, LLC hereby	request	exemption	from	part	21,	subpart	H;	and	Sections	45.23(b),

61.113(a)	and	(b),	91.7(a),	91.9(b)(2),	91.103(b),	91.109,	91.119,	91.121,	91.151(a),	91.203(a)	and	

(b),

91.405(a),	91.407(a)(1),	91.409(a)(2),	and	91.417(a)	and	(b)	of	Title	14,	Code	of	Federal	

Regulations	(14 CFR).

I	support	our	request with	the	following	information:

Jay	Gee	Holdings Inc. plans to	operate	two	UAS,	the	Yuneec Q500 Typhoon	and	the	DJI	Inspire	I.	

Both	are comprised	of	an	unmanned	aircraft	and	a transportable	ground	stations.	

The Q500 is	referred	to	as	a quad-copter	with	a maximum	gross	weight	of	about	1.7 kilograms. It	is	

equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	by	a battery.	The	UA	has	a

maximum	airspeed	of	8 m/s.	The	quad-copter utilizes	a built	in high	definition camera	system and	

is	supported	by	a	ground	station.

The	Inspire	1 is	referred	to	as	a quad-copter	with	a maximum	gross	weight	of	about	3 kilograms.	It	

is equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	by	a battery.	The	UA	has	a

maximum	airspeed	of	22	m/s.	The	quad-copter has a built	in	high	definition	camera.	It	is	supported	

bya	ground	station.

Jay	Gee	Holdings	Inc.	is	a privately	held company	that	owns	a Cessna	Citation	560	and	leases	Bell	

206	Helicopters	that	are flown by	professional	pilots. Its	sister	company	Triple	J	community	

Broadcasting	offers clients	comprehensive	video	production	services	and	produces	television	

shows,	commercials, and	online	and	social	media	content. Jay	Gee	Holdings	plans	to	man	and	

operate	the	UAS	aircraft	in	support	of	videography shoots	throughout	the	United	States to	enhance

television	productions	and	media	quality.	

We	will	only	operate	in	reasonably	safe	environments	that	are	strictly	controlled,	are	away	from	

power lines,	elevated	lights,	airports	and	actively	populated	areas;	and we will	conduct	extensive	

preflight	inspections	and	protocols,	during	which	safety	carries	primary importance.

Given	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the	aircraft	to	be utilized,	

an	exemption	from	14	CFR	part	21, Subpart	H (Airworthiness	Certificates)	and	§ 91.203	(a)	and

(b)	(Certifications	required),	subject	to	certain	conditions	and	limitations,	is	warranted	and	meets	

the requirements	for	an	equivalent	level	of	safety	under	14	CFR	part	11	and	Section	333	of	P.L.

112-95 (Section	333).

We request	an	exemption	from	§ 45.23	Marking	of	the	aircraft	because	this UA	will	not	have	a

cabin, cockpit	or	pilot	station	on	which	to	mark	certain	words	or	phrases.	Further,	that	two-inch

lettering	is	difficult	to	place	on such	a small	aircraft	with	dimensions	smaller	than	the	minimal	

lettering requirement.	Regardless	of	this,	we will	mark	the UAS	in	the	largest	possible	lettering	by	

placing the	word	“Experimental”	on	its	fuselage	as	required	by	§ 45.29(f)	so	that	anyone	assisting	

as	a spotter	will	see	the	markings.

We	request	an	exemption	from	§§	91.405(a),	91.407(a)(1),	91.409(a)(2)	and	91.417(a)	and	(b)

Maintenance	inspections	may	be	required	and	should	be	granted	since	they	only	apply	to	aircraft	

with an	airworthiness	certificate.	However,	we will	perform	a preflight inspection	of	the	UAS	

before	each	flight	as	outlined	in	the	aircraft	operating	documents.
UAS	Pilot	in	Command	(PIC)

The	UAS	aircraft	will	be	operated	by	professional	pilots with	commercial	ratings	or	higher and	will	

adhere	to	all	rules	and	regulations	pertaining	to	flight	operations. They	will	utilize	computer	

simulations	and	conduct	practice	flights	to	maintain	skill	sets	to	operate	the	UAS	aircraft	in	a	safe	

and	professional	manner.

UAS	Operating	Parameters:

We will	abide	by	the	following	additional	operating	conditions	under	this exemption.	Both	

aircraft	will	have	a	predetermined	flight	path	agreed	upon	by	the	pilot	and	videographer/	

cinematographer	assigned	to	the	mission.	For	the	Q500	aircraft	the	pilot	in	command	will	

maintain aircraft	control	and	take	guidance	for	the	resulting	picture	or	video	capture	from the	

videographer.	For	the	Inspire	1	aircraft	the	pilot	in	command	will	fly	the	prescribed	flight	path	

and	maintain	aircraft	control	while	the	videographer/cinematographer	will	control	the	

onboard	camera	system	with	a	slave	ground	station	to	obtain	the	desired	picture	or	video	

capture.

• The	UAS	aircraft	will	be	operated	at	or	below	300	feet	and	within	a radius	distance	of	1000	feet	

or	less	from	the	controller	to	both aid	in	direct	line	of	sight	visual	observation (VLOS)

• The	Q500	aircraft will	have	a	flight	time	of	7 minutes	not	to	exceed	10	and	land	as	soon	as	

possible	in	the	event	of	a	battery	low	volt	warning.

•The	Inspire	1	aircraft	will	have	a	flight	time	of	 7 minutes	not	to	exceed	10	with	battery	

TB47(4500mAh)	or	8	minutes	not	to	exceed	11	with	battery	TB48(5700mAh)	and	will	land	as	soon	

as	possible	in	the	event	of		battery	low	volt	warning.;

• UAS	aircrafts global	positioning	system	(GPS)	flight	safety	feature	whereby	it returns	to	a	preset	

home	point hovers	and	then	slowly lands	if	communication	with	the remote	control	pilot	is	lost	

will	be	utilized	at	all	times.

• Conduct	all	operations	under	flight	safety	protocols	(including	posting	a warning sign	reading:	

“Attention	Aerial	Photography	in	Progress – (Remain	Back	150	feet”)	contained	in	the operating	

documents	and	will	actively	analyze	flight	data	and	other	sources	of	information	to	constantly

update	and	enhance	safety	protocols;

• Contact	respective	airports	if	operations	will	be	within	5 statute	miles	to	advise	them	of	

estimated flight time,	flight	duration,	elevation	of	flight	and	other	pertinent	information;

• Flight	crews	will	obtain	all	necessary	permissions	prior	to	operation;	and have	procedures	in	place	

to	abort	flights	in	the	event	of	safety	breaches, weather	anomalies	or	potential	danger.

§ 91.7(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	certificate.	Since there	is	

currently	no	certificate	applicable	to	this operation,	this	regulation	is	inapplicable.

§ 91.9(b)(2) requires	an	aircraft	flight	manual	in	the	aircraft,	however	since	there	are	no pilots	or	

passengers	on	board	his	aircraft	and	given	its	size,	this	regulation	is	inapplicable.
§ 91.119	prescribe safe	altitudes	for	the	operation	of	civil aircraft,	but	that	it	allows	helicopters	to	

be	operated	at	lower	altitudes	in	certain	conditions.	We	will	not	operate	UAS	aircraft	above	the	

altitude	of	300	feet	above	ground	level	(AGL)	and	will	also	only operate	in	safe	areas	away	from	

the	public	and	traffic,	thus	“providing	a level	of	safety	at	least equivalent	to	or	below	those	in	

relation	to	minimum	safe	altitudes.	Given the	size,	weight, maneuverability,	and	speed	of	UAS	

aircraft an	equivalent	or	higher	level	of	safety	will	be	achieved.

§ 91.121	Altimeter	settings	is	inapplicable	since	UAS	aircraft	utilizes	electronic	GPS	with	a

barometric	sensor.

Public	Interest

Aerial videography	and	photography	for brands,	events,	and	television	has	been	around	for	a long	

time	through	manned	fixed	wing	aircraft	and	helicopters,	there expense has	been	cost-prohibitive

for	a	lot	of	productions	that	would	give	the	public	views	and	understanding	of	nature and	

surrounding	beauty.	The	unobtrusiveness	of	the	UAV	with	low	noise	and	the	high	quality	video	will	

allow	videographers	to	offer	many	prior	unobtainable	views. Granting	this	exemption would	allow

our	company to	provide this	service	at	a much	lower	cost. This	aircraft	will	directly	support	

Warriors	Outdoor Summit,	a production	that	features	returning	veterans	from	war	to	cope	with	

their	injuries	while	enjoying	hunting,	fishing	and	other	outdoor	activities.

Further,	we	would	like	to	indicate	that small	UAS	will	pose	no	threat	to	the	public	given	its	small	

size	and lack	of	combustible	fuel	when	compared	to	larger	manned	aircraft.	We would	also	like	to	

state	that	the operation	of	our	UAS will	minimize	ecological	damage	and	promote	economic	

growth	by	providing information	to	companies	or	individuals	looking	to	relocate	or build	in	the	

areas	that	are	served	by	our	companies.

(end	of	petition)

We	would	like	to	conclude	our petition	by	sincerely	thanking	the	FAA	for	their	consideration	and	for	

taking the	time	to	look	at	Jay	Gee	Holdings	Inc.	petition. While	Videography is	our sister’s	company			

passion	and	their work, we want	to	provide	aerial platforms	that	will	help	them	achieve	there	goals.

We	are	always looking	to	stay	on	the	forefront	of	new	videography	techniques	and	believe	their is	a

wonderful opportunity	with	these	safe,	reliable	UAs	that	will	only	allow	us	to	further	provide	a

masterwork product to	our	clients.	Thank	you	again	and	I look	forward	to	hearing	from	you	in	the	

near	future.

Best Regards,

Joseph	S.	Gans	III	

President	Jay	Gee	Holdings	Inc.

Manager	Tripple J	Community	Broacasting	Inc.

(www.wylntv)

1059	E.10th St.	Hazleton	PA.	18201

Office	570-455-4251

joegans@cabletvmtnc.com