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 exemptio n 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 advertisi ng 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 prov ide 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 consume r 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 flam mable 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 ag reement 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 i nterrupted, return home GPS point is set before each flightLow 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 requ irements 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 la w. 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 obser ver 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. W ill 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 unap proved 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 previ ously 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 government al laws.

# Appendix

S ection 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) Airworthine ss 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