Jon Carlson dba. JccMedia 12/21/2015

JccMedia 

22 Celeste Ct 

Novato CA

541-254-4676 

jc@jccmedia.com

Federal Aviation Administration:

Dear Sir or Madam,

I, Jon Carlson dba. JccMedia, am writing pursuant to the FAA Modernization and Reform Act of 2012

and the procedures contained within 14 C.F.R. 11, to request that I, Jon Carlson, an

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation

Regulations (“FARs”) listed below so that I, Jon Carlson, may operate a small ultra light

weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the

Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations &

Policies.

The Extent of Relief Jon Carlson dba. JccMedia Seeks exemption from: 

4 C.F.R. Part 21:

Airworthiness Certificates Given the size and limited operating area associated with the

aircrafts to be utilized by I, Jon Carlson, an exemption from Part 21 meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the reform

Act. In all cases, an analysis of these criteria demonstrates that the UA operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed

will be at least as safe, or safer, than conventional aircraft operating with an airworthiness

certificate without restrictions and conditions proposed. 

14 C.F.R. 45.23: 

Display of marks: general The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or

tail on which to mark certain words or phrases. Further, the two inch lettering is difficult

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

requirement. 

14 C.F.R. 61.113(a) & (b): 

Private pilot privileges and limitations: Pilot in

command The FAA has previously declared that additional manned airship experience of

a commercially certified pilot would not correlate to the airmanship skills necessary for

similarly proposed operations in previously issued exemptions to this regulation through

Exemption Nos. 11062 and 11138. 

14 C.F.R 91.7: 

Civil aircraft airworthiness Currently,

since there is no certificate applicable to the UAs in question, this regulation is

inapplicable. 

14 C.F.R. 91.9 (b)(2): 

Civil aircraft flight manual, marking, and placard

requirements Requires an aircraft flight manual in the aircraft, however there are no pilots

or passengers on board this aircraft and given its size, this regulation is inapplicable. An
equivalent level of safety will be achieved by maintaining a safety/flight manual with the

operator. 

14 C.F.R. 91.119(c): 

Minimum safe altitudes I, Jon Carlson will ensure that

UAS do not operate any higher than 400 feet at ground level. I will not fly over congested

areas. I will plan operations before hand, for proper flight safety, and proper height

analysis as to avoid collisions. 

14 C.F.R. 91.121: 

Altimeter settings The UAS utilize

electronic GPS with a barometric sensor. An equivalent level of safety will be achieved

by using this. 

14 C.F.R. 91.151(a)(1): 

Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries that

currently have a flight limit of approximately no more than 20 minutes. Therefore, due to

the limitations of the batteries, it is currently impossible to comply with part 91.151. 

14

C.F.R. 91.203(a) and (b): 

Civil aircraft: Certifications required Currently, there are no

procedures for providing airworthiness certificates for the mentioned UAS.

I, Jon Carlson, however will always fly safely while having the manuals of the

DJI Phantom 3. 

14 C.F.R. 91.405(a): 

Maintenance Required, 

14 C.F.R. 91.407(a)(1): 

Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417

(a) and (b): Maintenance records Maintenance inspections may be required and should be

granted since they only apply to aircraft with an airworthiness certificate. However I,

Jon Carlson, will perform preflight inspections of the UAS before each flight as outlined

in the operating documents. I, Jon Carlson, will also follow manufacturer

recommendations from said operating documents. Public Interest Aerial photography and

videography as an available service to the public allows for a inexpensive method to

capturing imagery data.

To operate DJI’s : Phantom 3, along the guidelines of the accompanying DJI Phantom 3 Operator’s 

manual. 

I. INTRODUCTION

I Jon Carlson with over a decade of maintaining and operating remote controlled aircraft have flown the DJI

Phantom 3 quadcopter recreationally for over 200 hours without incident and having held a FAA sport pilot

certificate since October 2010. I will be the sole operator (PIC) of this DJI Phantom 3.

The requested exemption would permit Jon Carlson to pursue commercial interests in providing services to 
companies interested in aerial data that can only be captured by using newly developed sUAS in the 

following areas: 

 Agriculture crop assessment and growth patterns

 Construction site and ecological impact assessment 

 Golf course management

 Insurance company claim assessment 

 Special events

 Surveying and 3D aerial mapping 

 Volumetric measurements of quarries, piles, buildings

EQUIVALENT LEVEL OF SAFETY

I, Jon Carlson dba. JccMedia, proposes that his DJI Phantom 3. UAS requested exemption with the 

characteristics and as

operated with the limitations listed below, provide for at least an equivalent or even higher

level of safety to operations under the current regulatory framework.

These limitations and conditions to which I Jon Carlson agrees to be bound when conducting

commercial operations under an FAA issued exemption include:

1.) The DJI Phantom 3. UAS utilized by I Jon Carlson will weigh Less than 55 lbs, operate at a speed of

no more than 100 mph (87 knots), and will remain under 400 ft. (AGL).

2.) Flights will be operated only during daylight hours, only in visual meteorological

conditions, and only within visual line of sight (VLOS) of the pilot in command (PIC)

of the UAS.

3.) Operations will utilize a visual observer (VO) if needed, in addition to the pilot in command

(PIC) assist.

4.) Maximum total flight time for each operational flight will be approximately 30

minutes, or when the Low Battery warning activates

IN THE PUBLIC INTEREST

The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will

greatly benefit the public by drastically reducing the levels of air and noise pollution generated

during traditional aerial video and still photography flight operations.

The DJI Phantom 3 UAS (weighingapproximately 2.8 pounds at their maximum gross weight with diagonal

dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage to 

life and property on the ground, and in the air, compared to the manned aircraft that typically conduct

similar operations 

I respectfully request exemption under Section 333 to enable me to operate efficient, limited, low risk 

commercial sUAS operations for the activities stated, respecting at all times, the space and privacy of 

citizens and property.

Sincerely, 

Jon Carlson 

JccMedia 

22 Celeste Ct 

Novato CA

541-254-4676

jc@jccmedia.com