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. Anequivalent 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 tocompanies 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 V  olumetric 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