James Williams Jonas Musson

Manager, Flight Standards Service 2472 Myrtle Ave

Unmanned Aircraft Systems Integration Hermosa Beach, CA 90254

Office Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591 

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Re: Request for exemption from multiple regulatory provisions to allow the use of small 

unmanned aerial systems on land controlled by clients of Jonas Musson (JM) to assist in aerial 

photography and the safe evaluation of infrastructure and operations for our clients. 

Dear Mr. Williams: 

Jonas Musson respectfully requests an exemption from several provisions of Title 14 of the Code 

of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial systems (UAS) to 

assist in the evaluation of infrastructure and operations for our clients. This request is motivated 

primarily by the desire to maximize safety in infrastructure and operations. While an exemption

would not eliminate the current need for in-person visual inspection required by various federal 

regulatory departments, it would allow JM to broadly evaluate assets and operations with UAS 

resulting in a safer and more efficient infrastructure network. Accordingly, the grant of an 

exemption is consistent with Congress’ intent, reflected in Section 333 of the FAA Modernization 

and Reform Act of 2012 (Modernization Act), 1 that safe systems be permitted in the national 

airspace prior to the issuance of final regulations governing general use of these systems.2 A 

summary of this request suitable for publication in the Federal Register is provided as Appendix 

A. 

Appendix B provides the manufacturers information regarding the design, aircraft performance, 

and fail-safe features. We have provided manufacturer information related to operating 

limitations, normal and emergency procedures, and maintenance and inspection procedures. As 

we add aircraft designs, we will update this appendix appropriately. 

Appendix C provides the Drone Fleet & Aerospace Management Operations Manual for flights 

covered under this Exemption Request. 

1 P.L. 112-95, 126 Stat 11, February 14, 2012.

2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon 

a finding that a type of UAS, as a result of its size, weight, speed, operational capacity, proximity 

to airports and populated areas, and operations within visual line of sight do not create a hazard 

to users of the NAS or the public or pose a threat to national security. 

Background Information 

JM is in the business of providing aerial photography services and consulting UAS for our clients. 

JM’s Clients look to us for Safe Operations of UAS. We have developed specific JM Safe UAV 

Operational Procedures. Increasingly, we have clients looking to operate UAS for Aerial 

Photography and Infrastructure Inspections. 

Areial Photography and Infrastructure Safety Inspection Operations: 
Movie Production

Aerial Photography

Construction Site Inspection

As part of this JM is requesting FAA Exemption for UAS operations for safety, inspection and 

video capture usage. 

Regulatory Basis for Exemption Request 

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may grant 

an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the 

public interest. The FAA has imposed a separate requirement in its procedural regulations, 

providing that the petitioner shall explain why granting the exemption would not adversely affect 

safety or how the exemption would provide at least an equivalent level of safety as compliance 

with the underlying regulation. In this case, approval of this exemption would advance the public 

interest by significantly enhancing the safety and efficiency of infrastructure operations and by 

providing the FAA with valuable user experience on UAS in a context with appreciable economic 

and societal benefits. As described more fully below, the requested exemption would permit the 

operation of UAS under tightly controlled conditions, thus ensuring that operations will not have 

an adverse impact on safety. To the contrary, as explained below, JM anticipates that use of UAS 

will enhance safety in infrastructure operations. Granting an Exemption is in the Public Interest. 

The safety and efficiency of infrastructure operations is heavily dependent upon constant analysis 

of assets, right-of-way, infrastructure and other assets/facilities. There are a wide variety of 

factors that can affect conditions and cause problems for infrastructure. Even relatively small 

objects or minor failures can lead to accidents or other incidents causing downtime of 

infrastructure. Extreme weather events can lead to flooding or overheating infrastructure. For 

example earthquakes, landslides, and abandoned vehicles at grade crossings can block 

infrastructure. The potential for sabotage and terrorism – or even just trespassing – are also 

among the many risks that modern infrastructure faces. 

As a result, pursuant to federal regulations and company policy, our client’s maintenance 

employees routinely inspect the infrastructure, such as bridges, tunnels, support structures and 

signals. At present, this work is done primarily by company personnel in motor vehicles, on foot, 

in specialized equipment. This is often a labor-intensive and sometimes arduous job. While our 

clients do all they can to make these inspections as safe as possible, there is an irreducible 

element of risk involved whenever employees are required to go out on structures. Employees 

may need to climb over or onto structures, which can be slippery, rough, and/or exposed to the 

elements. Some structures, such as bridges, are high above the ground. Equipment moving 

through inspection zones can increase risk as well, especially in high-traffic areas. While the use 

of UAS for supplemental infrastructure and general asset evaluation would not eliminate

these risks entirely (as it is an additive safety measure), it would reduce the risks to employees by 

allowing for remote aerial review. 

Additionally, the sheer amount of assets and the widely dispersed locations – in many instances 

far from sizeable population centers – means that visual inspection in all instances by company

personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical 

because the required altitudes for safe flight reduce visibility below meaningful levels – it is simply 

not possible to see all asset anomalies from such heights. Helicopters present better vantage 

points; however manned helicopters are much more costly, subject to human safety and carry 

highly explosive jet fuel making them impractical for deployment. By using UAS for supplemental 

asset evaluation, JM will be able to substantially upgrade its capacity to detect and address 

issues with the right-of- way and other assets before they become a problem for safe operations.

Thus, the use of UAS has the potential to improve efficiency, resulting in faster and safer delivery 

of goods, energy & natural resources vital to the U.S. economy.
Granting an Exemption will not Adversely Affect Safety 

JM notes that there is no applicable standard for an equivalency determination. Some have 

argued that the appropriate standard is that for model aircraft, noting that their operations, if 

conducted for recreational purposes, would fall completely within the allowable operations for 

model aircraft. We believe it is difficult to argue that there is sufficient correlation between model 

operations controlled by the Academy of Model Aeronautics and the ones contemplated by JM. At 

the same time, it is clear that equivalency cannot be established for traditional, manned civil 

aircraft because the design and use profiles between traditional aircraft and UAS are simply too 

different. As such, we believe it makes more sense to focus on why the contemplated operations 

would not adversely affect safety, which is all that §11.81(e) requires. 

Granting an exemption will not adversely affect safety. JM contemplates conducting UAS 

operations over client owned or controlled land, solely during daylight hours, at altitudes well 

below that which would pose a risk to other aircraft. In general, UAS operations are intended to 

be conducted in areas distant from both congested areas and airports. Moreover, because of the 

inherent risks presented by standard infrastructure operations, our clients have already taken 

steps to secure property against unauthorized public access. For example, substantial stretches 

of pipeline, utilities, railroad track and oil production sites are fenced, elevated, or otherwise 

secured to prevent access. Other long stretches of infrastructure are, as noted above, in very 

remote wilderness areas. The nature of operations anticipated by JM requires that the UAS be 

flown at relatively low altitudes and relatively low speeds. JM expects that in most instances, the 

UAS will be flown less than 75 feet from the highest structure along the path of the UAS. 

Accordingly, the risk of interference with another aircraft is minimal. JM also plans to conduct 

UAS operations at least three miles from any public airports (including heliports). In the event an 

operation needs to be conducted closer to an airport, JM will inform the airport operator and 

airport air traffic control tower of the contemplated operation and will comply with any directions 

issued by air traffic control at that airport. 

Approval of exemptions allowing commercial operations of UASs in the infrastructure aerial 

inspection industry will enhance safety by reducing risk. Conventional operations, using jet or 

piston power aircraft, operate at extremely low altitudes just feet from the subject being inspected 

and in extreme proximity to people and structures; and present the risks associated with vehicles 

that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 

gallons for jet helicopters). Such aircraft must fly to and from the inspection site. In contrast, a 

UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lack of combustible fuel carried on board. The UAS is carried to the 

inspection site. The UAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including 333 Aircraft Exemption Status exempting the applicant from 

conventional aircraft requirements and allowing commercial 

Operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a 

controlled environment and, as a result, are far safer than conventional operations conducted with 

turbine helicopters operating in close proximity to the ground and people. 

The safety of those on the ground is protected by the fact that no one will be allowed into the area 

without the permission of the company. Security will be established for the flight area as part of 

the pre-flight control. Each individual within the secure area will be briefed prior to flight and will 

consent to being in the area. All others will be excluded from the area. 
JM initially intends to use a dedicated staff for UAS operations. All operations will be within visual 

line-of-sight (i.e., no more than approximately 0.5 miles from the manipulator of the controls, or 

pilot in command (PIC). Each PIC will conduct at least three take-offs and landings with the UAS 

on which he or she is trained every 90 days. PIC’s will establish their qualifications thru a 

combination of aeronautical knowledge, UAS airmanship skills, and verification through testing of 

flight ability before infrastructures operations have commenced. Depending on the type of 

operation, additional ground-based visual observers may be employed as well. These observers 

will be within constant visual line of sight and in constant contact with the PIC. The visual 

observers will assist the PIC in avoiding objects near the UAS. 

There are no standards for either Private or Commercial UAS pilot certificates. The safe operation 

and control of the UAS as described in this application does not depend on the type of FAA 

license held by the PIC. Given the restricted and controlled airspace within which operations will 

take place, the key factors needed by the PIC are knowledge of the airspace within which the 

operation will take place and how that airspace fits into the National Airspace System (NAS). That 

knowledge can be and is gained primarily through ground school and not through flight training in 

fixed wing or rotor aircraft, nor is it dependent on the acquisition of a commercial or private pilot’s 

certificate. Those certificates demonstrate knowledge of the factors and skills needed for the safe 

operation of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a 

commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to 

safely operate a small unmanned aerial vehicle, operating at 400 AGL or lower, within strictly 

controlled pre-approved airspace. Besides knowledge of airspace regulations, dexterity in the 

control and operation of the UAS acquired from actual operation of the aircraft is the most 

important factor in establishing an equivalent level of safety. 

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues 

are (1) where the aircraft will be flown, (2) the size of the aircraft relative to what is being used 

today to accomplish the same mission, and (3) what precautions will be taken to ensure the 

safety of those in the area of operation. We propose that the PIC has at least an FAA Private 

Pilots Certificate and a Class III medical; the aircraft be operated within a secure environment; 

and that no one be allowed to enter the secure environment unless they are part of the operation, 

have been fully briefed of the risks prior to operation of the UAS, and have consented to the risks 

associated with being in the operating area. Should there be a mishap, the UAS being flown pose 

significantly less of a threat than the helicopters and fixed wing aircraft now being employed 

because they are a fraction of the size, carry no flammable fuel, do not carry crew or passengers, 

and pose an infinitesimal risk to others. This is in stark contrast to conventional aircraft that are 

flown to the site, carry explosive fuel, carry passengers and crew, and operate in a much larger 

area. 

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who are also 

qualified to fly the type of UAS that are utilized for infrastructure image-capture operations. There 

are even fewer commercial pilots that can fly these UAS – to the point that to do both is 

considered rare. Assuming that it is unlikely for a company to find a pilot that has both 

qualifications, that company would either have to source a qualified UAS pilot to train and obtain 

a commercial certificate, or find a commercial certificated pilot who would be willing to learn to fly 

a UAS to the competency level required for professional use. 

Minimum requirements for the PIC include:

1) A minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 

10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor); 

2) A minimum of 5 hours as UAS pilot with the make and model of UAS to be utilized for 

operations under the exemption and 3 take offs and landings in the preceding 90 days; 
3) Have undergone a qualification process as specified in the Flight Operations & Procedures 

Manual consisting of a knowledge & skill test of the aircraft to be used. 

JM intends to use commercially available UAS Components for UAS. These UAS systems will be 

tested for quality & safety in our test facility before being deployed to the field. The UAS is less 

than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a 

secured area. We have a routine maintenance schedule to verify that the UAS will remain in safe 

and operational condition. Please see Appendix B, for Specific Types of UAS. 

Notes Regarding: 14 C.F.R. Part 21, Subpart H 

In accordance with the statutory criteria provided in Section 333 of PL 112---95 in reference to 49 

USC 44704, and in consideration of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, we request that this aircraft exemption meets the 

conditions of Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any 

associated noise certification and testing requirements of part 36, is not necessary. 

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft

Given the size of the sUAV, two-inch lettering will be impossible. UA will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N---Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness

JM’s request is based on the fact that no airworthiness certificate will be issued for the UAS. JM’s 

UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. 

Based on the fact that an airworthiness certificate will not be issued, exemption from § 91.7(a) is 

not necessary. 

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard Certifications 

required, the original intent of these regulations was to display an aircraft’s airworthiness, 

certification, and registration documents so they would be easily available to inspectors and 

passengers. Based on the FAA Memorandum subject “Interpretation regarding whether certain 

required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 

2014, the requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary. 

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests Small 

UASs, by their design, do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. 

Aircraft being considered for use by JM allow the UAS Instructor to place the aircraft into ‘loiter’ 

mode (fixed altitude stationary hold). In the event of the student losing control, the UAS Instructor 

can quickly and via alternate equipment (equipment not in the hands of the student) place the 

aircraft into a mode that then allows the instructor to bring the aircraft back into control and back 

to the pre- determined and/or safe landing location. 

JM does not describe training scenarios in which a dual set of controls would be utilized or 

required, i.e. dual flight instruction, provided by a flight instructor or other company-designated 

individual, that would require that individual to have fully functioning dual controls. Rather, JM

evaluates the qualification of its PICs based on their experience with the UAS to be operated and 

verifies through testing, in lieu of formalized training. As such, JM does not seek relief from 14 

CFR § 91.109. 

Notes Regarding § 14 CFR 91.119(b)

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, because the 

JM’s operations will only be conducted within the secured area described herein. 
JM Safety Operations & Procedures Overview: 

Technology Considerations: 

Best-in-class, tried and proven technologies that are in advanced iterations. Software from highlyreputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If the UAS loses 

communications, the UAS will have capability to return to a pre-determined location within the 

Security Perimeter and land. 

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other words, we can monitor the 

scene from our perspective for collision avoidance, and to maintain spatial orientation. 

5. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all 

times: speed, altitude, number of GPS satellites (when available), heading and voltage. 

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link failures 

occur (highly improbable), vehicle returns automatically to the point of launch. 

8. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data 

feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude 

information will be generated by equipment installed on board the aircraft, using GPS 

triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination 

thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for 

accuracy by the pilot. 

Mechanical/Physical: 

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, 

thus eliminating the concern of signal severance (flying behind objects/walls). 

2. The UAS will weigh less than 55 lbs and travel at less than 50 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site. 6. UA operated 

under this exemption will be marked in accordance with 14 

CFR part 45 or as otherwise authorized by the FAA. 

Personnel: 

1. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, gimbal 

op, director) 
2. Radio spectrum analysis for interference on the frequencies utilized for vehicle 

control/communication. 

3. A briefing will be conducted in regard to the planned UAS operations prior to each day’s 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

4. The operator will obtain the consent of all persons involved in the UAS operations and ensure 

that only consenting persons will be allowed within 100 feet of the flight operations. 

5. Observer and pilot will at all times be able to communicate by voice. 

6. Written and/or oral permission from the relevant property holders will be obtained. 

7. Pilot and observer will have been trained in operation of UAS generally 

and received up-to-date information on the particular UAS to be operated. 

Operations: 

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy 

source(s) and equipment. Operations authorized by this petition of exemption are limited to the 

following aircraft described in Appendix B. Proposed operations of any other aircraft will require a 

new petition or a petition amendment to this request. 

2. The UA may not be flown at a ground speed exceeding 50 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), 

as indicated by the procedures specified in the operator’s manual. All altitudes reported to 

ATC must be in feet AGL. 

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued medical certificate. 

5. The operator’s manual included as Appendix C and this petition of exemption must be 

maintained and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in the 

operator’s manual, the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operator’s manual. 

The operator may update or revise its operator’s manual. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for extension or 

amendment. If the operator determines that any update or revision would affect the basis for 

which the FAA grants this petition for exemption, then the operator must petition for amendment 

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operator’s manual. 

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance has been performed and the 
UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alterations must be properly documented 

in the aircraft records. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight in accordance with the operator’s manual. The PIC who conducts the functional test flight 

must make an entry in the UAS aircraft records of the flight. The requirements and procedures for 

a functional test flight and aircraft record entry must be added to the operator’s manual. 

9. The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements must 

be established and identified in the operator’s manual. At a minimum, requirements for the 

following must be included in the operator’s manual: 

a. Actuators/Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (ifused);and

j. Any other components as determined by the operator; 

12. Prior to operations conducted for the purpose of infrastructure inspection, a flight 

demonstration, administered by an operator-approved and -qualified pilot must be successfully 

completed and documented. This documentation must be available for review upon request by 

the Administrator. Because the knowledge and airmanship test qualifications have been 

developed by the operator, and there are no established practical test standards that support a 

jurisdictional FAA FSDO evaluation and approval of company designated examiners, the 

petitioner will conduct these tests in accordance with the operator’s manual. 

13. The UA may not be operated directly over any person, except authorized and consenting 

personnel, below an altitude that is hazardous to persons or property on the surface in the event 

of a UAS failure or emergency. 

14. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must be 

essential to the operations. 

15. Regarding distance from nonparticipating persons, the operator must ensure that no persons 

are allowed within 500 feet of the area except those consenting to be involved and necessary for 

the infrastructure inspection operations. This provision may be reduced to no less than 200 feet if 

it would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the 

infrastructure inspection area to note terrain features, obstructions, buildings, safety barriers, etc. 

Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from 

debris in the event of an accident. 
18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance with the 

operator’s manual. 

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

20. Each UAS operation must be completed with 25% battery power remaining. 

21. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

22. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures must be added to the operator’s 

manual. 

23. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

24. The operator must develop UAS technician qualification criteria. These criteria must be added 

to the operator’s manual. 

25. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable 

components, items, or equipment, not covered in the relevant preflight inspection sections of the 

operator’s manual. 

26. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request. 

30. The UA must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.). 

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized. 

32. The UAS may not be operated by the PIC from any moving device or vehicle. 

33. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

34. The UA may not operate in Class B, C, or D airspace without written approval from the FAA. 

The UA may not operate within 5 nautical miles of the geographic center of a non-towered airport 

as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a NOTAM 
as required by the operator’s COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request. 

35. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C.F.R. §11.81, JM provides the following 

information: 

Contact Information: 

Jonas Musson

2472 Myrtle Ave

Hermosa Beach, CA 90254

(310) 600-1182 jonasmusson@gmail.com

Regulatory Provisions from which JM seeks an Exemption 

JM believes it may need an exemption from the following provisions to conduct the contemplated 

operations. In some instances, relief is needed because relief from another provision renders 

compliance with the regulation at hand infeasible. 

333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c)

14 C.F.R. §91.121 

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)(1)&(2)

14 C.F.R. §91.417(a)&(b)

JM believes an exemption is only needed from the above-listed regulatory provisions. To the 

extent that the FAA believes that additional relief is required for JM to conduct the operations 

described here, we request an exemption from any such regulatory provisions as well. 33 For 

example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as 

applicable”. Since none of the underlying requirements (e.g., inspection intervals) can be met and 

will require an exemption, JM believes a separate exemption should not be required for 

§91.417(a). 

The Extent of Requested Relief and the Reasons Relief is Needed 

Section 333 Aircraft Exemption Status: 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement 

for an airworthiness certificate based on a consideration of the size, weight, speed, operational 

capability of the particular UAS, as well as its proximity to airports and populated areas. An 

analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate 

in the areas and under the conditions contemplated by JM will be at least as safe, or safer, than a 
conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without 

the conditions proposed in this request. 

The UAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will 

be tightly controlled and monitored by the operator and observer. Operations will be conducted in 

compliance with the FAA and with local public safety requirements to provide security for the area 

of operation as is now done with conventional equipment, infrastructure, bridge and out building 

evaluation. These safety enhancements provide an expanded degree of safety to the inspectors 

over conventional operations. Lastly, application of these same criteria demonstrates that there is 

no credible threat to national security posed by the UAS, due to its size, speed of operation, 

location of operation, lack of explosive materials and inability to carry a substantial external load. 

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act (49 U.S.C.¤44701 (f)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without 

the restrictions and conditions proposed. 

14 C.F.R. §61.113(a) and (b) 

§61.113 Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and JM anticipates initially using a 

cadre of specially trained staff to conduct the UAS operations. While these individuals will not 

hold commercial pilot licenses. The UAS will not carry property for compensation or hire since 

they will be used solely to assist in evaluation of the infrastructure, equipment, right-of-way, 

assets, bridges, tunnels and out-buildings in furtherance of JM’s client’s primary business, the 

successful operation of a infrastructure; however, the employees’ operation of the UAS will not be 

incidental to their employment with JM, and they will be compensated for such work. Without an 

exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. 

However, the risk associated with the contemplated operations is less than the risk posed by a 

traditional aircraft. The UAS will fly at altitudes well below the permissible limits for other civil 

aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole 

control of JM clients. Accordingly, the risk would be limited to JM personnel, who will be 

appropriately outfitted in safety gear, and JM client’s property on the ground. Requiring a 

commercial pilot certificate would provide no appreciable safety benefit and would needlessly 

impose additional cost on JM. Because the contemplated operations would not comply with 

§61.113(b)(1) and none of the other exceptions to paragraph (a) apply, relief is needed from both 

paragraphs (a) and (b). 

14 C.F.R. 91.119©
§91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

*** 

© Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. 

*****

JM submits that the only relief it requires from §91.119 is from the minimum altitudes listed in 

paragraph ©. Relief is required from paragraph © for fixed wing operations because asset 

evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since 

operations at this altitude also pose a heightened risk of collision with another aircraft, safety can 

only be assured through the grant of an exemption. The anticipated rotorcraft operations should 

be adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from 

paragraph (a) because an emergency landing of the aircraft due to a power failure will not create 

an undue hazard to persons or property on the surface. As noted in the explanation of why an 

exemption will not adversely affect safety, JM clients has exclusive use of the land over which the 

UAS will be operated, and public access is restricted. It also has exclusive use of significant 

portions of land adjacent to the infrastructure and structures that will be the objects of evaluation 

and analysis. JM’s Clients tightly control access to land and have the ability to assure that no 

individuals unassociated with the planned operations are on the affected land. As such, the risk of 

injury is minimal. JM does not contemplate conducting operations over congested areas, so relief 

is not requested from paragraph (b). 

14 C.F.R. 91.121 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “Éto the elevation of the departure airport or an appropriate 

altimeter setting available before departure.”

***** 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight.

Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data feed, 

which downlinks from the aircraft to a ground-based on-screen display. This altitude information 

will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally 

encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a 

zero altitude initiation point will be established and confirmed for accuracy by the pilot. 

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes. 
(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 20 minutes. 

*****

Operating the UAS in a pre-defined area with less than 30 minutes of reserve fuel does not raise 

the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it 

has to be flown to an alternate airport or circle the planned airport in the event of unanticipated 

conditions. JM does not intend to use the UAS for point-to- point flights and will not operate the 

UAS beyond visual line of sight. Nor will the UAS require an airport in order to land. Rather, JM

will operate the UAS using pre-planned flight paths (taking into account weather conditions) 

designed to allow the UAS to fly to the point of intended landing. As such, there is no need for a 

time-based excess fuel requirement. Rather it should be sufficient to require only as much 

additional excess flight capacity as necessary to safely land the UAS. We believe that a 25% 

battery reserve is more than sufficient to meet this objective. 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) 

§91.405 Maintenance required. 

Each owner or operator of an aircraft Ð

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter; *****

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, rebuilding, or alteration 

unless Ð

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter;

*****

§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had __

(1) An annual inspection in accordance with part 43 of this chapter and

has been approved for return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

*****

§91.417 (a) & (b)

***** 

JM believes that an exemption from these three maintenance requirements is appropriate 

because the FAA has not developed maintenance standards that would allow an operator to meet 

the part 91 maintenance requirements. In particular, there are no individuals authorized by the 

FAA to approve a UAS for return to service under §91.407(a) or to conduct the initial 

airworthiness and annual return to service inspections required by §91.409(a). JM will maintain 

the aircraft as instructed in the owner’s manual and ASTM F2909, where applicable, and will not 

operate the aircraft until it has reasonably determined that any needed repairs have been made. 

However, because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate. 
Please do not hesitate to contact me at the phone number or via the e-mail address provided 

above should you have any questions or concerns. 

Respectfully submitted, 

Jonas Musson

Appendix A 

Summary for Federal Register Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register should the FAA determine that publication is needed. 

Petitioner: Drone Fleet & Aerospace Management, Inc. (JM) 

Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 

C.F.R. §91.119(c) 

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

14 C.F.R. §91.417(a)&(b) 

Description of Relief Sought: 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 

61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to 

conduct UAS operations over JM Client’s owned or controlled land, solely during daylight hours, 

to assist in the safe evaluation and analysis of infrastructure and operations. In general, UAS 

operations are intended to be conducted in areas remote from both congested areas and airports. 

The nature of operations anticipated by JM requires that the UAS be flown at relatively low 

altitudes. JM expects that in most instances, the UAS will be flown less than 75 feet from the 

highest structure along the path of the UAS and in no instances will be flown higher than 400 feet 

above the ground. Accordingly, the risk of interference with other aircraft is minimal. 

Appendix B 

Specific type(s), make, and model 
DJI Phantom 3

See Attached Flight Manuals:

DJI Phantom 3 User Manual