ScoJack Drone Technologies Attn: Jonathan Jackson/ Reginald Scoggins 6704 south Indiana unit 1 Chicago, IL., 60637

U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulationsfrom: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14CFR 91.9(b)(2); 14CFR 91.103; 14CFR 91.109; 14CFR 91.119(c); 14CFR 91.121; 14CFR 91.151(a); 14CFR 91.203 (a) and (b); 14CFR 91.405 (a); 14CFR 91.407 (a) (1) 14CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b) To whom it may concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, ScoJack Drone Technologies, operator ofan UnmannedAircraft System (UASL herebyapplies for an exemption from the listed Federal Aviation Regulations("FARs") to allow commercial operation of its UAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. Commercial operation ofan UAS, as described more fully below, which are equipped with camera(s) and sensors, would operate in the following manner:
• Aerial video and/or photographyfor public and/or private use includingtelevision, public events, cinematography and gathering news information.
• Aerial photography and/orvideofor public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.
• Aerial inspection/photographyof residential/commercial structures under contractwiththe owners or local government authority.
• Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster onlywhen the local authorities or government has requested it by contract or donation.• Aerial inspection/photographyof residential/commercial utility infrastructure including but not limited to electrical power lines, windturbines and cell towers. •Abilityto offertraining to persons individually or belonging to both private and/or public organizations that have interests in the use and application ofa UAS forthe purpose ofthe safe operation ofa UAS to enhance the safetyofthe National Airspace System (NAS) as well as forthe protection ofthe persons and property. As described fully below, the requested exemption would permitthe operation ofa UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is: ScoJack Drone Technologies Attn: Jonathan Jackson/ Reginald Scoggins Phone: 219-293-2493 Email: johnjack200085@gmail.com Address: 6704 south Indiana unit 1, Chicago, IL., 60637
Regulations from which the exemption is requested: 14CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14CFR 91.103 14 CFR 91.109 14CFR 91.119 (c) 14CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14CFR 91.405 (a) 14CFR 91.407 (a) (1)14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b)
Scojack Drone Technologies will operate the DJI Phantom 3 Professional, Model W323, with atotal weight of 1280g or2.82192 lbs. The dimensions are 590mm or 23.2283 inch X590mm or 23.2283inch X 254mm or 10inch. Under still airthe maximum speed is no more than 16m/sor 35.791mph with a cruising speed of 10m/s or 22.37mph. The DJI Phantom 3 Professional has the abilityto hover and move along avertical and horizontal plane simultaneously.The DJI Phantom 3 Professional has four motors, Motor Model DJI 2312/960kv, powered by a4- cell4480mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 9450, in use. The DJI Phantom 3 Professional will be controlled withthe GL300A remote controllerwith an operatingfrequency of2.400GHz- 2.483GHz. The live video feed will have an operating frequency of2.400GHz- 2.483GHz. The applicant will operate the UAS in line ofsightwithin a closed offand predetermined area owned and/operated bythe property representative. Given the small size ofthe UAS and the controlled environment provided the proposed operationswill adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordinglythe applicant requests thatthe FAA grant the requested exemption with minimum delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions towhich the applicant agrees to adhere towhen conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include:
• The UAS will weigh less than 55 lbs.
• The UAS will have a maximum operating speed of no more than 50mph.
• Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO). • Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes offlight time whichever occurs first.
• Flights will be operated at an altitude ofno more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.
• Minimum crew for each operation will consist ofthe UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.• The UAS pilotwill be a designated Pilot in Command (PIC) and hold a Private Pilot License along with a Third or higher Class Medical Certificate. Ifthe PIC feels another operatorto be qualified with the necessary skills to be PIC & possess a Private Pilot License along with aThird or higher Class Medical Certificate, that person may be designated PIC provided they have a minimum of20 hours offlight time with the UAS.
• A briefingwill be performed regarding the planned UAS operations priorto each day's flight consisting ofall the days' production activities.
• All flights will occur underVisual Flight Rules Meteorological Conditions(VFR) only.
• The flights will occur no closerthan a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) ofatower controlled or uncontrolled airport.
• Ifoperations will be within a 5 mile radius ofthe geographic center/Airport Reference Point (ARP) ofa tower controlled or uncontrolled airportthe respective airports will be contacted advisingthem ofthe estimated flight time,flight duration, elevation offlight and other pertinent information.
• The operatorwill obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet oftheflight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.
• The PIC and VO will have been trained in operation of UAS and receive up-to-date information forthe particular UAS to be operated.
• The PIC and VO will be able to communicate byvoice or radio at all times.
• Written and/orverbal permission and permitswill be obtained from territorial, state, countyor city jurisdictions, including lawenforcement, fire or other appropriate governmental agencies.
• Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to a pre-determined location within adesignated location and land autonomously.
• The UAS will have the capabilityto abort aflight in case of unpredicted obstacles, weather, or emergencies. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishesthe procedural requirementsforthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemptionfrom Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operatedwithout an airworthiness certificate, in the restricted environment and underthe conditions proposed will be atleast as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured and designated area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree ofsafetytothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed bythe UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator mustalso display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance tothe cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuantto 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate mayact as a pilot in command ofan aircraftthat is carrying passengers or propertyfor compensation or hire. ScoJack Drone Technologies may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do notcarry any pilots or passengers nor property. The risks attendantto the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14CFR 61. The PIC ofthe UAS will have a Private Pilot's License along with a current Third Class or higher Medical exceedingthe current safety levels in relation to 14CFR 61.113 (a) & (b). Ifeel the operation and limitations set forth in the FOM will equate tothe safe operation ofthe UAS. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is 

### in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, noFAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safetywill be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it. 14C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight. 14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fullyfunctioning dual controls. UAS and remotely piloted aircraft, bytheir design do not have fully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates withthe aircraft via radio communications. The FAA has approved exemptions for flight training withoutfully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalent level ofsafety provided bythe fact that neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicoptersto be operated at less thanthe minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopterand the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein,the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point onthe structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafetywill be achieved given the size, weight, speed ofthe UAS as wellas the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice tothe property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must complywith Section 91.119. 14C.F.R. §91.121 AltimeterSettings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe 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 ofsafetywill be achieved bythe operator, pursuant to the safety check list and live flight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight. 14C.F.R. § 91.151(a): Fuel Requirementsfor Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothe first point of intended landing, and, assuming normal cruising speed- (1) Duringthe day, tofly afterthat for at least 30 minutes; or (2) At night, tofly afterthatfor at least 45 minutes." The battery poweringthe UAS provides approximately 30 minutes of powered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ortwilightVFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and propertyowners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minuteswould greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or 25% of battery power- whichever happens first.This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following:(1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level ofsafetywill be achieved by keeping these documents atthe ground control pointwhere the pilotflyingthe UAS will have immediate access to them, tothe extentthey are applicable tothe UAS. 14 C.F.R. §91.405 {a); 407 {a) {1); 409 {a) {2); 417{a) & {b): Maintenance Inspections. These regulations require that an aircraft operatoror owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will notapplytothe applicant. Maintenance will be accomplished bythe operator pursuantto the flight manual and operating handbook. An equivalent level ofsafetywill be achieved because the UAS is very limited in size and will carry asmall payload and operate only in restricted areas fora limited period oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight and perform required maintenance needed. Additional Information Jonathan Jackson and Reginald Scoggins; are hobbyistthat has constructed, studied and utilized remote controlled ground and aircraft modelsfor more than 8years. Their passion for the hobby is what broughtthem togetherto partner on theirjourney.They both would now like to take their expertise to the next level by utilizing itfor commercial use. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2.012. provide more than adequatejustification for the grant ofthe requested exemptions allowingthe commercial operation ofthe applicant's UAS.
Sincerely, Jonathan Jackson 

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