CORRECTED COPY

The FAA is reissuing the April 16, 2015, grant of exemption of Exemption No. 11334. A 

correction was made to revise the company name to Jackson Family Wines, as well as the 

Exemption Number from 42780 to 11334. Below is the amended Exemption No. 11334 that 

includes the aforementioned change. We made the correction in our records as of April 27, 

2015.

April 16, 2015

 Exemption No. 11334

 Regulatory Docket No. FAA−2015−0047

Mr. Tim B. Adelman

Leclair Ryan, P.C.

Counsel for Jackson Family Wines

180 Admiral Cochrane Drive

Suite 370

Annapolis, MD 21401

Dear Mr. Adelman:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letters dated December 31, 2014 and January 7, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Jackson Family Wines (hereinafter petitioner or operator) 

for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft 

system (UAS) to conduct surveillance over private property.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.
2

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is an AirCover QR–425.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that the relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption No. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Jackson Family Wines is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 
3

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Jackson Family Wines is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the AirCover QR−425

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. 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 airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
4

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

22. 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

___________________________________________________

JACKSON FAMILY WINES,

 Petitioner.

Docket No. FAA-2014-_____

PETITION OF JACKSON FAMILY WINES

FOR AN EXEMPTION FROM TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS 

Tim B. Adelman

Leclair Ryan, P.C.

180 Admiral Cochrane Drive, Suite 370

Annapolis, MD 21401

Phone: 410-224-3000

Fax: 410-224-0098

tim.adelman@leclairryan.com

Submitted on January 7, 2015
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TABLE OF CONTENTS

I. Petition for Exemption Summary

II. Interests of Petitioner

III. Proposed Conditions and Limitations for Petitioner’s Exemption

IV. Information Required to Support a Petition for Exemption

A. Contact Information of Counsel

B. Specific Sections of 14 CFR to be Exempt

C. The Extent of Relief Sought, and the Reason for Such Relief

D. Reasons Why an Exemption Would Further the Public Interest

E. Reasons Why an Exemption Would Not Adversely Affect Safety

F. Federal Register Summary

1. Exemptions Requested

2. Brief description of the nature of the exemption 

G. Additional Information Supporting an Exemption

V. Conclusion

Exhibit A – “Area of Operations”

Exhibit B – “Proposed Conditions and Limitations”

Exhibit C – “Maintenance Manual”

Exhibit D – “Training Materials”
3

I. Petition for Exemption Summary

Jackson Family Wines (“Jackson”) seeks exemption from the requirements of 14 C.F.R. 

§§ 61.56 (flight review), 61.113(a) and (b) (private pilot limitations), 91.7(a) (airworthiness), 

91.119 (minimum safe altitudes), 91.121 (altimeter settings), 91.151 (VFR fuel requirements), 

91.405(a) (maintenance inspections), 91.407(a)(1) (return to service after maintenance), 

91.409(a)(1) and (2) (annual inspection), and 91.417(a) and (b) (maintenance records). Jackson 

seeks these exemptions to permit it to conduct Unmanned Aircraft System (“UAS”) operations 

over its private property in California and Washington. 

II. Interests of Petitioner

Jackson owns and operates over 35,000 acres on which it grows and harvests grapes and 

conducts its large scale wine production business. For the purposes of this Petition, Jackson is 

focused on its properties in California and Washington, as depicted in Exhibit A “Area of 

Operations.” The vineyards are large areas of farm land that is vulnerable to trespass and illegal 

activities. Currently, to protect the integrity of these properties, Jackson contracts with private 

security companies using human ground surveillance teams with local sheriff’s department’s 

canine units integrated into the surveillance teams. When the surveilling security guard 

discovers signs of trespassory use of Jackson property—often in the form of using Jackson 

irrigation and water systems for marijuana plant harvesting—the security guard contacts local 

law enforcement to request dispatch to these sites of suspected criminal activity. 

The UAS operation will compliment Jackson’s current surveillance efforts. It will

minimize the need to utilize potentially dangerous surveillance methods where security guards 

and canine partners directly confront trespassers and their illegal activities. When a canine team 

alerts on potential illicit activity, highly trained UAS pilots will fly UAS equipped with still and 
4

video photography over the Jackson properties to provide reliable birds-eye-view footage of 

what is occurring on the ground. This ability to see the properties for a few hundred feet in the 

air will allow Jackson to significantly enhance the effectiveness of its surveillance both in quality 

and quantity. When the photography detects suspicious activity, the images will be available to 

local law enforcement for further investigation. 

Jackson’s UAS operation will be conditioned and limited as described, in Section III of 

this Petition. It will not adversely affect safety; rather, it will minimize potential confrontations 

between Jackson’s private security guards, their canine partners, and trespassers using Jackson’s 

property for illicit operations. In furtherance of the goals of 14 C.F.R. § 11.81, the UAS 

operation utilizing still and video photography to report to local law enforcement will be in the 

public interest and will provide a level of increased safety by minimizing the potential dangerous 

situations for the Jackson agents and contractors currently providing direct human surveillance. 

Moreover, Jackson will be more effective at preventing the illegal marijuana grows and property 

theft.

III. Proposed Conditions and Limitations for Petitioner’s Exemption

Jackson proposes that its UAS operation be conducted pursuant to the Conditions and 

Operating Limitations set forth in Exhibit B – “Proposed Conditions and Limitations.” Each of 

the conditions and limitations set forth in Exhibit B is consistent with previously granted small 

UAS Section 333 exemptions and FAA guidance.1

IV. Information Required to Support a Petition for Exemption

A. Contact Information of Counsel

Jackson Family Wines submits this Exemption Petition through counsel:

 

1

See Exemption No. 11110 (December 10, 2014; Docket FAA-2014-0367) (“Trimble Exemption”); Exemption No. 

11109 (December 10, 2014; Docket FAA-2014-0507) (“Clayco Exemption”); Exemption No. 11062 (September 25, 

2014; Docket FAA-2014-0352) (“Astraeus Exemption”).
5

Timothy B. Adelman

LeclairRyan, P.C.

180 Admiral Cochrane Drive, Suite 370

Annapolis, MD 21401

Phone: 410-224-3000

Fax: 410-224-0098

tim.adelman@leclairryan.com

B. Specific Sections of 14 CFR to be Exempt

14 C.F.R. § 61.56 — Flight Review

Id. at § 61.113 — Private Pilot Privileges and Limitations: Pilot in Command

Id. at § 91.7(a) — Civil Aircraft Airworthiness

Id. at § 91.119 — Minimum Safe Altitudes: General. 

Id. at § 91.121 — Altimeter Settings

Id. at § 91.151 — Fuel Requirements for Flight in VFR Conditions

Id. at § 91.405(a) — Maintenance Required

Id. at § 91.407(a)(1) — Operation After Maintenance, Preventive maintenance, 

Rebuilding, and Inspections

Id. at § 91.409(a)(1), (2) — Inspections

Id. at § 91.417(a), (b) — Maintenance Records

C. The Extent of Relief Sought, and the Reason for Such Relief

i) When Jackson agents or contractors rely on UAS operations to conduct surveillance 

of Jackson’s private property, Jackson will promote the safety, security, and wellbeing of all people and property involved by strictly abiding by the Proposed 

Conditions and Limitations set forth in Exhibit B. In order to conduct its proposed 

UAS operations with the AirCover QR-425s, Jackson requests exemptions from 
6

certain Federal Aviation Regulations that were intended to promote the safety of 

manned aircraft.

To conduct its UAS operations, Jackson petitions the FAA for an exemption from the 

following federal regulations for the reasons noted:

14 C.F.R. § 61.56 — Flight Review

Jackson requests an exemption from this regulation to the extent necessary to permit 

Jackson to conduct UAS operations over its private property with aircraft controlled by PICs 

who have completed AirCover’s training regimen and successfully passed the FAA’s Private 

Pilot Knowledge Exam. We respectfully submit this request in good faith after considering the 

numerous conditions and limitations proposed by this petition and the extensive nature of the

AirCover’s training program. A copy of AirCover’s proprietary training materials is provided 

for FAA review in Exhibit D – “Training Materials.” However, recognizing the FAA has denied 

a similar request for an exemption to the FAA pilot certificate requirement, Jackson alternatively 

will agree to utilize airmen with at least a private pilot certificate for the pilots of its UAS 

operation. 

14 C.F.R. § 61.113 — Private Pilot Privileges and Limitations: Pilot in Command

If the FAA determines that a private pilot certificate is necessary for UAS PICs, Jackson 

requests an exemption from § 61.113 to the extent necessary to permit Jackson to conduct UAS 

operations with PICs holding FAA private pilot certificates. In most instances, the FAA would 

require a pilot to hold a commercial pilot certificate where there is compensation either to the 

pilot or for the operation. Jackson seeks waiver from this requirement, consistent with 

previously granted Section 333 exemptions, because requiring the Jackson pilots operating the 

AirCover QR-425s to adhere to the commercial pilot certification requirements will not improve 
7

the safety of operations. Requiring airman “aeronautical knowledge,” “aeronautical experience,” 

and “flight proficiency” at the commercial certificate level for those individuals operating a 

remote-controlled, battery-powered UAS aircraft weighing less than 7 pounds and operated in 

accordance with the conditions and limitations set forth in Exhibit B would not bring the 

corresponding safety benefits contemplated in the manned commercial aircraft setting. 

Therefore, consistent with the certificate requirements imposed on the UAS pilots in recently 

granted Section 333 exemptions (see Astraeus Exemption, Trimble Exemption, and Clayco 

Exemption), Jackson requests the FAA grant an exemption from 14 C.F.R. § 61.113 and allow 

Jackson’s UAS pilots who hold a FAA private pilot certificate or future FAA certification to 

serve as pilots for Jackson’s UAS operations. 

14 C.F.R. § 91.7(a) — Civil Aircraft Airworthiness

Jackson requests an exemption from the airworthiness certificate requirement because the 

aircraft flown in Jackson’s UAS operations will not have an airworthiness certificate pursuant to 

14 C.F.R. Part 21, Subpart H. Jackson understands that without an airworthiness certificate, it 

must inspect each aircraft before each flight to determine that it is compliant with Jackson’s UAS 

Operations Manual which is provided in Exhibit C “Maintenance Manual.” The AirCover 

Maintenance Manual was reviewed by the FAA in conjunction with an experimental 

airworthiness application submitted by AirCover. The Maintenance Manual was approved by 

Brook B. Stewart (SAC FSDO) on April 3, 2014. Jackson bases this particular exemption 

request on the rationale that “[C]ompliance with [Jackson’s] Manuals [is a] sufficient means for 

determining an airworthy condition.” Trimble Exemption, at 16.

14 C.F.R. § 91.119 — Minimum Safe Altitudes: General. 
8

Jackson requests an exemption from this regulation so that its UAS operations may fly at 

low altitudes to better capture reliable video and still photography of its private property. In fact, 

only subpart (c) is relevant to Jackson’s UAS operations because Jackson only intends to conduct 

UAS operations over its private vineyards which are not located near any populated areas and 

easily classified as “sparsely populated areas” contemplated by subpart (c). 

Specifically with respect to subpart (c), Jackson requests an exemption from the 

restriction that “aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, 

or structure.” An exemption from subpart (c) will allow Jackson UAS operations’ aircraft to 

optimally assess the conditions of its property and any suspected illicit activity occurring 

thereon. The lower the aircraft can fly for purposes of capturing video and still photography, the 

more it alleviates the danger to human and canine surveillance teams. As the reliance on human 

and canine surveillance teams diminishes, the potential for dangerous confrontations with 

trespassers also diminishes. Specifically, an exemption would allow Jackson to operate within 

500 feet of vehicles and structures on its property as part of its surveillance. However, Jackson 

will not operate within 500 feet of persons, vessels, vehicles or structures not located within its 

private property.

14 C.F.R. § 91.121 — Altimeter Settings

Jackson requests an exemption from this regulation. While the AirCover UAS does not 

use a barometric altimeter, it determines altitude with a GPS signal. Jackson’s UAS operations 

pilots will check the aircraft’s altitude reading prior to each takeoff, and will effectively zero the 

aircraft’s altitude at the point of takeoff, to ensure that measurements of the aircraft’s altitude are 

accurate relative to the local elevation. Jackson will also be conducting flights within visual line 
9

of sight. If this approach is deemed to not satisfy 14 C.F.R. § 91.121, Jackson requests an 

exemption so that Jackson UAS operations can utilize this GPS signal methodology. 

14 C.F.R. § 91.151 — Fuel Requirements for Flight in VFR Conditions

Jackson requests an exemption from this regulation to permit Jackson UAS pilots to plan 

for only 10 (ten) minutes of operating reserve time to be available at the end of each UAS 

operation. Jackson’s UAS operations will all occur within the boundaries of its private property. 

The takeoff and landing will occur within view of the pilot and at all times during the flight, the 

UAS aircraft will be less than 1 (one) mile from its takeoff and landing sight and on Jackson’s 

private property. 

Jackson understands that the policy behind this regulation is to account for unexpected 

weather conditions and logistical delays occurring during a flight or when an aircraft seeks to 

land at its first planned destination. Jackson requests an exemption from this regulation because 

these considerations are not applicable here where Jackson’s UAS operations will be hyperlocalized and will not realistically face the considerations undergirding the regulation’s policy. 

Moreover, a shorter reserve will be an additional safety mechanism by limiting the ability of the 

UA to fly far from its initial launch location. 

14 C.F.R. § 91.405(a) — Maintenance Required

Jackson requests an exemption from this regulation’s obligation to perform inspections 

and discrepancy repairs by FAA authorized mechanics. Jackson proposes Conditions and 

Limitations in Exhibit B, that will require a level of maintenance consistent with the FAA’s 

standards communicated in the Astraeus Exemption and the Trimble Exemption. Moreover, 

AirCover’s maintenance and operations manual have been reviewed by the FAA AIR-230 in 

connection with its application for experimental airworthiness and approved by Brook B. Stewart 
10

(SAC FSDO) on April 4, 2014. A copy of AirCover’s proprietary Maintenance and Operations 

manual are provided for FAA review in Exhibit C – “Maintenance Manual.” 

Jackson’s exemption request regarding this regulation is limited to subpart (a) because it 

will make appropriate logbook entries in aircraft maintenance records in compliance with subpart 

(b), appropriately mark any inoperative instrument or item of equipment for which maintenance 

has been properly deferred in compliance with subpart (c), and appropriately placard listed 

discrepancies that include inoperative instruments or equipment in compliance with subpart (d). 

14 C.F.R. § 91.407(a)(1) — Operation After Maintenance, Preventive maintenance, Rebuilding, 

and Inspections 

Jackson requests an exemption from this regulation to permit Jackson to conduct its UAS 

operations without having to have the UAS approved for return to service by a person authorized 

under 14 C.F.R. § 43.7. AirCover has developed a comprehensive maintenance manual that has 

been reviewed by AIR-230 and approved by Brook B. Stewart (SAC FSDO) on April 3, 2014, in 

conjunction with its application for experimental airworthiness certificate. Maintaining the UAS 

consistent with the maintenance manual will provide an adequate level of safety and will not 

adversely affect safety with regard to the regulatory maintenance and alteration requirements.

Jackson has accounted for the requisite conditions and limitations described in the 

Trimble Exemption and the Astraeus Exemption in crafting Jackson’s own Conditions and 

Limitations. Jackson proposes that its UAS operations be subject to scrutiny under its 

Conditions and Limitations in lieu of the requirement that it satisfy 14 C.F.R. § 91.407(a)(1). 

Related to this regulation, Jackson UAS operations will comply with subpart (a)(2) because

Jackson UAS operations will require completion of maintenance record entries. 

14 C.F.R. § 91.409(a)(1) and (2) — Inspections 
11

Jackson requests an exemption from this regulation so that Jackson will not be required to 

obtain annual inspections and airworthiness certificate inspections required by this regulation. 

Instead, Jackson will maintain the UAS in accordance with the approved AirCover maintenance 

manual. Moreover, Jackson will adhere to the proposed Conditions and Limitations, which will

provide a level of safety at least equivalent to that provided by this regulation and the requisite 

conditions and limitations described in the Trimble Exemption and the Astraeus Exemption. 

14 C.F.R. § 91.417(a), (b) — Maintenance Records

Jackson requests an exemption from this regulation so that Jackson will not be required to 

keep the maintenance records described by this regulation. Instead, Jackson will maintain the 

UAS in accordance with the approved AirCover maintenance manual. Moreover, Jackson will 

adhere to the proposed Conditions and Limitations, which will provide a level of safety at least 

equivalent to that provided by this regulation and the requisite conditions and limitations 

described in the Trimble Exemption and the Astraeus Exemption. 

D. Reasons Why an Exemption Would Further the Public Interest

With the FAA grant of Jackson’s exemption petition, Jackson will be better able to safely 

monitor its private property. Using small UAS operations as an integrated part of the human and 

canine teams will reduce the potential for hostile confrontations between these teams and 

trespassers using Jackson’s property. By providing the video and still photography captured by 

the UAS operations to local law enforcement, Jackson UAS operations will effectuate a smarter, 

more informed, and better prepared response to any illicit activities taking place on Jackson’s 

property. Providing additional security to its properties, reducing the threat of theft and 

preventing illegal marijuana grows. Jackson’s UAS operations will protect the public interest by 

reducing crime and reducing the burden on local law enforcement. 
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E. Reasons Why an Exemption Would Not Adversely Affect Safety

Jackson’s UAS operations will be conducted over its private property, allowing Jackson 

to maintain a sterile operating environment. As such, Jackson will be able to conduct its 

operations without adversely affecting safety. Every flight will be restricted to Class G airspace 

above its own private property. Further, if the exception to 14 C.F.R. § 91.119 (the minimum 

safe altitudes provision) is granted, the UAS will be authorized to fly at low altitudes with little 

to no air traffic. Conducting its UAS operations at relatively low altitudes over its private 

property that is only frequented by (a) authorized Jackson agents or (b) unauthorized trespassers 

using Jackson’s private property for illicit purposes, will allow Jackson to minimize safety risks 

created by the UAS aircraft. Concurrently, the UAS will eliminate the risk to the safety of the 

surveillance teams and local law enforcement that would otherwise be protecting the integrity of 

Jackson’s property. 

F. Federal Register Summary

1. Exemptions Requested

Jackson Family Wines seeks exemption from the requirements of 14 C.F.R. §§ 61.56, 

61.113(a) and (b), 91.7(a), 91.119, 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

and 91.417(a) and (b).

2. Brief description of the nature of the exemption

The FAA exemption will permit Jackson Family Wines to operate an Unmanned Aircraft 

System (“UAS”) over its private property located in the States of California and Washington as a 

means of surveilling its property with video and still photography equipment mounted on UAS 

aircraft being flown immediately above its property by pilots trained pursuant to Jackson’s 

Safety Conditions and Limitations provided to the FAA with Jackson’s Exemption Petition. 
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G. Additional Information Supporting an Exemption 

Jackson will readily provide additional information that the FAA might find helpful, or to 

answer questions in response to any FAA requests. A confidential copy of each of the Manuals

will be submitted to the FAA Assistant Chief Counsel for International Law, Legislation, and 

Regulations as supporting documentation for this petition. The Manuals contain proprietary 

information of Jackson and AirCover. Therefore, Jackson requests that the FAA treat the 

Manuals as confidential and not disclose them to the public. 

V. Conclusion

As set forth above, Jackson seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012. The exemption will permit 

safe operation of the AirCover UAS for the special purpose of conducting aerial surveillance of 

Jackson uninhabited, private, agrarian property in the States of California and Washington. By 

granting this petition, the FAA Administrator satisfies the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the public interest by allowing 

Jackson to conduct UAS operations over its private property. 

Respectfully Submitted,

Tim B. Adelman

Leclair Ryan, P.C.

COUNSEL FOR JACKSON FAMILY VINEYARDS