J2 Engineering and Environmental Design 4649 E. Cotton Gin Loop, Suite B2 Phoenix, Arizona 85040 (602) 438-2221 dhewitt@j2design.us

Dear Sir or Madam:

This petition is being submitted on my behalf wi thout legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, J2 Engineering and Environmental De sign, hereinafter referred to as J2, is a Limited Liability Company offering engineering and landsca pe architectural services, hereby applies for an exemption from the Federal Aviation Regulations (F ARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit J2 to pursue t heir commercial interests in providing services to clients using a small advanced sUAV in the following areas: Data Collection. J2 states that all sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the UAS’ radius during filming and photography applications.

J2 has demonstrated the ability to safely and effectivel y fly the sUAS DJI Phantom 2 which will be used for all commercial and private purposes. J2 complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of sUAS.

The DJI Phantom 2 that will be operated by J2 will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R. Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

All flights will occur in ordinance with any state or local laws regarding privacy.

J2 is seeking the exemption because it is committ ed to complying with all of the rules, guidelines, limitations, and future legislation set forth by t he FAA. J2 agrees to operate the sUAS in the manner described, and for the purposes that described. Without the exempt ion request granted, J2 would be unable to safely and effectively run my business, and it is my intention to comply with the FAA and obtain an exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of responsibilities I assume as operato r; it also contains information regarding the aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which exemption is requested: 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) 91.12191.151 (a) (1) 91.405 (a) (1) 91.409 (a) (1) and (2) 91.4174 (a) and (b)

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES
1. Operations authorized by this gr ant of exemption are limited to the DJI Phantom 2 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 moti on 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 airs peed 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 (V LOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any devic e other than corrective lenses, as specified on the PIC’s FAA-issued airman medical ce rtificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). T he 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 perfo rm 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 lim itations stated in this grant of ex emption, are hereinafter referred to as the operating documents. The operating docume nts must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures out lined in the operating documents, the conditions and limitations herein take precedence and must be fo llowed. 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 enforceme nt 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 determine s that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must pe tition 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 altera tions 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. F unctional 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 in spection 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 co mply 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, P uerto Rico, a territory, a possession, or the Federal government. The PIC must also meet th e flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is ra ted on his or her pilot certificate. 5
14. The operator may not permit any PIC to operate unles s 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 ma intaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours and cu rrency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for t he 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, trai ning operations may only be conducted during dedicated training sessions. During training, proficiency, and ex perience-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 (V MC). 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 Direct ory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-publish ed aeronautical chart, unless a letter of agreement with that airport’s management is obtained or othe rwise permitted by a COA issued to the exemption holder. The letter of agreement with the airp ort 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 t he UA to conduct the intended operation and to operate after that for at least five minutes or with the re serve 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 CO A. 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 exempt ion 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.
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 timethe 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 l east 500 feet from all nonparticipating persons, vessels, vehicles, and structures unl ess: a. Barriers or structures ar e 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 pr otection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the sa fety 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 assessm ent 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 nonpart icipating persons under this exemption.
27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authoriz ed 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 tr ansgresses the lateral or vertical boundaries of the operational area as defined by the app licable 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.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 12645

Public Benefit and Safety

Given the above stated evidence, procedures and precautions operating UAS commercially for the purposes of data collection and marketing in the fields of engineering and landscape architecture will ultimately be in the public interest. These operations, when executed with prudence, will exceed the current level of safety as the regulat ions from which exemption is sought.

The utilization of sUAS in aerial data collection benef its the public directly by drastically reducing the levels of air and noise pollution associated with traditional methods of aerial data collection such as helicopters. By the very nature of being an unmanned aircraft, the potent ial risk to life to personnel is negated.

The DJI Phantom 2 utilized by J2 also has a fails afe function that is triggered in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually.

The utilization of sUAS in aerial data collection is economically beneficial to United States based companies and contribute to the growth of the U.S. economy. Conducting sUAS operations for aerial data collection in engineering and landscape architec ture provides a greater breadth of information which were previously unaffordable and impracti cal for J2. By operating sUAS J2 can remain competitive and profitable by providi ng our clients with a better product, additionally resulting in greater job stability to employee s and our contractors.