Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

February 15, 2015

U. S. Department of Transportation

Docket Management System

1200 new Jersey Ave, SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from Part 21, Sections 91.7(a) and (b), 91.9(b)(2), 91.103(b), 91.119(c), 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

Dear Sir or Madam:

I, Ross L. Stephenson, Jr. (hereinafter “the petitioner”), am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 

11, to request exempted from the Federal Aviation Regulations (“FARs”) listed below in 

order to operate a small ultra light weight unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, the petitioner is a licensed building construction contractor within 

the State of Florida under the name of Stephenson Construction Management, LLC 

(CC4686601753). In addition, the petitioner is a tenured-track professor of aeronautics at 

Jacksonville University and an experienced aviator with fixed and rotary wing 

experience. It is the intent of the petitioner to utilize a DJI INSPIRE 1 quad-copter for 

aerial videography /cinematography to enhance academic community awareness for those 

individuals and companies unfamiliar with the geographical layout of the metro 

Jacksonville area, and augment real estate listing videos; following exemption and 

approval by the FAA. Thereby, enhancing their academic research experience for the 

metro Jacksonville area. 

The petitioner has extensive experience in fixed and rotary wing aviation. Initial flight 

training was completed at the Naval Aviation Schools Command in Pensacola while 

serving on active duty with the United States Marine Corps. The petitioner has received 

formal aviation safety training within the Naval Aviation Schools Command, the 

Aviation Safety Officer course at Naval Postgraduate School, and recent attendance of 

the Unmanned Aerial Vehicles Workshop at Embry-Riddle Aeronautical University. The 

petitioner has over 1250 combat operational hours flying B200, B300, and B350 aircraft 

in the airspace of Iraq and Afghanistan during OPERATION ENDURING FREEDOM 

during coordinated operations with various UAS models, all operating within close 

proximity. The petitioner’s experience and first hand knowledge of UAS capabilities and 

limitations should provide an enhanced level of safety awareness during the requested 

operations. 

Granting the petitioner’s request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the 
Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the 

Reform Act specific to the use of UAS's for real estate purposes. Further, the petitioner 

will conduct all operations in compliance with the protocols described herein or as 

otherwise established by the FAA.

For the reasons stated below, the petitioner respectfully requests the grant of an

exemption allowing the petitioner to operate ultra light weight, remote controlled UAS

for academic community awareness to benefit/stimulate attraction to the metro 

Jacksonville area and to enhance real estate listing videos for homeowners who cannot 

afford expensive manned aircraft for the same purpose. Both of which will promote local

economic growth through increased employment and increased tax base. Both with

public safety in mind by keeping heavier manned aircraft containing combustible fuel

that poses potential public hazard.

I. Contact Information:

Ross L. Stephenson, Jr. 

Stephenson Construction Management, LLC

177 Water Oak Drive

Ponte Vedra Beach, FL 32082

Mobile: (410) 507-7202

Email: rossstephenson@me.com

II. Regulations from which the exemption is requested:

14 CFR 21

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(1) & (2)

14 C.F.R. 91.417(a) & (b)

Part 21 prescribes the procedural requirements for issuing and changing design approvals, 

productions approvals, airworthiness certificates, and airworthiness approvals.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an 

airworthy condition.
Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft 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.

Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls.

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitude 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.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “...to the elevation of the 

departure airport or an appropriate altimeter setting available before departure.”

Section 91.151(a) prescribes that 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 [emphasis added].

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft 

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an 

effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft registration Application as provided for in 

§ 47.31(c).

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft 

unless the airworthiness certificate or a special flight authorization issued under § 91.715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have 

that aircraft inspected as prescribed in subpart E of the same part and shall, between 

required inspections, except as provided in paragraph (c) of the same section, have 

discrepancies repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft 

that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless 

it has been approved for return to service by a person authorized under § 43.7 of the same 

chapter.

Section 91.409(a)(1) prescribes, in pertinent part, that no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had an annual inspection in 
Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

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.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had an inspection for the issuance 

of an airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration 

and records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—

(i) A description (or reference to data acceptable to the

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified time 

basis.

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. 

If the AD or safety directive involves recurring action, the time and 

date when the next action is required.
Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under

§ 43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service.

III. The following information is provided in support of this petition:

The petitioner provides the following information – contained in this petition and 

supporting documentation including: 1) Appendix A-INSPIRE 1 User Manual (EN) v1.0, 

2) Appendix B-INSPIRE 1 Safety Guidelines v1.0, 3) Appendix C-Intelligent Flight 

Battery Safety Guidelines v1.0, 4) Appendix D-Protocols and Controls, 5) Appendix ESafety/Flight Manual (all hereinafter referred to as “operating documents”).

The information contained within this petition is contained within four sections: 1) the 

unmanned aircraft system (UAS), 2) the UAS Pilot In Command (PIC), 3) the UAS 

operating parameters and 4) Public Interest.

Unmanned Aircraft System

The petition requests operation of a UAS, the DJI INSPRIRE 1, which is comprised of an 

unmanned aircraft and a transportable ground station. The INSPRIE 1 is referred to as a 

quad-copter with a maximum gross weight of 6.5 pounds. It is equipped with four rotors 

that are driven by electric motors powered by batteries. The UAS has a maximum 

airspeed of 43 knots. The UAS is quipped with a 4K, 12-megapixel video camera and the 

petitioner plans to operate the UAS over various areas near Jacksonville, Florida to 

enhance academic community awareness and augment real estate listing videos. 

Petitioner makes the following representations of operational enhancements, which he 

proposes to abide by to ensure this exemption will provide a level of safety at least equal 

to existing rules:

• The petitioner will only operate in reasonably safe environments that are strictly 

controlled, are away from power lines, elevated lights, airports and actively 

populated areas; and
Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

• The petitioner will conduct extensive preflight inspections and protocols, during 

which safety carries primary importance.

The petitioner states that given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized by him, an exemption from 14 CFR part 21, 

Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), 

subject to certain conditions and limitations, is warranted and meets the requirements for 

an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 

(Section 333).

The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and 

(2), and 91.417(a) and (b) Maintenance inspections may be required and should be 

granted since they only apply to aircraft with an airworthiness certificate. However, the 

petitioner, as a safety precaution, will perform a preflight inspection of his UAS before 

each flight as outlined in his operating documents.

UAS Pilot in Command (PIC)

The petitioner possesses the following certificates:

AIRLINE TRANSPORT PILOT

AIRPLANE MULTIENGINE LAND

COMMERCIAL PRIVILEGES

AIRPLANE SINGEL ENGINE LAND

ROTORCRAFT-HELICOPTER

INSTRUMENT-HELICOPTER

FLIGHT INSTRUCTOR

ROTORCRAFT-HELICOPTER

INSTRUMENT HELICOPTER

GROUND INSTRUCTOR

ADVANCED

The petitioner completed flight training at the Naval Aviation Schools Command in 

Pensacola Florida while on active duty with the United States Marine Corps. 

Additionally, the petitioner is currently a tenured-track professor of aeronautics at 

Jacksonville University and maintains current awareness of aviation policy and the 

aviation industry and provides instruction on private pilot and commercial/multi-engine 

pilot ground school courses. Regarding UAS operational training, numerous practice 

flights as a hobbyist have been flown to gain familiarity with the characteristics of quadcopters under different temperature and weather conditions. The petitioner’s training and 

experience have produced the airmanship skills necessary to safely operate the UAS

within the NAS for commercial use. The petitioner will maintain a second-class medical 

certificate during periods of flight operations.

UAS Operating Parameters

The petitioner will abide by the following additional operating conditions under this 

exemption:
Ross L. Stephenson, Jr., Ponte Vedra Beach, FL – Section 333 Exemption Petition

• Operate the UAS below 400 feet and within a radius distance of 1000 feet from the 

controller to both aid in direct line of sight visual observation;

• Land the UAS prior to the manufacturer’s recommended minimum level of battery 

power;

• Operate the UAS only within visual line of sight (VLOS);

• Utilize the UAS’ global positioning system (GPS) flight safety feature whereby it 

hovers and then slowly lands if communication with the remote control pilot is lost;

• Conduct all operations under personal and flight safety protocols (including posting 

a warning sign reading: “Attention Aerial Photography in Progress – Remain Back 

150 feet”) contained in the operating documents and will actively analyze flight 

data and other sources of information to constantly update and enhance operational 

safety protocols;

• Contact respective airports if operations will be within 5 miles to advise them of his 

estimated flight time, flight duration, elevation of flight and other pertinent 

information;

• Always obtain all necessary permissions prior to operation; and

• Have procedures in place to abort flights in the event of safety breaches or potential 

danger.

Section 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

Since there is currently no certificate applicable to his operation, this regulation is 

inapplicable. However, the petitioner will comply the UAS operating documents prior to 

every flight, ensuring that the aircraft is in an airworthy condition.

Section 91.9(b)(2) requires an aircraft flight manual in the aircraft. However, since there 

are no pilots or passengers on board his aircraft and given its size, this regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight 

manual with the UAS ground station.

Section 91.119(c) prescribes safe altitudes for the operation of civil aircraft, but that it 

allows helicopters to be operated at lower altitudes in certain conditions. The petitioner 

will not operate his UAS above the altitude of 400 feet above ground level (AGL) and 

will also only operate in safe areas away from the public and traffic, thus “providing a 

level of safety at least equivalent to or below those in relation to minimum safe altitudes.” 

Given the size, weight, maneuverability, and speed of the UAS, an equivalent or higher 

level of safety will be achieved.

Section 91.121 Altimeter settings is inapplicable since he UAS utilizes electronic GPS 

with a barometric sensor. However, these sensors will provide the necessary altitude 

information to be communicated to ATC in AGL.

The petitioner requests an exemption from § 91.151(a) Fuel requirements for flight in 

VFR conditions. Prior relief has been granted for manned aircraft to operate at less than 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 

for daytime, VFR conditions. The petitioner commits to land the UAS prior to the