Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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Petition for Exemption 14 CFR # 11.81

A Part of FAA Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333 

December 31, 2015 

Sought for: Midwest UAS Services & Supply LLC (A Startup Company) 

Hague E. Howey CEO/President 

15206 Dorcas Circle (Temporary operating address)

Omaha, Nebraska 68144 

Hague.Howey@MidwestUASservices.com 

402-330-5182 

 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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Sections of 14 CFR upon which relief is being sought: 

Air Worthiness Certification: 

The UAS planned for use are: DJI Inspire 1 Professional; DJI Phantom 3; 

Altus Delta X8; SenseFly eBee EXOM; SenseFly eBee Ag; SenseFly eBee 

RTX; SenseFly SA eBee; SenseFly SA eBee RTK; DJI Spreading Wings 

S1000 Professional Octocopter. These all have been approved by the FAA 

prior to this submission and certified by the Manufacturers as complying with: 

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 these aircraft meet the 

conditions of Section 333. Therefore, the FAA is being asked for relief from 

14 CFR part 21, Certification procedures for products and parts, 2 Subpart 

H—Airworthiness Certificates, and any associated noise certification and 

testing requirements of part 36. 

Specific sections of 14 CFR that we are seeking relief, to carry 

out business activities of: 

Aerial surveying, mapping & photography; other civil engineering data 

gathering such as shoring & retaining wall condition analysis, dam & levy 

assessments; and motion metrics; videography; insurance inspection; real 

estate documentation & presentment; agriculture crop & livestock 

management; marketing, cinematography, legal documentation, 

infrastructure analysis, motion picture, technology, government, private & 

public security, law enforcement use as directed, technology, oil rig 

inspection, gas pipeline & product pipeline inspections; wind turbine 

inspection, power transmission & distribution line inspections & routes; 

research & education; project & construction management/progress 

documentation; search & rescue; golf course management, environmental 

inspection & assessment; economic geography, inventory data collection, 

disaster assessment & FEMA directed, fish & game inspection & 

management, land fill assessments; bridge, paving & tower assessments; 

interior structures; interior & exterior assessments of smoke stacks; solar 

farm assessment, infrared imaging for inefficiencies of photovoltaic cells, 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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roof leaks & structure envelopes; rail & harbor assessments; forestry 

management data and fire suppression; closed set motion picture filming, 

event & attraction marketing; environmental abnormalities data collection, 

and UAS training plus any applications where humans maybe at risk in 

making an assessment or where human welfare can only be accessed & 

assessed. 

The fore listed activities have characteristics of high risk factors to human 

life, if conducted by traditional methods; deployment of applied technology 

can avoid and/or avoid human suffering and disruption of daily living activity; 

previously traditional methods were not able to be conducted with the same 

precision that new technology can render; environmental advantages are 

gained by less disturbance of wildlife and plants; greater precision and 

quicker diagnosis of illness in animals and identification of plant stress and 

disease. If called upon by Law Enforcement, the above devices can aid in 

protecting the public and officials through both distant and close surveillance, 

searches and assessments.

Basis for Request: 

The FAA has previously issued grants of exemption in circumstances similar 

in all material respects to those presented in this petition. Those being in 

Grants of Exemption Nos. 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), 11213 to 

Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), and 12645 to Allied 

Drones (see Docket No. FAA-2014-0804), the FAA found that the enhanced 

safety achieved using an unmanned aircraft (UA) with the specifications 

described by that petitioner and carrying no passengers or crew, rather than 

a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gave the FAA good cause to find that a UAS 

operation was in the public’s best interest thus giving cause for the 

exemption approval. 

As a Condition of Granting this Exemption: 

Midwest UAS Services & Supply LLC, will subscribe to the same 

restrictions and limitations imposed upon others granted this exemption with 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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the understanding that failing to comply with any of the conditions and 

limitations of this exemption, will be grounds for the immediate suspension 

or rescission. 

1. Operations authorized by this grant of exemption is limited to: The UAS 

planned for use: DJI Inspire 1 Professional; DJI Phantom 3; Altus Delta X8; 

SenseFly eBee EXOM; SenseFly eBee Ag; SenseFly eBee RTX; SenseFly 

SA eBee; SenseFly SA eBee RTK; DJI Spreading Wings S1000 Professional 

Octocopter, all appearing on the FAA’s approved list of UAS when weighing 

less than 55 pounds, including payload. Proposed operations of any aircraft 

not included in this list will generate a new petition and request for modifying 

this granted operating exemption. 

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

filming are called out in a special section (Items 30 - 32). 

 

3. The UA will not be flown at a speed exceeding 87 knots (100 miles per 

hour). This will be determined by groundspeed or calibrated airspeed. In no 

case will the UA be operated at airspeeds greater than the maximum UA 

specified by the aircraft manufacturer. 

 

4. The UA will not be operated at an altitude greater than 400 feet above 

ground level (AGL). Flight records will document the maximum altitude of a 

completed mission. 

 

5. The UA will all ways be operated in visual line of sight (VLOS) of the PIC. 

The PIC will maintain eye view of the UA at all times during a mission unaided 

by any device other than corrective lenses that are specified on the PIC’s 

current Medical Certificate, which is to be on his person while on a flight 

mission. 

6. All flight operations will have a visual observer (VO). The UA will 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 will always be able to 

communicate verbally during a mission; electronic messaging or texting will 

not be allowed during flight operations. The PIC will be designated before a 

flight and will not be transferred during a flight’s duration. The VO will be 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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chosen by the PIC based upon their ability to carry out completely their 

accountabilities. 

7. A copy of the issued FAA Exemption plus any amendments, 

Manufacturers Operation Manual with updates, UA Flight Log, Flight Plan, 

Company Policy Manual, and Pilots Qualifying Certification, will be made 

available for inspection upon request by any official at the site of an active 

operation. 

8. Anytime a payload is changed or a new PIC is assigned and is not familiar 

with the equipment, it will be required that they undergo a functional test flight 

and they will not begin a mission until such time as they have become 

comfortable in the handling of the UA and its equipment. Test flights will be 

conducted by the PIC with a VO that will be at least 500’ away and in the 

absence of any objects or persons that may be exposed to a risk or danger 

should there arise a problem. Such test duration and/or decision to abort will 

be at the discretion of the PIC. 

 

9. The Director of Field Operations has the responsible for maintaining and 

inspecting the UAS on a routine basis to ensure that it is in a condition for 

safe operation. 

10. The PIC has the responsibility of following the Company’s specified 

manufacturer preflight check list and making any adjustments to the UA as 

required to make it ready for flight. The adherence to the prescribed check 

list will be documented with any modifications to the UA logged in it’s 

respective maintenance manual. Any discovered conditions which can’t be 

properly addressed, are to be brought to the attention of the Director of Field 

Operations with the UA prominently “Red Lined” and tagged prominently as 

out of service. 

11. Hours for each UA will be individually logged and tracked such that each 

flight mission log sheet will have the ascending (accumulated hours) 

descending (hours remaining) until the manufacturers specified interval of 

inspection/service/substantial overhaul/or replacement is reached on the UA 

or any of its components. 

12. All UAS Manufacturer bulletins, when received, will be logged, directive 

actions taken with dates noted as to the action taken, copies made with the 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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originals placed in the master UA office log and copies placed in the UA’s 

traveling document log. 

 

13. All PIC’s will be holders of either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC will 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, territory, possession, or the Federal 

government. The PIC will be current on his requirements specified in 14 

CFR § 61.56 in an aircraft for which he is rated on his/her pilot certificate. 

14. The Field Operations Manager (Chief Pilot) of Midwest UAS Services & 

Supply LLC, will determine by what measures or means of demonstrated 

competency will be required before a person will become designated as a 

PIC under the exemption. This will include evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours and currency will be 

logged in a manner consistent with 14 CFR § 61.51(b). Flights for the 

purposes of training PICs and VOs (training, proficiency, and experiencebuilding) will be focused on the PIC’s ability to safely operate the UAS 

commensurate with flight assignments. Training operations will only be 

conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights, all persons not essential to flight operations, 

nonparticipants, will be kept an appropriate distance from flight operations, 

in accordance with 14 CFR § 91.119. 

 

15. UAS operations will not be conducted during night, as defined in 14 CFR 

§ 1.1. FAA (14 CFR 1) Night means the time between the end of evening 

civil twilight and the beginning of morning civil twilight, as published in the 

American Air Almanac, converted to local time). All operations will be 

conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) will not be conducted with UAVs. 

16. The UA will not be 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 FAA-published aeronautical chart, unless a letter of 

agreement with the airport’s management signing off on a letter of 

authorization setting out the conditions of such authorization or otherwise 

permitted by a COA issued to Midwest UAS Services & Supply LLC. The 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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letter of agreement with the airport management will be on site and available 

for viewing by an FAA Administrator or any law enforcement official upon 

request. 

17. The UA will 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. Any tethered UAS operations will have colored pennants or streamers 

attached at not more than 50’ intervals beginning 150’ above the surface of 

the earth and visible from at least one mile. The requirement for pennants 

or streamers will not be followed when the air operation is below the top of 

and within 250’ of any structures as long as the UA operation does not 

obscure structure lighting. 

19. If the UAS loses communications or loses its GPS signal, the UA will be 

programed to return to a pre-determined location within the controlledaccess property. 

20. The PIC will abort any flight in an event of unpredicted obstacles, 

emergencies or any other variant conditions which, in his judgment, elevates 

risk factors to the living or property. 

21. The PIC will not begin a flight unless, wind and forecasted weather 

conditions, allows enough available power for the UA to conduct the intended 

operation plus, has at least a 5 minute power reserve—greater if it is 

recommended by the manufacturer to be greater. 

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization 

(COA). All operations will be conducted in accordance with an ATO-issued 

COA. If we anticipate/perceive the need to alter/deviate operations from our 

authorized COA, we will make application for an amended COA. Until that 

amended COA is received, operations will continue within the scope of the 

active COA. 

23. All aircraft operated in accordance with this exemption will be identified 

by serial number, registered in accordance with 14 CFR part 47, and have 

identification (N−Number) markings in accordance with 14 CFR part 45, 

Subpart C. All markings will be as large as practicable. 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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24. Documents used by the operator to ensure the safe operation and flight 

of the UAS plus any other documents required under 14 CFR §§ 91.9 and 

91.203 will be available to the PIC at the Ground Control Station of the UAS 

any time the aircraft is operating. These documents will be made available 

to the Administrator or any law enforcement official upon request. 

25. The UA will always give way and stay clear of all manned aviation 

operations and activities. 

26. The UAS will not be operated by the PIC from any moving device or 

vehicle. 

27. All Flight operations will be conducted at least 500’ 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 Midwest UAS Services & Supply LLC will ensure that 

nonparticipating persons will remain protected during flight operations. 

If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations will cease 

immediately in a manner ensuring the safety of nonparticipating 

persons*. 

b) The owner/controller of any vessels, vehicles or structures maybe 

asked and if permission is granted, for operating closer to objects than 

these minimums plus, upon the PIC’s safety assessment; that there is 

no increased risk or undo hazard, these limits can be modified*. 

*We have the understanding that the PIC, VO, operator trainees are 

essential personnel, thus considered participants and are excluded from the 

above, classification as nonparticipants. 

28. 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 before each flight is conducted. 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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29. All incidents, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area, as defined by the applicable 

COA, will be reported to the FAA's UAS Integration Office (AFS−80) within 

24 hours. Accidents will be reported to the National Transportation Safety 

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

www.ntsb.gov. 

 

Operations in closed-set motion picture and television 

Filming: 

We are request your further consideration of an extension of our exemption 

to include closed-set motion picture and television filming and production, 

with the understanding, that these align with additional conditions and 

limitations, imposed upon others: 

30. We will have a motion picture and television operations manual 

(MPTOM). 

31. At least 3 days before aerial filming, Midwest UAS Services & Supply 

LLC the operator of the UAS will submit a written Plan of Activities to the 

local Flight Standards District Office (FSDO) with jurisdiction over the area 

of proposed filming. (It is our understanding that the 3-day notification may 

be waived with the concurrence of the FSDO). The plan of activities will 

minimally include: 

a) Dates and times for all flights. 

b) Name and phone number of Midwest UAS Services & Supply LLC, the 

UAS aerial filming contractor operating 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 Midwest UAS Services & Supply LLC, has obtained 

permission from property owners and/or local officials to conduct the 

filming production event—a list plus contact information for each of 

those granting permission which could be made available to any 

inspector or official that might request. 
Midwest UAS Services & Supply LLC, Hague Howey, 15206 Dorcas Circle, Omaha Nebraska 68144 

(402) 330-5182 Hague.Howey@MidwestUASservices.com

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g) Signature of an official of Midwest UAS Services & Supply LLC or 

designated manager. 

h) This document is to include a description of the flight activity, including 

maps and/or diagrams of any area, city, town, county, and/or state over 

which the filming will be conducted and the altitudes essential to 

accomplish the operation. 

32. If Flight operations are to be conducted closer than 500 feet from any 

involved participants, those participants will sign an acknowledgement and 

consent for the filming production, as specified in the MPTOM. The UAS 

PIC, and the UAS operation will comply with all applicable parts of 14 CFR 

including parts 45, 47, 61, and 91. 

Importance of your Granting of this Requested Waver:

Your granting of this waver is the foundation for a new Start up business. 

Without your approval, this new business cannot proceed forward. The 

founder, Hague Howey, is very active in the Omaha Community which he 

has made a hobby, starting over 30 years ago when he founded Hague 

Howey Custom Builders Inc. The economic down turn of 2007 – 2008 in 

construction, like many, forced him to reassess and close out operations. 

The outstanding leadership role filled by him in serving on Chamber Boards 

and Youth Mentoring also came to a close. It is his desire to reestablish his 

role and public service using Midwest UAS Services & Supply LLC, as a 

vehicle in continuing his hobby of Community Service. Because of his 

ascribed to personal standards it is his hope--to be looked upon as one of 

the founders and integrators of this new technology in public use and service 

while realizing the tremendous challenges that exist to Public Safety.