Page 1 of 5 07 January 2015

To:

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

To Whom It May Concern,

In accordance with Section 333 of the FAA Modernization and Reform Ac t of 2012 and 14 C.F.R. Part 11 I, Mr. Asia L. Stewart dba For Official Use Only LLC

, do hereby apply for exemptions from the following Federal Aviation Regulation s (FARs) in order to operate an Unmanned Aircraft System (UAS)
for hire in and around airspace governed by the Federal Aviation Administration (FAA).

I, Asia L. Stewart , L icensed Private Pilot ( 3046548), Licensed U.S.C.G. Charter Boat Captain (OUPV less than 100GT) , Active Duty Service Member and owner of For Official U se Only LLC , request these exemptions in order to perform the following for hire flight operations with a commercially purchased radio controlled quadcopters or UAS :

 A erial photography

 Aerial videography

 Aerial Surveying

 Search & Rescue

 Special E vent Monitoring

Regulations from which an exemption is requested:

14 CFR 61.113(a)

14 CFR 91.7(a)

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR Subpart E (91.401

– 91.417)Page 2 of 5

PROPOSED UNMANNED AIRCRAFT SYSTEM:

Due to the low cost of operation, small size , reduced noise and environmental impact, we believe that or
UAS will be an efficient and economical solution for public and private consumers of our services.

I am seeking this exemption in order to operate a DJI Phantom (series) , DJI Ins pir e (series) & the
Yuneec Electric Aviation TYPHOON (series) quadcopter s equipped with a 3

- axis gimbal an d camera
all weighing less than 55 pounds

. The quadcopter s include the following s afety features :

 Geo

- fence capability that will limit the height and horizontal distance that the Phantom can fly from the operator.

 RTL mode

- In the case of low battery or lost communication between the Phantom and the operator, the Phantom will return to the point of takeoff and land itself. This mode can be manually activated by the operator at any point in the flight.

 Land mode

- Loss of GPS signal will e ngage land mode. The Phantom will land automatically at its current position if in a flight mode that requires GPS signal.

 Telemetry radio communication provides real time feedback of flight data, including current altitude, latitude, altitude change rate, and GPS coordinates.

The above indicated safety features combined with the PIC’s personal and career knowledge and experience obtained during UA and Private Pilot flight training will successfully mitigate operation al safety issues that may exist before or during the operation of the UAS

.

FLIGHT OPERATIONS

The operator, Mr. Asia L. Stewart dba For Official Use Only LLC , the pilot in command and visual
observer will guarantee that operations adher e to regulations as req uired by current or f uture Federal, State and Local regulations :

 The PIC will check open source publications , desktop and mobile applications to assure that
location and airspace is safe and not restricted from operating the UA.

 The UA will not exceed airs peeds or ground speeds of 87knots

.

 The UA will not operate above 400 feet above ground level (AGL) without prior consent from the
FAA and its nearest facility

.

 The UA will be operated within visual line of sight (VLOS) at all times.

 All operations will uti lize 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 will not perform any other duties beyond assisting the PIC with seeing and avoiding traffic and other ground based obstacles.

 Proper preflight inspections will take place before each flight.

 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.

 The PIC will maintain a battery reserve that allows the UA to return to point of landing at normal cruise speed and land with 20 % battery power.

 The UA will remain clear of give way to all other air traffic.

 Flight operatio ns will remain 500 feet from any non

- participating persons, vehicles, and
structures unless:Page 3 of 5

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the
event of an accident.

b. All pa rticipating persons are aware of the dangers UA and the safet y precautions and features that are in place.

c. If th e aircraft is operated near vessel, vehicles, or structures where the property owner/controller has granted permission and the PIC has made a safety assessment in regard to the close operation to these objects.

d. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per 91.119(a).

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

For Official Use Only LLC requests an exemption from the following regulations as well as any
additi onal regulations found by the FAA to be necessary for safe and efficient UAS flight operations.

14 CFR 61.113(a), Private pilot privileges and limitations: Pilot in command

This regulation states that no person holding a private pilot certificate may act a s pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

We believe that a PIC with a private pilot license has sufficient ski ll and knowledge to complete operations, especially after completing a UAS knowledge and training course. We do not think that a commercial pilot license will significantly improve a PIC’s performance while operating a UAV. Therefore, we ask for an exempti on from 14 CFR 61.113(a) in order to operate commercially with the minimum of a private pilot license.

14 CFR 91.7(a) Civil aircraft airworthiness

As a UAS will not require an airworthiness certificate, we believe that this regulation is not applicable.
Th erefore, we request exemption from this regulation.

14 CFR 91.119(c) Minimum safe altitudes

This regulation states that no person may operate an aircraft below 500 feet above the surface as well as within 500 feet of any person, vessel, vehicle, or structu re.

We believe that, because of the nature of most UAS operations, an exemption is required in order to allow operation closer than 500 feet to vessels, vehicles, or structures as long as permission is granted from the owning/controlling parties and an ass essment is made to assure that people and property are safe from undue harm. We also request that operations be allowed over congested areas as long as the operations stay within the following standards:

 Flight operations will remain 500 feet from all nonp articipating persons, vehicles, and structures
unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the
event of an accident.Page 4 of 5

b. Participating persons are made aware of the dangers of the UAS opera tion and the safety precautions that have been put into place.

c. The aircraft is operated near vessel, vehicles, or structures only where the property owner/controller has granted permission and the PIC has made a safety assessment in regard to the close operation to these objects.

d. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per 91.119(a).

e. All operations will be conducted over private or controlled

- access property with prior permission from the property owner/control ler or authorized representative.

14 CFR 91.121 Altimeter settings

As our UAS does not utilize a standard barometric altimeter, we request exemption from 91.121 to the extent necessary to comply with applicable conditions and limitations. The altimeter reading for our UAS is calculated by GPS. The accurate and continuous readings that we receive from this GPS system allow us to operate our drone below set minimums at all times.

14 CFR 91.151(a) Fuel requirements for flight in VFR conditions

This regulati on states that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and, after that, fly for an additional 30 minutes. This regulation is intended to create a safe fl ying environment by creating sufficient fuel reserves. Therefore, we do not request an exemption from this regulation but, instead, request that the term “fuel” be changed to “battery power.” We also request that our battery power rese rve for our UAS

opera tions be 20 %.

Our UAS has capabilities that allow the PIC to monitor battery power levels as well as a return to land feature that will engage when battery levels reach a critical level, therefore returning the UAS automatically to the point of takeoff.

14 CFR Subpart E (91.401

– 91.417)

I requests an exemption from the stringent maintenance regulations that are designed to increase the safety of the flying environment by ensuring adequate inspections and servicing of aircraft. We are requesting exemption f

rom these regulations because we believe that, due to the simplicity and the ease of repair, general and preventive maintenance can be performed by the PIC. The PIC is required to make a thorough preflight inspection before each operation. In the case of a discovery of faulty equipment, most replacement and repair can simply be done on site as long as repairs are of an airworthy manner. Major repair will still have to be performed by a licensed repair facility which will be logged in the UAS
records.

We bel ieve that t he simplici ty of the UAS itself, the simplicity of the UAS’s operations, and the fact that no passengers are on board the aircraft make our operations eligible for exemption from CFR Subpart E (91.401

– 91.417).Page 5 of 5

I, Asia L. Stewart dba For Off icial Use Only LLC, do respectfully request exemption s under Section 333 in order to pursue for hire UAV operations.

Thanks

,

Mr. Asia L. Stewart

For Official Use Only LLC

804 Kearney Place

Virginia Beach, VA 23462

(757) 528

- 0443

/S/ ASIA L. STEWART