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06 November 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 Act 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 Regulations (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, Licensed Private Pilot (3046548), Licensed U.S.C.G. Charter Boat Captain (OUPV 

less than 100GT), Active Duty Service Member and owner of For Official Use Only LLC, request these 

exemptions in order to perform the following for hire flight operations with a commercially purchased 

radio controlled quadcopters or UAS: 

• Aerial photography 

• Aerial videography 

• Aerial Surveying 

• Search & Rescue 

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) 
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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 3 (series) quadcopter equipped with a 3-

axis gimbal and camera all weighing less than 55 pounds. The DJI Phantom (series) quadcopter include 

the following safety 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 engage 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 operational

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 adhere to regulations as required by current or future 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 airspeeds 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 utilize 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 operations will remain 500 feet from any non-participating persons, vehicles, and 

structures unless: 
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a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the 

event of an accident. 

b. All participating persons are aware of the dangers UA and the safety precautions and features that are 

in place. 

c. If the 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 

additional 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 as 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 skill 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 exemption 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. 

Therefore, 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 structure. 

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 assessment 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 nonparticipating persons, vehicles, and structures 

unless: 

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

event of an accident. 
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b. Participating persons are made aware of the dangers of the UAS operation 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/controller 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 regulation 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 flying 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 reserve for our UAS 

operations 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 from 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 believe that the simplicity 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). 
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I, Asia L. Stewart dba For Official Use Only LLC, do respectfully request exemptions 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