May 11, 2015

Exemption No. 11536 Regulatory Docket No. FAA–2015–0401

Mr. Ross L. Stephenson, Jr. Stephenson Constructi on Management, LLC

177 Water Oak Drive Ponte Vedra Beach, FL 32082

Dear Mr. Stephenson:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated February 15, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Stephenson Construc tion Management, LLC (hereina fter petitioner or operator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial videography and cinematography to enhance a cademic community awareness and to augment real estate listings.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petiti oner is a DJI Inspire 1.2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the 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, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pres ented in your petition. In Grants of Exemption No s. 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), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, Stephens on Construction Manage ment, LLC is granted an exemption from 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), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to a llow the petitioner to operate a UAS to perform aerial data collection. This exemption is subj ect to the conditions and limitations listed

below.3

Conditions and Limitations

In this grant of exemption, Stephenson Cons truction Management, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exem ption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payl oad. 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 motion 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 airspeed to determine compliance with the 87 knot speed restricti on. 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 (VLOS) of th e PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C 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 pe rmitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform 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 limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,4

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted this exemption, then the operator must petition for an amendmen t 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 alterations that aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal 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. Th e pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection 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 manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot 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, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-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, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants 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 me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity 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 that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport 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 pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.6

22. All aircraft operated in accord ance with this exemption 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 th e 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 time the 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 wa y 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 least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment 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 es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller or authorized 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 transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight St andards ServiceRoss 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 “th e 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 we ight 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 Steph enson 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

ae rial v ideography /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 v ideos; f ollowing 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 a t 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 a t 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 knowled ge of UAS capabilities and limitations should provide an enhanced level of safety awareness during the requested operations.

Granting the petitioner’s r equest comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and aut hority to not only integrate UAS's into theRoss 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 U AS'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 request s 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

affo rd 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 pos es 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.

S ection 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 Fli ght 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 aircraf t below the following altitude o ver 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 lea st 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 th e 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 owne r 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 inRoss 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 a n 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 ai rcraft, 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 eac h, 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 provide s the following information

– contained in t his 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

- Intellig ent Flight Battery Safety Guideli nes v1.0, 4 ) Appendix D

- Protocols and Controls, 5) Appendix E

Safety/Flight Manual (all hereinafter referred to as “ operating documents ” ).

The inform ation 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 UA S has a maximum airspeed of 43 knots. The UA S is quipped with a 4K, 12

- megapixel video camera and the petitioner plans to operate the UA S over various areas near Jacksonville, Florida to
enhance academic commu nity 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; andRoss 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).

T he 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 docu ments.

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

ROTORC RAFT

- 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 quad

copters u nder different temperature and weather conditions. The petitioner ’s training and experience have produ ced 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.

U AS Operating Parameters

The petitioner will abide by th e following additional operating conditions under this exemption:Ross L. Stephenson, Jr., Ponte Vedra Beach, FL

– Section 333 Exemption Petition

• O perate the UAS below 4 00 feet and within a radius distance of 1000 feet from the

controller to both aid in direct li ne of sight visual observation;

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

power; • O perate 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 comm unication with the remote control pilot is lost;

• C onduct 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 do cuments and will actively analyze flight data and other sources of information to constantly update and enhance operational safety protocols;

• C ontact 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;

• A lways obtain all necessary permissions prior to operation; and

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

danger.

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

S ince there is currently no certificate applicable to his operation, this regulation is inapplicable. However, the petitioner will comply the UA S operating documents prior to every fli ght , ensuring that the aircraft is in an airworthy condition

.

Section 91.9(b)(2) requires an aircraft flight manual in the aircraft

. H owever , 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 p etitioner

w ill not operate his UAS above the altitude of 4 00 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.”

G iven 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 . P rior relief has been granted for manned aircraft to operate at less than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. I n 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