May 11, 2015 

 Exemption No. 11536 

 Regulatory Docket No. FAA–2015–0401 

Mr. Ross L. Stephenson, Jr. 

Stephenson Construction Management, LLC 

177 Water Oak Drive 

Ponte Vedra Beach, FL 32082 

Dear Mr. Stephenson: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the 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 Construction Management, LLC (hereinafter petitioner or operator) 

for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial videography and cinematography to enhance academic 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 petitioner 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, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined 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 material respects to those presented in your petition. 

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), 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 specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

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

 They are similar in all material respects to relief previously requested 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 situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant 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, Stephenson Construction Management, 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 allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below. 
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Conditions and Limitations 

In this grant of exemption, Stephenson Construction Management, LLC is hereafter referred 

to as the operator. 

Failure to comply with any of the conditions and 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 exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. 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 restriction. 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 the 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 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 must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure 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 discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised 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 which the FAA granted this exemption, then 

the operator must petition for an amendment 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 affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations 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 functional 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. The 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 manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot 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 flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles 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 experience-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 during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants 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 meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not 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 that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport 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 private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight 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 for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance 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 under the terms of the attached COA. 
6 

22. All aircraft operated in accordance 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 the 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 way 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 protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such 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 structures 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 essential persons are not considered 

nonparticipating persons under this exemption. 

27. 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 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 Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 
7 

If this exemption permits operations for the 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 over the area of proposed filming. The 3-day 

notification may be waived with 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 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 the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating 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 all 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 Standards Service 

 
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