Solid Shot LLC

375 East 76th Court, Anchorage, Alaska 99518

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE,

West Building Ground Floor, Room W12-140,

Washington, DC 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform 

Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 

61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 

91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b). 

PETITION FOR SUMMARY EXEMPTION 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Solid Shot, LLC, an operator of Small Unmanned Aircraft 

(UA) hereby applies for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of its UA. Solid Shot, LLC is eligible for a 

summary exemption for film/television production because Solid Shot, LLC wants to 

do aerial videography for TV, internet commercials, marketing, and also “for the motion 

picture and television industry for scripted closed set filming.”1 

If the petitioner does not have the option of using the Petitioner’s UA, the only 

other way to obtain the aerial footage is by using manned aircraft which pose a danger to 

the pilot as well as individuals on the ground. There are no pilots on board the UA and 

due to the small size of the UA, there is less risk posed to the public on the ground in case 

of an emergency. Additionally, the UA has multiple motors while most manned aircraft 

have only one engine. 

Manned airplanes and helicopters produce great amounts of noise pollution 

disrupting the quiet enjoyment of private property of the public on the ground. UA are 

much quieter and will not disrupt the public as much as manned aircraft; thus, the public 

will benefit from a reduction in noise pollution. 

In addition to the noise pollution reduction, engine or turbine powered aircraft 

produce exhaust which affects the environment, while the UA of the petitioner are 

electric and do not produce any emission. The environment and the public are benefited 

by the use of the UA. 

UA uses batteries for power which are not as flammable and explosive as 100LL 

or Jet A. If there was an emergency where the UA crashed, there is less chance of 

individuals being injured from an explosion or fire. UA also use smaller propellers than 
manned helicopters which will cause far less damage in the case of a crash than the 

“grenading” that typically happens during a manned helicopter crash. 

Lastly, the UA will be operated at lower altitudes than manned aircraft. Thus, the public 

benefits because the danger of a mid-air collision is lessened 

QUICK REFERENCE SUMMARY: 

 Types of aircraft to be flown:

o A Freefly Systems Alta Hexacopter previously granted exemption # 12092A.

o A DJI Phantom 3 previously granted exemption # 12657A

 The manual will be submitted confidentially via email. 

 The operations will be for aerial videography2 for TV, or internet commercials, and 

also “for motion picture television, and the content creation industry for scripted closed 

set filming.” This is from Exemption # 11284. 

We already agree to all the restrictions listed in Exemption # 11284, which are 

listed below. However, if the reviewer is able under a summary petition, we ask to be 

granted the battery reserve restrictions in Exemption # 11062 (“Each UAS operation must 

be completed within 30 minutes flight time or with 25% battery power remaining, 

whichever occurs first.”) instead of Exemption # 11284 (“intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.”). If evaluating the alternative 25% reserve restriction would 

cause delay in granting the petition, we immediately agree to the 5 minute reserve from 

Exemption # 11284 that is listed below. 

Based upon the FAA’s recent guidance, this petition is eligible for summary exemption 

and should be granted immediately. 

Solid Shot, LLC requests that the publication and comment procedures be 

waived in accordance with 14 C.F.R. § 11.87 which states:

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of 

my petition for exemption?

The FAA may not publish a summary of your petition for exemption and request 

comments if you present or we find good cause why we should not delay action on your 

petition. The factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously. 

(c) Whether our delaying action on your petition would affect you adversely. 

(d) Whether you filed your petition in a timely manner. 
Corresponding to the above sub-sections, Solid Shot, LLC has good cause to request the 

FAA to waive the comment period and not delay action on the petition because: 

(a) Solid Shot, LLC would not set any precedent. Solid Shot, LLC agrees to the SAME 

exact limitations as Exemption # 11284, except we are proposing to operate the Freefly 

Systems Alta that has been previously approved in Exemption # 12092A. The Alta 

Hexacopter in other exemptions such as 12657A as well as the A DJI Phantom 3 

previously granted exemption # 12657A.

(b) Solid Shot, LLC agrees to the SAME exact limitations as Exemption # 11284. 

(c) Delaying the granting of this petition would adversely affect the public, the FAA, 

and Solid Shot, LLC The public, as well as the FAA, would be better served by the FAA 

quickly granting this petition and thereby freeing up limited FAA resources and allowing 

FAA inspectors to dedicate their time and attention to much higher priorities. Moreover, 

Solid Shot, LLC is adversely affected by the above listed regulations. 

(d) The petition has been filed in a timely manner. 

Petitioner’s contact info: 

Solid Shot, LLC

Attn: Andrew Baugh

Email: andylbaugh@gmail.com

Address: 375 East 76th Court, Anchorage, Alaska 99518

Attn: Thomas Mace

Email: tfmace@gmail.com

Address 375 East 76th Court, Anchorage, Alaska 99518

Regulations from which the exemption is requested: 

 14 C.F.R. § 61.23(a) and (c) 

 14 C.F.R. § 61.101(e)(4) and (5) 

 14 C.F.R. § 61.113(a) 

 14 C.F.R. § 61.315(a) 

 14 C.F.R. § 91.7(a) 

 14 C.F.R. § 91.119(c) 

 14 C.F.R. § 91.121 

 14 C.F.R. § 91.151(a)(1) 

 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) 
This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law 

directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of 

the rulemaking required under Section 332 of the FAA Modernization and Reform Act. 

In making this determination, the Secretary is required to determine which types of UA 

do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

 The UA’s size, weight, speed, and operational capability; 

 Operation of the UA in close proximity to airports and populated areas; and, 

 Operation of the UA within visual line of sight of the operator (VLOS).3 

If the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." Id. § 333(c) (emphasis added).4 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under § 40101 of the Act that includes UAS’s, from the requirement that all civil 

aircraft must have a current airworthiness certificate.

“The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest.” 49 U.S.C. § 

44701(f). See also 49 U.S.C. § 44711(b). 

OPERATING DOCUMENTS 

Solid Shot, LLC will operate only within the limitations below and the limitations listed 

in the confidentially submitted user manual. The limitations below, from the previously 

granted exemption, will be followed if there is a conflict with the manual.

3 FAA Modernization and Reform Act of 2012 at § 333(a).

4 Applicant interprets this provision to place the duty on the Administrator to not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions for the 

safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill 

the statutory requirements for approval.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein applies to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure.

These limitations and conditions are identical to Exemption # 11284 except for the 

difference in aircraft. Solid Shot, LLC agrees to be bound when conducting commercial 

UA operations. The list of limitations and conditions include the following: 

1. Operations authorized by this grant of exemption are limited to the Freefly Alta and 

DJI Phantom UAS 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 

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, 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 Colombia, 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. 

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 the 

predetermined 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. 

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. 

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. 

STATUTORY CRITERIA PROVIDED IN SECTION 333 

The Federal Aviation Act (49 U.S.C.§ 44701 (f)) and Section 333 of the Reform 

Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS. In all cases, an analysis 

of these criteria demonstrates that the UAS operated without an airworthiness certificate 

and under the restrictions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

Since the UA fully loaded weighs no more than 55 lbs. and is operated without an 

onboard pilot, there is no ability or place to carry certification and registration documents 

or to display them on the unmanned aircraft. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying 

the UA will have immediate access to them. Given the size of the unmanned aircraft, the 

FAA registration number will be displayed on the airframe in as large a font as possible. 

14 C.F.R. § 61.23(a) & (c): MEDICAL CERTIFICATES

Exemption # 11221, # 11284, and many others have provided that a U.S. driver’s license 

could be used in lieu of the medical certificate. 

14 C.F.R. § 61.101(e)(4) & (5): RECREATIONAL PILOT PRIVILEGES AND LIMITATIONS & 14 

C.F.R. § 61.315(a): SPORT PILOT LIMITATIONS. 

Exemption # 11221, # 11284, and many others have provided that the “PIC must 

hold either an airline transport, commercial, private, recreational, or sport pilot 
certificate.” Likewise, Solid Shot, LLC is also performing commercial UAS work and is 

asking for the same restrictions which have been previously deemed to provide an 

equivalent level of safety as the burdensome regulations. 

14 C.F.R. § 61.113 (a): PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN 

COMMAND. 

Sub-sections 61.113(a) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot's license or sport pilot certificate rather than a commercial pilot's 

license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the UAS is remotely controlled with no living thing on board. 

14 C.F.R. § 91.7(a): CIVIL AIRCRAFT AIRWORTHINESS. 

The Freefly Systems Alta that has been previously approved in Exemption # 

12092A. The A Dji Phantom 3 has previously been approved in exemption # 12657A

Therefore, this aircraft should not be required to have an airworthiness certificate based 

upon the FAA’s previous determinations. 

14 C.F.R. § 91.119: MINIMUM SAFE ALTITUDES 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. 

Because of the lack of flammable fuel, any risk associated with these operations is 

far less than those presently presented with conventional aircraft operating at or below 

500 AGL. In addition, the low-altitude operations of the UAS will ensure separation 

between these small UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

14 C.F.R. § 91.121: ALTIMETER SETTINGS

This regulation requires 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." As the UAS may not have 

a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the operating 

manuals. 

14 C.F.R. § 91.151(a): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 

Section 91.151 (a) prohibits an individual from beginning "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; or (2) At night, to fly 

after that for at least 45 minutes." 

Applicant believes that an equivalent level of safety can be achieved by restricting 

operations to “be completed within 30 minutes flight time or with 25% battery power 

remaining, whichever occurs first.” Exemption # 11062, at page 27. 

If, however, the above limitations are not satisfactory to the Administrator, the 

petitioner is prepared, in the name of expediency, to accept limiting the PIC from 

beginning a UAS flight unless (considering wind and forecast weather conditions and 

assuming normal cruising speed) “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.” Exemption # 11284, at page 

5. 

14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): 

MAINTENANCE INSPECTIONS 

These regulations require that an aircraft operator or owner "shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter"5 and others shall inspect or maintain the 

aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to 

aircraft with an airworthiness certificate, these sections will not apply to the applicant. An 

equivalent level of safety will be achieved because these small UAS’s are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods 

of time. Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. Lastly, the petitioner will operate in accordance with the manuals submitted 

confidentially which will provide an equivalent level of safety as the burdensome 

regulations. 

CONCLUSION: 

The operation of Solid Shot, LLC using a small UAS, weighing less than 55 lbs., 

conducted under the proposed restrictions outlined above, will provide an equivalent 

level of safety supporting the grant of the exemptions requested herein.

If I can be of any assistance to further expedite this petition, please do not hesitate to 

contact me at (907)-230-8899 or at my email andylbaugh@gmail.com

Sincerely Yours, 

Andrew Baugh