UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C.

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

BEL TECHNOLOGY SOLUTIONS, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF 3D ROBOTICS SOLO

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on October 1, 2015

Bel Technology Solutions, LLC

Belvie J. Foster(owner/operator)

211 South Clark #2233

Chicago, IL 60690

773.638.1235

773.841.7115

Bel@beltechnology.com
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS. ...............................................................................................3

SUMMARY. .......................................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER.................................................................4

BACKGROUND.................................................................................................................................4

BASIS FOR PETITION......................................................................................................................5

NAME AND ADDRESS OF PETITIONER. .....................................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

BEL TECHNOLOGY SOLUTIONS, LLC, SEEKS EXEMPTION. .................................................6

THE EXTENT OF RELIEF BEL TECHNOLOGY SOLUTIONS, LLC, SEEKS AND 

THEREASON BEL TECHNOLOGY SOLUTIONS, LLC, SEEKS THE

RELIEF.................. .......................................................................................................................9

THE REASONS WHY GRANTING BEL TECHNOLOGY SOLUTIONS, LLC, 

REQUESTWOULD BE IN THE PUBLIC INTEREST ....................................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY. ....................................................................................................13

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ................................22

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT BEL TECHNOLOGY SOLUTIONS, LLC’s REQUEST.... ...........................................22

CONCLUSION. ....................................................................................................................................23

APPENDICES........................................................................................................24
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SOP Standard OperatingProcedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer 

VTOL Vertical Takeoff and Landing
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	4

SUMMARY

Bel Technology Solutions, LLC, seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit me to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography for short films, sporting events, golf courses, wedding events, construction sites, 

vacation resorts, real estate photography, and special events over certain areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Bel Technology Solutions, LLC, provides clients with high quality media and 

photography services via advanced technologies and solutions to increase efficiency, productivity 

and effectiveness. Bel Technology Solutions, LLC, also provides clients with the highest quality 

digital content for use in their commercial, personal, and non-profit multimedia projects. 

Petitioner has over 14 years of professional experience in information technology, public/media 

relations, videography and photography. Petitioner’s objective in aerial video and photography 

operations is to increase public knowledge of UAS and promote safe UAS operations provide 

high quality imaging for a variety of state government, commercial, public, and residential uses,

specifically targeting:

• Individual Clients

• Corporate / Non-Profit Clients, including universities and colleges

• Construction Firms

• Real Estate and Leasing Agents

• Golf and Vacation Resorts

BACKGROUND

Unmanned Aircraft Systems: 3DR Solo

Bel Technology Solutions, LLC, seeks an exemption to operate 3D Robotics (3DR) Solo 

Quadcopter systems for compensation or hire within the NAS. The 3DR Solo Quadcopter is a

vertical takeoff and landing (VTOL) Unmanned Aircraft System (UAS) with a Ground Control 

Station (GCS) utilizing electronic Android or iOS tablet or smart phone systems. The 3DR Solo

has a maximum gross weight of approximately 1.8 kg (3.9 lbs) with payload, while having a 

length of 18 inches, width of 18 inches, height of 10 inches, and a maximum speed of

approximately 55mph or 48 knots. The 3DR Solo UAS is equipped with four main rotors, driven 

by Lithium Polymer battery powered electric motors.

The 3DR Solo UAS that will be operated by Bel Technology Solutions, LLC, will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R 

Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification 

and Registration Marking.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	5

BASIS FOR PETITION

Petitioner, Bel Technology Solutions, LLC, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitionsthe

Administrator to commercially operate the 3DR Solo UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Bel Technology Solutions, LLC, will meet the conditions of

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H.

Accordingly, Bel Technology Solutions, LLC, requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements

for maintenance that only apply to aircraft with an airworthiness certificate.

Bel Technology Solutions, LLC, submits that the requested relief is proper since an

equivalent level of safety will be ensured. Petitioner will use his technical experience or 

experienced personnel to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and 3DR Solo Instruction Manual). Furthermore, Petitioner will document and 

maintain all maintenance records for the 3DR Solo UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Bel Technology Solutions, LLC, to 

the extent necessary to allow a Pilot in Command (PIC) by meeting minimum flight-hour and

currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Bel Technology Solutions, LLC, seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the 3DR Solo UAS do notrequire an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Bel Technology Solutions, LLC will 

ensure that the 3DR Solo UAS is in an airworthy condition, prior to every flight, by determining 

that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, 

and 3DR Solo Instruction Manual),and that the aircraft is in a condition for safe flight.

Bel Technology Solutions, LLC, also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the 3DR Solo UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the 3DR Solo UAS will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the 

flight path. This altitude information, combined with my operation of the 3DR Solo UAS within 

visual line ofsight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, Bel Technology Solutions, LLC, seeks an exemption from the requirements 

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Bel Technology 

Solutions, LLC,submits that safety will not be affected by operation of the 3DR Solo UAS

during daylight hours in visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total duration of approximately 15 minutes to the

first point of intended landing and, assuming normal cruising speed, to fly after that for at least
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	6

4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Bel Technology Solutions, LLC, provides the

following information in support of its petition for exemption:

A. Name And Address Of The Petitioner:

Bel Technology Solutions, LLC

Belvie J. Foster(owner/operator)

211 South Clark #2233

Chicago, IL 60690

Tel: (773) 638-1235 | Mobile: (773) 841-7115

Email: bel@beltechnology.com

B. The Specific Sections Of 14 C.F.R. from Which Bel Technology Solutions, LLC. Seeks 

Exemption.

1. Bel Technology Solutions, LLC, Seeks Exemption From The 

Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Bel Technology Solutions, LLC, Seeks Exemption From The Requirements Of 

Section91.7(a).

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthycondition.

3. Bel Technology Solutions, LLC, Seeks Exemption From The Requirements Of 

Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	7

100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available

station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting availablebefore

departure.

4. Bel Technology Solutions, LLC, Seeks Exemption From The Requirements 

Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions,subsection (b), 

states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for 

at least 20 minutes.

5. Bel Technology Solutions, LLC, Seeks Exemption From The Requirement 

Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part andshall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Bel Technology Solutions, LLC, Seeks Exemption From The Requirements 

Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states thefollowing:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7of

this chapter.

7. Bel Technology Solutions, LLC, Seeks Exemption From The Requirements 

Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	8

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had –

(1) An annual inspection in 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;or

(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter.

8. Bel Technology Solutions, LLC, Seeks Exemption From The Requirements 

Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 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 eachengine,

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
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	9

recurring action, the time and date when the next action is required.

(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.

C.The Extent Of Relief Bel Technology Solutions, LLC, Seeks And The Reason Bel 

Technology Solutions, LLC, Seeks The Relief.

1. Extent Of Relief Bel Technology Solutions, LLC, Seeks And The Reason Bel 

Technology Solutions, LLC, Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or 

higher level certificate, as well as a current and valid airman medical certificate, and who has 

met certain flight-hour and currency requirements, to conduct the proposed UAS flight

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Bel Technology Solutions, LLC, submits that an 

equivalent levelof safety will be maintained because no PIC will be allowed to operate the 3DR 

Solo UAS except for the petitioner.

Further, Bel Technology Solutions, LLC submits that all flights of the 3DR Solo UAS, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to petitioner 

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Bel Technology Solutions, LLC, Seeks And The Reason Bel 

Technology Solutions, LLC, Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Bel Technology Solutions, LLC, to determine that the 3DR Solo UAS is in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	10

operating documents (i.e., Operations Manual, Monthly Maintenance Log, and 3DR Solo

Instruction Manual).

Bel Technology Solutions, LLC, seeks the requested relief because the 3DR Solo UAS

does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Therefore, Bel Technology Solutions, LLC, will ensure that the 3DR Solo UAS is in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly Maintenance 

Log, and 3DR Solo 3 Instruction Manual) prior to every flight, and further, determine that the 

aircraft is in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Bel Technology Solutions, LLC, Seeks And The Reason Bel 

Technology Solutions, LLC, Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the 3DR Solo UAS, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information from the UA to 

the PIC at the ground control station (GCS). Since the FAA requires that any altitude 

information concerning UAS operations be reported to air traffic control (ATC) in feet above 

ground level (AGL), Bel Technology Solutions, LLC, seeks the requested relief because the 

3DR Solo UA’s altimeter may be set on the ground to zero feet AGL, rather than the local

barometric pressure or field altitude, before eachflight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the

3DR Solo UAs are equipped with a barometric pressuresensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Bel Technology Solutions, LLC, Seeks And The Reason Bel 

Technology Solutions, LLC, Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered 3DR Solo UAs during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 15 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. Bel Technology Solutions, LLC, seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered 3DR Solo UAs will severely constrain the practicality of any aerial video

or still photo flight operations that Bel Technology Solutions, LLC, proposes to conduct 

pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR Solo UAS, the 

3DR Solo operating documents, and Bel Technology Solutions, LLC, proposed operating 

limitations, ensure that Bel Technology Solutions, LLC, will safely operate the battery powered 

3DR Solo UAS during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), with enough battery power to fly for a total duration of 15 minutes to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes.
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5. Extent Of Relief Bel Technology Solutions, LLC, Seeks And The Reason Bel 

Technology Solutions, LLC, Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, Bel Technology Solutions, LLC, requests relief 

from these Sections because the 3DR Solo UAS do not require airworthiness certificates. As set 

forth more fully below, the 3DR Solo UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Bel Technology Solutions, LLC, 

will perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the Operations 

Manual, Monthly Maintenance Log, and 3DR Solo Instruction Manual). Furthermore, Bel 

Technology Solutions, LLC, will document and maintain all maintenance records for the 3DR 

Solo UAS.

D.The Reasons Why Granting Bel Technology Solutions, LLC’s Request Would Be 

In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Bel Technology 

Solutions, LLC, to safely, efficiently, and economically perform aerial video and photography 

of construction sites, vacation and golf resorts, real estate properties, sporting and special events 

over certain areas of the United States.

Additionally, use of the 3DR Solo UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Bel 

Technology Solutions, LLC, proposed operation of the 3DR Solo UAS will be realized without 

implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The 3DR Solo UAS are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to performaerial acquisitions, an exemption allowing the use

of a 3DR Solo UAS would reduce the amount of manned aircraft in the NAS, reduce noise and 

air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in theNAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The3DR 

Solo UAS does not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial video and photography missions would result in fewer aircraft that 

must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing 

phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 3DR Solo UAS.

Conducting aerial acquisitions with the 3DR Solo UAS, instead of manned aircraft, will

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power 

and electric motors, the 3DR Solo UAS produces no air pollution, and is the most viable 
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	12

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The 3DR Solo UAs, while

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS

are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the 3DR Solo UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the 3DR Solo UAS (weighing 

approximately 4 lbs with payload, with length of 18 inches, width of 18 inches, and with no fuel 

on board), has less physical potential for collateral damage to life and property on the ground, 

and in the air, compared to the manned aircraft that typically conductsimilar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 

34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The 3DR Solo UAS

Will Benefit The Economy.

In addition to being safe and efficient, the 3DR Solo UAS are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 

3DR Solo UAS will allow United States based companies, like Bel Technology Solutions, LLC, 

to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising

cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered 3DR Solo

UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft.

By operating the 3DR Solo UAS, companies such as Bel Technology Solutions, LLC, 

can remain competitive and profitable, and therefore, provide greaterjob stability to employees 

and contractors, which will ultimately contribute to growth of the U.S. economy. Improved

financial performance of U.S. companies, through commercial use of the 3DR Solo UAS,

provides a stable workforce that increases consumer spending; improves local, state, and federal 

tax revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Bel Technology Solutions, LLC, proposed operation of the 3DR Solo UAS will not 

implicate any privacy issues. Specifically, the 3DR Solo UAS will be operated only in 

compliance with operating documents (i.e., the Operations Manual, Monthly Maintenance Log, 

and 3DR Solo Instruction Manual) which requires propertyowner involvement as well as local 

law enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	13

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Bel Technology Solutions, LLC, Seeks 

Exemption.

1. Reasons Why The 3DR Solo UAS Meets The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, my operation of the 3DR Solo UAS meet the conditions of 

FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determinationunder 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required 

for the operation of unmanned aircraft systems identified under paragraph 

(1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace 

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

aircraft systems in the national airspace system.

In seeking this exemption, Bel Technology Solutions, LLC, submits that the 3DR Solo

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the 3DR Solo UAS; (b) the pilot certification requirement; and (c) the specific 

operating limitations.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	14

a. The Specifications Of The 3DR Solo UAS Demonstrate Its Safe

Characteristics.

The 3DR Solo UAS do not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering itssize, weight, speed, and operational capability.

i. Technical Specifications Of The 3DR Solo UAS.

The technical specifications of the 3DR SoloUAS are set forth by the 3DR Solo

Specifications andData Sheet.

ii. The 3DR Solo UASAutonomous Flight And Navigation Modes Enable 

The UAS To Remain Within A Defined Operational Area.

The 3DR Solo UAS may be operated in both manual and fully autonomous flight modes.

A complete description of the flight and navigational modes of the 3DR Solo UAS is available 

on-line at 3DR Solo User Manual.

iii. The 3DR Solo UAS AreDesigned For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the 3DR Solo UAS will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the 3DR Solo UAS do not reacquire control link data from 

the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home 

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the 3DR Solo UAS is available online at 3DR Solo User Manual.

a. Flights Of 3DR Solo UAS Will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, Bel Technology Solutions, LLC, proposes to commercially 

operate 3DR Solo UAS for the purpose of conducting aerial video and photography over certain

areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: 3DR Solo Unmanned Aircraft Systems. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this

grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC mustbe 
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	15

in feet AGL.

5. The UAs 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 otherthan

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or visual observer (VO) is not permitted.

7. All operations must utilize a visual observer (VO). 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 functions prescribed in the operating documents.

8. The VO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations 

contained in the grant of exemption 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 

upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA

granted the exemption, then the operator must petition for 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.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for 

safe flight. 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. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

11. 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. The PIC who conducts the functional test flight must make an 

entry in the aircraft records.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	16

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service.

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

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third 

class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s 

PICs are permitted under the terms of the 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 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If

flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of

agreement with the airport management must be made available to the Administrator 

upon request.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	17

21. The UA may not be operated less than 400 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

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

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable.

27. Before conducting operations the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law

enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, VO, operator trainees or essential 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
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	18

within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closerto those

objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each

flight to be conducted.

33. 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.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And

(b) Would Not Adversely Affect Safety.

Bel Technology Solutions, LLC, submits that the equivalent level of safety established 

bySection 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

3DR Solo UAS except Bel Technology Solutions, LLC, and that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate 

the 3DR Solo UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Bel Technology Solutions, LLC’s, proposed area of operations, and the

operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the 3DR Solo UAS, Bel Technology Solutions, 

LLC, submits that the additional manned airmanship experience of a commercially certificated

pilot would not correlate to the airmanship skills necessary for Bel Technology Solutions, 

LLC’s, specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS,

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161).

Bel Technology Solutions, LLC, will not allow any PIC to operate the 3DR Solo UAS 

except petitioner and that PIC has demonstrated, by meeting minimum flight-hour requirements 

or the 3DR Solo UAS trainingand currency requirements, that the PIC is able to safely operate 

the 3DR Solo UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	19

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that 

was obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during my proposed operations. The Administrator has held that prior documentedflight

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 hours make and model time may be included in the 10 hours of multi-rotor time and the

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90

days (for currency purposes). The FAA finds that at a minimum, the flight-hour

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.119.

Accordingly, Bel Technology Solutions, LLC, will ensure safe operations by not 

allowing any PICto operate the 3DR Solo UAS unless that PIChas demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC isable to safely operate the 3DR 

Solo UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because

prior to every flight, Bel Technology Solutions, LLC, will ensure that the 3DR Solo UAS is in

an airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	20

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would 

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the 3DR Solo UAs will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined with my 

operation of the 3DR Solo UAs within visual line of sight, at or below 400 feet AGL, will

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated 

byGPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 3DR Solo UAS; 

(2) the limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, Bel Technology Solutions, LLC, will ensure that it will safely operate 

the battery powered 3DR Solo UAS during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 15 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 3DR Solo UAS; the

limitations on the proposed flight operations; and the location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, 

safety will be ensured as the 3DR Solo UAS provide audible and visual warnings to the PIC at 

the GCS when the UAS experiences low battery voltage, the first warning occurring at 

approximately 25% remaining battery power, and again at approximately 10% remaining 

battery power. At the critically low battery level, the 3DR Solo UAS will descend and land

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and operating

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at 

less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS,in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	21

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not

Adversely Affect Safety.

In seeking this exemption, Bel Technology Solutions, LLC, submits that the equivalent 

level of safety with regard to the regulatory maintenance and alteration requirements established 

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Bel Technology Solutions, LLC, will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the Operations Manual, Monthly Maintenance Log, 

and 3DR Solo Instruction Manual). Furthermore, Bel Technology Solutions, LLC, will 

document and maintain all maintenance records for the 3DR SoloUAS.

Likewise, the exemption sought will not adversely affect safety because Bel Technology 

Solutions, LLC, will use existing technical experience to perform maintenance, alterations or

preventive maintenance on the UAS using the methods, techniques, and practices prescribed by 

the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR 

Solo UAS will be performed by Bel Technology Solutions, LLC. Maintenance will be 

documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of my proposed operating limitations, the operating documents, and the

technical aspects of the 3DR Solo UAS, Bel Technology Solutions, LLC, submitsthat safety will 

not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

relief specific to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Bel Technology Solutions, LLC, 

requests that the FAA prescribe special conditions for the intended operation of the 3DR Solo

UAS, which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited 

purpose of conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness 
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	22

certification in accordance with any requirements that must be established for the safe operation 

of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the 3DR Solo UAS, since the airworthiness regulations of 14 C.F.R.

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, orpropeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Leading Edge’s intended operation of the 3DR Solo UAS,

which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part21, Subpart H, and 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

F. A Summary That Can Be Published In The Federal Register, stating: The RulesFrom

Which Bel Technology Solutions, LLC, Seeks Exemption:

Bel Technology Solutions, LLC, seeks exemption from the requirements of 14 C.F.R

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) &(b).

A Brief Description Of The Nature Of The Exemption Bel Technology Solutions, 

LLC, Seeks:

This exemption will permit Bel Technology Solutions, LLC, to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Bel 

Technology Solutions, LLC, Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, Bel Technology Solutions, LLC’s request for 

exemption maybe granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, 

as set forth above.
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	23

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Bel Technology Solutions, LLC, will operate the 3DR Solo

UAS safely in the NAS, without creating a hazard to users of theNAS, or the public, or 

otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Bel Technology Solutions, LLC, seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the 3DR Solo UAS commercially, without an airworthiness

certificate, for the limited purpose of conducting aerial video and photography over certain areas 

of the United States. By granting this Petition, theFAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing Bel Technology Solutions, LLC, to safely, 

efficiently, and economically operate the 3DR Solo UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and theFAA

Modernization and Reform Act of 2012, Section 333, Bel Technology Solutions, LLC, 

respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1)& (a)(2), and 91.417(a) & (b), and permit Bel Technology Solutions, 

LLC, to operate the 3DR Solo UAS commercially for the purpose of conducting aerial video

and photography over certain areas of the United States.

Dated: October 1, 2015

Respectfully submitted,

Bel Technology Solutions, LLC

Belvie J. Foster(owner/operator)

211 South Clark #2233

Chicago, IL 60690

Home Tel: (773) 638-1235

Cell: (773) 841-7115
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	24

APPENDICES

Appendix A – 3D Robotics Solo Technical Specifications 

Appendix B - 3DR Solo Pre-Flight Inspection Check List 

Appendix C – Monthly Maintenance Log

Appendix D – System Context

Appendix E – Solo Overview
Bel	Technology	Solutions,	LLC,	PETITION	FOR	EXEMPTION	:	Page	25

APPENDIX A

3DR SOLO Technical Specifications

Bel Technology Solutions, LLC, only utilizes safe and reliable UAS. 3D Robotics is an industry 

leader in small UAS production. 3DR UAS are loaded with ground breaking software enabling 

the user to set parameters which will not allow flight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

to a predetermined and set distance. In addition, 3DR software provides real-time altitude and

location information to the PIC via the linked monitor (iOS or Android smart phone/tablet

devices).

SPECIFICATIONS

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4

Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10′′ diameter 4.5′′ pitch self-tightening (24 cm diameter 144 cm pitch); glass-reinforced nylon

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or later

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skill. Listed 

flight time applies to elevations less than 2,000 ft above sea level.

**Depending on environmental conditions; controller is expandable, allowing us or third parties to amp up the range in 

the future.

Solo Smart Battery:

Rechargeable lithium polymer (Li-Po)

5200 mAh

14.8 Vdc

Weight: 1 lb. (.5 kg)

Solo Gimbal:

Three-axis stabilization

Fully compatible with 3DR Solo and GoPro HERO3+ and HERO4; camera charging and stabilization only with 

HERO3

HDMI video output

Wireless software upgrade through Solo

Controllable range: 0° to -90° pitch
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APPENDIX B

3DR SOLO Pre-Flight Inspection CheckList

Before flying, check the following conditions.

Location

Your current location and environmental conditions are suitable for flight. (Section 3.1)

Solo is on a level surface at a clear launch point a sufficient distance from yourself and others. (Section 3.1)

Components

The propellers are correctly attached. (Section 2.4)

The propellers can spin smoothly and without obstruction when turned.

No components on Solo appear loose or damaged.

Power

The controller is powered on with at least 50% charge. (Section 2.3)

Solo is powered on with a fully charged battery. (Section 2.2)

Video (Optional)

The Solo app is connected to Solo and streaming video. (Section 2.6)

The GoPro® is recording.
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APPENDIX C

3DR SOLO Maintenance Logs

This application will be used to record maintenance activities for the 3DR Solo 

Quadcopter.
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APPENDIX D

3DR SOLO System Context
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APPENDIX E

3DR SOLO Overview