U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue

SE Washington, DC 20590

January 30, 2016

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the

FAA Regulations and certain parts of the FARs.

Dear Sir or Madam:

Request:

In order to provide safe and environmentally-friendly aerial Videography and Photography for and 

public business interests, I, Jamal A. Warner, pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 ("FRMA"), would like to formally submit for exemptions from the following Section 

333 regulations:

• 14 C.F.R. Part 21

• 14 C.F.R. 45.23(b)

• 14 C.F.R. 61.113(a) and (b)

• 14 C.F.R. 91.7(a)

• 14 C.F.R. 91.9(b)(2)

• 14 C.F.R. 91.119(c),

• 14 C.F.R. 91.121,

• 14 C.F.R. 91.151(a)(l),

• 14 C.P.R. 91.203(a) and (b),

• 14 C.F:R. 91.405(a),

• 14 C.F.R. 91.407(a)(l),

• 14 C.F.R. 91.409(a)(l) and (2),

• 14 C.P.R. 91.417(a) and (b)
I am requesting these exemptions so that I may safely operate the 3DR Solo UAS commercially along the 

guidelines of the accompanying operator's manual as well as FAA guidelines for UAS flight and safety 

guidelines set by the Academy of Model Aeronautics (AMA).

Proposed UAS and Operations

The 3DR Solo weighs less than five pounds, will always be flown under 400 feet limited via software by 

its GPS and barometric sensors, is electrically powered by a lithium ion battery, carries no combustible 

fuel or crew, and will be transported in proper storage to and from all flight areas (in accordance with 

FAA guidelines). The aforementioned proposed exemptions would allow me to operate the 3DR Solo 

UAS for commercial purposes of aerial Videography and Photography as a service to public and business 

interests, including: real-estate Photography and Videography, wedding and private individual 

Photography and Videography, public and commercial Photography and Videography, and agricultural 

Photography and Videography. 

As evidenced by recent Exemption Nos. 12045 and 12058, the FAA recently approved similar use of such 

UAS. These particular UAS have been proven reliable and safe flying machines managed by 

gyroscopically-stabilized flight, ground detection, GPS-aided navigation, a built-in compass, blinking LED 

lights, a manual and automatic failsafe "Return to Home" mode for returning to the point of takeoff, and 

propeller guards in order to protect both the UAS and the environment. This particular model combines 

state-of-the-art, proven technology with high quality manufacturing and user-friendly control to ensure 

safe operation, easy maintenance and care.

All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight 

(VLOS) of the PIC(Jamal A. Warner) and VO at all times. The VO and PIC(Jamal A. Warner) will be able to 

communicate verbally at all times; The PIC(Jamal A. Warner) will be the only PIC of this aircraft. The 

PIC(Jamal A Warner) will ensure that the VO can perform the duties required of the VO. 

Specific section(s) of 14 CFR which I seek relief and the reason(s) I seek relief:

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with the UAS to be utilized, an exemption from Part 

21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform 

Act. As evidenced in Exemption No. 12045, "in all cases, an analysis of these criteria demonstrates that 

the UAS operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an 

airworthiness certificate without restrictions and conditions proposed."

14 C.F.R. 45.23: Display of marks:

Because the 3DR Solo does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to 

mark large words, numbers, or phrases, I request exemption from the above regulation. However, in 

efforts to comply with the above regulation and those set by the Academy of Model Aeronautics (AMA), 

I will affix a small label to the external hull of the UAS indicating my name, address, and my AMA 

Member Number 
14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: 

Pilot in command Under § 61.113 (a) and (b), certified private pilots are limited to noncommercial 

operations. However, I am able to achieve an equivalent level of safety through current FAA regulations 

of UAS operation and AMA safety guidelines (outlined in the summary of this document) without such a 

certification because of the above mentioned safety features of the 3DR Solo. According to Exemption 

No. 12045 in which a similar UAS was authorized for similar operation, "The FAA has previously declared 

that additional manned airship experience of a commercially certified pilot would not correlate to the 

airmanship skills necessary for similarly proposed operations in previously issued exemptions to this 

regulation through Exemption Nos. 11062 and 11138." Therefore, bearing any pilot certification or

license will not ensure remote piloting skills of a UAS; the risks of operating this UAS are far less than the 

risk levels inherent in commercial activities with traditional aircraft given the 3DR Solo 's safety features 

and the limited range and speed of the UAS. The FAA has approved a similar exemption to the above 

rule as evidenced in Exemption No. 12058.

14 C.F.R 91.7: Civil aircraft airworthiness

Currently there is no certificate applicable to this UAS, and therefore it will be up to myself, Jamal A. 

Warner, to determine the airworthiness of the 3DR Solo in accordance with its official operating manual. 

Written and signed pre and post-flight inspections of the propellers, motors, frame, landing stands, 

camera and gimbal unit, connected mobile device, a compass calibration and properly ensured GPS 

locks as indicated by the 3DR Solo's display of "Safe to Fly" message will be performed before and after 

each flight, accurate records of which will be kept with the UAS's storage and transportation system at 

all times. These records will be logged and will include the total flight time of each flight.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

As evidenced in Exemption 12045, since there are "no pilots or passengers on board this aircraft, and 

given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining 

a safety/flight manual with the operator." In addition to the official safety/flight manual provided by 

3DR upon purchase of the Solo, following the AMA guidelines for safe flight operations and the FAA 

regulations for UAS operations will ensure a high level of safety.

14 C.F.R. 91.119(c): Minimum safe altitudes

I, Jamal A. Warner will ensure that the UAS does not operate any higher than 400 feet at ground level by 

setting the maximum altitude at 400 feet in 3DR Solo's pilot application and ensuring this is set before 

each flight as part of the pre-flight inspection. I will not fly over congested areas or directly above 

unprotected people or moving vehicles. I will plan operations before hand for proper flight safety and 

proper height analysis as to avoid collisions. The GPS and barometric sensors equipped on the 3DR Solo 

will ensure accurate altitude readings, the output of which will be fed to my tablet device in real time as 

I operate the UAS. 

14 C.F.R. 91.121: Altimeter settings
The 3DR Solo utilizes the latest GPS technologies as well as a barometric sensor with live data output to 

the tablet device attached to the transmitter. An equivalent level of safety and accurate altimeter 

telemetry will be achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The 3DR Solo is electrically-powered by lithium ion batteries which are made by 3DR specifically for this 

particular UAS. They are rated as providing no longer than 25 minutes of flight time (no load) and 20 

minutes of flight time with camera and gimbal. Therefore, due to the limitations of the batteries, it is 

currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, 

Jamal A. Warner, however will always fly safely while having the manuals of the 3DR Solo and abiding by 

FAA regulations for UAS operation and AMA safety guidelines.

14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(l): Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a)(l) and (2): Inspections & 14 

C.F.R. 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should be granted since they apply to aircraft with an 

airworthiness certificate. However I, Jamal A. Warner, will perform both preflight and post-flight 

inspections of the UAS before and after each flight as outlined in the operating documents. I, Jamal A. 

Warner, will also follow manufacturer recommendations from said operating documents and keep a 

digital record of any maintenance done to the UAS.

Public Interest and Public Safety:

Aerial photography and videography provided to the public allows for a more cost-effective, safe, and 

environmentally-friendly method to capturing imagery than its alternative: manned aircraft and 

helicopters. The latter are expensive to operate and maintain, create a high level of noise, and are much

more hazardous due to size and combustible fuel - especially if flown at low altitudes required for some 

operations. I, Jamal A. Warner, in addition to using my UAS for commercial endeavors, will also gladly 

offer my services free of charge upon request and with proper coordination to any official search and 

rescue or emergency services organization to benefit the public. Because of this, an increase of

commercial activity and a gaining of more detailed understanding of private and/or farm land would 

help local and area communities by: reducing pollution, risk, and operating costs by alternative aerial 

Videography and Photography services such as manned airplanes and helicopters, reducing carbon 

emissions and traffic congestion by vehicles looking to view properties such as real-estate or farm land, 

and increase visibility to local attractions thereby bolstering local commerce and tourism.

Given that there is no fuel and no crew on this UAS, that it weighs under five pounds and has propeller 

guards, as well as having a low maximum speed (less than 60mph), safe operation of this craft does not 

pose any immediate danger to the environment, wildlife, infrastructure or people. 
Given its GPS and ground-sensing capabilities, a failsafe "Return to Home" mode will safely return the 

craft to the operator at the push of a single button or automatically when the craft is either low on 

power or operating outside of its transmitter's range. This ensures that the craft will not remain 

airborne in unsafe conditions and pose any public danger.

Summary

I, Jamal A. Warner, am seeking exemption from the following rules: 14 C.F .R. Part 21, 14 C.F.R. 45.23(b), 

14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 

91.151(a)(l), 14 C.P.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(l) 

and (2), 14 C.F.R. 91.417(a) and (b). 

With the exemptions of the mentioned rules I, Jamal A. Warner, will be seeking to make my UAS 

Photography/Videography services available to public and commercial interests. The FAA has authorized 

similar operations under Exemption Nos. 12045 and 12053. Alternatively, public and commercial 

interests had previously sought the use of manned aircraft to achieve what I can offer in a safer, more 

cost-efficient and environmentally-friendly manner by not using combustible fuel, flying at safe heights, 

not carrying a crew and strictly following the usage recommendations from 3DR and safety procedures 

by the Academy of Model Aeronautics. 

These include but are not limited to:

• Flying the 3DR Solo safely in accordance with its operator's manual

• Maintaining active and full membership in the Academy of Model Aeronautics (AMA), which provides' 

a high level of insurance and training programs to its members.

• Always flying below 400 feet, using the 3DR Solo's altitude limiter to ensure this.

• Completing thorough inspection of UAS before and after flights and keeping inspection records with 

the craft at all times

• Keeping the UAS in VLOS (visual line of sight) at all times when in operation with an VO(Visual 

Observer)

• Remaining safely clear of and do not interfere with manned aircraft operations

• Not flying directly over unprotected persons or moving vehicles

• Not flying within 5 miles of an airport or control tower

• Not flying in adverse weather conditions such as high winds, rain, snow, fog or impaired visibility

• Not flying under the influence of alcohol or drugs 

• Ensuring the operating environment is safe

• Not flying over sensitive infrastructure or property such as power stations, water treatment facilities, 

correctional facilities, etc.
• Checking and following all local laws and ordinances before flying over private property

• Not conducting surveillance or photographing persons in areas where there is an expectation of 

privacy without the individual's permission

In addition to these above general standards, I, Jamal A. Warner, will follow and abide by the 

following 3DR’s manufacturer safety guidelines:

FLIGHT CHECK

It’s good practice to perform a thorough pre-flight check every time you fly. Do the propellers, landing 

gear or other parts of your Solo show signs of wear? Are all the LEDs working? Has the compass been 

calibrated (the Solo app can walk you through this)? Is the battery charged and properly installed? 

Anything in the motors that might cause obstruction?

Spinning props can cause injury—make sure the propellers are disarmed before handling your drone. 

With Solo, turning those spinning props off is as easy as hitting the “power” button on your controller.

Before you take off, make sure you’re at a safe distance from your drone. And, unless you’re using the 

“Selfie” Smart Shot, avoid taking off with the drone facing towards you (“nose in”). This isn’t only for the 

obvious don’t-fly-at-your-face reasons, but also because when the drone is facing you the command 

sticks become inverted: “Forward” on the stick actually appears to send the drone backwards, towards 

you. It’s easy to get disoriented.

IN FLIGHT

The best way to assure a successful flight is to keep your drone within visual line of sight at all 

times. Always watch your drone. Keeping visual track of your drone and its orientation at all times will 

go a long way towards preventing crashes and loss of control.

Fly under 400 ft. (100 m). Not only is this an FAA regulation and ensures your flight doesn’t interfere 

with manned flights in your area, but it helps you maintain line of sight. To give you an idea of how high 

400 feet is, the Statue of Liberty is 300 feet tall and the Washington Monument is 555 feet tall.

Maintain a safe distance from people, vehicles, buildings and other major structures or geographical 

features. Maintain a distance of 5 miles from airports (per FAA regulations) so as not to interfere with 

manned flights. It’s also a good idea to make sure no structures come between you and your drone that 

CROWDS

It’s your job to ensure the safety of the people around you, and you should avoid flying over people and 

crowds at all times. Should you lose control or battery power, your drone may fall and strike someone. 

Though our drones are relatively low-weight and the chances of them doing serious harm are quite slim, 

the sharp spinning propellers can do damage, and the drone itself can cause a scare or a nasty bump on 

the head.

So please: Steer clear of crowds, and make sure your drone maintains a safe distance from spectators
NO-FLY ZONES

Regulations on when and where to fly might seem complex and subject to frequent changes. Thankfully 

the FAA plans to launch an app called B4UFLY, which will advise drone users of any flight restrictions in 

their area, based on their GPS location. It’s our expectation that the FAA, whose mission it is to ensure a 

safe national airspace, will keep this database accurate and up to date. If you’d rather go the private 

route, you can also check out Airmap, an app that serves much the same purpose. We highly 

recommend that all 3DR users reference a resource like these apps before they fly.

That said, here’s a cursory rundown on what’s off currently off-limits to drones in the US. This isn’t only 

for the safety of those around you, but for your own—violations of some of these spaces could get you 

thrown in jail.

o Airspace above 400 ft

o Airspace within 5 miles of an airport or airbase

o Certain sensitive metropolitan and government areas (e.g., Washington DC; Manhattan)

o National parks and recreation areas

o Sensitive infrastructure (e.g. dams)

o Many stadiums and arenas

o Major public events, as the FAA determines case-by-case (e.g., the Super Bowl, the Boston 

Marathon)

FAILSAFES

While we can’t ever rely entirely on technology to prevent accidents or bad behavior, as an innovative 

and conscientious company we do know there are some steps we can take to help ensure safe and 

successful flights. Here are the failsafes we’ve built into Solo—many are on all 3DR drones.

o Auto takeoff/land—Solo offers pushbutton takeoff and landing

o “Pause” button—an emergency airbrake that immediately stops Solo mid-flight and brings it to 

a hover

o “Return Home”—push this button (with the image of a house) on Solo’s controller and Solo will 

automatically fly to a height of 50 feet and return to its point of takeoff, where it will auto-land

o Loss of GPS signal—If this happens in a mode that requires GPS, Solo will switch to manual flight 

mode

o Loss of connection to controller—Solo returns home to land

o Low battery—Solo first alerts you to a low battery; if you don’t bring it home, it will then come 

home to land

o Common sense—duh
11.3 Regulatory Compliance 11.3.1 U.S. 

- FCC (Federal Communication Commission) 

3DR Solo FCC: 2ADYD-S111A 

3DR Solo Controller FCC: 2ADYD-AT11A 

This device complies with Part 15 of the FCC rules. Operation is subject to the following two conditions: 

(1) This device may not cause harmful interference, and (2) this device must accept any interference 

received, including interference that may cause undesired operation.

Changes or modifications not expressly approved by 3D Robotics could void the user’s authority to 

operate the equipment. 

Radiation Exposure Statement: 

The Solo system has been tested to ensure compliance with FCC-mandated limits for general population 

radio frequency (RF) exposure for an uncontrolled environment. These limits ensure that no harmful 

effects will result from operating Solo according to the standard operating procedures described in this 

manual.

UAS Information:

Make: 3DR Year: 2016

Model: Solo FAA UAS Certificate Number: FA3H9XTNKA

FAA Registration Issue Date: 01/29/16 FAA Registration Expiration Date: 01/29/2019

I thank you for your time and effort in processing this request.

Sincerely,

Jamal A. Warner

522 Kalmia Sq NE

Leesburg, VA 20176

571-526-8044