UNITED STATES OF AMER I CA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASH I NGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

SOLUTIONS 101, 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 COM MERCIAL
OPERATION OF A DJI INSPIRE 1 AND /OR 3DR AERO UNMANNED
AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

SOLUTIONS 101, LLC Jim Sykes, Owner
N2828 Givens Rd Hortonville, WI 54944
920

- 378

- 1784 jsykes@solutions101llc.com2 TABLE OF CONTENTS

Page

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

SUMMARY.........................................................

.......................................... . .......................4

I N TRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND..................................................................................................................

. .5

BA S I S FOR PETITION.........................................................................................................5

N AME AND ADDRESS OF PETITIONER...........................................................................8

THE SPECI FI C SECTIONS OF 14 C.F.R. FROM WHI CH SOLUTIONS 101, LLC

SEEKS EXEMPT I ON.............................................................................................................8

THE EXTENT OF RELIEF SOLUTIONS 101, LLC SEEKS AND THE REASON

SOLUTIONS 101, LLC SEEKS THE RELIEF.................................................... ...............12

THE REASONS WHY GRANTING SOLUTIONS 101, LLC REQUEST WOULD BE IN

THE PUBLIC I N TEREST ...................................................................................................16

THE REASONS WHY GRANTING THE EXEMPT I ON WOULD NOT ADVERSE L Y

AFFECT SAFETY..............................................................................

. ...................................16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REG I STER.....................34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT SOLUTIONS 101, LLC REQUEST....................................................................35

CONC L USION.............................................

. ........................................................................ .36

SUPPORTING DOCUMENTS

................... . ........................................................ATTACHED3 GLOSSARY OF ABBREVIATIONS

AG L Above Ground Level

AO I Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

A V Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FA A Federal Aviation Administration

FA R Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning S y stem

LOL Loss of Link

NA S National Airspace S y stem

NOTAM Notice to Airman

P I C Pilot I n Command

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

S O Safety Observer

SOP Standard Operating Procedures

U A Unmanned Aircraft

UA S Unmanned Aircraf t S y stem

VF R Visual Flight Rules

VLOS Visual L ine of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 SUMMARY

SOLUTIONS 101, 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 SOLUTIONS 101, LLC to operate an Unmanned Aircraft

System (UAS) for the co mmercial purpose of conduc ting a erial data collection for

industries including conservation, construction, photography, real estate, and education.

INTRODUCTION AND INTERESTS OF THE PETITIONER

SOLUTIONS 101

, LL C i s a specialty construction services company, providing

customers with project management solutions, design/build capabilities, and consulting

services. SOLUTIONS 101

, LL C ownership has over 40 years experience in construction

and project management for Fe derally funded projects including an emphasis the past 5

years on conservation projects. SOLUTIONS 101, LLC project manager is a licensed pilot

and has built and flown sUAS recreationally for 2 years. Additionally, the project manager

started a separate 300 member sUAS enthusiast grou p which focuses on sUAS safety and

education. Th e objectiv e o f SOLUTIONS 101

, LL C UAS operation s i s t o provid e hig h

qualit y imagin g fo r a variet y o f commercial, public

, an d private uses , specificall y targeting:

 Aerial Data C ollection for Conservation and Construction

 Video and Photographic Capture for 3rd Party Marketing Teams

 Assist Search and Rescue Operations with local law enforcement5 BACKGROUND

Unmanned Aircraft Sy stems: DJI Inspire 1 and/or 3DR Aero UAS

SOLUTIONS 101, LLC seeks an exemption to operate DJI Inspire 1 and/or 3DR

Aero system s for compensation or hire within the NAS. The DJI Inspire 1 are vertical

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Groun d Control Station

(GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a

maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7

inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI

Inspire 1 UAs is equipped with four main rotors; driven by L ithiu m Polyme r batter y

powered electric motors. The 3DR Aero is a fixed wing Unmanned Aircraft (UA) with a

Ground Control Station (GCS) using electronic tablet or smart phone syste ms. THe 3DR

Aero has a maximum gross weight of 6 pounds 12.8 ounces, a length 51 inches, width of

74 inches, height of 14.5 inches, and an operational speed of approximately 28 knots. The

3DR Aero is driven by a single Lithium Polymer battery powered ele ctronic motor.

The DJI Inspire 1 and/or 3DR Aero UAs that will be operated by SOLUTIONS

101, 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

.

BASIS FOR PETITION

Petitioner, SOLUTIONS 101, 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 (FMR A), Section 333, Special Rules for Certain Unmanned Aircraft Systems

,

hereby petitions the Administrator to commercially operate the DJI Inspire 1 and/or 3DR6

Aero UAS in the National Airspace S ys tem (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, SOLUTIONS 101, LLC operation of DJI

Inspire 1 and/or 3DR Aero UAS meets 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.

According ly

, SOLUT IONS 101

, 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.

SOLUTIONS 101, LLC submits that the requested relief is proper since an

equivalent level of safety will be ensured. SOLUTIONS 101, LLC will use experienced

personnel or technicians to perform mainte n ance, alterations, or preventive maintenance

on the UAS using the methods, techniques, and practices prescribed in the operating

documents (i.e., M onthl y Maintenance Lo g, DJI I nspire 1 Instruction Manual , and 3DR

Aero Instruction Manual ). Furthermore, SOLUTIONS 101, LLC will document and

maintain all maintenance records for the DJI Inspire 1 and/or 3DR Aero UAS.

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

privileges and limitations: Pilot in command , is requested by SOLUTIONS 101, LLC to the

extent necessary to allow a Pilot in Command (P IC) holding a private pilot or higher level

certificate, as well as an airman medical certificate, and who has

demonstrated, by meetin g minimum flight

- hour and currency requirements, that the PIC

is able to safely operate the DJI I nspire 1 and 3DR Aero UAS in a manner consistent with7

this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

SOLUTIONS 101, LLC seeks relief from Section 91.7(a), entitled Civil aircraft

a irworthiness , bec a use the DJI Inspire 1 and/or 3DR Aero UAS do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

SOLUTIONS 101, LLC submits tha t it will ensure that the DJI Inspire 1 and/or 3DR Aero

UAS ar e in an airworthy condition, prior to every flight, by determining that the UAS are

in compliance with the operating documents (i.e., Monthl y Maintenance Log, DJ I I nspire

1Instruction Manual , and 3DR Aero Instruction Manual ), and that the aircraft are in a

condition for sa f

e flight.

SOLUTIONS 101, LLC also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings , as the DJI Inspire 1 and/or 3DR Aero UAs will not

have a typical barometric altimeter onboard. However, altitude i nformation of the DJI

I nspire 1 and 3DR Aero UAS will be provided to the PIC via Global Positioning System

(GPS) equipment and radio communications telemetry data link, which downlinks from

the UA to the GCS for active monitoring of the flight path. This altitude information,

combined with SOLUTIONS 101, LLC operation of the DJI Inspire 1 and/or 3DR Aero

UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equi valent to Section 91.121.

Additionally, SOLUTIONS 101, LLC seeks an exemption from the

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

conditions . SOLUTIONS 101, LLC submits that safety will not be a ffecte d by

operation of the DJI Inspire 1 and/or 3DR Aero UAs during daylight hours in visual8

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fly for 25% more time than the anticipated flight duration.

In accordance with 14 C.F.R. § 11.81, SOLUTIONS 101, LLC provides the following

information in support of its petition for exemption:

A

. Nam e A nd Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

SOLUTIONS 101, LLC James Sykes, President
N2828 Givens Rd Hortonville, WI 54944
920

- 378

- 1784 jsykes@solutions101llc.com

B. The Specific Sections Of 14 C.F.R. From Whic h SOLUTIONS 101, LLC Seeks Exemption.

1. SOLUTIONS 101, 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 (P I C) of an aircraft that is carr y ing passengers or proper t y for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilo t ma y , for compensation or hire, act as PIC of an
aircraft in connection with a n y busine ss or empl o y m ent i f

—

(1) The flight is only incidental to that business or emplo y ment; and

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

2. SOLUTIONS 101, LLC Seeks Exemption From The Requirements Of Section 91.7(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 airworthy

condition.9

3. SOLUTIONS 101, 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 o r flight level of that aircraft, as the case may be, b y reference to an

alti meter that is set, when operating

--

(1) Below 18,000 feet MS L , to

--

( i) The current reported altimeter setting of a station along the

route and within 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 ava ilable before departure.

4. SOLUTIONS 101, 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. SOLUTIONS 101, 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 subpar t 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[.]

6. SOLUTIONS 101, LLC Seeks Exemption From The Requirements Of Section 91 .407(a)(1)10 Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration

, subsection (a)(1), states the following:

(a) No person may operat e an y aircraft that has undergone maintenance, preventive maintenance, reb uilding, or alteration unless

--

(1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]

7. SOLUTIONS 101, 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:

(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 b y a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance o f an airworthiness certificate in accordance with part 21 of this chapter.

8. SOLUTIONS 101, 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:11 (1) Records of the maintenance, preventive mainten a nce, and alteration and

records of the 100

- hour, annual, pr ogressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircra f t.
The records must include

--

(i) A description (or reference to data acceptabl e 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 lif e

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all i tems 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
dir e ctives including, for each, the method of compliance, the AD or
safe t y directive number and revision date. If the AD or safety directive
invol ves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and current l y 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 b y other work or for 1 y e ar after th e work is performed.12 (2) The records specified in paragraph (a)(2) of this section shall be retai ned

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

thi s chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief SOLUTIONS 101, LLC Seeks And The Reason SOLUTIONS 101
, LLC Seeks The Relief.

1. Extent Of Relief SOLUTIONS 101, LLC Seeks And The

Reason SOLUTIONS 101, LLC Seeks Relief From Section 61.113(a) And (b).

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

limitations: Pilot in comman d , is requested to the extent necessary to allow a P I C 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 requ ested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot ma y , for compensation or hire, act as P I C of an aircraft in

connection with a n y business or empl o y m ent if: (1) The flight is only incidental to that

business or emplo y ment; and (2) The aircraft does not carry passengers or proper t y for

compensation or hire.

As set forth more fully below, SOLUTIONS 101, LLC submits that an equivalent

level of safet y will be maintained because no PIC will be allowed to operate the DJI

Inspire 1 or 3DR Aero UAS unless that PIC has met certain flig h t

- hour and currency

requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1

or 3DR Aero UAS in a manner consistent with the operations speci fications as described

in this exem p tion, including evasive and emergency maneuvers, as well as maintaining

appropriate distances from people, vessels, vehicles and structures.14 Further, SOLUTIONS 101, LLC submits that all flights of the DJI Inspire

1 and/or 3DR Aero UAS, conducted by the PIC pursuant to the grant ing of this

Petition: (1) will be incidental to SOLUTIONS 101, LLC business; and (2) will

not carry passengers or property fo r compensation or hire.

2. Extent Of Relief SOLUTIONS 101, LLC Seeks And The

Reason SOLUTIONS 101, 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 SOLUTIONS 101, LLC to determine that the DJI I nspire 1 and

3DR Aero UAS are in airworthy condition prior to every fligh t b y ensuring that the UAS

is in compliance with the operating documents (i.e., the SOLUTIONS 101, LLC Aerial

Operations Manual, Monthly Maintenance Log, DJI Inspire 1 I nstruction Manual , 3DR

Aero Instruction Manual ).

SOLUTIONS 101, LLC seeks the requested relief because the DJI I nspire 1 and

3DR Aero UAS do not require an airworthiness certificate in accordance with 14 C. F .R.

Part 21, Subpart H. Therefore, SOLUTIONS 101, LLC will ensure that th e DJI Inspire

1 and 3DR Aero UAS are in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 I nstruction Manual,

3DR Aero Instruction Manual) prior to every flight, and further, determine that the aircraft

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

3. Extent Of Relief SOLUTIONS 101, LLC Seeks And The

Reason SOLUTIONS 101, LLC Seeks Relief From Section
91.121.

Relief from Section 91.121, entitled Altimeter settings, ma y be required to allow

flight operations of the DJI Inspire 1 and/or 3DR Aero UAS , which utilize a barometric

pressure sensor, GPS equipment, and a radio communications telemetry data link to15

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),

SOLUTIONS 101, LLC seeks the requested relief because the DJI Inspire 1 and 3DR

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

barometric pr e ssure or field altitude, before each flight.

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

91.12 1 is sought to the extent necessary to comply wit h the applicable conditions and

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the DJI Inspire 1 and/or 3DR Aero UAs are equipped with a

baro metric pressure sensor 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

- u p displa y of the GCS.

4. Extent Of R elief SOLUTIONS 101, LLC Seeks And The

Reason SOLUTIONS 101, 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

DJI Inspire 1 and/or 3DR Aero UAs during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly

for 25% more time than the anticipated flight duration.

SOLUTIONS 101, LLC seeks the requested relief because without an

e x emption from Section 91.151(b), the flight time duration of the battery powered

DJI I nspire 1 and 3DR Aero UAs will severely constrain the practicality o f flight

operations that SOLUTIONS 101, LLC proposes to conduct pursuant to this Petition.16

Significantly, as set forth below, the technical specifications of the DJI Inspire 1 and 3DR

Aero UAS, the DJI Inspire 1 and/or 3DR Aero operating documents, and SOLUTIONS

101 , LLC proposed operating limitations, ensure that SOLUTIONS 101, LLC will safely

operate the battery powered DJI Inspire 1 and/or 3DR Aero UAs during daylight hours in

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough

bat tery power to fly for 25% more time than the anticipated flight duration.

5. Extent Of Relief SOLUTIONS 101, LLC Seeks And The Reason SOLUTIONS 101, 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)

onl y apply to aircraft with an airworthiness certificate, SOLUTIONS 101, LLC requests

relief from these Sections because the DJI Inspire 1 and 3DR Aero UAS do not require

ai rworthiness certificates. As set forth more fully below, the DJI Inspire 1 and/or 3DR

Aero UAS meet the conditions of FMRA Section 333 for operation without an

airworthiness cer t ificate. Accordingly, SOLUTIONS 101, LLC will use trained

technicians to perfo rm maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the UAS operating documents

(i.e., the SOLUTIONS 101

, LLC Aerial Operations Manual, Monthly Maintenance Log,

DJI Inspire 1 Instruction Manual , and 3DR Aero Instruction Manual ). Furthermore,

SOLUTIONS 101, LLC will document and maintain all maintenance records for the DJI

Inspire 1 and/or 3DR Aero UAS.

D. The Reasons Why Granting SOLUTIONS 101
, LL C Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.17

Granting the present Petition will further the public interest by allowing SOLUTIONS

101, LLC to safely, efficiently, and economically perform aerial data collection fo r

industries including conservation, construction, photography, real estate, and

education.

Additionally, use of the DJI Inspire 1 and/or 3DR Aero UAS will decrease

congestion of the NAS, reduce pollution, and provide significant benefits to the

ec o nom y

. Notabl y, the benefits of SOLUTIONS 101, LLC proposed operation of the

DJI Inspire 1 and/or 3DR Aero UAS will be realized without implicating any privacy

issues.

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

The DJI Inspire 1 and 3DR Aero UAs are battery powered and serve as a

safe, efficient, and economical alternative to the manned ai r craft traditionally

utilized to obtain aerial data

. B y reducing the amount of manned aircraft needed to

perform aerial acquisitions, an exemption allow ing the use of a DJI Inspire 1 and/or

3DR Aero 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 gro u nd.

Furthermore, b y reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departi n g aircraft will be reduced. The

DJI Inspire 1 and/or 3DR Aero UAs do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft cond ucting aerial data collection mis sions

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.18 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 and/or 3DR Aero UAS.

Conducting aerial acquisitions with the DJI Inspire 1 and 3DR Aero UAS,

instead of manned aircraft, will greatly benefit the public by drastically re d ucing the

levels of air and noise pollution generated during traditional aerial flig h t operations.

By using battery power and electric motors, the DJI Inspire 1 and/or 3DR Aero UAS

produce no air pollution, and is the most viable envir o nmentally conscious

alternative to the cabin c lass, si x cy linder internal combustion engine aircraft that

are t ypicall y utilized for aerial video and photograph y , while burning approximately

20

- 30 gallons per hour of leaded aviati o n fuel. The DJI Inspire 1 and/or 3DR Aero

UAs, while reducing the carbon footprint of aerial acqui sitions, also eliminates noise

pollution, as the UAs are propelled by battery powered electric motors, rather than

an internal combustion engine.

B y using the DJI Inspire 1 and/or 3DR Aero UAS to perform aerial acquisitions,

the substantial risk to life and property in the air and on the ground, which is u sually

associated with traditional manned aircraft flight operations, will be substantially reduced

or completely eliminated. Aside from t he lack of flight crew members located onboard the

aircraft, the DJI Inspire 1 and/or 3DR Aero UAs have less physical potential for collateral

damage to life and property on the ground, and in the air, compared to the manned aircraft

that ty picall y conduct similar operations

.19 3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 and/or 3DR Aero UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 and/or 3DR Aero UAS are also

an economical alternative to using manned aircraft to conduct similar ae r ial operations. As such,

operation of the DJI Inspire 1 and/or 3DR Aero UAS will allow United States based companies,

like SOLUTIONS 101, 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 a l ternative technology in order to remain competitive. Operating

the battery powered DJI Inspire 1 and/or 3DR Aero UAS is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such

flexibility without the high operationa l cost of a traditional manned aircraft.

B y operating the DJI Inspire 1 UAS, companies such as SOLUTIONS 101, LLC, can

remain competitive and profitable, and therefore, provide greater job stability t o employ ees

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

DJI Inspire 1 and/or 3DR Aero UAS, provides a stable workforce that increases consumer

spending; improves local, state, and federal ta x r e venues; 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, SOLUTIONS 101, LLC proposed operation of the DJI Inspire 1 and/or 3DR

Aero will not implicate any privacy issues. Specifically, the DJI Inspire 1 and 3DR Aero

UAS will be operated only in compliance with operating documents (i.e., SOLUTIONS

101, LLC Aerial Operations Manual, Monthly Maintenance Log, DJI Inspire 1 Instruction

Manual , and 3DR Aero Instruction Manual ) which requires property owner involvement as20

well as local law enforcement notification, and in accordance with the Federal Aviat ion

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

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 SOLUTIONS 101, LLC Seeks Exemption.

1. Reasons Why The DJI Inspire 1 and/or 3DR Aero UAS Meet The
Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited ope rating area

associat e d with the unmanned aircraft and its operation, SOLUTIONS 101, LLC

operation of the DJI Inspire 1 and/or 3DR Aero 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 s e curi t y.

Specifical l y, 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 Transportatio n 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.21 ( b ) Assessment of Unmanned Aircraft Systems.

- - In making the determination under subsection (a), the Secretary shall determine, at a minimu m

--

( 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 sec tion 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 sy stem.

In seeking this exemption, SOLUTIONS 101, LLC submits that the and DJI Inspire 1 and/or 3DR Aero UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot cert ification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 and/or 3DR Aero UAS
Demonstrate Its Safe Characteristics.

The DJI Inspire 1 and/or 3DR Aero UAS do not create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security considering its

size, weight, speed, and operational capability.22 i. The DJI Inspire 1 and/or 3DR Aero UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Def ined Operational Area.

The DJI Inspire 1 and/or 3DR Aero UAS may be operated in manual an d fully

autonomous flight modes

- both of which include the option for a "Geo

- Fence". A

Geo

- Fence is a pre

- determined maximum distance from the GCS, beyond which the

UA will not fly regardless of control inputs by the PIC. A complete description of

the flight and navigational modes of the DJI Inspire 1 and/or 3DR Aero UAS are in

their respective Instruction Manuals.

ii. The DJI Inspire 1 and/or 3DR Aero UAS Ar e Designed For
Automatic Return To Home Point In The Event Of Loss Of The
Control Link Or Navigation.

When the Control Link is lost, the DJI Inspire 1 UAs will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 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. Similarly, if after 3 sec onds, the 3DR Aero does not

reacquire control link data from the GCS, the UAs will assume that the Control Link is lost

and the UA will return to the home position (i.e., failsafe mode) via GPS. Complete

descriptions may be found in the attachments.

iii. The DJI Inspire 1 and/or 3DR Aero GCS and their Operation.

A complete description of the operation a n d specifications of the DJI Inspire 1

and/or 3DR Aero GCS and flight control software is provided in the attachments.23 b. Flight Operations Of DJI Inspire 1 and/or 3DR Aero UAS Are Limited
To The Line Of Sight Of A Certificated Pilot in Command With A Safety
Observer.

SOLUTIONS 101, LLC will only utilize certificated pilots who possess a

current and valid airman certif icate to act as a pilot in command (PIC) of t h e DJI

Inspire 1 and/or 3DR Aero UAS

. Additionally, a safety observer will assist all pilots

during flight time.

c. Flights Of DJI Inspire 1 and/or 3DR Aero UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, SOLUTIONS 101, LLC proposes to commercially

operate DJI Inspire 1 and/or 3DR Aero UAS for the special purpose of conducting

aerial data collection , pursuant to the following specific operating limitations:

1. Opera tions authorized by this grant of exemption will be limited to the followi n g aircraft described in the operating documents, UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 and/or 3DR Aero Unmanned
Aircraft S ys tems. 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 data collection.

3. The UAs may not be flown at a n indicated airspeed exceeding 8 0 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitud es reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the P I C at all times. This requires the PIC to be able to use human vision unaided by a n y device other than corrective lenses, as specif ied on the P I C’s FAA

- issued airman
medical certificate.24 6. The use of first person view (FPV) b y the P I C or safe t y observer (SO) is not permitted.

7. All operations must utilize a safe t y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alwa y s maintains V L O S capabilit y

. The SO and P I C 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 P I C must ensure that the SO can perform the functions prescribed in the operating docum e nts.

8. The SO must not perform any other duties be y ond assisting the P I C with seeing and avoiding other ai r 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 i t s 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 I ntegration O f

fice (AF S

- 80 ) ma y be contacted if questions arise regarding updates or revisions to the operating documents

.

10. Prior to each flight the P I C 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 ma intenance 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 proper l y documented in the aircraft records.

11. Any U AS 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 P I C who conducts the functional test flight must make an e ntry in the aircraft records.

12. The pr e

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or e quipment, not already covered in the relevant sections of the operating documents.25 13. The operat or must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carr y out its maintenance, inspections, and record keeping requirements, in accordance with the op erating 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 P I C 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 P I C meets the operator’s qualification cr iteria and demonstrates the ability to safe l y 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
onl y be co nducted during dedicated training sessions. During training, proficienc y , and experienc e

- building flights, all persons not essential for flight operations are considered nonparticipants, and the P I C must operate the UA with appropriate distance from nonpar ticipants 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 manag ement must be made available to the Administrator upon request.26 21. 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

P I C.

22. If the UA loses communications or loses its GPS signal, it must return to a p r e

determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The P I C must abort the flight in the event of unpredicted obsta cles or emergencies in accordance with the operating documen t s.

24. The P I C 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 a n y 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 clas s of airspace, altitude level and potential transponder require m ents.

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 ( N

- Number) mark ings 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 requir e ments.

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 a n y time the UAS is operating. These documents must be made available to the
Administrator or a n y law enforcement official upon request.

29. The UA must remain clear and y i eld the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated b y 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 P I C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:27 a. B arriers or structures are present that su f ficiently 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 non participating persons leave such protection and are 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 struct ures has granted permission and the P I C h as made a safe t y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the P I C, SO, 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 controlle d

- access property with permission from the land owner/controller or authorized representative.
Permission from land owner/cont roller or authorized representative wi l l 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 rep orted to the FAA's UAS Integration Office (AF S

- 80) within 24 hours. Accidents must be reported to the National Transportation Safe t y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requireme n ts Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

SOLUTIONS 101, LLC submits that the equivalent level of safety established

by Section 61.113(a) and (b) will be maintained because no PIC will b e allowed to

operate the DJI Inspire 1 or 3DR Aero UAS unless that PIC has demonstrated, by

meeting minimum flight

- hour and currency requirements, that the PIC is able to safely

operate the DJI Inspire 1 and/or 3DR Aero UAS in a manner consistent with the

exemption, includi n g evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Considering SOLUTIONS 101, LLC proposed area of operations, and the

operating l imit ations set forth

- above; the parallel nature of private pilot aeronautical

knowledge requirements to those of commercial pilot requirements (S e e Exemption28

No. 11062); and the airmanship skills necessary to safely operate the DJ I Ins pire 1

UAS, SOLUTIONS 101, LLC submits that the addi tional manned airmanship

experience of a commercially certificated pilot would not correlate to the

airmanship skills necessary for SOLUTIONS 101, LLC specific proposed flight

operations.

The FAA has previous l y 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).

SOLU TIONS 101, LLC will not allow any P I C to operate the DJ I I nspire

1 or 3DR Aero UAS unless that PIC has demonstrated, by meeting minimum flight

h o ur requirements or the DJI Inspire 1 and/or 3DR Aero UAS training and currency

requirements, that the PIC is able to safely o p erate the DJI Inspire 1 and/or 3DR Aero

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

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

structures.

Specifical l y, the P I C 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 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, th e P I C

must accomplish 3 takeoffs and landings in the preceding 90 da y s (for currency purposes).29 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

exp e rience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during SOLUTIONS 101, LLC proposed operations. The Administrator has

held that prior documented flight experience that was obtained in compliance wi t h

applicab le 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 l o gged, 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

P I C 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 mo del 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

P I C must accomplish 3 takeoffs and landings in the preceding 90 da y s (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 th at prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficienc y , and experienc e

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficienc y , and experienc e

- building flights the P I C is required to operate the UA with appropriate
distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, SOLUTIONS 101, LLC will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 and/or 3DR Aero UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and cur r ency requirements, that the PIC is able to safely operate the DJI Inspi re 1 and/or

3DR Aero UAS in a manner consistent with the exemption, including evasive and emergency maneu v ers and maintaining appropriate distances from people, vessels, vehicles and structures.30 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety esta b lished by Section 91.7(a) will be maintained

because prior to every flight, SOLUTIONS 101, LLC will ensure that the DJI Inspire 1

and/or 3DR Aero 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.

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

UAS, in circumstances similar, in all materi al 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 Requirem e nts Of S ection 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety esta b lished by Secti o n 91.121 will be maintained

because the altitude information of the DJI Inspire 1 and/or 3DR Aero 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 SOLUTIONS 101, LLC operation of

the DJI Inspire 1 and/or 3DR Aero UAs within vi sual line of sight, at or below 500 feet

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information

will b e generated by GPS 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, 11138,31

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would
Not A d versely 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 DJI

I nspire 1 and 3DR Aero UAS; (2) the limitations on the proposed flight operations; and (3)

the location of the proposed flig ht operations. Accordingly, SOLUTIONS 101, LLC will

ensure that it will safely operate the battery powered DJI Inspire 1 and/or 3DR Aero

UAS during da y light hours in VFR conditions, with enough battery power to fly for 25%

more time than the anticipated flight duration.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire

1 and 3DR Aero UAS; the limitations on the proposed flight operations; and the l o cation of

the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b). Furthermore, sa fet y will be ensured as the DJI Inspire 1 and/or 3DR

Aero UAS provide audible and visual warnings to the P I C at the GCS when the UAs

experiences low battery voltage, the first warning occurring a t approximately 33% remaining

battery power, and again at approximately 10% remaining batter y power. At the critically

lo w batter y level, the DJI Inspire 1 and/or 3DR Aero UAS will descend and land

automatically.

Significant l y, previous exemptions granted b y the FAA concerning Section 91.151

e stablish that safe t y is not adverse l y affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to opera te at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief32

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those

pre sented 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).

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, SOLUTIONS 101, LLC submits that the equivalent level of safet y

with regard to the regulatory maintenance and alterat ion 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 SOLUTIONS 101, LLC will use trained technicians to perform

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

practices presc r ibed in the operating documents (i.e., SOLUTIONS 101, LLC Aerial Operations Manual,

Monthl y Maintenance Log, DJI Inspire 1 Instruction Manual , and 3DR Aero Instruction Manual ).

Furthermore, SOLUTIONS 101, LLC will document and maintain all maintenance recor d s for the DJI

Inspire 1 and/or 3DR Aero UAS.

Since the DJI Inspire 1 and/or 3DR Aero UAS will be inspected as prescribed by the

operating documents, SOLUTIONS 101, LLC will maintain the equivalent level of safety established

by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of t h e DJI Inspire 1 and/or 3DR Aero

User Manuals are attached

.

Likewise, the exemption sought will not adversely affect safety because SOLUTIONS 101, LLC

will use trained t echnicians 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 establish ed by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 and/or 3DR33

Aero UAS will be performed by trained tec h nicians. Maintenance will be documented and maintained

utilizing the monthly maintenance log.

Significant l y, previous exemptions granted b y the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safe t y is not adverse l y

affected wh e n the technical characteristics and operating limitations of the UAS are considered.

In consideration of SOLUTIONS 101, LLC proposed operating limitations, the operating

documents, and the technical aspects of the DJI Inspire 1 and 3DR Aero UAS, SOLUTIONS 101, LLC

submits that safety will not be adversely affected by granting

e xemption 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 N os. 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 M odernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, SOLUTIONS 101, LLC requests that the FAA prescribe

special conditions for the intended operation of the DJI Inspire 1 and/or 3DR Aero UAS, which contain

such saf ety standards that the Administrator finds necessary to establish a level of safe t y equivalent to

that established b y 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 data collection over

certain are a s of the United States for compensation or hire. FMRA Section 333 sets forth the

requi rements 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 a uthority for such UAS to operate34

without airworthiness certification in accordance wit h 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 DJI Inspire 1 or 3DR Aero UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safe t y 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 safe t y standards for an aircraft, aircraft engine, or propeller because of a no v el or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes s pecial conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety stand a rds 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

ma y prescribe special conditions for L eading Edge’s intended operation of the DJI Inspire 1

and/or 3DR Aero UAS, which contain such safety standards that the Administ r ator finds

necessary to establish a level of safe t y equivalent to that established b y 14 C.F.R. Part 21,

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 S ummary That Can Be Published In The Federal Register, stating: The Rules From Which SOLUTIONS 101, LLC Seeks Exemption:

SOLUTIONS 101, 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 SOLUTIONS 101, LLC Seeks:35 This exemption will permit SOLUTIONS 101, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial data collection, video

, and photography over certain areas of the United States.

G

. Any Additional Information, Vi ews, Or Arguments Available To Support SOLUTIONS 101, 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, SOLUTIONS 101, LLC request for exemption ma y

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

set forth above.

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

cr eate a hazard to users of the NAS or the public, or otherwise pose a threat to national

securi t y ; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in detail above, SOLUTIONS 101, LLC will operate the

DJI Inspire 1 and/or 3DR Aero UAS safely in the NAS, without creating a hazard to

users of the NAS, or the public, or otherwise pose a threat to national secu r it y.

Please see the attachments for full documentation of the Solutions 101 LLC Aerial

Operations Manual, DJI Inspire 1 Manufacturer Manuals, and 3DR Aero Manufacturer

Manuals.36 CONCLUSION

As set forth herein, SOLUTIONS 101, 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 DJI Inspire 1 and/or 3DR Aero UAS commercially, without

an airworthiness certificate, for the limited purpose of conducting aerial data collection

. By

granting this Petition, the FAA 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 SOLUTIONS 101, LLC to safely, efficiently, and economically operate

the DJI Inspire 1 and/or 3DR Aero UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, SOLUTIONS 101, 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 SOLUTIONS 101, LLC

to operate the DJI Inspire 1 and/or 3DR Aero UAS commercially for the purpose of

conducting aerial data collection

.

Dated: October 2 , 2015

Respectfully submitted: James Sykes, Owner

SOLUTIONS 1 01, LLC

N2828 Givens Rd Hortonville, WI 54944