UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, 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 COMMERCIAL 

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.com
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TABLE OF CONTENTS 

Page

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

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

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

BACKGROUND....................................................................................................................5

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

NAME AND ADDRESS OF PETITIONER...........................................................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SOLUTIONS 101, LLC

SEEKS EXEMPTION.............................................................................................................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 INTEREST ...................................................................................................16

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY..................................................................................................................16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.....................34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

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

CONCLUSION.......................................................................................................................36

SUPPORTING DOCUMENTS ............................................................................ATTACHED
3

GLOSSARYOFABBREVIATIONS

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

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

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 commercial purpose of conducting aerial data collection for 

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

INTRODUCTIONANDINTERESTSOFTHEPETITIONER

SOLUTIONS 101, LLC is a specialty construction services company, providing 

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

services. SOLUTIONS 101, LLC ownership has over 40 years experience in construction 

and project management for Federally 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 group which focuses on sUAS safety and 

education. The objective of SOLUTIONS 101, LLC UAS operations is to provide high

quality imaging for a variety of commercial, public, and private uses, specifically targeting:

 Aerial Data Collection for Conservation and Construction

 Video and Photographic Capture for 3rd Party Marketing Teams

 Assist Search and Rescue Operations with local law enforcement
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BACKGROUND

UnmannedAircraftSystems:DJI Inspire 1 and/or 3DR Aero UAS

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

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

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 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 Lithium Polymer battery

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 systems. 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 electronic 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 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems,

hereby petitions the Administrator to commercially operate the DJI Inspire 1 and/or 3DR 
6

Aero 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, 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.

Accordingly, SOLUTIONS 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 maintenance, alterations, or preventive maintenance 

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

documents (i.e., 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.

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 (PIC) holding a private pilot or higher level 

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

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC

is able to safely operate the DJI Inspire 1and 3DR Aero UAS in a manner consistent with 
7

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 

airworthiness, because 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 that it will ensure that the DJI Inspire 1 and/or 3DR Aero 

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

in compliance with the operating documents (i.e., Monthly Maintenance Log, DJI Inspire 

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

condition for safe 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 information of the DJI

Inspire 1and 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

equivalent 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 affected by 

operation of the DJI Inspire 1 and/or 3DR Aero UAs during daylight hours in visual 
8

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. Name And 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 Which 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 (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. 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 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 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 available 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 subpart E of this part and shall 

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

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

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 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 §

43.7 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 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. 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:
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(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required.

(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.
12

(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 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) 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, SOLUTIONS 101, LLC submits that an equivalent 

level of safety 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 flight-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 specifications as described 

in this exemption, 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 granting of this 

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

not carry passengers or property for 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 Inspire 1and 

3DR Aero UAS are in airworthy condition prior to every flight by 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 Instruction Manual, 3DR 

Aero Instruction Manual).

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

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 the DJI Inspire 

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

operating documents (i.e., Monthly Maintenance Log, DJI Inspire 1 Instruction 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, may 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 to 
15

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 1and 3DR 

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

barometric pressure or field altitude, before each flight.

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 DJI Inspire 1 and/or 3DR Aero UAs are equipped with a 

barometric 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-up display of the GCS.

4. Extent Of Relief 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 

exemption from Section 91.151(b), the flight time duration of the battery powered 

DJI Inspire 1and 3DR Aero UAs will severely constrain the practicality of 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 1and 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 

battery 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) 

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

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

airworthiness 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 certificate. Accordingly, SOLUTIONS 101, LLC will use trained 

technicians to perform 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, LLC 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 for 

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 

economy. Notably, 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 1and 3DR Aero UAs are battery powered and serve as a 

safe, efficient, and economical alternative to the manned aircraft traditionally

utilized to obtain aerial data. By reducing the amount of manned aircraft needed to 

perform aerial acquisitions, an exemption allowing 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 ground.

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

congestion around airports caused by arriving and departing 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 conducting aerial data collection 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.
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 1and 3DR Aero UAS, 

instead of manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial flight 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 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 DJI Inspire 1 and/or 3DR Aero 

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 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 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 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 typically 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 aerial 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 alternative 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 operational cost of a traditional manned aircraft.

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

remain competitive and profitable, and therefore, provide greater job 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

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

Aero will not implicate any privacy issues. Specifically, the DJI Inspire 1and 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 as 
20

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.

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 operating area

associated 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 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.
21

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

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, 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 certification 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 Defined 

Operational Area.

The DJI Inspire 1 and/or 3DR Aero UAS may be operated in manual and 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 Are 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 seconds, 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 and 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 certificate to act as a pilot in command (PIC) of the 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. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, UAS weighing less than

55 pounds maximum gross weight: DJI Inspire 1 and/or 3DR Aero 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 data collection.

3. The UAs may not be flown at an indicated airspeed exceeding 80 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 by ATC. All altitudes 

reported to ATC must be 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 other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate.
24

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO 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 SO can perform the

functions prescribed in the operating documents.

8. The SO 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.

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.
25

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.
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 

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 (N- Number) 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, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:
27

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately 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 closer to those objects and determined that it does not present 

an undue hazard, and;

c. Operations nearer to the PIC, 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 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.

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 be 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, including 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 limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (See Exemption 
28

No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1

UAS, SOLUTIONS 101, LLC submits that the additional 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 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).

SOLUTIONS 101, LLC will not allow any PIC to operate the DJI Inspire

1 or 3DR Aero UAS unless that PIC has demonstrated, by meeting minimum flighthour requirements or the DJI Inspire 1 and/or 3DR Aero UAS training 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 this exemption, including evasive and emergency

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

structures.

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 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).
29

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 SOLUTIONS 101, LLC proposed operations. The Administrator has 

held that prior documented flight 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.

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 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, including evasive 

and emergency maneuvers 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 established 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 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 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 visual line of sight, at or below 500 feet 

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

will be 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 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 DJI

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

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

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

UAS during daylight 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 

1and 3DR Aero 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 DJI Inspire 1 and/or 3DR 

Aero 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 33% remaining 

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

low battery level, the DJI Inspire 1 and/or 3DR Aero 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
32

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).

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 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 SOLUTIONS 101, 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., 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.

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 copy of the 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 technicians 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 DJI Inspire 1 and/or 3DR 
33

Aero UAS will be performed by trained technicians. 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 SOLUTIONS 101, LLC proposed operating limitations, the operating 

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

submits that 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, 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 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 data collection 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 
34

without airworthiness 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 DJI Inspire 1 or 3DR Aero 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, or propeller 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 DJI Inspire 1 

and/or 3DR Aero 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 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 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, Views, 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 may

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 

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, 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 security.

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

Asset 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 101, LLC

N2828 Givens Rd

Hortonville, WI 54944