U.	S.	Department	of	Transportation	Docket	Management	System

1200	New	Jersey	Ave,	SE

Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation	

Regulations	from	14	C.F.R.	45.23(b);	14	C.F.R.	Part	21;	14	C.F.R.	61.113(a)&(b);	91.7(a);	

91.9(b)	(2);	91.103(b);	91.109;	119.121;	91.151(a);	91.203(a)&(b);	91.405(a);	

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

To	whom	it	may	concern,	

I,	Alan	Smith,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	

2012	and	the	procedures	contained	within	14	C.F.R.	11,	to	request	that	I,	Alan	Smith,	an	

owner	and	operator	of	small	unmanned	aircraft	and	to	be	exempted	from	the	Federal	

Aviation	Regulations	(“FARs”)	listed	below	so	that	I	may	operate	my	small	lightweight	

unmanned	aircraft	system	commercially	in	airspace	regulated	by	the	Federal	Aviation	

Administration	(“FAA”).	

As described	throughout,	I am	a	photographer	and	videographer	with	ample experience	in	

flying	my	hobby	aircraft	for	recreational	purposes.	I	have	added	a	3DR to	my	inventory	

equipped	with	a	self-contained	camera	with	intent	for	aerial	photography	and	

videography;	following	exemption	and	approval	by	the	FAA.	

The	request	of	exemption would	permit	the	operation	of	my	light	weight,	unmanned	

(piloted	by	remote	control)	and	comparatively	inexpensive	3DR (Section	1)	in	tightly	

controlled	and	limited	airspace.		It	will	be	predetermined	in	areas	away	from	large	public	

gatherings,	airports	and	heliports	for	community	videos,	photos	and	video	of	new	and	

remodeled	commercial	buildings/projects,	individual	homeowner	aerial photography	and	

videography,	photography	and	video	of	land	developments	for	builders,	and	nature	photos	

and videos	in	completely	unpopulated	areas	and	other	community	related	events	upon	

request.	

Currently,	similar	lightweight,	remote	controlled	sUASs	are	legally	operated	by	

unmonitored	amateur	hobbyists	with	no	safety	plan	or	controls	in	place	to	prevent	

catastrophe. I	have	personally instilled safety	protocols	and	controls	(Section	2) to	avoid	

and	prevent	public	hazard,	as	well	as	manned	aircraft	hazards/catastrophe.	 This	will	act	to	

further	safety	protocols	exclusive	to	lightweight	sUAS's	specific	to photography	&	

videography	usage	as I record	flight	data	and	other	information	gained	

through	permitted	flight	operations	to	share	with	the	FAA	through	any	required	FAA	

reports	to	assist	with future	protocol	and	safety	regulation.	
Granting my	request	comports	with	the	Secretary	of	Transportation’s	(FAA	

Administrator’s)	responsibilities	and	authority	to	not	only	integrate	UASs	into	the	national	

airspace system,	but	will	“establish	requirements	for	the	safe	operation	of	such	aircraft	

systems	in	the	national	airspace	system”	under	Section	333(c)	of	the	Reform	Act	specific	to	

the	use	of	sUASs	for	photography	&	videography	purposes.	 Further	I	will	conduct	my	

operations	in	compliance	with	the	protocols	described	herein	or	as	otherwise	established	

by	the	FAA.	

For	the	reasons	stated	below	I respectfully	request	the	grant	of	an	exemption	allowing	me	

to	operate	ultra-light	weight,	remote	controlled	sUASs	for	the	purposes	of	acquiring	aerial	

photos	&	videos,	both	of	which	will	promote	local	economic	growth	through	increased	

employment	and	increased	tax	base.		Both	with	public	safety	in	mind	by	keeping	heavier	

manned	aircraft	containing	combustible	fuel	that	that	poses	potential	public	hazard.		

(section	3:	3DR	User	manual,	protocols,	built	in	safety	precautions	and	controls)

I:		Contact	Information:	

Aerial	Vantage	Point,	LLC

Alan	Smith	– Owner	and	Operator

5231	N	Pine	Slope	Ct	SW

Wyoming,	MI	49519

(616)	389-7512	and/or	smity141@gmail.com

II:		 The	Specific	Sections	of	Title	14	of	the	Code	of	Federal	Regulations	from	which	Alan	

Smith	requests exemption	are: 14	CFR	21;	14	C.F.R.	45.23(b);	14	CFR	61.113	(a)	&	(b);	14	

C.F.R.	91,	et	seq.;	14	CFR	407	(a)	(1);	14	CFR	409	(a)	(2);	and,	14	CFR	417	(a)	&	(b).	

III: The	Extent	of	relief	Alan	Smith seeks	and	the	Reason	He	Seeks	Such	Relief:

I,	Alan	Smith,	submit	this	application	in	accordance	with	the	Reform	Act,	112	P.L.	95	§§	

331-334,	seeking	relief	from	any	currently	applicable	FARs	operating	to	prevent	me,	Alan	

Smith,	contemplated	commercial	cinematic,	academic	and	other	flight	operations	within	

the	national	airspace	system.	The Reform	Act	in	Section	332	provides	for	such	integration	

of	civil	unmanned	aircraft	systems	into	our national	airspace	system	as	it	is	in	the	public’s	

interest	to	do	so.	

My	ultra-lightweight	sUAS	meets	the	definition	of	“small	unmanned	aircraft”	as	defined	in	

Section	331	and	therefore	the	integration	of	my	ultra-lightweight	sUAS is	expressly	

contemplated	by	the Reform	Act.	 I	would	like	to	operate	my	ultra-lightweight	sUAS	prior	

to	the	time	period	by	which	the	Reform	Act	requires	the	FAA	to	promulgate	rules	

governing	such	craft.	Thereby,	providing	direct	experience	and	valuable	information	for	
formal	regulation	that	can	be	administered	uniformly	to	all	related	sUAS	aerial	

photography	&	videography.	

The	Reform	Act	guides	the	Secretary	in	determining	the	types	of	sUASs	that	may	operate	

safely	in	our	national	airspace	system.	Considerations	include:	The	weight,	size,	speed	and	

overall	capabilities	of	the	sUASs;	whether	the	sUAS	will	be	operated	near	airports	or	

heavily	populated	areas;	and,	whether	the	sUAS	will	be	operated	by	line	of	sight.	112	P.L.	

95	§	333	(a).	Each	of	these	items	reflect	in	favor	of	an	exemption	for	me,	Alan	Smith.	My	

sUAS	utilizes	four	(4)	counter-rotating	propellers	for	balance,	control	and	stability.	My	

sUAS	is	equipped	with	GPS	and	auto	return	safety	technology.	Weighing	less	than	five	(5)	

pounds	(far	below	the	maximum	55	pound	limit);	including	camera	with	gimbal.		(section	3	

with	further	details)

I,	Alan	Smith, consider	safety	as	upmost	importance	with	every	flight.	My	small	unmanned	

aircraft	is	designed	to	hover	in	place	via	GPS	and	operate	in	less	than	a	16	knot	(17	mph)	

wind.	For	safety,	stability	and	fear	of	financial	loss	I	will	not	fly	in	winds	exceeding	14	knot	

(15	mph).	Built	in	safety	systems	include	a	GPS	mode	that	allows	my	sUAS	to	hover	in	place	

when	radio	controls	are	released.	With	three	modes	to	choose	from,	I	utilize	the	GPS	Mode4	

for	aerial	photography	and	videography.	 This	is	the	safest,	most	reliable	and	stable	mode	

to	prevent	accidents	and	hazards.	When	pilot	communication	is	lost,	the	sUAS	is	designed	

to	slowly	descend	to	point	of	take-off.	

I	do	not	operate	my	sUAS	near	airports,	Hospitals	nor	Police	heliports,	and	do	not	operate	

near	areas	where	general	public	is	within	thirty	to	one	hundred	(30-100)	yards	depending	

on	location,	conditions	and	weather.	I	am	constantly	on	alert	for	any	manned	aircraft	

(Police/Medical	helicopters,	etc.)	and	prepared	to	land	/	abort	immediately	to	the	nearest	

and	safest	ground	point	should	a	manned	aircraft	approach	my	location	or	I	suspect	

manned	aircraft	may	approach	near	my	location.	My	sUAS	is	capable	of	vertical	and	

horizontal	operations,	and	are	flown	only	within	my	line	of	sight	of	me,	as	the	remote	

control	pilot.	Utilizing	battery	power	rather	than	combustible	fuels,	flights	generally	last	

between	10-15 minutes,	with	an	altitude	under	two	hundred (200)	feet.	I,	Alan	Smith,	

utilize	a	fresh, fully	charged	battery	with	each	flight	as	a	safety	precaution;	full	flight	time	

limit	for	each	battery	is	20-25 minutes	as	tested.	

I	do	not	operate	my	sUAS	at	or	below	the	manufacturer	recommend	minimum	charge

levels	for	operation;	 preferring	to	remain	well	within	a	safe	operating	range	to	insure	

adequate	communication	between	radio	control	and	sUAS	to	eliminate	potential	for	crash,	

loss	of	control	or	hazards.	Reserve	batteries	are	at	hand	with	each	exercise	to	insure	

replacement	for	sufficient	safe	level	of	operation.	I	do	not	believe	in	taking	risk	that	may	

cause	a	crash,	which	could	create	hazards	to	the	public	/	property	/	manned	aircraft,	and	
have	no	desire	to	lose	an	investment.	I	have	done	scores	of	practice	flights	in	remote	areas	

as	a	hobbyist	simulating	flights	for	future	commercial	use	to	gain	familiarization	with	the	

characteristics	of	this	specific	sUAS’s	performance	under	different	temperature	and	

weather	conditions.			All	for	the	sake	of	safety.	

I,	Alan	Smith,	am	extremely	cautious	when	operating	of	my	sUAS	/	ultra-lightweight	

unmanned	aircraft	and	will	not	“create	a	hazard	to	users	of	the	national	airspace	system	or	

the	public.”	112	P.L.	95	§	333	(b).	Given	the	small	size	and	weight	of	my	sUAS	it	falls	well	

within	Congress’s	contemplated	safety	zone	when	it	promulgated	the	Reform	Act	and	the	

corresponding	directive	to	integrate	sUASs	into	the	national	airspace	system. My	sUAS	

used	in	hobby	flight,	has	a	demonstrable	safety	record	and	does	not	pose	any	threat	to	the	

general	public	or	national	security.	

IV:		 How	Alan	Smith	 Request	Will	Benefit	the	Public	as	a	whole:	

Aerial	photography	and	has	been	around	for	a	long	time	through	manned	fixed	wing	

aircraft	and	helicopters.	 For	small	budget	productions, the	expense	of	such	aerial	

photography	and	videography	is	cost	prohibitive.	Only	larger	companies	can	afford	to	

absorb	such	expense.	Manned	aircraft	pose	a	threat	to	the	public	through	the	potential	of	a	

catastrophic	crash.	My,	sUAS poses	no	such	threat	since	size	and	lack	of	combustible	fuel	

alleviates	any	potential	threat	to	the	public.	 Congress	has	already	proclaimed	that	it	is	in	

the	public’s	interest	to	integrate	commercially	flown	sUASs	into	the	national	airspace	

system,	hence the	passing	of	the	Reform	Act.	Granting	my exemption	request	furthers	the	

public	interest	through	academic/visual	awareness	of	the	photography	and	videography	

fields	throughout	the	Grand	Rapids	area.	 My	ultra-lightweights	UAS	is	battery	powered	

and	creates	no	emissions	that	can	harm	the	environment.	The	consequence	of	my	ultralightweights	UAS	crashing	is	far	less	than	a	full	size	helicopter	or	fixed	wing	aircraft;	which	

are	heavy,	contain	combustible	fuel	and	can	cause	catastrophic	devastation	to	the	public.	

The	public’s	interest	is	furthered	by	minimizing	ecological	and	crash	threat	by	permitting	

aerial	photography	and	videography	captured	through	my	battery	operated	ultralightweights	UAS's.	Permitting	me,	Alan	Smith,	to	immediately	fly	within	national	air	space	

furthers	economic	growth.	 Granting	my	exemption	request	substantially	furthers	the	

economic	impact	for	the	Grand	Rapids	area	for	companies	looking	to	use	aerial	

photography	and	videography,	both	of	which	serve	as	a	stimulus	to	the	community.	

V:		 Reasons	Why	Alan	Smith’s Exemption	Will	Not	Adversely	Affect	Safety	Or	How	The	

Exemption	Will	Provide	a	Level	of	Safety	At	Least	Equal	To	Existing	Rule:	

My,	Alan	Smith,	exemption	will	not	adversely	affect	safety.	 Quite	the	contrary,	for	the	

reasons stated permitting	me	to	log	more	flight	time	in	FAA	controlled	airspace,	with	

communication	with	the	FAA,	will	allow	me	to	contribute	to	the	innovation	and	
implementation	of	new	and	novel,	as	of	yet	undiscovered	safety	protocols	for	

photographers	and	videographers	for	development	in	cooperation	with	

the	FAA.	

In	addition	I,	Alan	Smith,	submit	the	following	representations	of	enhancements	to	current	

aerial	photography/videography.	 My	sUAS	weighs	less	than	5	pounds	complete	with	a	

small	ultra-lightweight	high	quality	camera;	I	only	operate	my	sUAS	below	400	feet	(within	

the	400	foot	permissible	ceiling	set	by	the	FAA	Modernization	and	Reform	Act	of	2012);	My	

sUAS	only	operates	for	10-20 minutes	per	flight;	I	land	my	sUAS	prior	to	manufacturer	

recommended	minimum	level	of	battery	power;	I	pilot	my	sUAS	through	remote	control	

only	by	visual	line	of	sight;	My	sUAS	has	GPS,	a	flight	safety	feature	whereby	it	hovers	and	

then	slowly	lands	if	communication	with	the	remote	control	pilot	is	lost;	I	actively	analyze	

flight	data	and	other	sources	of	information	to	constantly	update	and	enhance	safety	

protocols;	I	only	operate	in	reasonably	safe	environment	away	from	airports	and	areas	

with	large	groups	of	people;	I	conduct	extensive	pre-flight	inspections	and	protocol, during	

which	safety	carries	primary	importance;	I	always	obtain	all	necessary	permissions	prior	to	

operation;	and,	I	have	procedures	in	place to	abort	flights	in	the	event	of	safety	breaches	or	

potential	danger.	

My,	Alan	Smith,	safety	protocols	provide	a	level	of	safety	equal	to	or	exceeding	existing	

rules (Section	2:	Common	Sense).	It	is	important	to	note	that	absent	the	integration	of	

commercial	sUAS	into	our	national	airspace	system,	helicopters	are	the	primary	means	of	

aerial	photography	and	videography. While	the	safety	record	of	such	helicopters	is	

remarkably	astounding,	there	has	been	incidents	involving	loss	of	life	as	well	as	extensive

property	damage;	it	is	far	safer	to	operate	a	battery	powered	ultra-lightweight	sUAS.	

First,	the	potential	loss	of	life	is	diminished	because	sUASs	carry	no	people	on	board	and	I	

only	operate	my	sUAS	in	specific	areas	away	from	mass	populations.	Second,	there	is	no	

fuel	on	board	a	sUAS	and	thus	the	potential	for	fire	or	explosions	is	greatly	diminished.	

Third,	the	small	size	and	extreme	maneuverability	of	my	sUAS	allow	me	to	remotely	pilot	

away	from	and	avoid	hazards	quickly	and	safely.	Lastly,	given	its	small	size	and	weight,	

even	when	close	enough	to	capture	amazing	images,	my	sUAS	need	not	be	so	close to	the	

objects	they	are	focused	on	through	the	technology	and	use	of	post	editing	software	

allowing	panning,	tilting	and	zooming.	

Accordingly,	my	sUAS	has	been	experimentally	operated	for	familiarization/competency	

and	will	continue	to	operate	at	and	above	current	safety	levels.	
VI:		 A	Summary:	The	FAA	May	Publish	in	the	Federal	Register:

A.	14	C.F.R.	21	and	14	C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	the	Like.	14	C.F.R.	

21,	Subpart	H,	entitled	Airworthiness	Certificates,	sets	forth	requirements	for	procurement	

of	necessary	airworthiness	certificates	in	relation	to	FAR	§	91.203(a)(1).	The	size,	weight	

and	enclosed	operational	area	of	my sUAS	permits	exemption	from	Part	21	because	my	

sUAS	meets	(and	exceeds)	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	

Reform	Act.	The	FAA	is	authorized	to	exempt	aircraft	from	the	airworthiness	certificate	

requirement	under	both	the	Act	(49	U.S.C.	§	44701	(f))	and	Section	333	of	the	

Reform	Act.	Both	pieces	of	legislation	permit	the	FAA	to	exempt	sUASs	from	the	

airworthiness	certificate	requirement	in	consideration	of	the	weight,	size, speed,	

maneuverability	and	proximity	to	areas	such	as	airports	and	dense	populations.	My current	

and	projected	sUASs	meets	or	exceeds	each	of	the	elements.	14	C.F.R.	91.7(a)	prohibits	the	

operation	of	an	aircraft	without	an	airworthiness	certificate.			As no	such	certificate	will	be	

applicable	in	the	form	contemplated	by	the	FARs,	this	Regulation	is	inapplicable.	B.	C.	D.	E.	

14	C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are	no	on	

board	pilots	or	passengers,	and	given the	size	of	the	sUASs,	this	Regulation	is	inapplicable.	

An	equivalent	level	of	safety	will	be	achieved	by	maintaining	a	safety/flight	manual	

delineating	areas	of	where	safety	can	be	defined.		5	The	FAA	has	previously	issued	

exemptions	to	this	regulation	in	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	

9565B,	10167,	10167A,	10602,	10700	and	32827.	14	C.F.R.	§	91.121	regarding	altimeter	

settings	is	inapplicable	insofar	as	my	sUAS	utilizes	electronic	global	positioning	systems	

with	a	barometric	sensor.	14	C.F.R.	§	91.203	(a)	and	(b)	provides	for	the	carrying	of	civil	

aircraft	certifications	and	registrations.	They	are	inapplicable	for	the	same	reasons	

described	above.	The	equivalent	level	of	safety	will	be	achieved	by	maintaining	any	such	

required	certifications	and	registrations	by	me,	Alan	Smith.	14	C.F.R.	§	45.23:	Marking	of	

the	Aircraft.	Applicable	Codes	of	Federal	Regulation	require	aircraft	to	be	marked	

according	to	certain	specifications.	My	sUASs	are,	by	definition,	unmanned.	They	therefore	

do	not have	a	cabin,	cockpit	or	pilot	station	on	which	to	mark	certain	words	or	phrases.	

Further,	two-inch	lettering	is	difficult	to	place	on	such	small	aircraft	with	dimensions	

smaller	that	minimal	lettering	requirement.	Regardless,	I	will	mark	the	sUASs	in	the largest	

possible	lettering	by	placing	the	word	“EXPERIMENTAL”	on	its	fuselage	as	required	by 14	

C.F.R.	§45.29	(f)	so	that	I,	the	pilot,	or	anyone	assisting	me	as	a	spotter	with	the	UAV	will	

see	the	markings.	The	FAA	has	previously	issued	exemptions	to	this	regulation	through	

Exemptions	Nos.	8738,	10167,	10167A	and	10700.	14	C.F.R.	§	61.113:	Private	Pilot	

Privileges	and	Limitations:	PIC.	Pursuant	to	14	C.F.R.	§§	61.113	(a)	&	(b),	private	pilots	are	

limited	to	non-commercial	operations.	I,	Alan	Smith,	can	achieve	an	equivalent	level	of	

safety	as	achieved	by	current	Regulations	because	my	sUAS	does	not	carry	any	pilots	or	

passengers.	Further,	while	helpful,	a	pilot	license	will	not	ensure	remote	control	piloting	

skills.	The	risks	attended	to	the	operation	of	my	sUAS	is	far	less	than	the	risk	levels	
inherent	in	the	commercial	activities	outlined	in	14	C.F.R.	§	61,	et	seq.	Thus,	allowing	me,	

Alan	Smith,	to	operate	my	sUAS	meet	and	exceed	current	safety	levels	in	relation	to	14	

C.F.R.	§61.113	(a)	&	(b).	14	C.F.R. 91.119:	Minimum	Safe	Altitudes.	14	C.F.R.	§	91.119	

prescribes	safe	altitudes	for	the	operation	of	civil	aircraft.	It	allows	helicopters	to	be	

operated	at	lower	altitudes	in	certain	conditions.	My	sUAS	will	never	operate	at	an	altitude	

greater	than	400	AGL.	I will	however	operate	my	sUAS	in	safe	areas	away	from	public	and	

traffic,	providing	a	level	of	safety	at	least	equivalent	to	or	below	those	in	relation	to	

minimum	safe	altitudes.		Given	the	size,	weight,	maneuverability	and	speed	

of	my	sUAS,	an	equivalent	or	higher	level	of	safety	will	be	achieved.	14	C.F.R.	91.405	(a);	

407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections. The	above-cited	

Regulations	require,	amongst	other	things,	aircraft	owners	and	operators	to	“have	[the]	

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.	.	.	.”	

These	Regulations	only	apply	to	aircraft with	an	airworthiness	certificate.	They	will	not,	

therefore,	apply	to	my,	Alan	Smith,	sUAS.		However,	as	a	safety	precaution	I	thoroughly	

inspect	my	sUAS	before	and	after	each	flight.	

The	FAA	May	Publish	in	the	Federal	Register:	A.	14	C.F.R.	21	and	14	C.F.R.	91:	

Airworthiness	Certificates,	Manuals	and	The	Like.	14	C.F.R.	21,	Subpart	H,	entitled	

Airworthiness	Certificates,	sets	forth	requirements	for	procurement	of	necessary	

airworthiness	certificates	in	relation	to	FAR	§	91.203(a)(1).	The size,	weight	and	enclosed	

operational	area	of	my	sUAS	permits	exemption	from	Part	21	because	my,	Alan	Smith,	sUAS	

meets	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform	Act.	The	FAA	

is	authorized	to	exempt	aircraft	from	the	airworthiness	certificate	requirement	under	both	

the	Act	(49	

U.S.C.	§	44701	(f))	and	Section	333	of	the	Reform	Act.	 Both	pieces	of	legislation	permit	the	

FAA	to	exempt	sUASs from	the	airworthiness	certificate	requirement	in	consideration	of	

the	weight,	size,	speed,	maneuverability	and	proximity	to	areas	such	as	airports	and	dense	

populations.			My	sUAS	meets	or	exceeds	each	of	the	elements.	14	C.F.R.	91.7(a)	prohibits	

the	operation	of	an	aircraft	without	an	airworthiness	certificate.	As	no	such	certificate	will	

be	applicable	in	the	form	contemplated	by	the	FARs,	this	Regulation	is	inapplicable.	14	

C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are	no	pilots	

or	passengers,	and	given	the	size	of	the	sUASs,	this	Regulation	is	inapplicable.			An	

equivalent	level	of	safety	will	be	achieved	by	maintaining	a	manual.	The	FAA	has	previously	

issued	exemptions	to	this	regulation	in	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	

9565,	9565B,	10167,	maintenance	program	that	involves	regular	software	updates	and	
curative	measures	for	any	damaged	hardware.	Therefore,	an	equivalent	level	of	safety	will	

be	achieved.	

In	summary,	Alan	Smith seeks	an	exemption	from	the	following	Regulations:	

14	C.F.R.	21,	subpart	H;	14	C.F.R.	45.23(b);	14	C.F.R.	§§	61.113	(a)	&	(b);	14	C.F.R.	§	

91.7	(a);	14	C.F.R.	§	91.9	(b)(2);	14	C.F.R.	§	91.103(b);	14	C.F.R.	§	91.109;	14	C.F.R.	§	

91.119;	14	C.F.R.	§	91.121;	14	C.F.R.	§	91.151(a);	14	C.F.R.	§§	91.203(a)	and	(b);	14	C.F.R.	§	

91.405	(a);	14	C.F.R.	§	91.407	(a)(1);	14	C.F.R.	§	91.409	(a)(2);	14	C.F.R.	§	91.409	(a	)	(2);	

and,	14	C.F.R.	§§	91.417	(a)	&	(b)	to	commercially	operate	my,	Alan	Smith,	small	unmanned

vehicle/lightweight	unmanned	aircraft	vehicle	in	community	awareness	and	aerial	

photography	and	videography	operations.	 Currently,	area	awareness	and	aerial	

photography	and	videography	relies	primarily	on	the	use	of	larger	aircraft	running	on	

combustible fuel.	 Posing	potential	risk	to	the	public.	 Granting	my request	for	

exemption	will	reduce	current	risk	levels	and	thereby	enhance	safety.	 My	sUAS	craft	does	

not	contain	potentially	explosive	fuel,	is	smaller,	lighter	and	more	maneuverable	than	

conventional	aircraft	with	much	less	flight	time.	Further,	I	operate	at	lower	altitudes	and	in	

controlled	airspace	eliminating	potential	public	risk	flying	to	and	from	established	air	

fields.	I,	Alan	Smith,	have	been	informally	analyzing	flight	information	and	will	compile	

safety	protocols	and	the	implementation	of	a	flight	operations	manual	that	exceeds	

currently	accepted	means	and	methods	for	safe	flight.	Formal	collection	of	information	

shared	with	the	FAA	will	enhance	the	FAA's	internal	efforts	to	establish	protocols	for	

complying	with	the	FAA	Modernization	and	Reform	Act	of	2012.	There	are	no	personnel	

on-board	my	sUAS	and	therefore	the	likelihood	of	death	or	serious	bodily	injury	is	

significantly	diminished.	My operation	of	my	sUAS,	weighing	less	than	5	pounds and	

travelling	at	lower	speeds	within	limited	areas	will	provide	an	equivalent	level	of	safety	as	

that	achieved	under	current	FARs.	Accordingly	I,	Alan	Smith,	respectfully	request	that	the	

FAA	grant	my	exemption	request	and	am	willing	to	cooperate	in	sharing	information	to	

benefit	the	FAA,	safety	of	manned	aircraft,	and	the	general	public	at	large.	

Respectfully	submitted,	

Alan	Smith,	Photographer	/	Videographer	

Aerial	Vantage	Point,	LLC

5231	N	Pine	Slope	Ct	SW

Wyoming,	MI.	49519
Appendix

Section	1:		Overview	

- 3DR	Solo	has	a	dedicated	Pause	button	immediately	brings	Solo to	a	midair	halt-and-hover	

so	you	can	regain	your	bearings.	The	onscreen	color	display	tells	you	exactly	what’s	going	

on	during	flight	and	the	controller	will	instantly	alert	you	if	something	goes	wrong.	The	

controller	also doubles	as	Solo’s	“black	box”:	Its	1	GHz	computer	automatically	saves	

valuable	flight	data	along	500	parameters directly	to	its	

internal	memory,	20	times	a	second.
Section	2:			Built	in/additionl Safety	Precations

FAILSAFES

 You	cannot	depend	on	the	technology	for	safety	and	protection...3DR	has	built	in	failsafes	to	

prevent	as	much	safety	as	possible.

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

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

it	to	a	hover

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

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

auto-land

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

flight	mode

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

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

come	home	to	land

Emergency	Procedures

 If	you	experience	a	problem	in	flight,	use	one	of	the	following	emergency	procedures	to	stop	

Solo,	end	your	flight,	or	shut	off	the	motors.	

Pause	

 The	controller’s	Pause	button	allows	you	to	stop	Solo	mid-air.	Solo	will	hover	at	the	paused	

location	until	given	another	command.	Use	the	Pause	button	to	stop	Solo	from	hitting	an	

obstacle	or	to	re-orient	Solo	for	navigation.	Press	Pause	during	Return	Home	or	Land	to	

pause	Solo	and	stop	the	landing.	Pause	is	available	only	with	GPS	lock.	

Regain	Manual	Control	

 Keep	the	controller	easily	accessible	at	all	times	during	flight,	including	during	Smart	Shots,	

and	be	prepared	to	regain	manual	control	at	any	time.	To	return	to	standard	flight	during	

Smart	Shots,	Return	Home,	or	Land,	press	the	Fly	button.	

Return	Home	

 If	Solo	acquired	GPS	lock	prior	to	takeoff,	press	the	controller’s	Home	button	to	return	Solo	

to	the	launch	point	and	land.	Use	return	home	after	receiving	a	low	battery	notification	or	to	

end	your	flight	easily.	Solo	will	not	avoid	obstacles	while	returning	home;	always	verify	that	

the	return	path	is	clear	before	activating	Return	Home.	

Land	

 To	land	Solo	at	its	current	position,	press	and	hold	the	Fly	button.	Lift	the	throttle	at	any	

time	to	exit	the	landing	procedure.	If	Solo	does	not	have	GPS	lock,	there	will	be	no	automatic	
positioning	as	Solo	descends,	and	drifting	may	occur	depending	on	environmental	

conditions.	

Motor	Shutoff	

 To	shut	off	the	motors	at	any	time,	either	in	flight	or	on	the	ground,	hold	the	A,	B,	and	Pause	

buttons	at	the	same	time.	An	initial	screen	will	appear	on	the	controller	to	confirm	the	

shutoff	command;	continue	to	hold	A,	B,	and	Pause	buttons	to	activate	motor	shutoff.	Use	

the	emergency	motor	shutoff	only	as	a	last	resort.

COMMON	SENSE

It’s	getting	easier	and	easier	to	fly	drones—or,	like	with	Solo,	to	have	the	drones	fly	themselves.	

This	is	good	news	for	a	number	of	reasons:	More	people	can	enjoy	the	incredible	feeling	of	flight	

and	the	experience	of	creating	great	aerial	video;	drones	are	becoming	more	useful,	with	new	

applications	discovered	or	invented	every	day;	and	of	course,	the	drones	themselves	are	getting	

safer	as	technology	and	ease	of	use	advance.

But	when	it	comes	to	safe	flying,	we	can’t	lean	exclusively	on	technology.

3DR	users	are	conscious	and	aware.	They’re	courteous	and	respectful	of	applicable	laws	and	they	

listen	to	the	needs	of	their	neighbors.	They	don’t	fly	in	ways	that	endanger	people	or	property.	

When	appropriate,	they	let	people	nearby	know	when	and	where	they’re	flying.	They	use	their	

drones	for	recreation	and	constructive	purposes.	They’re	informed	about	rules,	regulations	and	the	

technology	they’re	using.	And	they	advocate	for	safe	and	responsible	flying	by	setting	an	example	

for	others—and	the	industry—to	follow.

This	should	go	without	saying,	but	I	use	common	sense	when	I	fly.	Fly	with	your	eyes	and	ears	

open—not	recklessly,	or	oblivious	to	congested	and	highly	trafficked	areas,	or	to	sensitive	areas	

such	as	airports	or	other	“No-Fly	Zones.”	I	do	not	fly	the	drone	in	a	reckless	or	aggressive	manner	

that	might	cause	you	to	lose	control.	Don’t	fly	too	far	away,	where	you	might	lose	control	or	lose	the	

connection	between	your	controller	and	the	drone.	Don’t	fly	your	drone	where	it’s	illegal	to	do	so.			

Don’t	fly	your	drone	in	a	way	that	might	intimidate	someone	– not	everyone	is	as	comfortable	with	

the	drone	as	you	are.	While	flying,	don’t	take	your	eyes	off	your	drone	for	stretches	of	time.		

Unfortunately,	there’s	no	agreed-upon	definition	of	common	sense,	and	the	list	of	foolish	uses	(of	

any	technology)	is	infinite.	Bottom	line:	I	will	keep	my	wits	about.		Drones	have	sharp,	fast-spinning	

propellers	that	can	hurt	someone or	damage	property.		I	will	make	sure	to	know	the	boundaries	of	

the	safe	flying	area,	and	bring	the	drone	back	if	you	exceed	them.	And	if	the	drone	starts	behaving	

strangely	in	flight,	bring	it	back	home.		Common	sense	flying	will	nip	most	safety	concerns	in	the	

bud.

FLIGHT	CHECK

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

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

compass	been	calibrated	(the	Solo	app	can	walk	you	through	this)?	Is	the	battery	charged	and	
properly	installed?	Anything	in	the	motors	that	might	cause	obstruction?

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

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

controller.

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

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

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

the	command	sticks	become	inverted:	“Forward”	on	the	stick	actually	appears	to	send	the	drone	

backwards,	towards	you.			It’s	easy	to	get	disoriented.

IN	FLIGHT

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

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

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

Fly	under	200	ft	(50	m).	Not	only	is	this	an	FAA	regulation	and	ensures	your	flight	doesn’t	interfere	

with	manned	flights	in	your	area,	but	it	helps	you	maintain	line	of	sight.	

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

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

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

drone	that	might	interfere	with	the signal	and	cause	loss	of	control.

CROWDS

It’s	my	job	to	ensure	the	safety	of	the	people	around	me,	and	I	should	avoid	flying	over	people	and	

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

Though	the	3DR	drones	are	relatively	low-weight	and	the	chances	of	them	doing	serious	harm	are	

quite	slim,	the	sharp	spinning	propellers	can	do	damage,	and	the	drone	itself	can	cause	a	scare	or	a	

nasty	bump	on	the	head.

I	will	steer	clear	of	crowds,	and	make	sure	the	drone	maintains	a	safe	distance	from	spectators.

NO-FLY	ZONES

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

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

flight	restrictions	in	their	area,	based	on	their	GPS	location.	It’s	our	expectation	that	the	FAA,	whose	

mission	it	is	to	ensure	a	safe	national	airspace,	will	keep	this	database	accurate	and	up	to	date.		

Example	of	restrictions	include:

Airspace	above	400	ft

Airspace	within	5	miles	of	an	airport	or	airbase
Certain	sensitive	metropolitan	and	government	areas	(e.g.,	Washington	DC;	Manhattan)

National	parks	and	recreation	areas

Sensitive	infrastructure	(e.g.	dams)

Many	stadiums	and	arenas

Section	3:		System	overview	and	manual

The	Solo	system	includes	Solo,	the	controller,	the	“3DR	Solo”	app,	and	you.	As	the	operator,	you	

interact	with	the	controller	and	app	on	the	ground,	and	the	controller	communicates	with	Solo	

during	flight.	

Solo	

Solo	is	a	small	unmanned	aerial	vehicle	powered	by	four	motors	and	four	propellers.	Solo’s	onboard	

computers	control	navigation,	attitude,	and	communications	in	flight	while	sending	real-time	

telemetry	and	video	output	and	receiving	control	inputs	over	the	3DR	Link	secure	Wi-Fi	network.	

Solo	is	optimized	for	capturing	aerial	video	using	a	GoP

Controller	

The	controller	provides	control	mechanisms	and	displays	in-flight	data	on	a	full-color	screen.	Using	

twin	long- range	antennas,	the	controller	acts	as	the	central	hub	for	all	communication	on	the	3DR	

Link	network,	receiving	all	communications	from	Solo	and	the	app,	forwarding	telemetry	outputs	to	

the	app,	and	managing	the	transmission	of	all	control	inputs	to	Solo.	

App	

The	“3DR	Solo”	app	outputs	a	live	video	stream	from	an	onboard	GoPro®	camera	to	an	Android	or	

iOS	device.	The	app	allows	you	to	view	the	live	video	with	overlaid	telemetry	and	access	a	

simplified	graphic	interface	for	controlling	Solo’s	advanced	functions.	The	app	also	connects	to	the	

3DR	Link	network	to	receive	video	and	telemetry	outputs	and	send	control	inputs.	

Operating	Parameters:

Estimated	flight	time	 up	to	25	minutes*	

Default	maximum	altitude	150	ft.	(46	m)	above	ground	level**	

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

Payload	capacity	 1	lb.	(450	g)	

Cruise	speed	 18	mph	(8	m/s)	

Maximum	speed	 33	mph	(15	m/s)****	

Wind	speed	limitation	 25	mph	(11	m/s)	

Operating	temperature	 32°	F	- 113°	F	(0°	C	to	45°	C)	

		
Preflight	Checklist	

Before	flying,	check	the	following	conditions.	

Location	

- Your	current	location	and	environmental	conditions	are	suitable	for	flight.		

-		Solo	is	on	a	level	surface	at	a	clear	launch	point	a	sufficient	distance	from	yourself	and	

others.		

Components	

 The	propellers	are	correctly	attached.	

 The	propellers	can	spin	smoothly	and	without	obstruction	when	turned.	

 No	components	on	Solo	appear	loose	or	damaged.

Power	

 The	controller	is	powered	on	with	at	least	50%	charge.	

 Solo	is	powered	on	with	a	fully	charged	battery.		

Video	(Optional)	

 The	Solo	app	is	connected	to	Solo	and	streaming	video.	

 The	GoPro®	is	recording.	

In-Flight	Data	

Always	verify	that	there	is	a	clear	path	to	the	home	point	before	activating	Return	Home.	

Use	the	controller’s	main	data	display	to	monitor	Solo’s	status	in	flight.	

1. Flight	battery	percentage	remaining	

2. GPS	signal	strength	and	number	of	active	satellites	

3. Active	mode	or	Smart	Shot	(“Fly”	indicates	standard	flight.)	

4. Controller	battery	level	

5. Solo	Wi-Fi	signal	strength	

6. Horizontal	distance	from	the	home	position	(launch point)	

7. Current	altitude	

Specs:

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

Streaming	video	quality:	720p

Flight	time:	25	minutes;	20	minutes	with	payload*

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

Max	speed:	55	mph	(89	km/h)
Max	ascent	speed:	10	m/s	in	stabilize	mode;	5	m/s	in	“fly”	mode

Max	descent	speed:	ditto

Max	payload:	420	g

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

Motors:	880	kV

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

nylon

Autopilot:	Pixhawk	2

Software:	APM:Copter

Communication:	3DR	Link	secure	WiFi	network

Frequency:	2.4	GHz

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

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

Flight	battery:	Lithium	polymer	5200	mAh	14.8	Vdc

Battery	charge	time:	~1.5	hours

Controller	battery:	2600	mAh	7.2	Vdc	rechargeable	lithium	ion

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

Regulatory	Compliance	10.3.1	U.S.	- FCC	(Federal	Communication	Commission)	

3DR	Solo	FCC:	2ADYD-S111A	3DR	Solo	Controller	FCC:	2ADYD-AT11A	

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

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

interference	received,	including	interference	that	may	cause	undesired	operation.	

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

operate	the	equipment.	

Radiation	Exposure	Statement:

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

population	radio	frequency	(RF)	exposure	for	an	uncontrolled	environment.	These	limits	ensure	

that	no	harmful effects	will	result	from	operating	Solo	according	to	the	standard	operating	

procedures	described	in	this	manual.