Petition for exemption under Section 333

Petitioner: Ian Padden, (DBA Solliton Technologies Ltd) 

Airman’s Certificate No: 3523043 

Commercial Pilot: Airplane Single & Multi engine land; 

Instrument Airplane; Rotorcraft-helicopter. 

Current 2nd Class Medical 

Last BFR 03-28-2015 

Total Logged Hours: 10,065 

 A&P/IA - Current - Sacramento FSDO 

1. Seeking exemptions to the following Sections of 14 C.F.R. 45.23(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The 

proposed exemption would allow Ian Padden and Solliton Technologies Ltd the right to operate 

the DJI Inspire 1 Pro (Model T600) quad-copter unmanned aircraft system (Micro UAS: 2935g 

– 6.47lb ) to conduct aerial photography and cinematography over private property with prior 

permission and restricted access by non-participants. The initial general geographic area of 

operations would be Sacramento, Solano, Yolo and Eldorado counties California but would on 

occasions include other regions with appropriate notifications to the FSDO responsible for the 

region. 

2. This petition is based on the precedent set by the Regulatory Docket No. FAA-2014-0481, 

Exemption No. 11138 Douglas Trudeau issued January 5th, 2015. 

3. The requested exemptions will allow myself personally, and my company to provide aerial 

photography, cinematography, data collection, safety inspections and surveys for clients in the 

Oil, Agriculture, Construction, Real Estate, Surveying, other such commercial entities and 

Federal and State agencies while meeting the necessary safe operating parameters and 

regulations defined by the FAA and other local and regional agencies. 

4. Relevant Experience: I have been flying RC helicopters and fixed wing model aircraft for the 

past 30 years and I have been flying UAS (Various Quad copters - DJI Phantom 2 and 3, etc.) 

since June 2012. I have experienced emergency landings, had no significant crashes, no injuries 

to persons or damage to personal property. Furthermore, as a current commercial pilot of fixed 

wing and rotorcraft (helicopter) I have flown pipeline and oil well safety and inspection patrols 

as well as photographic surveys. 

5. Public Benefit: Conducting aerial work with micro UAS craft, such as the DJI Inspire 1 Pro, 

instead of manned aircraft, will benefit the public by drastically reducing the levels of air and 

noise pollution since they are electric powered and considerably quieter than piston or turbine 

powered helicopters of aircraft. Additional benefits are greater flexibility, enhanced safety and 
the considerable cost savings to both the public and commercial organizations as compared the 

use of traditional aircraft. 

6. I have attached below my personal pre-operational, pre-flight safety and technical check lists 

as well as flight rules that will be observed during operations. Additionally, I will comply with 

any further requirements mandated by the FAA. 

Thank you for your consideration in this matter. 

Ian Padden 

ian@solliton.com

Tel: 805-828-0424 
Pre-operational Procedures: 

Ground reconnaissance of area of operation: Location of potential hazards to flight: Location of 

‘sensitive’ areas not specified by FARs such as hospitals, schools, stadiums, animal breeding 

facilities, retirement homes, etc. In agricultural areas check on local crop dusting operations. 

Check area for any significant Radio Transmitters that might interfere with UAS signals. 

Obtain necessary permissions from property owners/local authorities, etc. 

Advise local FSDO at least three days in advance. 

Advise Local law enforcement agency about UAS operations in their area. 

Immediately Prior to Operations: (Day of Operations) 

Check: NOTAMS/AIRMETS/SIGMETS/METAIRS/TFRs/Solar wind conditions etc. 

Immediately Prior to Flight: 

Conduct safety briefing with Visual Observer and personnel involved in the operation (client’s 

representative, etc.). Situational awareness, emergencies such as UAS failure and intrusion of 

non-participating parties, etc. Brief all concerned on the flight plan. 

General Flight Rules: 

Comply with all FAR’s as well as rules specific to UAS operations 

Maintain Line of Sight (LOS) with the UAS at all times at all times. 

Have at least one Visual Observer (VO) at all times. 

VO to be in verbal communication with UAS operator at all times during operations. 

Conduct flight only during daylight hours and VFR as per FARs 

Maintain a minimum clearance off the ground of at least 10 feet. 

Not to exceed a flying height 400’ above ground level 

Maintain 30’ of clearance of all objects and obstacles being observed. 

Perform an emergency landing if the situation becomes unsafe. 

Perform and emergency landing if the vessel shows any unstable characteristics. 

Return to ground with 15% battery life in reserve. 

UAS Preflight check list: 

Inspect rotors for shape, and cracks, any signs of loss of integrity. 

Inspect / Attach rotors – check rotation direction and nut tension. 

Inspect overall vessel for signs of damage and loose connections. 

Inspect motors for smooth balanced, quiet operation - free of debris. 

Check battery – minimum 95% charged, clean connections, no defects. 

Check all external devices are attached securely: gimbal, camera, etc. 
Check camera lens is clean. 

Check camera settings are correct. 

Check all control switches are in proper start up position. 

Calibrate compass. 

Confirm GPS satellite coverage. 

Clear and reset flight clock to zero. 

Check take off area is clear of objects and persons for 10 ft radius. 

Announce “Clear Prop “ 

Spin up rotors, listen for unusual noises or vibrations. 

Allow the system to complete its full start up procedure. 

Confirm that the system status is flight-ready. 

Check that battery still indicates operational status at 95% or better 

Start flight-clock. 

Lift off and hover at 4 feet. 

Check all status lights on the UAS and Controller. 

Check that hover is stable (not drifting or erratic). 

Check that the camera is fully operational. 

Check that all control commands are responsive. 

Set altitude to not to exceed requirement. (Max 400 ft) 

Set current home location for Lost Link: “Return to Home” 

Confirm Visual Observer readiness, and proceed with the flight 

plan.