1

July 27, 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: MYRON MORROW 

REQUEST AN EXEMPTION 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 3D Robotics 

Solo, DJI Phantom 3 and DJI Inspire 1UNMANNED AIRCRAFT SYSTEMS PURSUANT 

TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

MYRON MORROW 

3904 Maverick Trail

McKinney, Texas 75070

972-971-9133

mmorrowpb@gmail.com
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TABLE OF CONTENTS

GLOSSARY OF ABREVIATIONS....................................................................................................3 

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

INTRODUCTION AND INTERESTS OF PETITIONER.................................................................5

BACKGROUND.................................................................................................................................6

BASIS FOR PETITION......................................................................................................................7

NAME AND ADDRESS OF PETITIONER......................................................................................9

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MYRON MORROW SEEKS 

EXEMPTION......................................................................................................................................9

THE EXTENT OF RELIEF MYRON MORROW SEEKS AND THE REASON MYRON 

MORROW SEEKS THE RELIEF.................................................................................................11

THE REASONS WHY GRANTING MYRON MORROW’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST ......................................................................................................................12 

THE REASONS WHY GRANTING THE EXEMPTION TO MYRON MORROW WOULD NOT 

ADVERSELY AFFECT SAFETY...................................................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...............................22

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

MYRON MORROW’S REQUEST.................................................................................................23

CONCLUSION.................................................................................................................................23

APPENDICES................................................................................................... 24
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GLOSSARY OF ABBREVIATIONS

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) 

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
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SUMMARY

MYRON MORROW 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 (3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1) 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit MYRON MORROW to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography of construction sites, 

residential and commercial real estate, civil landscapes, agricultural lands and events over certain 

areas of the United States. 
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INTRODUCTION AND INTERESTS OF THE PETITIONER

MYRON MORROW has over 15 years experience in operating manned aircraft and holds an FAA 

Airline Transport Pilot certificate as well as Certificated Flight Instructor ratings to include MultiEngine and Instrument instructor privalidges. MYRON MORROW has approximately 3,000 hours 

of accumulated flight in many types of manned fixed wing aircraft as well as many years of hobby

experience with remote control airplanes, helicopters and complex quadcopters. The objective of 

MYRON MORROW is to use Unmanned Aircraft Systems (3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1) for aerial operations to provide a more affordable, high-quality production system for 

a variety of governmental, commercial, public, and residential uses, specifically targeting:

 Agricultural Data Collection and Surveying

 Residential and Commercial Real Estate Marketing

 Oil and Gas Pipeline and Site Inspection

 Small Business Marketing 

 Wildlife Studies and Data Collection

 Livestock Monitoring and Data Collection
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BACKGROUND

Unmanned Aircraft Systems: 3D Robotics Solo, DJI Inspire 1

MYRON MORROW seeks an exemption to operate DJI and 3D Robotics systems for compensation 

or hire within the NAS. The 3D Robotics Solo and 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 3D Robotics Solo has a maximum gross weight of approximately 3 

pounds 13 ounces, while having a length of 18 inches width of 18 inches, height of 10 inches, and a 

maximum speed of approximately 30 knots. The DJI Phantom 3 has a maximum gross weight of 

approximately 2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of 

approximately 16.4’fps and a maximum flying height of 400'. 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 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 UA are equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors.

The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UA that will be operated by MYRON 

MORROW 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.
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BASIS FOR PETITION

Petitioner, MYRON MORROW, 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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1, 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, MYRON MORROW’S operation of 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 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, MYRON MORROW 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. 

MYRON MORROW submits that the requested relief is proper since an equivalent level of safety 

will be ensured. MYRON MORROW 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, and 3D Robotics 

Solo, DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, MYRON MORROW will 

document and maintain all maintenance records for the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 UAS. 

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

limitations: Pilot in command, is requested by MYRON MORROW 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 Phantom UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

MYRON MORROW seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS do not require an airworthiness 

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

that they will ensure that the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS is 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, and 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. 

MYRON MORROW also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS will not have a 

typical barometric altimeter onboard. However, altitude information of the 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 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 
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GCS for active monitoring of the flight path. This altitude information, combined with MYRON 

MORROW’s operation of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, MYRON MORROW seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. MYRON MORROW submits that safety

will not be affected by operation of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS 

during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), 

with enough battery power to fly for a total duration of approximately 20 minutes. Battery power 

indicators are also able to show exactly how much battery power is left, as well as how much time 

is needed to return safely back to point of take off.
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In accordance with 14 C.F.R. § 11.81, MYRON MORROW 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:

MYRON MORROW 

3904 Maverick Trail

McKinney, Texas 75070

972-971-9133

mmorrowpb@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which MYRON MORROW Seeks Exemption. 

1. MYRON MORROW 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. MYRON MORROW 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. 

3. MYRON MORROW 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. MYRON MORROW 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. MYRON MORROW 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—
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(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. MYRON MORROW Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

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. MYRON MORROW 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. MYRON MORROW 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: 

(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. 

(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. 
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(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 MYRON MORROW Seeks And The Reason MYRON MORROW Seeks 

The Relief. 

1. Extent Of Relief MYRON MORROW Seeks And The Reason MYRON MORROW 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 flighthour 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, MYRON MORROW submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 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.

Further, MYRON MORROW submits that all flights of the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental 

to MYRON MORROW’s business; and (2) will not carry passengers or property for compensation 

or hire. 

2. Extent Of Relief MYRON MORROW Seeks And The Reason MYRON MORROW 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 MYRON MORROW to determine that the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., MYRON MORROW Aerial Operations Manual, 

Monthly Maintenance Log, and 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 Instruction 

Manual). 

MYRON MORROW seeks the requested relief because the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, MYRON MORROW will ensure that the 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 

1) 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 MYRON MORROW Seeks And The Reason MYRON MORROW Seeks Relief 

From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of 

the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station (GCS). Since the FAA requires 
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that any altitude information concerning UAS operations be reported to air traffic control (ATC) in 

feet above ground level (AGL), MYRON MORROW seeks the requested relief because the 3D 

Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 3D Robotics Solo, 

DJI Phantom 3 and DJI Inspire 1 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 MYRON MORROW Seeks And The Reason MYRON MORROW 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 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual 

flight rules (VFR), for a total duration of 20 minutes. MYRON MORROW seeks the requested 

relief because without an exemption from Section 91.151(b), the flight time duration of the battery

powered 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that MYRON MORROW proposes to 

conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the 3D Robotics Solo, DJI Phantom 

3 and DJI Inspire 1 UAS, the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1operating 

documents, and MYRON MORROW’s proposed operating limitations, ensure that MYRON 

MORROW will safely operate the battery powered 3D Robotics Solo, DJI Phantom 3 and DJI

Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration of 20 minutes.

5. Extent Of Relief MYRON MORROW Seeks And The Reason MYRON MORROW 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, MYRON MORROW requests relief from these Sections 

because the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS do not require airworthiness 

certificates. As set forth more fully below, the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 

UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, MYRON MORROW 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., Aerial Operations Manual, Monthly Maintenance Log, and 3D 

Robotics Solo, DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, MYRON 

MORROW will document and maintain all maintenance records for the 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 UAS. 

D. The Reasons Why Granting MYRON MORROW Request Would Be In The Public Interest; 

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

Granting the present Petition will further the public interest by allowing MYRON MORROW to 

safely, efficiently, and economically perform aerial video and photography operations over certain 

areas of the United States. 

Additionally, use of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 
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the benefits of MYRON MORROW’s proposed operation of the 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 UAS will be realized without implicating any privacy issues. 

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

The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS are battery powered and serve as a 

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

aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 3D Robotics Solo, DJI

Phantom 3 and DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction 

of manned aircraft conducting aerial video and photography 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.

2. The Public Will Benefit From The Safety And Efficiency Of The 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 UAS. 

Conducting aerial acquisitions with the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS, 

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

and noise pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 

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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS, while reducing the carbon footprint 

of aerial photography and videography, also eliminates noise pollution, as the UAS are propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 

3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS has 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 (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The 3D Robotics Solo, DJI Phantom 

3 and DJI Inspire 1 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS 

are also an economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS will allow United 

States based companies and individuals, like MYRON MORROW, 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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 

UAS is one such technology that not only allows companies greater operational flexibility
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compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS, companies such as 

MYRON MORROW, 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 3D 

Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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, 

MYRON MORROW’s proposed operation of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 

1 UAS will not implicate any privacy issues. Specifically, the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e.,Aerial 

Operations Manual, Monthly Maintenance Log, and 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 Instruction Manual) which requires property owner involvement as 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 MYRON MORROW Seeks Exemption. 

1. Reasons Why The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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, MYRON MORROW’s operation of the 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 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. 

(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 
15

establish requirements for the safe operation of such aircraft systems in the national airspace 

system. 

In seeking this exemption, MYRON MORROW submits that the 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 

UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS Demonstrate 

Its Safe Characteristics.

The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS does 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. 

i. Technical Specifications Of The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS. 

The technical specifications of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS are set 

forth by the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1User Manual, attached hereto as 

Appendix A. 

ii. The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS Global Positioning Modes Enable 

The UAS To Remain Within A Defined Operational Area. 

The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS may be operated in both manual and 

global positioning flight modes. A complete description of the flight and navigational modes of the 

3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS is provided in the manuals of the 3D 

Robotics Solo, DJI Phantom 3 and DJI Inspire 1 and are attached hereto as Appendix A. 

iii. The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS Are Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 UAS does not reacquire control link data from the GCS, the UAS will 

assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 UAS are set forth at pages 12 through 14 of the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1User Manual, attached hereto as Appendix A. 

iv. The 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1GCS And Its Operation.

A complete description of the operation and specifications of the 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1GCS and flight control software is provided in the 3D Robotics Solo, DJI Phantom 

3 and DJI Inspire 1 User Manuals. 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 User 

Manuals are attached hereto as Appendix A. 

b. Flight Operations Of 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS Is Limited To The 

Line Of Sight Of A Certificated Pilot in Command With A Safety Observer if possible.

MYRON MORROW will be the only person to act as a pilot in command (PIC) of the 3D Robotics 

Solo, DJI Phantom 3 and DJI Inspire 1 UAS.

c. Flights Of 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS Will Be Conducted Pursuant 

To Specific Operating Limitations. 

In seeking this exemption, MYRON MORROW proposes to commercially operate 3D Robotics 

Solo, DJI Phantom 3 and DJI Inspire 1 UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, 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, rotorcraft UAS weighing less than 55 pounds maximum 

gross weight: 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 Unmanned Aircraft Systems. 
16

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 video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 30 knots.

4. The UA must be operated at an altitude of no more than 400 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. 

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

7. All operations may 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.
17

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.

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 for 

hire 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) or instrument flight rules (IFR) 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 for hire 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. 

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. 
18

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined 

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 unless said 

vehicle is stationary.

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: 

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). 
19

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.

MYRON MORROW 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 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

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

structures. 

Considering MYRON MORROW’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements and those of 

commercial pilot requirements; and the airmanship skills necessary to safely operate the 3D 

Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS, MYRON MORROW submits that the 

additional manned airmanship experience of a commercially certificated pilot would correlate to the 

airmanship skills necessary for MYRON MORROW’s 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). 

MYRON MORROW will not allow any PIC to operate the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements 

or the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS training and currency requirements, 

that the PIC is able to safely operate the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 rotorcraft 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). 

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 

MYRON MORROW’s 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 
20

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 multirotor 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, MYRON MORROW will ensure safe operations by not allowing any PIC to operate 

the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

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, MYRON MORROW will ensure that the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 MYRON MORROW’s operation of the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 UAS within visual line of sight, at or below 400 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, 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.
21

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 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, MYRON MORROW will ensure that it will 

safely operate the battery powered 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS during 

daylight hours in VFR conditions, with enough battery power to fly for a total duration of 20 

minutes. 

Here, as in Exemption No. 11109, the technical specifications of the 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 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 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 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, MYRON MORROW 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 MYRON MORROW 

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., 

Aerial Operations Manual, Monthly Maintenance Log, and 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 Instruction Manual). Furthermore, MYRON MORROW will document and maintain 

all maintenance records for the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS. 

Since the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS will be inspected as prescribed 

by the operating documents, MYRON MORROW 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 3D Robotics Solo, 

DJI Phantom 3 and DJI Inspire 1 User Manuals are attached hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because MYRON MORROW 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 3D Robotics Solo, DJI 

Phantom 3 and DJI Inspire 1 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. 
22

In consideration of MYRON MORROW’s proposed operating limitations, the operating documents, 

and the technical aspects of the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS, MYRON 

MORROW 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, MYRON MORROW requests that the FAA 

prescribe special conditions for the intended operation of the 3D Robotics Solo, DJI Phantom 3 and 

DJI Inspire 1 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 video and photography 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 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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 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 3D Robotics Solo, DJI Phantom 3 

and DJI Inspire 1 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).

A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

MYRON MORROW Seeks Exemption: 

MYRON MORROW 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 MYRON MORROW Seeks: 

This exemption will permit MYRON MORROW to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial video and photography over certain areas of the 

United States.
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Any Additional Information, Views, Or Arguments Available To Support MYRON MORROW’s 

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, MYRON MORROW’s 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, MYRON MORROW will operate the 3D Robotics Solo, DJI Phantom 

3 and DJI Inspire 1 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. 

CONCLUSION

As set forth herein, MYRON MORROW 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 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and photography over 

certain areas of the United States. 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 MYRON MORROW to safely, efficiently, and 

economically operate the 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 UAS commercially 

within the NAS. 

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

and Reform Act of 2012, Section 333, MYRON MORROW 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 Leading Edge to operate the 3D Robotics Solo, DJI Phantom 3 and DJI 

Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Dated: July 27, 2015

Respectfully submitted,

MYRON MORROW 

3904 Maverick Trail

McKinney, Texas 75070

972-971-9133

mmorrowpb@gmail.com
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Appendices:

A – Link to 3D Robotics Solo, DJI Phantom 3 and DJI Inspire 1 Manuals: 

Copy links into your browser to view the manuals:

http://3drobotics.com/kb/solo-user-manual/

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf