- 1 -

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

Petition for Exemption 14 CFR 11.81 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF MICHAEL R. ARNOLD FOR AN EXEMPTION 

SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS PART 21 SUBPART H, 91.103(b), 91.105, 91.109, 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 DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS AND 3D Robotics SOLO UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

112-95) 

Submitted on October 20, 2015 

Michael Arnold

45049 Weaver Circle

Callahan, FL 32011

904-583-6159

michaelrayarnold@gmail.com

TABLE OF CONTENTS 

1. SUMMARY

2. INTRODUCTION AND INTERESTS OF PETITIONER BACKGROUND 

3. THE SPECIFIC SECTIONS OF 14 C.F.R. MICHAEL R. ARNOLD SEEKS EXEMPTION AND THE REASONS 

WHY GRANTING THIS EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

4. THE REASONS WHY GRANTING MICHAEL R. ARNOLD REQUEST WOULD BE IN THE PUBLIC 

INTEREST AND HOW IT WOULD BENEFIT THE PUBLIC AS A WHOLE 

5. HOW MICHAEL R. ARNOLD PLANS TO OPERATE THE SUAV IF THIS PETITION IS GRANTED

6. TECHNICAL SPECIFICATIONS OF THE DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS AND 3D Robotics SOLO SUAVs

7. CONCLUSION

8. APPENDICIES
- 2 -

SUMMARY 

Michael Arnold, a certified Part 141 Private Pilot, seeks exemption from the requirements of 14 C.F.R § 

91.103(b), 91.105, 91.109, 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), AND 

91.417(a) & (b) to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will allow Michael R. Arnold to operate 

an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography of real estate, special events, film sets, agricultural use land (farms) and construction sites 

within the United States only. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Michael R. Arnold is a professional photography and videography provider who serves Northeast Florida 

and Southeast Georgia. I provide design, photography and videography services for television, web and 

print media. Michael R. Arnold, is a Private Pilot of over 10 years and has

5 years’ experience in flying remotely controlled aircraft. If this petition is granted, Michael Arnold will 

be the PIC directly responsible for the operation of the SUAV. Michael Arnold has logged flight time in

time in manned fixed wing aircraft since 2005. Additionally, Michael Arnold owns over 5 SUAVs and has 

logged over 150 hours of SUAV flight time for recreational use. This combination of experience and 

technical expertise makes the operator well versed in the technical and regulatory aspects of SUAV

operations. 

BACKGROUND 

Michael R. Arnold seeks an exemption to operate DJI and 3D Robotics sSUAV systems for compensation 

or hire within the National Airspace System. Michael R. Arnold desires to operate a DJI Phantom 3 

Professional, the DJI Phantom 2 Vision Plus and 3D Robotics Solo. These Unmanned Aerial Vehicles are 

each a four bladed “quad” copter allowing for vertical takeoff and landing. Each unit is powered by a 

Lithium Polymer battery which supplies power to the four flight motors. Each craft is controlled 

wirelessly through a Ground Control Station allowing it to be operated using a remote radio transmitter 

and an electronic tablet or smart phone system. The DJI Phantom 3 Professional has a max speed of 35

MPH and a maximum gross weight of 2.82 pounds with dimensions of 7.25 in. tall, 23 in. diagonal 

(including propellers). The DJI Phantom 2 Vision Plus has a max speed of 33 MPH and a maximum gross 

weight of 2.74 pounds with dimensions of 7 in. tall, 13.78 in. motor-to-motor diagonal (excluding 

propellers). The 3D Robotics Solo has a max speed of 55 MPH and a maximum gross weight of 

approximately 3.3 pounds, with dimensions of 10 in. tall, 18 in. motor-to-motor. The DJI Phantom 3 

Professional, DJI Phantom 2 Vision Plus and 3D Robotics Solo all comply with all FCC radio frequency 

regulations. Michael R. Arnold can provide a FCC compliance letter upon request. 

If this petition is granted, the DJI Phantom 3 Professional, DJI Phantom 2 Vision Plus and 3D Robotics

Solo that will be operated by Michael R. Arnold will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, and 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 

C.F.R. Part 45, Identification and Registration Marking. 

THE SPECIFIC SECTIONS OF 14 C.F.R. MICHAEL R. ARNOLD SEEKS EXEMPTION AND THE REASONS WHY 

GRANTING THIS EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY. 
- 3 -

Petitioner, Michael R. Arnold, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI 

PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo in the National Airspace 

System (NAS), and for an exemption from the following requirements: 

-14 C.F.R. Part 21, Subpart H 

Based on the size, weight and speed of all sSUAVs, they meet 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. 

The Reasons Why Granting the Exemption Would Not Adversely Affect Safety: 

Michael R. Arnold believes that safety will not be affected without an airworthiness certificate because 

the process of obtaining an airworthiness certificate is intended for the certification of manned aircraft 

and not small SUAVs. Small SUAVs, like the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS and 3D Robotics Solo are in a separate category of aircraft, as FMRA Section 333 recognizes. 

-14 C.F.R 91.103 (b) 

Michael R. Arnold seeks an exemption from the requirements of Section 14 C.F.R. 91.103(b) entitled 

Preflight Action. If this petition is granted, Michael R. Arnold will be operating a DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo which do not require a runway. The 

DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo take off vertically 

without a runway. Therefore, it is not necessary for the PIC to calculate runway takeoff and landing 

distances. 

Reasons Why an Exemption from The Requirements of Section 14 C.F.R. 91.103(b) Would Not 

Adversely Affect Safety:

Michael R. Arnold believes that safety will be enhanced without the need of a runway. Additionally, the 

size and weight of the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics

Solo is so minimal, that any takeoff or landing accident would cause minimal damage to persons or 

property when compared to manned aircraft takeoff and landing accidents. 

-14 C.F.R 91.105 

Michael R. Arnold seeks an exemption from the requirement of Section 14 C.F.R. 91.105, entitled flight 

crew members at stations. Because this is an Unmanned Aerial Vehicle, it is operated from the ground. 

Therefore, the operator has no need to wear seat belts while flying. Michael R. Arnold believes the SUAV

can be safely operated from the Ground Station and still maintain safety of flight. 

Reasons Why an Exemption from The Requirements of Section 14 C.F.R. 91.105 Would Not Adversely 

Affect Safety:

Michael R. Arnold believes that SUAVs are much safer than manned aircraft because the PIC is safely on 

the ground. Any inflight turbulence does not affect the safety of the PIC. In the event of a crash, the PIC 
- 4 -

risks significantly less physical damage from the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS and 3D Robotics Solo than he or she would inside a manned aircraft during a crash. Michael R. 

Arnold believes that safety is improved by operating a SUAV in lieu of a larger, manned aircraft. 

-14 C.F.R 91.121 

Michael R. Arnold also seeks an exemption from the requirements of Section 14 C.F.R. 91.121, entitled 

Altimeter Settings, as the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics

Solo does not have a barometric altimeter. The DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS and 3D Robotics Solo altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. Altitude information is provided to the Pilot in 

Command via the telemetry data link. This information is displayed to the Pilot in Command via the 

ground station tablet or display interface. This altitude information, combined with visual line of sight 

will ensure a level of safety equivalent to that of Section 14 C.F. R. 91.121. 

Reasons Why an Exemption from The Requirements of Section 14 C.F.R. 91.105 Would Not Adversely 

Affect Safety:

Michael R. Arnold holds that safety will be maintained because the PIC still has altitude information 

available to him or her at all times during the flight. This, combined with line of sight, attitude and 

ground speed information keeps the PIC completely aware of the SUAV and its surroundings. 

-14 C.F.R 91.151(b) 

Michael R. Arnold seeks an exemption from the requirements of Section 14 C.F.R. 91.151(b), entitled 

Fuel requirements for flight in VFR conditions. Michael R. Arnold believes that the standard Lithium 

Polymer batteries that power the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D 

Robotics Solo will be adequate for the short flights needed for his operations. The DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS have enough battery power to fly for a total duration of 

approximately 20 minutes with an additional 3 minutes of reserve power for additional flying at normal 

speed and 3D Robotics Solo has enough battery power to fly for a total duration of approximately 15

minutes with an additional 5 minutes of reserve power for additional flying at normal speed. Michael R. 

Arnold seeks the requested relief because without an exemption from Section 91.151(b), it would not be 

possible to fly a DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS or 3D Robotics Solo. This 

would severely constrain the practicality of any aerial video or still photo flight operations that Michael 

R. Arnold proposes to conduct pursuant to this Petition. 

Furthermore, safety will be ensured as the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS and 3D Robotics Solo sSUAVs provide audible and visual warnings to the PIC at the ground station 

when the SUAV 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, sSUAVs described herein will descend and land automatically. 

Reasons Why an Exemption from the Requirements of Section 14 C.F.R. 91.105 Would Not Adversely 

Affect Safety:
- 5 -

Michael R. Arnold believes that safety will still be maintained because the DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo would always be flown within line of 

sight. This ensures that a landing can immediately be made within 1 minute. Additionally, the ability to 

takeoff or land vertically allows the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 

3D Robotics Solo to land on virtually any flat surface. This ensures that the DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo will have adequate battery reserves 

allowing each sSUAV to always be able to safely land after a flight. 

-14 C.F.R 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b). 

Michael R. Arnold requests relief from these sections as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. Michael R. Arnold requests 

relief from these Sections because neither the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS nor the 3D Robotics Solo require airworthiness certificates as set forth in the conditions of FMRA 

Section 333. 

A maintenance logbook will be developed to record all maintenance, alterations or repairs made on the 

SUAV. Prior to any revenue flight, the PIC will be required to determine the flight readiness of the DJI 

PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo SUAV in a manner 

consistent with this exemption. 

Michael R. Arnold will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the sSUAVs using the methods, techniques, and practices prescribed in the SUAV

operating documents (Monthly Maintenance Log, and DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 

VISION PLUS and 3D Robotics Solo Instruction Manual). Furthermore, Michael R. Arnold will document 

and maintain all maintenance records for the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION 

PLUS and 3D Robotics Solo. 

Michael R. Arnold submits that it will ensure that the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 

VISION PLUS and 3D Robotics Solo SUAV are in an airworthy condition, prior to every flight, by 

determining that the SUAVs are in compliance with the operating documents (Maintenance Log, and DJI 

PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo Instruction Manual), 

and that the aircraft is in a condition for safe flight. 

Reasons Why an Exemption from the Requirements of Section 14 C.F.R. 91.105 Would Not Adversely 

Affect Safety:

Michael R. Arnold will carefully and meticulously operate the DJI PHANTOM 3 PROFESSIONAL, DJI 

PHANTOM 2 VISION PLUS and 3D Robotics Solo in accordance with the manufacturer’s operating 

manual. The exemption sought will not adversely affect safety because Michael R. Arnold will use 

trained technicians to perform maintenance, alterations or preventive maintenance on the SUAV using 

the methods, techniques, and practices prescribed by the operating documents. Michael R. Arnold

believes that safety will not be affected because the procedures established above ensure the the DJI 

PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo will always be 

maintained and operated in a structured, organized and consistent manner. Using the procedures above 

ensures that each flight is taken with the utmost care. 
- 6 -

The Reasons Why Granting Michael R. Arnold’s Request Would Be in the Public Interest AND How It 

Would Benefit the Public of the United States:

Reason #1. Expanding the availability of affordable aerial photos for industry 

Granting this petition will further the public interest by expanding the availability of economically 

affordable aerial cinematography and photography. Historically, the public has used aerial photos for a 

variety of reasons. These aerial photos and videos have been obtained using manned aircraft, costing 

hundreds and thousands of dollars per hour to operate. Granting this petition will increase the quality of 

aerial photography services, while at the same time decreasing the price. This service will allow for the 

following: 

-Enhanced and dynamic real estate marketing, benefiting property owners and real estate agents.

-Crop surveying for the agricultural industry (field drainage monitoring, crop insurance documentation, 

pesticide monitoring, etc.) which will lead to increased farming efficiency benefiting both farmers and 

consumers.

-Insurance claim documentation for insurance companies such as hail damage, crop damage, bridge

collapses, flooding, etc., which will benefit the insurance companies and consumers of insurance 

products 

-Construction progress for residential, commercial, and industrial construction companies. 

-Wetland and water drainage mitigation for public works departments, which will enhance the ability of 

civil engineers to plan for water drainage mitigation.

-Utility inspection services for utility companies -many more potential applications exist 

The increased efficiency and lower cost of operating an sSUAV for aerial applications will benefit the 

economy as a whole by allowing scarce resources, such as aircraft fuel, to be used in other areas of the 

economy. This will ensure that the United States remains competitive on the global market for aerial 

applications and ensure that more jobs stay located within the United States. 

Reason #2. Reduced Levels of Environmental and Noise Pollution 

Using the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo sSUAVs, 

to conduct aerial operations instead of manned aircraft will greatly benefit the public by reducing the 

levels of air and noise pollution. Small SUAVs are much more energy efficient than traditional manned 

aircraft. By using battery power and electric motors, the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 

2 VISION PLUS and 3D Robotics Solo sSUAV produce no environmental pollution that the traditional four 

to six cylinder internal combustion aircraft engines that are typically utilized for aerial video and 

photography. The DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo 

sSUAVs also eliminate a significant amount of noise pollution. The small propeller blades and electric 

motors produce only a fraction of the noise level that traditional fixed-wing aircraft or helicopters 

produce. 
- 7 -

Reason #3 Increased Public Safety 

The public will benefit from the safety and efficiency of the DJI PHANTOM 3 PROFESSIONAL, DJI 

PHANTOM 2 VISION PLUS and 3D Robotics Solo SUAV. The light weight of the DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo, pose a negligible threat to people 

and property on the ground in the unlikely event of a crash. The damage a small SUAV can do is minor

compared to the damage that a manned aircraft with leaded fuel onboard would cause to both the 

occupants of the aircraft and those on the ground, not to mention the environment.

Reason #4. Reduced Congestion of the National Airspace System 

Granting this request also benefits the public as a whole by reducing the number of manned aircraft, 

thereby decreasing the overall congestion of the NAS. This in turn, relieves the air traffic control system 

of unnecessary aircraft traffic. This will allow the air traffic control system to focus their resources more 

on the needs of other types of manned flights. 

How Michael R. Arnold plans to operate the sSUAVs if this petition is granted. 

If this petition is granted, flights of DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D 

Robotics Solo sSUAVs will be conducted according Specific Operating Limitations.

1. The sSUAV 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. 

2. The sSUAV must be operated at an altitude of no more than 400 feet AGL 

3. The sSUAV 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.

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

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the 

operating documents. 

5. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

6. The operating documents and the grant of exemption must be accessible during SUAV 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. 
- 8 -

7. Prior to each flight the PIC must inspect the SUAV to ensure that it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the SUAV, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the SUAV 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. 

8. Any SUAV that has undergone maintenance or alterations that affect the SUAV operation or flight 

characteristics, e.g. replacement of a critical flight component, must undergo a functional test flight. The 

PIC who conducts the functional test flight must make an entry in the aircraft records. 

9. 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. 

10. 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 

SUAV to service. 

11. Each SUAV operated under this exemption must comply with all manufacturer Safety Bulletins. 

12. SUAV operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

13. The SUAV may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart, or within the lateral limits of class B, C or D airspace as 

denoted on a current FAA-published aeronautical chart unless specific authorization from air traffic 

control is obtained.

14. If the SUAV 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. 

15. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents. 

16. 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 sSUAV with 25% battery power remaining. 

17. 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. 
- 9 -

18. The sUAV must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

19. The sUAV may not be operated by the PIC from any moving device or vehicle. 

20. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless the following conditions are present: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

sUAV 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 sUAV, 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). 

21. 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. 

Flight safety will be maintained because the PIC operating the DJI PHANTOM 3 PROFESSIONAL, DJI 

PHANTOM 2 VISION PLUS and 3D Robotics Solo is already a Private Pilot and has demonstrated that the 

PIC is able to safely operate the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D 

Robotics Solo SUAV in a manner consistent with safe operation, including evasive and emergency 

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

Michael R. Arnold will not allow any PIC to operate the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 

VISION PLUS or 3D Robotics Solo unless that PIC has demonstrated, that he or she is able to safely 

operate the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo sUAV in 

a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Technical Specifications of the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D 

Robotics Solo SUAV. 

Both the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo sUAV

Autonomous Flight and Navigation Modes enable the sUAV to remain within a defined operational area. 

The DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo sUAV may be 

operated in both manual and fully autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D 

Robotics Solo SUAV are provided in the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS

and 3D Robotics Solo User Manuals (see attachments).
- 10 -

The DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo SUAV are 

designed for automatic return to home point or hover in the event of communication control link is lost. 

When the control link is lost, the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D 

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

PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS or 3D Robotics Solo SUAV does not reacquire 

control link data from the GCS, the sUAV will assume that the Control Link is lost and the sUAV 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 DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 

VISION PLUS and 3D Robotics Solo SUAV are set forth in the DJI PHANTOM 3 PROFESSIONAL, DJI 

PHANTOM 2 VISION PLUS and 3D Robotics Solo User Manuals (see attachment). A complete description 

of the operation and specifications of the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS

and 3D Robotics Solo GCS and flight control software is also provided in the User Manuals and in the 

Mission Planner Guide.

Considering the size, weight, speed and operation capability, Michael R. Arnold believes the DJI 

PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo SUAV do not create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. For further 

technical information concerning the DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 

3D Robotics Solo, see the attached operator’s manual.

CONCLUSION 

Michael R. Arnold seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo sUAV 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 Michael R. Arnold to safely, efficiently, and economically operate the 

DJI PHANTOM 3 PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo commercially within 

the NAS. 

In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 

2012, Section 333, Michael R. Arnold respectfully requests that the Administrator grant this Petition for 

an exemption from the requirements of 14 C.F.R Sections 91.103(b), 91.105, 91.109, 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 the DJI PHANTOM 3 

PROFESSIONAL, DJI PHANTOM 2 VISION PLUS and 3D Robotics Solo SUAV commercially for the purpose 

of conducting aerial video and photography over certain areas of the United States. 

Dated: October 20, 2015 

Respectfully submitted, 

Michael R. Arnold