### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 1 February 16, 2016

Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA M odernization and Reform Act 2012 of the Federal Aviation Regulations from 14 CFR Part 21; 14 CFR 45.23(b); 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (b); 91.203 (a) & (b); 91.405(a) ; 91.407 (a)(1); 91.409 (a) (2); 91.417 (a) & (b)

CONCERNING COMMERCIAL OPERATION OF 3DR So lo UNMANNED AIRCRAFT SYSTEMS PURSUANT TO

SECTION 333 OF THE FAA MODERNIZATION A ND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Richard Mack

President Richard Mack Photography, Ltd.

2331 Hartzell Street
Evanston, Illinois 60201-1410

Studio: 847-869-7794

Fax: 847-869-7798

Cell: 847-840-0081 Email: richard@mackphoto.com

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 2 February 17, 2016

To Whom It May Concern:

Richard Mack of RICHARD MACK PHOTOGRAPHY, LTD. , a professional photography and video production
firm, hereafter referred to as RICHARD MACK PHOTOGRAPHY , LTD. seeks exemption from the requirements of pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 21, 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 (3DR Solo) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit RI CHARD MACK PHOTOGRAPHY, LTD. to allow commercial operation of Multi-Rotor, so long as operations are conducted within and under the conditions outlined within and under the conditions outlined herein or may be established by the FAA as required by Se ction 333. As described more fully below, the request is to operate an Unmanned Aircraft System (UAS), the 3DRobitics Solo, for the commercial purpose of conducting aerial video and photography of c onstruction sites, residential and commercial real estate, aerial landscapes and cityscapes over certain areas of the Un ited States. As described more fully below, the requested exemption would permit the operation of small, unma nned and relatively inexpe nsive sUAS under controlled conditions in airspace that is:

1. Limited

2. Predetermined

3. Controlled as to access

4. Would provide safety enhancements to the already safe operations in the industrial film, and television production community presently using conventional and unmanned aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secret ary of Transportation's (the FAA Administrator's) responsibilities to establish requirem ents for the safe operation of such aircraft systems in the national airspace system." Section 333 (c) of the Reform Act.

Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is:

Richard Mack

President Richard Mack Photography, Ltd.

2331 Hartzell Street
Evanston, Illinois 60201-1410

Cell: 847-840-0081 Email: richard@mackphoto.com

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 3 Regulations form which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 9b) 14 C.F.R 61.113 (a) & (b)
14 C.F.R. 91.7(a) 14 C.F.R. 91.9 (b)(2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151 (b) 91.203 (a) & (b)
91.405(a)
91.407(a)(1)
91.409 (a)(2) 91.417(a) & (b)

INTRODUCTION AND INTERESTS OF THE PETITIONER

RICHARD MACK PHOTOGRAPHY, LTD. has for over thirty-f ive years provided their clients (which include private sector businesses and non-prof its) with expertise and knowledge in still images, video and multimedia marketing, advertising, and public re lations photography and video production advanced technologies and solutions.
RICHARD MACK PHOTOGRAPHY, LTD. has worked on thousan ds of productions over the past 36 years in all types of locations with a perfect client and employee safety record. In the past we have supplied our clients aerial video and still photography using commercial aircraft . The objective of RICHARD MACK PHOTOGRAPHY, LTD. and our Unmanned Aircraft System (3DR Solo) aerial operations is to provide a more affordable, high-quality production system for a variety of governmental, commercial, public, and residential uses, specifically targeting

 Landscapes and cityscapes for documentary films

 Landscapes and cityscapes for comme rcial, advertising, TV video

 Real-estate marketing

 Architectural Photography aerials fo r Architects and Construction Firms

 Economic development

 Civic landmarks

 Documentary Films

 Stock imagery

 Environmental assessment

 Environmental documentary films

I have safely flown small RC electric quadcopters recreati onally for approximately 1 year without incident. I will always use the 3DR Solo software with FAA notices in the system along with the B4UFLY Mobile Application for safe flying. In the mid 1980’s I was a student pilot and had 50+ hour s of flying experience. Only had to fly the final check ride when my first child was born keeping me from finishin g at the time. I have done aerial work from helicopters and fixed wing aircraft for the last 35 years.

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 4 BACKGROUND Unmanned Aircraft Systems: 3DR Solo, UAS

RICHARD MACK PHOTOGRAPHY, LTD. seeks an exemption to operate 3DR Solo system for compensation or

hire within the NAS. The 3DR Solo is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The 3DR Solo has a maximum gross weight of approximately 3.5 lb. while having a diagonal dimens ion of 22”, a maximum speed of approximately 55mph and a maximum flying height of 400'. The 3DR Solo is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The 3DR Solo that will be operated by RICHARD MACK PHOTOGRAPHY, LTD. 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 Re gistration Marking

.

1. Flights will be operated manually with in visual line of sight (VLOS) of the Pilot and aircrew (Spotter / Observer, Camera / Sensor Operator).

2. Maximum total flight time for each operational flight will be 20 minutes. Flights wi ll be terminated at 20% battery power reserve should that oc cur prior to the 20-minute limit.

3. Flights will be operated at an altitude of no more th an 400 feet AGL or, not more than 200 feet above an elevated platform from which airborne data collection is planned.

4. A pre-flight briefing will be conducted in regard to the planned sUAS operation prior to each day's production activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimete r be present for this briefing.

5. Pilot, Camera Operator, and Spotter (Observer) will ha ve been trained in operation of sUAS generally and received up-to-date information on the particular sU AS to be operated as required in the 3DRobotics

Manual

6. Any Spotter (Observer) and Pilot will at all times be able to communicate by voice, radio, and/or text.

7. Written and/or oral permission from the re levant property holders will be obtained.

8. All required permissions and permits will be obtained fr om territorial state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

9. If the sUAS loses communications or loses its GPS signal, the 3DRobotics Solo will have capability to return to a pre-determined location and land safely.

10. The sUAS will have the capability to abort a flight in case of unpredicted ob stacles or emergencies.

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 5 B. The Specific Sections Of 14 C.F.R. From Which RICHARD MACK PHOTOGRAPHY, LTD. Seeks Exemption and The Reason RICHARD MACK PHOTOGRAPHY, LTD. Seeks The Relief.

1. RICHARD MACK PHOTOGRAPHY, LTD. Seeks Exemptio n From The Requirements Of Section 14 CFR Part 21, Subpart H: Airworthiness Ce rtificates 14 CFR §91.203 (a) (1) Subpart H, entitled Airworthiness Cert ificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an eq uivalent level of safety under

Part I l and Section 333 of the Reform Ac t. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement capability, and proximity to airports and populated areas of the particular 3DR SOLO. In all cases, an analysis of these cri teria demonstrates that the 3DR SOLO operated without an
airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed-wing or rotorcraft) operating with an airworthiness certificate with out the restrictions and condi tions proposed.

The sUAS to be operated hereunder is less th an 55 lbs. fully loaded, carries neithe r a pilot nor passenger, carries no explosiv e materials or flammable liquid fuels, and operates exclusively with in a secured area as set out in the Manual. Unlike other civi l aircraft, operations under this exemption will be tightly contro lled and monitored by both the Operator, pursuant to safety requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. Th e FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to th e public and property owners than conventi onal operations conducted with airworthiness

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is n o credible threat to national security posed by the 3DR SOLO, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, a nd inability to carry a substantial external load.

2. RICHARD MACK PHOTOGRAPHY, LTD. Seeks Exem ption From The Requirements Of Section 14 CFR §45.23 (B): Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the re gistration number is displayed on limited, restricted or lightsport category aircraft or experi mental or provisionally certificated aircraft, th e operator must also display on that aircraft near each entrance to the cabin, cockpit, or pi lot station, in letters not less than 2 in ches nor more than 6 inches high, the words "limited," "restricted", "light-sport," "experimental," or "provisional," as applicable. Even though the 3DR Solo will have no airworthiness certificate, an exemption may be needed as the 3DR Solo will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUAV, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).

3. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 61.113(a) And (b).

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 6 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 leve l certificate, as well as a current and valid airman
medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connect ion with any business or employ ment 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, RICHARD MACK PHOTOGRAPHY , LTD. submits that an equivalent level of safety will be maintained because no PIC will be allowed to ope rate the 3DR Solo UAS unles s that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the 3DR Solo UAS in a manner consistent with the operations specifications as described in this exempt ion, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessel s, vehicles and structures.
Further, RICHARD MACK PHOTOGRAPHY, LTD. submits that all flights of th e 3DR Solo UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to RICHARD MACK PHOTOGRAPHY, LTD.’s business; and (2) will not carry passengers or property for compensation or hire.

4. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD MACK PHOTOGRAPHY, LTD. 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 RICHARD
MACK PHOTOGRAPHY, LTD. to determine that the 3DR So lo UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., RICHARD MACK PHOTOGRAPHY, LTD. Aerial Operations Manual, Monthly Maintenance Log, and 3DR Solo Instruction Manual). RICHARD MACK PHOTOGRAPHY, LTD. seeks the requested relief because the 3DR Solo UAS do not require an

airworthiness certificate in accordance with 14 C.F. R. Part 21, Subpart H. Therefore, RICHARD MACK
PHOTOGRAPHY, LTD. will ensure that the 3DR Solo UA S are in airworthy condition based upon its compliance with the operating documents (i.e., M onthly Maintenance Log, and 3DR Solo) prior to every flight, and further, determine that the aircraft are in condition for safe flig ht, as stated in the conditions and limitations below.

5. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft Section 91.9 (b) (2) provides: No person may operate a U.S.-r egistered civil aircraft (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in th e aircraft a current approved Airplane or Ro torcraft Flight Manual approved manual ma terial, markings, and placards, or any

combination thereof.

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 7 The sUAS, given its size and configuration has no ability or plac e to carry such a flight manual on the aircraft, not only beca use there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keepin g the flight manual at the ground control point where the pilot flyi ng the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos.

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700

6. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD
MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 91.103 14 CFR §91.103: Preflight Action This regulation requires each pilot in command to take certain acti ons before flight to insure th e safety of flight. As FAA app roved rotorcraft flight manuals will not be provided for the aircraft an exemption will be need ed. An equivalent level of safety will be provided as set forth in Sections J and K of the Manual. The PI C will take all actions including reviewing weather, flight batt ery requirements, landing and takeoff distances and airc raft performance data before initiation of flight.

7. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD
MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 14 CFR §91.109: Flight Instruction Section 91.109 provides that no person may opera te a civil aircraft (except a manned free balloon) that is being used for fligh t instruction unless that aircraft has fully functioning dual cont rols. SUASs and remotely piloted aircraft, by their design do n ot have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exempti ons for flight training without fully functional dual controls f or a number of aircraft and for flight inst ruction in experimental aircraft. See Exem ptions Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that aircraft.

9. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD
MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 91.119. Section 91.1 19 establishes safe altitudes for operation of ci vil aircraft. Section 91.1 19 (d) allows helicopters to be operated at less than the minimums prescribed, provided th e person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a rotorcraft request authority to operate at altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited
conditions stated in the Manual, the 3DR SOLO will never operate at higher than 400 ft. AGL-. It will however at times be operated in restricted area with security peri meter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given th e size, weight, speed of the 3DR SOLO as well as location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 8 of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in th e Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. pr oposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those pres ently presented with conventional aircraft operating at or below 500 ft. AGL in the movie industry. In addition, the lo w-altitude operations of the sUAS will ensure separation between these small 3DR SOLO operations and the operations of conventional aircraft that must comply with Section

91.1 19.

10. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD
MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 3DR Solo UAS, which utilize a barometric pressure sensor, GPS equi pment, 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 that any altitude information concerni ng UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), RICHARD MACK PHOTOGRAPHY, LTD. seeks the requested relief because the 3DR Solo 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 limi tations stated below. As more fully set forth herein, an equivalent level of safety will be main tained since the 3DR Solo 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.

11. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 91.151 (b). Relief from Section 91.151(b) entitled Fuel requirements fo r flight in VFR conditions, is requested to the extent required to allow flights of the battery powered 3DR So lo UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 20 minutes. RICHARD MACK PHOTOGRAPHY, LTD. seeks the requested relief because without an exempti on from Section 91.151(b), the flight time duration of the battery powered 3DR Solo UAS will severe ly constrain the practicality of any aerial video or still photo flight operations that RICHARD MACK PHOTOG RAPHY, LTD. proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical sp ecifications of the 3DR Solo UAS, the 3DR Solo operating
documents, and The RICHARD MACK PHOTOGRAPHY, LTD.’s proposed operating limitations, ensure that RICHARD MACK PHOTOGRAPHY, LTD. will safely operate the battery powered 3DR Solo UAS during daylight hours in visual meteorological conditions (VMC), under visu al flight rules (VFR), with enough battery power to fly
for a total duration of 20 minutes, which leaves 5 minutes of reserve to land.

### Richard Mack Photography Ltd

23 31 HARTZELL STREET, EVANSTON, ILLINOIS 60201 T 8 47 86 9 7794 F 8 47 86 9 779 8 MACKPHOTO.COM

Page | 9 12. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD MACK PHOTOGRAPHY, LTD. Seeks Relief From Section 91.203 (a) and (b). 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and curren t airworthiness certificate.. (b) No person may operate a civil aircraft unless the airworth iness certificate required by paragraph (b) of this section or a special flight authorization issued under §91 .715 is displa yed at the cabin or cockpit entrance so that it is legible

to passengers or crew. The 3DR SOLO fully loaded weighs no more than 55 lbs. a nd is operated without an onboard Pilot. As such, there is no ability or place to carry certification and regist ration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keepin g these documents at the ground control point where the Pilot flying the 3DRobotics Solo will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

13. Extent Of Relief RICHARD MACK PHOTOGRAPHY, LTD. Seeks And The Reason RICHARD MACK PHOTOGRAPHY, LTD. Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a) & (b), And 91.417(a) & (b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a) & (b), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, RICHARD MACK PHOTOGRAPHY, LTD. requests relief from these Sections because the 3DR Solo UAS do not require airworthines s certificates. As set forth more fully below, the 3DR Solo UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, RICHARD MACK
PHOTOGRAPHY, LTD. will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, a nd practices prescribed in the UAS operating documents (i.e., the RICHARD MACK PH OTOGRAPHY, LTD. Aerial Operations Manual, Monthly Maintenance Log, and 3DR Solo Instruction Manual). Furthermore, RICH ARD MACK PHOTOGRAPHY, LTD. will document and

maintain all maintenance records for the 3DR Solo UAS.

C. The Reasons Why Granting RICHARD MACK PH OTOGRAPHY, LTD. 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 RICHARD MACK PHOTOGRAPHY, LTD. to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, events and civic landscape over certai n areas of the United States. Additionally, use of the 3DR Solo UAS will decrease congestion of the NAS, reduce pollution, and prov ide significant benefits to the economy. Notably, the benefits of RICHARD MACK PHOTOGRAPHY, LTD.’s proposed operation of the 3DR Solo UAS will be realized without implicating any privacy issues.

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Page | 10 1. The Public Will Benefit From Decreased Congestion Of The NAS. The 3DR Solo 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 manne d aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR Solo UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increa se the safety of life and property in the air and on the ground. Furthermore, by reducing the numbe r of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 3DR Solo UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting ae rial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, take off, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safet y And Efficiency Of The 3DR Solo UAS. Conducting aerial acquisitions with the 3DR Solo UAS, in stead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution ge nerated during traditional aerial video and still photography flight operations. By using battery power and electric mo tors, the 3DR Solo UAS produce no air pollution, and is the most viable environmentally conscious al ternative to the cabin class, six cylinde r internal combustion engine aircraft that are typically utilized for aerial video and photogra phy, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The 3DR Solo UAS, while reducing th e carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the 3DR Solo UAS to perform aerial acquisit ions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditio nal manned aircraft flight oper ations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 3DR Solo UAS (weighing approximately 3. 5 pounds at their maximum gross weig ht with diagonal dimension of 22.0 inches, and with no fuel on board), has less physical poten tial for collateral damage to life and property on the ground, and in the air, compared to the manned aircra ft 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 3DR Solo UAS Will Benefit The Economy. In addition to being safe and efficient, the 3DR Solo UAS ar e also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 3DR Solo UAS will allow United States based companies, like RICHARD MACK PHOTOGRAPHY, LTD., to remain competitive and contribute to growth of the U.S. economy. Specifically, with the ri sing 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 3DR Solo UAS is one such

### Richard Mack Photography Ltd

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Page | 11 technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operationa l cost of a traditional manned aircraft.

By operating the 3DR Solo UAS, companies such as RICHARD MACK PHOTOGRAPHY, LTD., can remain competitive and profitable, and therefor e, provide greater job stability to em ployees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial pe rformance of U.S. companies, through commercial use of the 3DR Solo UAS, provides a stable work force 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 operati ons that have been conducted for decades, The RICHARD MACK PHOTOGRAPHY, LTD.’s proposed operation of the 3DR Solo UAS will not implicate any privacy issues. Specifically, the 3DR Solo UAS will be operated only in compliance with operating documents (i.e., RICHARD MACK PHOTOGRAPHY, LTD. Aerial Operations Manual, Mo nthly Maintenance Log, and 3DR Solo Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the mini mum altitude requirements of 14 C.F.R. § 91.119.

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Page | 12 D. 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 RICHARD MACK PHOTOGRAPH Y, LTD. Seeks Exemption.

1. Reasons Why The 3DR Solo 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 op erating area associated with the unmanned aircraft and its operation, RICHARD MACK PHOTOGRAPHY, LTD.’s operati on of the 3DR Solo UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordan ce with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness cert ification and sets forth requirements for considering whether a UAS will create a h azard 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 re quirement of this subtitle, and not later than 180 days after the date of enactmen t of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the nation al airspace system before completion of the plan and rulemaking re quired by section 332 of this Ac t or the guidance required by se ction 334 of this Act. (b) Assessment of Unmanned Aircraft Systems. --In making the determination under subsec tion (a), the Secretary shall determine, at a

minimum-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weig ht, speed, operational capability, proximi ty to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspac e system or the public or pose a threat to national security; and (2) whether a certificate of waiv er, certificate of authorization, or airworthiness certificat ion under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems id entified under paragraph (1). (c) Requirements for Safe Operation.--If th e Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary sh all establish requirements for th e safe operation of such aircr aft systems in the national airspace system. In seeking this exemption, RICHARD MACK PHOTOGRAPH Y, LTD. submits that the 3DR Solo UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstr ated by: (a) the characteristics of the 3DR Solo UAS; (b) the pilot certification requirement; a nd (c) the specific operating limitations. a. The Specifications Of The 3DR Solo UAS Demonstrate Its Safe Characteristics.

The 3DR Solo 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 3DR Solo UAS. The technical specifications of the 3DR Solo UAS are set forth by the 3DR Solo User Manual, attached hereto as Appendix A. ii. The 3DR Solo UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area.

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Page | 13 The 3DR Solo UAS may be operated in both manual and glob al positioning flight modes. A complete description of the flight and navigational modes of the 3DR Solo UAS is provided at pages 26-27 of the 3DR Solo User Manual attached hereto as Appendix A. iii. The 3DR Solo 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 3DR Solo UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 3DR Solo 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, an d will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the 3DR Solo UAS are set forth at pages 53 through 56 of the 3DR Solo User Manual, attached hereto as Appendix A. iv. The 3DR Solo GCS And Its Operation. A complete description of the operation and specifications of the 3DR Solo GCS and flight control software is provided at pages 30 through 59 of the 3DR Solo User Ma nual. 3DR Solo User Manual is attached hereto as Appendix A. b. Flight Operations Of 3DR Solo UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. RICHARD MACK PHOTOGRAPHY, LTD. video production sta ff will be the only persons to act as a pilot in command (PIC) of the 3DR Solo UA S. Additionally, a safety observer will assi st him at all times during flight time. c. Flights Of 3DR Solo UAS Will Be Conducte d Pursuant To Specific Operating Limitations. In seeking this exemption, RICHARD MACK PHOTOGRAPH Y, LTD. proposes to commercially operate 3DR Solo 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 wi ll be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximu m gross weight: 3DR Solo Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this

grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAS may not be flown at an i ndicated airspeed exceeding 55 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a spec ial 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 obse rver (SO) is not permitted.

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Page | 14 7. All operations must utilize a safety ob server (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 fl ight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the dur ation 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 du ties 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 oper ating 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 oper ator 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 determ ines that any update or revision would affect the basis upon which the FAA granted the exemption, then the opera tor must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) ma y 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 inspec tion. All maintenance and alterations must be properly

documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations th at affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functi onal 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. inopera ble components, items, or equipment, not already covered in the releva nt sections of the operating documents. 13. The operator must follow the UAS manufacturer’s ai rcraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspection s, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterati ons, and status of replacement/overhaul component parts must be noted in the aircraft records, including total ti me 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 co mply with all manufactu rer 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.

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Page | 15 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 maneuver s and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qual ification 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 th e terms of the exemption. However, training operations may only be conducted during de dicated training sessions. Duri ng 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 condi tions (VMC). If flight at night is re quired, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart unless a le tter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as requ ired 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. 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 unpred icted 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 intend ed 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 ho urs 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 leve l and potential transponder requirements. 26. All aircraft operated in accordance with the exempti on must be identified by se rial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in acco rdance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spec trum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate gove rnment oversight agency
requirements.

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Page | 16 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 operat ing. 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 PI C from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonpart icipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehi cles, and structures unless: a. Barriers or structures are present that sufficiently prot ect 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 protec tion 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/c ontroller of such vessels, vehicles or structures has granted permission and the PIC has made a safe ty assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled-access pr operty 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 transgre sses the lateral or vertical boundaries of the operational area as defined by the applicable CO A must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Trans portation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requir ements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. RICHARD MACK PHOTOGRAPHY, LTD. submits that the equi valent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flig ht-hour and currency requirements, that the PIC is able to safely operate

the 3DR Solo UAS in a manner consistent with the ex emption, including evasive and emergency maneuvers and maintaining appropriate distances from peop le, vessels, vehicles and structures. Considering RICHARD MACK PHOTOGRAPHY, LTD.’s proposed area of operations, and the operating limitations set forth-above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exem ption No. 11062); and the airmanship skills necessary to safely operate the
3DR Solo UAS, RICHARD MACK PHOTOGRAPHY, LTD. submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for RICHARD MACK PHOTOGRAPHY, LTD.’s specific proposed flight operations.

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Page | 17 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, 111 53, 11156, 11158, 11159, 11160, 11161). RICHARD MACK PHOTOGRAPHY, LTD. will not allow any PIC to operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirem ents or the 3DR Solo UAS training and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining a ppropriate distances from peopl e, 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 th e exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preced ing 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience th at was obtained in compliance with applicable regulations will ensure an equivalent level of sa fety during RICHARD MACK PHOTOGRAPHY, LTD.’s proposed operations. The Administrator has held that prior documented fl ight 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 accumu lated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UA S 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 ma ke and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these mi nimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be include d in the 10 hours of multi-rotor time and the 10 hours may

be included in the total 25 hours of UAS rotorcraft ti me. 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, profic iency, and experience-building flights the PIC is required to operate the UA with appropriate distan ces in accordance with 14 C.F.R 91.119.

Exemption No. 11138. Accordingly, RICHARD MACK PHOTOGRAPHY, LTD. will ensu re safe operations by not allowing any PIC to operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner consistent with the exemption,

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Page | 18 including evasive and emergency maneuvers and maintaining a ppropriate distances from peopl e, 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 establ ished by Section 91.7(a) will be mainta ined because prior to every flight,
RICHARD MACK PHOTOGRAPHY, LTD. will ensure that the 3DR Solo 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 Secti on 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 Requir ements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety establis hed by Section 91.121 will be maintained be cause the altitude information of the 3DR Solo UAS will be provided to the PIC via GPS equi pment and a radio communications telemetry data link,

which downlinks from the UA to the GCS for active monito ring of the flight path a nd altitude. This altitude
information, combined with RICHARD MACK PHOTOGRAP HY, LTD.’s operation of the 3DR Solo UAS within visual line of sight, at or below 500 fe et 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 esta blished by the UAS at ground level. The FAA has previously granted relief fr om Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Ex emption 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 Requirem ents Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C. F.R. Section 91.151(b) as a result of (1) the technical specificati ons of the 3DR Solo UAS; (2) the limi tations on the proposed flight operations; and (3) the location of the proposed flight operations . Accordingly, RICHARD MACK PHOTOGRAPHY, LTD. will ensure that it will safely operate the battery powered 3D R Solo UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes. Here, as in Exemption No. 11109, the tech nical specifications of the 3DR Solo 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 en sured as the 3DR Solo UAS provide audible and visual warnings to the PIC at the GCS when the UAS experience s 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 3DR Solo UAS will descend and land automatically.

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Page | 19 Significantly, previous exemptions granted by the FAA concerning Section 91.151 esta blish that safety is not adversely affected when the technical characteristics and ope rating 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 ha s 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, RICHARD MACK PHOTOGRAPHY, LTD. submits that the equivalent level of safety with regard to the regulatory maintenance and altera tion requirements establishe d by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b ) will be met because RICHARD MACK PHOTOGRAPHY, LTD. 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., RICHARD MACK PHOTOGRAPHY, LTD. Aerial Operations Manual, Monthly Maintenance Log, and 3DR Solo Instruction Manual).
Furthermore, RICHARD MACK PHOTOGRAPHY, LTD. will document and maintain all maintenance records for

the 3DR Solo UAS. Since the 3DR Solo UAS will be inspected as prescr ibed by the operating documents, RICHARD MACK PHOTOGRAPHY, LTD. will maintain the equivalent level of safety established by Se ctions 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 3DR Solo User Manuals are attached hereto as Ap pendix A; a 3DR Solo UAS Maintenance LOG will be maintained by RICHARD MACK PHOTOGRPAHY, LTD. Likewise, the exemption sought will not adversely affe ct safety because RICHARD MACK PHOTOGRAPHY, LTD. will use trained technicians to perform maintenance, alte rations or preventive maintenance on the UAS using the methods, techniques, and pr actices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equi valent level of safety esta blished by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR Solo UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.
In consideration of RICHARD MACK PHOTOGRAPHY, LTD. ’s proposed operating limitations, the operating documents, and the technical aspects of the 3DR So lo UAS, RICHARD MACK PHOTOGRAPHY, LTD. submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Secti ons 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has prev iously granted relief specif ic to UAS in circumstances similar, in all material respects, to those pres ented 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).

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Page | 20 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernizat ion and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, RICHARD MACK PHOTOGRAPH Y, LTD. requests that the FAA prescribe special conditions for the intended operation of the 3DR Solo UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety eq uivalent 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 photograph y over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whet her 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 Administ rator may prescribe special conditions pursuant to 14 C.F.R.§ 21.16, for operation of the 3DR Solo UAS, since th e airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to th e novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditi ons, 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 beca use of a novel or unusual desi gn feature of the aircraft, aircraft engine or propeller, he prescribes special c onditions and amendments thereto for the product. The special

conditions are issued in accord ance with Part 11 of this chapter and cont ain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establ ish a level of safety equivalent to that established in the regulations. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special
conditions for RICHARD MACK PHOTOGRAPHY, LTD.’s intended operation of the 3DR Solo UAS, which contain such safety standards that the Ad ministrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Su bpart 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 RICHARD MACK PHOTOGRAPHY, LTD. Seeks Exemption: RICHARD MACK PHOTOGRAPHY, LTD. seeks exemption from th e 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 RICHARD MACK PHOTOGRAPHY, LTD.

Seeks: This exemption will permit RICHARD MACK PHOTOGRAPHY, LTD. to commercially op erate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain ar eas of the United States. Any Additional Information, Views, Or Ar guments Available To Support RICHARD MACK PHOTOGRAPHY, LTD.’s Request. This Petition is made pursuant to the F AA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Se cretary of Transportation to determine if certain UAS may operate safely in
the NAS. As such, RICHARD MACK PHOTOGRAPHY, LTD.’s request for exemption may be granted pursuant to

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Page | 21 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 h azard 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 deta il above, RICHARD MACK PHOTOGRAPHY, LTD. will operate the 3DR Solo 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, RICHARD MACK PHOTOGRAPHY, LTD. 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 3DR Solo UAS commercially, without an airworthiness certif icate, 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 Moderni zation and Reform Act of 2012, while also advancing the interests of the public, by allowing RICHARD MA CK PHOTOGRAPHY, LTD. to safely, efficiently, and economically operate the 3DR Solo UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, RICHARD MACK PHOTOGRAPHY, LTD. resp ectfully 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 RICHARD MACK PHOTOGRAPHY, LTD. to operate the 3DR Solo UAS commer cially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: February 16, 2016

Respectfully submitted,

Richard Mack

President Richard Mack Photography, Ltd.

2331 Hartzell Street
Evanston, Illinois 60201-1410

Studio: 847-869-7794 Fax: 847-869-7798 Cell: 847-840-0081 richard@mackphoto.com

Appendices: A – Link to 3DR Solo Manual: Click on link below, or, if needed we can supply a PDF of the 3DR Solo Manual. https://3dr.com/kb/solo-user-manual/