Russell J. Ullrich July 8th, 2015

466 Isle Royale Rd

Galesburg, IL 61401

Cell (309) 335 7300

Email: ullrichr@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1) 3DR Solo User Manual 

2) 3DR Solo (safety notes)

3) 3DR Solo Altitude Limit document

4) 3DR Solo training guide

5) Flight Log

6) exemption/rulemaking

References: 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481

 in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in

 the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355

 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I Russell J. Ullrich, referred to 

hereafter as the petitioner, request exemption from the following sections of Title 14, Code of 

Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

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

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 

cinematography, videography, and other flight operations that could be performed safely and 

more cost effectively with the use of small UAS at low altitude within the U.S. national airspace 

system as compared to a manned aircraft. Operations will be performed only at the request of 

and with the authorization and permission of clients or their authorized agents in order to 

facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems.
So long as such operations are conducted within and under the conditions outlined herein 

or as may be established by the FAA as required by Section 333. The conditions identified and 

proposed by the petitioner are drawn from references 1-3.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an experienced UAS 

operator with the addition of a trained observer. All pre-flight inspection, maintenance and flight 

logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for

review; with the purpose of safely integrating civil UAS operation in the National Airspace

System.

91.119(c) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer 

than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential 

persons, or objects that would not be possible without additional relief. The petitioner requests 

modification, waiver or exemption and clarification concerning the terms “congested areas” and 

“densely populated”. The petitioner requests waiver for this condition to allow reasonable and 

responsible operations in areas of subdivisions and neighborhoods if required.

The petitioner will primarily operate the UAS between ground level and 200 feet. The 

UAS will be operated over designated properties with the owner’s consent and while maintaining 

a safe distance from persons. The petitioner will compile flight data from the logs. This data may

assist the FAA in development of regulations for commercial operations in low-risk, controlled 

environments. 

91.121 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for 

altitude information.

91.151(a) 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior 

relief has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has 

been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS 

provides battery power remaining in percent to the PIC. The UA batteries provide approximately

25 minutes of powered flight. Information provided in the operating documents discusses 

procedures regarding remaining battery power management. Those documents contain a 

condition in which the PIC will initiate a landing procedure when battery remaining reaches a 

specified level. Given the limitations on proposed operations and the location of those proposed 

operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR 

conditions was reasonable.

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

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to 

inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating 

documents. The FAA found that adherence to the petitioner’s operating documents and the 
conditions and limitations specified, describing the requirements for maintenance, inspection, 

and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS

The 3DR Solo is a highly successful consumer grade small rotorcraft in the quadcopter 

configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to 

carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots 

(15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by

four electric motors with a distance between motors of less than 14 inches (350mm).

It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented 

with global positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) unit. Real time video and 

telemetry information is transmitted back to a ground control station allowing the operator and/or 

PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera 

imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or 

GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can 

be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The 

onboard flight controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. An automatic termination of flight and landing will be initiated 

when the battery reaches a predetermined low state. It is anticipated that flights will usually last 

less than 12 minutes. More information is available in attachment 1. 

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be utilized in 

order to manage and mitigate risk and ensure public safety. A preflight checklist will be 

developed and employed to ensure that the UA airworthiness will be verified before launch. 

Airworthiness will be maintained by performance of routine inspections before each flight, 

maintaining flight and maintenance logs to record time on failure prone components. These 

documents will be made available to the FAA and SoT to assist in future implementation of 

safety standards and regulations. The petitioner will only operate the UAS over designated 

properties with the owner’s consent. Flight plans will be predetermined to limit the UASs flight 

time and limit safety concerns. The petitioner will take into account distance from persons and 

potential flight obstacles prior to operating the UAS. UAS operation will always be within 

VLOS of the PIC and the observer. 

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to 

facilitate commerce could lead to economic growth. Operations for this petition will enable 

service for property owners or their designees seeking an enhanced perspective for 

characteristics, amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level videography/photography. Aerial photography is a valuable 

marketing tool that can lead to increased commerce and enhance personal photography. Aerial 
surveying and inspections can increase work site efficiency, improve volumetric estimations and 

reduce risks. The petitioner will provide clients with photographic data for these purposes on a 

‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Flight data 

including UA flight time, Control Unit operation time, incident, accident, and details concerning 

any deviations from normal operations will be available to FAA for use in collecting data 

regarding the use of UAS as part of this application. This data may be submitted to FAA via 

traditional means or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, inspections and other flight operations”. The reason for such a 

general and broad based request is that the petitioner wishes to utilize a business strategy of 

horizontal integration and maximize economies of scope in order to capitalize on opportunities 

as they may arise in the future without the long turnaround time associated with additional 

exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS 

services to individuals or companies who wish to employ these services as a safe, effective, and 

legal option to enhance their business or hobby. The petitioner has refrained from engaging in 

commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the 

capability to offer those services while remaining in compliance. The petitioner has 5 years of 

experience in the radio control model aircraft hobby. 

Respectfully submitted

Russell J. Ullrich