GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Terry Lee Johnson

LHWH Advertising

3005 Highway 17 North Bypass

Myrtle Beach, SC 29577

Tel: 843-448-1123

Fax: 843-626-2390

Email: tjohnson@lhwh.com

B. The Specific Sections Of 14 C.F.R. From Which LHWH Advertising Seeks Exemption.

1. LHWH Advertising Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, 

entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

2. LHWH Advertising Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, 

entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an 

aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by 

reference to an altimeter that is set, when operating–

(1) Below 18,000 feet MSL, to–

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure.

4. LHWH Advertising Seeks Exemption From The Requirements Of Section 91.151(b). Section 

91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 20 minutes.

5. LHWH Advertising Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter[.]
6. LHWH Advertising Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 

91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless–

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter[.]

7. LHWH Advertising Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had –

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

8. LHWH Advertising Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) of 

this section:

(1) Records of the maintenance, preventive maintenance, and alteration and record

 of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include–

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves recurring 

action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

C. The Extent Of Relief LHWH Advertising Seeks And The Reason LHWH Advertising Seeks

The Relief.

1. Extent Of Relief LHWH Advertising Seeks And The Reason LHWH Advertising Seeks Relief From 

Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

Supplemental Pilot 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 connection with 

any business or employment if:

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, LHWH Advertising submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the 3DRobotics SOLO UA unless that PIC has 

met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate the 3DRobotics SOLO UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as well as maintaining 
appropriate distances from people, vessels, vehicles and structures. Further, LHWH Advertising 

submits that all flights of the 3DRobotics SOLO UAS, conducted by the PIC pursuant to the grant of 

this Petition:

(1) will be incidental to LHWH Advertising's business; and

(2) will not carry passengers or property for compensation or hire.

LHWH Advertising believes that though UAS are not traditional aircrafts, a PIC operating the UA must 

have knowledge of Airman rules, basic Airspace and comply with all the rules proposed by the FAA. 

However, considering the fact that a UA is almost like a toy, weighing less than 55 pounds, the PIC 

may be except from obtaining a Private Pilot Certificate, a Sports Certificate, a Recreational 

Certificate considering these certificates require flight hours of several thousand tons weighing 

aircrafts. Lastly, LHWH Advertising’s PICs will operate the UAS no higher than 150 feet, consequently 

causing no danger do any other aircraft in the NAS.

2. Extent Of Relief LHWH Advertising Seeks And The Reason LHWH Advertising 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 LHWH Advertising to determine that the 3DRobotics SOLO UAS is in airworthy condition prior 

to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the 

3DRobotics SOLO Instruction Manual). LHWH Advertising seeks the requested relief because the 

3DRobotics SOLO UAS does not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, LHWH Advertising will ensure that the 3DRobotics SOLO UAS is in 

airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and 3DRobotics SOLO Instruction Manual) prior to every flight, and further, 

determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations 

below.

3. Extent Of Relief LHWH Advertising Seeks And The Reason LHWH Advertising Seeks Relief From 

Section 91.121.

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

the 3DRobotics SOLO UAS, which utilizes a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station (GCS). Since the FAA requires that any altitude information concerning 

UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), LHWH 

Advertising seeks the requested relief because the 3DRobotics 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 limitations stated below. As more 

fully set forth herein, an equivalent level of safety will be maintained since the 3DRobotics SOLO UAS 

is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that 
a ground level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief LHWH Advertising Seeks And The Reason LHWH Advertising Seeks Relief From 

Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to 

the extent required to allow flights of the battery powered 3DRobotics SOLO UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 

15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 5 minutes. LHWH Advertising seeks the requested relief because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered 3DRobotics SOLO UA will 

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

Advertising proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DRobotics SOLO UAS operating 

documents, and LHWH Advertising proposed operating limitations, ensure that LHWH Advertising will 

safely operate the battery powered 3DRobotics SOLO UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for 

a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5 minutes.

5. Extent Of Relief LHWH Advertising Seeks And The Reason LHWH Advertising Seeks Relief From 

Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, LHWH Advertising requests relief from these Sections 

because the 3DRobotics SOLO UAS do not require airworthiness certificates. As set forth more fully 

below, the 3DRobotics SOLO UAS meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, LHWH Advertising will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the 3DRobotics SOLO Instruction 

Manual). Furthermore, LHWH Advertising will document and maintain all maintenance records for the 

3DRobotics SOLO UAS.
D. The Reasons Why Granting LHWH Advertising’s 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 LHWH Advertising to safely, 

efficiently, and economically perform aerial video and photography of real estate, special events, film 

sets, and landscape over certain areas of the United States.

Additionally, use of the 3DRobotics SOLO UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of LHWH Advertising’s 

proposed operation of the 3DRobotics SOLO UAS will be realized without implicating any privacy 

issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS. The 3DRobotics SOLO UA is

battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to 

perform aerial acquisitions, an exemption allowing the use of a 3DRobotics SOLO UAS would reduce 

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the 

safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The 3DRobotics SOLO UA do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video 

and photography missions would result in fewer aircraft that must be handled by air traffic control 

during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 3DRobotics SOLO UAS.

Conducting aerial acquisitions with the 3DRobotics SOLO UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and electric 

motors, the 3DRobotics SOLO UAS produces no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour 

of leaded aviation fuel. The 3DRobotics SOLO UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS is propelled by battery powered electric 

motors, rather than an internal combustion engine. By using the 3DRobotics SOLO UAS to perform 

aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will be substantially reduced or 

completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

3DRobotics SOLO UAS (weighing approximately 3 pounds 9 ounces at its maximum gross weight 

with lengths of 10 inches tall and 18 inches motor to motor, and with no fuel on board), has less 

physical potential for collateral damage to life and property on the ground, and in the air, compared to 
the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds 

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

3. Performing Aerial Video and Photography Operations With The 3DRobotics SOLO UAS Will 

Benefit The Economy. In addition to being safe and efficient, the 3DRobotics SOLO is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the 3DRobotics SOLO UAS will allow United States based companies, like LHWH 

Advertising, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the 

rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered 3DRobotics 

SOLO UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. By operating the 3DRobotics SOLO UAS, companies such as LHWH 

Advertising, can remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use of the 3DRobotics SOLO UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

LHWH Advertising’s proposed operation of the 3DRobotics SOLO UAS will not implicate any privacy 

issues. Specifically, the 3DRobotics SOLO UAS will be operated only

in compliance with operating documents (i.e., the 3DRobotics 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 minimum altitude requirements of 14 C.F.R. § 

91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule 

From Which LHWH Advertising Seeks Exemption.

1. Reasons Why The 3DRobotics SOLO UAS Meets The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited 

operating area associated with the unmanned aircraft and its operation, LHWH Advertising’s

operation of the 3DRobotics SOLO UAS meet the conditions of FMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 

provides authority for a UAS to operate without airworthiness certification and sets forth requirements 
for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.–Notwithstanding any other requirement of this subtitle, and not later than 180 

days after the date of enactment of this Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rule-making required by section 332 of this Act or the guidance 

required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.–In making the determination under

subsection (a), the Secretary shall determine, at a minimum–

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace system 

or the public or pose a threat to national security; and

(2) a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned 

aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft systems in the 

national airspace system. In seeking this exemption, LHWH Advertising submits that the 

3DRobotics SOLO UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the 3DRobotics SOLO UAS; (b) the pilot 

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

a. The Specifications of the 3DRobotics SOLO UAS Demonstrate Its Safe Characteristics.

The 3DRobotics 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 3DRobotics SOLO UAS. The technical specifications of the 

3DRobotics SOLO UAS is set forth by the 3DRobotics SOLO Specifications and Data Sheet, 

attached hereto as Exhibit A.

ii. The 3DRobotics SOLO UAS Autonomous Flight And Navigation Modes Enable The UAS To 

Remain Within A Defined Operational Area. The 3DRobotics SOLO UAS may be operated in 

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

navigational modes of the 3DRobotics SOLO UAS is provided at pages 26-32 and 37-38 of the 

3DRobotics SOLO User Manual sent as a separate attachment.

iii. The 3DRobotics SOLO UAS Is 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 

3DRobotics SOLO UA will remains stationary, in flight, for 3 seconds or more. If, after 3 

seconds, the 3DRobotics SOLO UA does not reacquire control link data from the GCS, the UA 

will assume that the Control Link is lost and the UA 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 3DRobotics SOLO UAS are set forth at pages 33 through 36 of 

the 3DRobotics SOLO User Manual sent as a separate attachment.

b. Flight Operations Of 3DRobotics SOLO UAS Are Limited To The Line Of Sight Of A Pilot in 

Command With A Safety Observer.

c. Flights Of 3DRobotics SOLO UAS Will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, proposes to commercially operate 3DRobotics 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 will be limited to the following aircraft described in 

the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: 

3DRobotics SOLO Unmanned Aircraft System. 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 for attractions, real estate marketing, special events and landscape 

photography.

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (33 m/h).

4. The UAS must be operated at an altitude of no more than 150 (400 per the User Manual) feet 

above ground level (AGL), as indicated by the procedures specified in the operating documents 

unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet 

AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses.

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

7. 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.
8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other 

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

or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations 

and made available to the Administrator upon request. If a discrepancy exists between the conditions 

and limitations contained in the grant of exemption and the procedures outlined in the operating 

documents, the conditions and limitations contained in the grant of exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents.

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

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

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

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

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

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts

must be noted in the aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

17. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the 

UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes 

of training the operator’s PICs are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 C.F.R. § 91.119.

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

must be conducted under visual meteorological conditions (VMC). If flight at night 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.

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

current FAA-published aeronautical chart unless a letter of agreement with that airport’s management 

is obtained, and the operation is conducted in accordance with a NOTAM as required by the 

operator’s COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request.

20. 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.

21. If the UA loses communications or loses its GPS signal, it must return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents.

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

with the operating documents.

23. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UA with 25% battery power remaining.

24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 
also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

25. 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.

26. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request.

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

activities at all times.

29. The UAS may not be operated by the PIC from any moving device or vehicle.

30. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures 

unless:

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

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons 

leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

31. 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.
32. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety.

LHWH Advertising submits that the equivalent level of safety established by Section 61.113(a) and (b) 

will be maintained because no PIC will be allowed to operate the 3DRobotics SOLO UAS unless that 

PIC has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is 

able to safely operate the 3DRobotics SOLO UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Considering LHWH Advertising proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the 3DRobotics SOLO UAS, LHWH Advertising submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for LHWH Advertising specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11158, 11159, 11160, 11161).

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely 

Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, LHWH Advertising will ensure that the 3DRobotics 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 Section 

91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the 3DRobotics SOLO UA will be provided to the PIC via GPS equipment and a radio 
communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of 

the flight path and altitude. This altitude information, combined with LHWH Advertising’s operation of 

the 3DRobotics SOLO UAS within visual line of sight, at or below 150 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment 

installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the 3DRobotics SOLO UAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, LHWH Advertising will ensure that it will safely operate the battery powered 3DRobotics 

SOLO UA during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 5 minutes. Here, as in Exemption No. 11109, the technical specifications of 

the 3DRobotics 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 ensured as the 3DRobotics SOLO UAS provide audible and 

visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first 

warning occurring at approximately 25% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the 3DRobotics SOLO UAS will descend 

and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less 

than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, LHWH Advertising submits that the equivalent level of safety with regard to 

the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because LHWH Advertising 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., the 3DRobotics 

SOLO Instruction Manual). A copy of the 3DRobotics SOLO User Manual is sent as a separate 

attachment. Furthermore, LHWH Advertising will document and maintain all maintenance records for 

the 3DRobotics SOLO UAS. Since the 3DRobotics SOLO UAS will be inspected as prescribed by the 

operating documents, LHWH Advertising will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversely 

affect safety because LHWH Advertising will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents. Furthermore, the exemption sought would maintain an 

equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the 3DRobotics 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 LHWH Advertising proposed 

operating limitations, the operating documents, and the technical aspects of the 3DRobotics SOLO 

UAS, LHWH Advertising submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA 

has previously granted relief specific to UAS in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, LHWH Advertising requests that the FAA prescribe special 

conditions for the intended operation of the 3DRobotics SOLO UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special 

conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and 

photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security; and further, provides the authority for such UAS 

to operate without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe 

special conditions pursuant to 14 C.F.R. § 21.16, for operation of the 3DRobotics SOLO UAS, since 

the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety 

standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual 

design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in accordance with Part 11 of 

this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the 

FAA may prescribe special conditions for LHWH Advertising’s intended operation of the 3DRobotics 

SOLO UAS, which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which LHWH Advertising Seeks Exemption:

LHWH Advertising seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption LHWH Advertising Seeks: This exemption will 

permit LHWH Advertising to commercially operate an Unmanned Aircraft System (UAS) for the 

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

G. Any Additional Information, Views, Or Arguments Available To Support LHWH Advertising’s

Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 

333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in 

the NAS. As such, LHWH Advertising request for exemption may be granted pursuant to the authority 

of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security; and further, provides the authority for such UAS to 

operate without airworthiness certification. As discussed in detail above, LHWH Advertising will 

operate the 3DRobotics 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, LHWH Advertising 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 

3DRobotics SOLO UAS commercially, without an airworthiness certificate, for the limited purpose of 

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

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization 

and Reform Act of 2012, while also advancing the interests of the public, by allowing LHWH 

Advertising to safely, efficiently, and economically operate the 3DRobotics 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, LHWH Advertising respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit LHWH Advertising to operate the 3DRobotics SOLO UAS commercially 

for the purpose of conducting aerial video and photography for attractions, real estate marketing, as 

well as filming of special events, film sets, scripted and unscripted television sets and landscape over 

certain areas of the United States. 

Respectfully submitted by, Terry Lee Johnson

Terry Lee Johnson

LHWH Advertising

3005 Highway 17 North Bypass

Myrtle Beach, South Carolina 29577

tjohnson@lhwh.com
APPENDIX A

3DRobotics Solo Spec Sheet

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4

Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10′′ diameter 4.5′′ pitch self-tightening (24 cm diameter 144 cm pitch); glass-reinforced 

nylon

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or later

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and 

pilot skill. Listed flight time applies to elevations less than 2,000 ft above sea level.

**Depending on environmental conditions; controller is expandable, allowing us or third parties to amp 

up the range in the future.