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IN THE MATTER OF THE PETITION OF

EXEMPTION OF AERIAL SOLUTIONS FOR AN

EXEMPTION SEEKING RELEIF FROM THE

REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS SECTIONS:

333 EXEMPTION DOCUMENT

CONCERNING COMMERCIAL OPERATION

OF 3DR SOLO & 3DR AERO M

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM

ACT OF 2012 (PUBLIC LAW 112-95)

Dawnstar Exploration LLC

Jeremiah Jolliff
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Table of Contents

SUMMARY ................................................................................................................................3

PROPOSED OPERATIONS of Dawnstar Exploration LLC..........................................3

THE 3DR SOLO & 3DR AERO M.......................................................................................3

Specifications of the 3DR SOLO......................................................................................................4

Specifications of the 3DR AERO M................................................................................................5

THE OPERATOR.....................................................................................................................6

OPERATING PARAMETERS..............................................................................................6

REGULATORY STATEMENT ............................................................................................6

PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81(a)) ........................6

SECTIONS OF TITLE 14 CODE OF FEDERAL REGULATIONS FOR WHICH 

RELIEF IS SOUGHT...............................................................................................................7

Part 61....................................................................................................................................................7

Part 91....................................................................................................................................................7

EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(c))..................................................9

STATEMENT OF PUBLIC INTEREST.......................................................................... 10

REASONS WHY A GRANT OF THIS EXEMPTION WILL NOT AFFECT 

PUBLIC SAFETY (14 C.F.R. § 11.81(e)).......................................................................... 10

FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81(f)) ........................................ 12

ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.81(g)).................... 13

Proposed specific operating limitations............................................................................. 13

CONCLUSION ....................................................................................................................... 16
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SUMMARY

Petitioner, Dawnstar Exploration LLC., is seeking exemption from the requirements of Title 14 of 

the Code of Federal Regulations (C.F.R.) Part 61 Sections 61.113(a) and (b), Part 91 Sections 

91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b) in order to commercially operate the 3DR SOLO & 3DR AERO M for the 

purpose of aerial survey and photography in support of agricultural operations, surveying, civil 

engineering services, infrastructure inspections, power outage surveying, real estate photography.

This Petition is submitted in accordance with the authority found in Section 333 of The FAA

Modernization and Reform Act of the 2012 and Title 14 C.F.R. Section 11 Subpart A.

PROPOSED OPERATIONS of Dawnstar Exploration LLC

Dawnstar Exploration LLC is seeking an exemption that will permit it to perform aerial 

photography and surveying services for property owners, individual farmers, agribusinesses, 

surveying\engineering companies, infrastructure, contracts, and insurance\finance companies. 

These services would be used to provide information and enhance decision-making abilities

through aerial based survey and photography.

THE 3DR SOLO & 3DR AERO M

The 3DR SOLO & 3DR AERO M are platforms for aerial photography and videography. They 

include cameras ideal for virtually any application and flight times that run as high as 23 minutes

and 40 minutes, respectively

The 3DR SOLO comes with a 2.4GHz transceiver that offers precision control of images and

flight with the ease of a 3DR SOLO application system. Actual Direction Control, Return Home 

and programmable waypoints provide pilots with tools allowing the Operator to focus on creative 

vision and flight control.

The 3DR AERO M is a fixed wing aircraft and comes with a DX7s radio control Ground station 

radios in 433 or 915MHz. The 3DR AERO M is used for aerial survey and mapping purposes and 

makes use of the Pix4Dmapper Mosaic 3DR Edition software.
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Specifications of the 3DR SOLO

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); glassreinforced 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
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Specifications of the 3DR AERO M

Pixhawk autopilot system

Motor: Tiger Motor 2820 830 kV

Propeller: Gemfan 11x7

Flight battery: 4S 6000 mAh 35C LiPo

Aircraft weight with battery: 6.8 lbs (3 kg)

Aircraft dimensions: 74 in (188 cm) wingspan, 51 in (129 cm) length

Case dimensions: 60.75 in x 14.5 in x 15.5 in (154 cm x 37 cm x 39 cm)

Payload capacity: 1.1 lbs (500 g)

Radio range: 1 km

Flight time: 40 min

Maximum operational wind conditions: 25 mph

Area coverage: 250 acres (1 km2)

Ground sampling distance: 2 inches per pixel (5 cm per pixel)*

Orthomosaic accuracy: 3-16 ft (1-5 m)

Henge MD933 servos

Dubro control linkages

External LED indicator and USB port

Digital airspeed sensor

Minimum speed: 22 mph (9.8 m/s)
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THE OPERATOR

The proposed Operator, defined as the person who manipulates the controls of the System, would 

hold, at minimum, a Private Pilot Certificate. To the extent the operation would dictate, the 

Petitioner proposes that the Operator would have the ability to augment the crew with a visual 

observer (Observer) to assist with scanning for hazards and maintain awareness of the 3DR 

SOLO & AERO M’s precise location, as noted in proposed Part 107.

OPERATING PARAMETERS

Dawnstar Exploration LLC is committed to the safe and compliant operation of the System at all 

times. Because the 3DR aerial platforms doe not carry crew or passengers on-board, are small, 

light, and slower than manned aircraft. The Petitioner seeks relief from several aspects of 14 

C.F.R. Part 91. Before each operation, the Operator will inspect the System to ensure that flight 

operations can be conducted safely and in accordance with instructions provided by the 

manufacturer. Operations will be primarily in rural areas, and over private property. All 

operations will be conducted in Class G airspace, or in compliance with Certificate of Waiver or 

Authorization (COA) obtained through the Air Traffic Organization (ATO).

REGULATORY STATEMENT

In accordance with the FAA Modernization and Reform Act of 2012, Section 333, entitled 

Special Rules for Certain Unmanned Aircraft Systems, and 14 C.F.R. §§ 11.61(b) and 11.81, the 

Petitioner submits the following:

PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 

11.81(a))

The name and address of the Petitioner is:

Dawnstar Exploration LLC

P.O. Box 146

Camden, Ohio 45311

The point of contact for purposes of this Petition is:

Jeremiah Jolliff

P.O. Box 146

Camden, Ohio 45311

Tel. (740) 590-6329

jdjolliff@gmail.com
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SECTIONS OF TITLE 14 CODE OF FEDERAL 

REGULATIONS FOR WHICH RELIEF IS SOUGHT

(14 C.F.R. § 11.81(b)) Relief is sought from the following provisions of Title 14 of the Code Of 

Federal Regulations:

Part 61

§ 61.113 (a) and (b), which state: Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private 

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire; nor may that person, for compensation or hire, act as pilot in command 

of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command 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.

Part 91

§ 91.7(a), which states: Civil aircraft airworthiness.

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

§ 91.119, which states: Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the

following altitudes: (a) Anywhere an altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. (b) Over congested areas. 

Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered 

parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to 

persons or property on the surface— (1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section.

§ 91.121(a), which states: Altimeter settings. 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; or (2) At or above 18,000 feet MSL, to 29.92ʺ Hg.

§ 91.151, which states:

Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is enough 
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fuel to fly to the first point of intended landing and, assuming normal cruising speed— (1) During 

the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes. (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.

§ 91.405(a), which states: Maintenance required. 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;

§ 91.407(a)(1), which states: Operation after maintenance, preventative maintenance, rebuilding, 

or alteration. (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; and...

§ 91.409(a)(1) and (2) which state: Inspections (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.

§ 91.417(a) and (b) which state: Maintenance records. (a) Except for work performed in 

accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, 

preventive maintenance, and alteration and records of the 100- hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each aircraft (including the airframe) 

and each engine, propeller, rotor, and appliance of an aircraft. The records must include— (i) A 

description (or reference to data acceptable to the Administrator) of the work performed; and (ii) 

The date of completion of the work performed; and (iii) The signature, and certificate number of 

the person approving the aircraft for return to service. (2) Records containing the following 

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

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

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

required to be overhauled on a specified time basis. (iv) The current inspection status of the 

aircraft, including the time since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. (v) The current status of applicable 

airworthiness directives (AD) and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is required. (vi) Copies of the 

forms prescribed by 

§43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for 

the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 year after the work is 

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

transferred with the aircraft at the time the aircraft is sold. (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.
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EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(c))

61.113(a) and (b). Relief is requested to the extent necessary to permit the holder of a private 

pilot certificate, with at least a current third-class medical certificate holder to conduct the 

proposed flight operations for compensation or hire.

91.7(a). Dawnstar Exploration LLC seeks relief from 91.7(a) to the extent that the 3DR system is 

not eligible for an airworthiness certificate under 14 C.F.R. 21 and therefore can not be airworthy 

in the context of the regulation.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations and the

limited capabilities of the System. Dawnstar Exploration LLC can ensure that each operation is 

conducted within the requirements of 91.119(a) and is therefore not seeking exemption from that 

section of the regulation. With respect to 91.119 (b) and (c) Dawnstar Exploration LLC seeks 

relief for two reasons. First, the small size and flight envelope of the UA, and the limited range of 

the System necessarily restrict operations to that of low level, low speed, line of sight operations. 

The intent of the operations will primarily be survey and photography of property; commercial

operation simply could not be done without exemption. Second, while not a manned helicopter, 

the 3DR system is more analogous to a helicopter than to other aircraft, which a private pilot is 

permitted to operate at less than the minimums prescribed in paragraph (b) or (c) of section 

91.119 so long as the operation is conducted without hazard to persons or property on the surface.

14. C.F.R. § 91.119(d).

91.121. Relief is sought from 91.121 due to the design of the system. While not possessing an 

altimeter that can be set in compliance with the regulation, however the System contains 

GPS derived altitude capabilities. Dawnstar Exploration LLC is not proposing relief to the extent 

that the Operator is not expected to check the System settings prior to each flight.

91.151. Dawnstar Exploration LLC requests relief from 91.151 due to the limited design range 

and associated battery storage capacity.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that 3DR

aircraft are not certificated pursuant to Part 21, nor issued airworthiness certificates, and due to 

the fact that the technology of the System is so different from traditional manned aircraft, the 

System does not fit well into the regulatory scheme of Part 91 Subpart E. As such Dawnstar 

Exploration LLC seeks relief from the above noted regulations. However, Dawnstar Explorations

LLC will maintain all maintenance records related to the system. Dawnstar Exploration LLC does 

not intend to document each battery replacement or charge, because the battery is analogous to 

fuel in manned aircraft, and documenting each charge would be as laborious as documenting each 

fueling of a certificated aircraft in that aircraft’s maintenance records.
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STATEMENT OF PUBLIC INTEREST

(14 C.F.R. § 11.81(d)) The public benefits commensurate with the commercial operation of the 

3DR UAS by Dawnstar Exploration LLC are numerous. By implementing this technology into 

the National Airspace System, the public’s interest will be served in that environmental impacts 

will be lessened, economies will be more efficient and relative public safety will increase. Being 

small electrically powered systems, environmental impacts are mitigated when used in place of 

presently approved manned aircraft operations. Because no fossil fuel is burned, the System itself 

has a low impact on the environment. The low weight and tiny motors reduce fuel consumption, 

reduce noise and reduce the likely hood of other negative environmental impacts such as bird 

strikes and fuel spills. Because the System is small and quick to deploy, crops can be monitored 

more closely for less cost. The need to dispense agricultural chemicals can be further minimized. 

Infrastructure such as roads, bridges, pipelines, and power lines, can be quickly assessed without 

the need for heavy equipment such as trucks, cranes, hoists and aircraft that run on fossil fuels. 

Additionally, studies regarding all aspects of land use, soil, and topography become possible 

where they were previously restricted due to economic reasons. The information collected by 

Dawnstar Exploration LLC will have a broader environmental impact that will benefit society. In

support of commercial operations, the public at large will benefit from the information this 

system brings into the aerial survey market. 3DR UAS services in agriculture will allow farmers 

to have access to aerial based crop studies performed on a more timely basis which will allow

them to reduce input costs (fuel, fertilizer, chemicals, etc).

In support of agricultural operations, 3DR UAS operations will provide the American consumer 

with lower food prices, better grain and income from the export of agricultural products.

3DR UAS will also contribute to relief operations in an efficient way. Government Agencies will 

be able to align their teams closely at disaster sites. The use of 3DR UAS in disaster scenarios 

will ensure that lives are saved and safety measures are efficient. Dawnstar Exploration LLC 

hopes to help emergency response agencies if requested during these unfortunate and unforeseen 

circumstances.

REASONS WHY A GRANT OF THIS EXEMPTION WILL 

NOT AFFECT PUBLIC SAFETY (14 C.F.R. § 11.81(e))

Dawnstar Exploration LLC is firmly convinced that these platforms will not affect public safety 

in any adverse way, but will in fact enhance safety. With respect to the safe operation of the 

aircraft, the Administrator, in exemption No. 11138 has already evaluated the technical 

specifications of similar aircraft. In noting their small size, limited speed and numerous safety 

features (such as low battery autonomous landing, lost-link event autonomous procedures, autopilot and stability control), Dawnstar Exploration LLC believes that the Administrator’s finding 

that these systems can be safely operated in the NAS system was correct.

In order to ensure safety, Dawnstar Exploration LLC would utilize a certificated pilot as the 

Operator, and abide by common sense operating limitations to ensure that the safety of the public 

is ensured. A list of proposed specific operating limitations is included in the additional

information section below. The Petitioner is only seeking relief from very specific regulations 

that relate to the operation of these Systems, and is suggesting specific alternative procedures to 
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ensure safety in lieu of those regulations from which Petitioner is seeking relief.

Dawnstar Exploration LLC further notes that by replacing certain manned operations with 

operations conducted by this small System, public safety will actually be enhanced. In those 

operations where traditional manned aircraft are presently used, the public bears the risk of the 

crash of a much larger, heavier vehicle travelling at a much higher rate of speed. 

Furthermore, many of those manned operations contribute to congestion in the NAS, increasing

risk of collision with other aircraft. Because 3DR UAS will be operated away from the airport 

environment, it will reduce the risk of collision by manned aircraft. With respect to each 

particular regulation for which relief is sought, Dawnstar Exploration LLC believes safety is

insured:

61.113(a) and (b). Relief is requested to the extent necessary to permit the holder of a private

pilot certificate, with at least a current third-class medical certificate holder to conduct the 

proposed flight operations for compensation or hire, or that the operator be properly trained in the 

use of 3DR UAS within the limited area it will be operating. Dawnstar Exploration LLC notes 

that private pilots are allowed to operate aircraft for compensation or hire so long as doing so is 

incidental to their business and they do not carry passengers. This is done in much heavier, faster 

aircraft, which pose a greater risk to persons or property on the ground. In the case of the

3DR aircraft, through it’s limited speed and weight poses less risk to those on the surface. The 

fact that the very small UA will be operated in accordance with the manufacturer’s instructions 

and over limited parcels of land, combined with it’s limited range, negates the long cross-country 

flying experience required for a commercial pilot certificate. Therefore Petitioner believes that an 

equivalent level of safety with respect to manned aircraft is met with a minimum certification 

level of Private Pilot.

91.7(a). Dawnstar Exploration LLC seeks relief from 91.7(a) to the extent that the 3DR UAS is 

not eligible for an airworthiness certificate under 14 C.F.R. 21 and therefore can not be airworthy 

in the context of the regulation. The Operator can, before each flight, determine whether or not 

the aircraft is capable of safe flight by visually inspecting the System, accomplishing appropriate 

pre-flight inspections, and ensuring compliance with the manufacturers operating manuals and 

therefore an equivalent level of safety will be met.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations and the

limited capabilities of the System. Dawnstar Exploration LLC can ensure that each operation is 

conducted within the requirements of 91.119(a) and is therefore not seeking exemption from that 

section of the regulation. With respect to 91.119(b) and (c) Dawnstar Exploration LLC seeks 

relief for two reasons. First, the small size and flight envelope of the UA, and the limited range of 

the System necessarily restrict operations to that of low level, low speed, line of sight operations. 

Combined with the intent of the operations primarily being the survey and photography of 

property; commercial operation simply could not be done without exemption. Second, while not a 

manned helicopter, the 3DR SOLO is more analogous to a helicopter than other aircraft, which a 

private pilot is permitted to operate at less than the minimums prescribed in paragraph (b) or (c) 

of section 91.119 so long as the operation is conducted without hazard to persons or property on 

the surface. 14. C.F.R. § 91.119(c).

With respect to operating the 3DR UAS over or near a structure, Dawnstar Exploration LLC 

would like to point out that it is often more dangerous for those involved if a person were to, for 

example, fall off of a roof or a ladder, or drop a heavy tool such as a hammer, than it would be for 

the 3DR to fall, so long as the Operator ensures that he has permission from the owner and 
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requires that any structure the 3DR is operated over or near is not occupied, nor are people in the 

immediate vicinity, a high level of safety can be achieved.

Due to the Systems limitations with respect to speed and altitude, light weight, and ability to 

maneuver like a helicopter (with an equally trained Private Pilot), and a restriction than any 

structure flown over with permission, Dawnstar Exploration LLC respectfully submits that an

equivalent level of safety is assured if relief is granted from 91.119 (b) and (c).

91.121. Relief is sought from 91.121 due to the design of the system. While not possessing an 

altimeter that can be set in compliance with the regulation, an equivalent level of safety can be 

met due to the fact that the System contains GPS derived altitude capabilities, thus ensuring an 

equivalent level of safety. That being said, Dawnstar Exploration LLC is not proposing relief to 

the extent that the Operator is not expected to check the System settings prior to each flight.

91.151. Dawnstar Exploration LLC requests relief from 91.151 due to the limited battery storage 

capacity. The Petitioner feels that a good balance of safety and utility can be met if the Operator 

is permitted to plan and initiate a daytime VFR flight to the first intended point of landing, at 

normal cruising speed which would require no more than 70% battery power. This System 

possesses several safety features with respect to power, including a low battery warning that first 

alerts at 30% remaining, and an automated landing function when a low battery is detected by the 

System. Should conditions change during the flight, this will leave 30% battery capacity to fly to 

a safe alternative landing zone.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that 3DR

aircraft are not certificated pursuant to Part 21, nor issued airworthiness certificates, and due to 

the fact that the technology of the System is so different from traditional manned aircraft, the 

System does not fit well into the regulatory scheme of Part 91 Subpart E. As such Dawnstar 

Exploration LLC seeks relief from the above noted regulations. In order to ensure an equivalent 

level of safety, Dawnstar Exploration LLC will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on 3DR UAS using the methods, techniques, and practices 

prescribed in the manufacturer’s manuals. Dawnstar Exploration will maintain all maintenance 

records related to the system.

Dawnstar Exploration LLC does not intend to document each battery replacement or charge 

because the battery operated systems are analogous to fuel in manned aircraft, and documenting 

each charge would be as laborious as documenting each fueling of a certificated aircraft in that 

aircraft’s maintenance records.

FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81(f))

Dawnstar Exploration LLC 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). This exemption will permit Aerial Solutions LLC to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial survey and photography 

within the United States.
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ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 

11.81(g))

Documents and Manuals

The documents and manuals for the 3DR UAS can be found at: https://3drobotics.com/

These documents are incorporated into this petition by reference. However, due to file size 

limitations they are not being attached.

Proposed specific operating limitations

1. Operations authorized by this grant of exemption are limited to the 3DR Unmanned Aircraft 

Systems.

2. The UA may not be flown at an indicated airspeed exceeding 30 knots.

3. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as

indicated by the procedures specified in the operating documents. All altitudes reported to ATC

must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the Pilot In Command (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.

5. The operating documents and this 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 in this exemption and the procedures outlined in the operating

documents, the conditions and limitations herein 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 he petitions for extension or 

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

would affect the basis upon which the FAA granted this 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.

6. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. 

If the inspection reveals a condition that affects the safe operation of the UAS, the UAS 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.

7. Any UAS 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.
14

8. The pre-flight inspection section in the operating documents must account for all discrepancies,

i.e. inoperable components, items, or equipment, not already covered in the relevant sections of

the operating documents.

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

replacement, inspection, and life limit requirements.

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

accordance with the operating documents. Maintenance, inspection, and alterations must be noted 

in the aircraft records, including total flight hours, description of work accomplished, and the 

signature of the authorized person returning the UAS to service.

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

Bulletins.

12. The authorized person must make an entry in the aircraft record of the corrective action taken

against discrepancies discovered between inspections.

13. UAS operations must be conducted by a PIC possessing at least a private pilot certificate and 

at least a current third-class medical certificate or be properly trained in the operation. The PIC

must also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which

the PIC is rated on his or her pilot certificate.

14. Prior to operations conducted for the purpose of aerial survey or photography (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR

61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10

hours logged as a UAS pilot with a multi-rotor UAS. Prior documented flight experience that was

obtained in compliance with applicable regulations may satisfy this requirement. Training,

proficiency, and experience-building flights can also be conducted under this grant of exemption

to accomplish the required flight time. However, said training operations may only be conducted

during dedicated training sessions. During training, proficiency, and experience14 building flights 

the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 

91.119.

15. Prior to operations conducted for the purpose of aerial survey or photography (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR

61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be

used in operations under the exemption; 5 hours make and model time may be included in the

10 hours of multi-rotor time prescribed above. The PIC must accomplish 3 take-offs and landings

in the preceding 90 days (for currency purposes). Training, proficiency, experience building, and

take-off and landing currency flights can be conducted under this grant of exemption to

accomplish the required flight time and 90 day currency. However, said training operations may

only be conducted during dedicated training sessions. During training, proficiency, and

experience-building flights the PIC is required to operate the UA with appropriate distances in

accordance with 14 CFR 91.119.

16. The operator may not permit the PIC to operate the UAS for the purpose aerial survey or

photography (or similar operations), unless the PIC has demonstrated and logged in a manner

consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent

with how the UAS will be operated under this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
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17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

18. 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.

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

accordance with the operating documents.

20. 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 30% battery power remaining.

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

Authorization (COA) prior to conducting any operations in Class E airspace. 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 that operation.

22. 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.

23. The documents required under 14 CFR 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. The UA must 

remain clear and yield the right of way to all manned aviation operations and activities at all 

times.

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

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

vessels, vehicles, and structures unless: 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; 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; Operations nearer to the 

PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons 

per § 91.119(a).

26. 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.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by an applicable COA must be reported to the FAA's UAS

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National
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Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, 

and the UAS operations must comply with all applicable parts of 14 CFR including, but not 

limited to, parts 45, 47, 61, and 91.

CONCLUSION

As set forth above, Dawnstar Exploration LLC seeks an exemption from certain parts of the 

Federal Aviation Regulations to permit Dawnstar Exploration LLC to operate a 3DR UAS, for 

compensation or hire, commercially in the United States for the purposes of conducting aerial 

photography and survey. Dawnstar Exploration LLC believes that a grant of exemption is in the 

public interest and that public safety will not be negatively affected. By use of an unmanned 

system in scenarios where manned aircraft are traditionally operated Dawnstar Exploration LLC

believes that public safety will actually be enhanced.

PETITIONER, Dawnstar Exploration, in accordance with the Federal Aviation Regulations and 

the FAA Modernization and Reform Act of 2012, Section 333, respectfully requests that the 

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

61.113(a) and (b), 91.7(a), 91.119(b) and (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) and (b), and permit Dawnstar Exploration LLC to operate 

the 3DR UAS commercially for the purpose of conducting aerial survey and photography over 

certain areas of the United States.

Respectfully Submitted,

__________________________________

Jeremiah Jolliff

P.O. Box 146

Camden, Ohio 45311

Tel. (740) 590-6329

jdjolliff@gmail.com