Taylor Thomas

1601 Woodsview Street 

Lincoln, NE 68502 760-443-5852

September 5th, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14

C.F.R Part 11, Taylor Thomas (the operator), seeks exemption from the Federal Aviation Regulations

(FAR’s) hereafter listed:

● 14 C.F.R. 21

● 14 C.F.R 45.23

● 14 C.F.R. 45.29

● 14 C.F.R. 61.3

● 14 C.F.R. 61.113(a)&(b)

● 14 C.F.R. 91.7(b)

● 14 C.F.R. 91.9(b)(2)

● 14 C.F.R. 91.109(a)

● 14 C.F.R. 91.119

● 14 C.F.R. 91.151(a)

● 14 C.F.R. 91.203(a)&(b)

● 14 C.F.R. Subpart E (91.401-417)

These requested exemptions would allow for commercial operations of an unmanned aerial vehicle

system (UAVs) for the purpose of aerial mapping and imaging by the operator within the United States.

The operator requests exemption for the 3D Robotics Solo built with 3D Robotics (3DR) flight

controller Pixhawk 2. 

This UAVs technology and the information that this UAVs technology can provide is highly desirable

for a variety of applications including real estate imaging, aerial inspection, aerial mapping, and

general aerial photography & videography. The UAVs technology removes the requirement for a

human to be airborne, which increases the safety of airborne operations.

Given the precedent for the exemption of the similar platforms, there is minimal risk to the population.

The operator will meet the following requirements prior to commercial operation of the UAVs:

● Maintain Private Pilot’s License (No. 3414817)

● Maintain knowledge of ongoing updates to FAA regulations related to General Aviation

(GA) and Unmanned Aerial Vehicles (UAVs)
● Maintain knowledge and competencies to best practices associated with UAV operations

as outlined by the FAA and private entities such as aircraft platform and flight controller manufacturers

1. DESCRIPTION OF THE AIRCRAFT

The UAVs is powered by lithium batteries that provide electricity to small electric motors that drive

propellers. The UAVs is launched by from a ground position, and flies no faster than 15 m/s. The

ground control station provides the operator with a graphical interface for configuring the aircraft,

planning the flight, and monitoring flight performance via a 915 MHz telemetry system. When the

UAVs detects low battery state or loses the 915 MHz telemetry connection, it will enter a configuration

that returns the aircraft to the launch location. The 3D Robotics Solo UAV has been used successfully

by hundreds of UAV operators. 

More information on UAVs specifications is below. This information is from the 3D Robotics Solo

User's Manual:

“Solo is a quad-rotor aerial vehicle powered by the 3DR Pixhawk 2 autopilot system and APM:Copter

flight control software. Solo communicates with the controller and Solo app over the 3DR Link secure

Wi-Fi connection. 

Autopilot: 3DR Pixhawk 2 

Flight code: ArduPilot Copter 

Control: 3DR Solo Controller 

Wireless communication: 3DR Link 1.0 

Frequency: 2.4 GHz 

Height: 10 in. (25 cm) 

Motor-to-motor dimension: 18 in. (26 cm) 

Propulsion: 880 KV motors, two clockwise rotating motors and two counterclockwise rotating motors

Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm) 

Weight with battery: 3.3 lbs. (1.5 kg) 

Controller battery life: 3 hours 

Extended controller battery life: 6 hours 

Controller battery: Li-ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery) 

Power: Electric (rechargeable lithium polymer battery) 

Battery: Lithium polymer, 5200 mAh, 14.8 Vdc 

Battery weight: 1 lb. (.5 kg) 

Estimated flight time: 25 minutes

Maximum altitude: 328 ft. (100 m) 

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

Payload capacity: 1.1 lbs. (500 g) 

Cruise speed: 5.7 mph (2.5 m/s) 

Maximum speed: 55 mph (25.5 m/s) 

Maximum climb rate: 11 mph (5.0 m/s) 

Maximum descent rate: 5.5 mph (2.5 m/s) 

Headwind limitation: 25 mph (11 m/s) 

Crosswind limitation: 25 mph (11 m/s) 

Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4 Full compatibility with GoPro®

HERO 3+ or 4 

Solo app compatibility: iOS 8.0 or later / Android 4.3 or later 

Operating temperature: 32° F”
The UAVs will undergo a rigorous and appropriate pre-flight inspection to assess the components of the

physical aircraft, the electronic 2.4 GHz radio control components, 915 MHz telemetry system, and 3D

Robotics autonomous flight control system. An example of the pre-flight checklist can be provided

upon request.

The primary aircraft characteristics are:

1. Stable flight characteristics

2. Lightweight

3. Small Size

4. Electric power

5. Autonomous, and manual (RC) flight

Due to the fact that this aircraft is small, lightweight, and flies at low airspeeds, the operator believes

that this aircraft does not pose any risks to the public, and is a safe option relative to manned aircraft

used for similar applications.

2. DESCRIPTION OF PROPOSED OPERATIONS

The operator will operate the UAV with a gross weight of less than 55 pounds, will not operate for the

purposes of motion picture or television filming, will not exceed speeds of 100 miles per hour, will not

operate at an altitude greater than 200 feet above ground level (AGL), will not operate within 5 nautical

miles of an airport, and will maintain unaided (except for corrective lenses) visual line of sight (VLOS)

at all times.

The operator believes that the UAVs outlined above should be considered for exemption due to the fact

that Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft systems may

operate safety in the national airspace system before completion of the plan and rulemaking required by

Section 332”. Section 333 also states “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 the users of the national airspace system or the public, or pose a threat to national security”.

The FAA is provided authority to determine if an airworthiness certification, as described under Title

49 Section 44707, is necessary for operation of the UAV. Furthermore, Section 333 (c) outlines

“whether 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”.

Operations of the UAV will follow strict protocols established by this document and by the FAA.

3. DESCRIPTION OF THE OPERATOR

The operator possesses extensive experience in aviation, including a Private Pilot’s License (No.

3414817) , and many years of remote control (RC) aircraft experience. The 3DR Solo will function in

conjunction with a digital camera system for visual and multispectral imaging of the landscape beneath

the UAV. The operator possesses a BA in Geography. A biography of the operator is available upon

request.

4. OTHER FACTORS AND SUMMARY

The operator will only perform operations in Class G and Class E airspace. When operation in Class E
airspace is required, Air Traffic Control (ATC) permission will be obtained. The UAV will operate at or

below 200 feet AGL. The operator will operate in accordance with Daytime Visual Flight Rules (VFR)

and only in daylight conditions as determined by the location and time of year. The UAV will not

operate over any people not directly involved in the operation.

The operator will comply with existing and future FAA regulations pertaining to operations of the UAV

at sites in the United States, and will comply with all protocols established in this document and

established by the FAA.

Sincerely, 

Taylor Thomas