Edward F. Beck

1910 Brookmonte Dr SE

Puyallup WA 98372

Tel: (253) 831-8905

Email: ed@edbeckphotography.com

Private Pilot Certificate Number: 3448860

Ed Beck Photography LLC petitions for a Grant of Exemption so that the company can conduct aerial 

videography and cinematography to enhance academic community awareness for those individuals and 

companies unfamiliar with the geographical layout of the Puget Sound area and to augment real estate 

listing videos. Specifically we request an exemption from part 21, subpart H; and Sections 

45.23(b),61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91 .151 (a), 91 .203(a) 

and (b), 91.405(a), 91.407(a)(1 ), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal 

Regulations (14 CFR). These flights would be conducted using 3D Robotics Solo with a GoPro camera.

With Safety being our primary goal we look at this operation as a safer alternate to operating a larger 

petroleum powered aircraft requiring airborne crew members. To ensure that we can meet those 

requirements we will make sure that all our PICs have at least a private pilots certificate with either a 

current FAA class 3 physical or a driver’s license. In addition we will insist that all PICs go through our 

ground training program that will cover the operation of the specific UAV they will be operating, 

weather requirements, UAV system operations both normal and emergency. The training will also cover 

the importance of documenting both the flight hours of the PIC and the UAV. Special emphasize will be 

put on documenting any and all maintenance discrepancies and the importance of properly 

documenting the resulting corrective action prior to any flight. In addition, we believe that every PIC 

needs to have accumulated at least 25 hours of UAS time of which at least 10 hours would be in multi 

rotor UAVs and have at least 5 hours in make/model prior to commercial operations. To maintain 

proficiency we will make sure the PIC makes at least 3 take offs and landings within any 90 day time 

frame and all these requirements will be documented in the Pilots log book. To ensure we do not 

interfere with any other manned aircraft we will not fly above 200' AGL or within 5 miles of any airport 

unless we are in radio contact with the control tower. To ensure all know of our presence we will post all 

flights on NOTAMS and will advise all local residence of impending flights. On the day of the flight we 

will post signage indicating that a UAV flight is in the immediate area. As for the actual UAV operation 

we will insist on that all PICs complete a preflight safety check of the UAS that will ensure all 

components of the system work as required.

Name and Address of the Petitioner.

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

Edward F. Beck

1910 Brookmonte Dr SE

Puyallup WA 98372

Tel: (253) 831-8905
Email: ed@edbeckphotography.com

Private Pilot Certificate Number: 3448860
Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions 

approvals, airworthiness certificates, and airworthiness approvals.

Section 45.23(b) prescribes that when marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental, n or "provisional," as applicable.

Because of the size of the aircraft we propose to install the "N" on the fuselage but do not think there is 

adequate space to also place any of the categories mentioned

Section 61 .113(a) and (b) prescribes thata) No person who holds a private pilot certificate may act as a 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.

Since we will not be carrying any passengers or property for compensation we feel a private pilot 

can carry out the responsibilities of the PIC.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy 

condition.

An exemption is requested to 91.7(a) because the UAV does not have to receive an airworthy condition 

by the FAA

Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for determining 

whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when un 

airworthy mechanical, electrical, or structural conditions occur.

We will terminate any flight when the aircraft becomes un airworthy with mechanical, electrical or 

structural conditions. There is no exception.
Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in the 

aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof.

There is no FAA approved manual for the 3D Robotics Solo but we are submitting the following that we 

feel will suffice. Flow Chart, quick start check list, user manual and advanced check list.

In addition we have prepared our own company operating manual and finally we have created a check 

list to ensure a safe operation.

Section 91.1 03(b) prescribes that a pilot shall for any flight, become familiar with runway lengths at 

airports of intended use, and takeoff and landing distance information.

The 3D Robotics Solo does not use any runway for take off and the company policy is that the 3D 

Robotics Solo will remain clear of all ramps, taxiways and runways associated with any airport.

Section 91.1 09(a) prescribes, in pertinent part, that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls.

The 3D Robotics Solo does not have dual flight controls and all instruction is via the one controller. We 

therefore request an exemption from this requirement

Section 91.119 prescribes that, 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.

We will not operate the Phantom 2 near any power lines, light posts or any other powered 

obstacle

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.

We will not operate the3D Robotics Solo over any congested areas.

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.

Because of small size of the 3D Robotics Solo (3.3 lbs) and the fact there is no fuel on board we 

feel as how we offer no risk to flying less than 500 in other than congested areas. We would like 

to operate like powered parachutes in that we will ensure that we do not present any hazard to 
persons or property on the surface. In addition we will ensure we have permission from the 

owner of any vehicle or property prior to getting within the 500 ft area.

d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface1) 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.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set " ... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure."

The 3D Robotics Solo does not have a barometric altimeter but uses GPS signals to compute altitude. The 

3D Robotics Solo has a setting for maximum AGL altitude, the default of which is 150’. We will set the

maximum altitude at or below 200’.

Section 91.151 (a) prescribes that no person may begin a flight in an airplane 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, (1) during the day, to fly after that for at least 30 

minutes.

Since the 3D Robotics Solo does not carry fuel but uses battery power we request the following. The 

battery on the 3D Robotics Solo App Interface shows flight battery percentage remaining. When the 

flight battery percentage remaining reads as 30% power and we use that as the planning to return for a 

safe landing. Most of our flights will not exceed 10 minutes in flight and since the battery has a normal 

25 minute range this 30% factor should provide a safe return point. We will ensure that all flights 

consider winds in determining the return point as they could have a head wind on return.

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has 

within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration 

certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft 

registration Application as provided for in § 47.31 (c).

An exemption is requested for the airworthiness requirement since the 3D Robotics Solo does not have an 

airworthiness certificate.
Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate or a special flight authorization issued under§ 91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew.

Since there is no requirement for an airworthiness certificate for the 3D Robotics Solo this requirement 

would not be appropriate. In addition because of the size of the aircraft there is just not a place to 

display the certificate.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall, between required inspections, except as 

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of 

the chapter.4

There is no approved maintenance program for the 3D Robotics Solo but we will ensure that it goes 

through a complete overhaul by an approved maintenance personnel annually.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved 

for return to service by a person authorized under§ 43.7 of the same chapter.

After any maintenance that requires change of engine or propeller that aircraft will undergo a test flight 

by the PIC in a remote unpopulated area to ensure the aircraft is operating safely

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter.

After any maintenance that requires change of engine or propeller that aircraft will undergo a test flight 

by the PIC in a remote unpopulated area to ensure the aircraft is operating safely
Section 91.417(a) and (b) prescribes, in pertinent part, thata) 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 

1 00-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 includei. 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

We will maintain an aircraft logbook that will reflect all flight t1me on the UAV. Any

maintenance performed on the UAV. There are no life-limited parts on the 3D Robotics Solo. 

No system of AD. If we are notified by the manufacture that there is a discrepancy we will

rectify it and annotate prior to the next flight if it relates to flight safety.
§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

Ed Beck Photography LLC provides the following supporting documentation including: 

1) Supplemental Response for Petition, 

2) 3D Robotics Solo User Manual including:

a. Preflight Checklist

b. Flight Instructions

c. Landing Instructions

d. 3D Robotics Solo Specifications.

e. 3D Robotics Solo Operating Parameters

3) Restricted areas map of planned flight area.

Unmanned Aircraft System

Flights are planned primarily for Pierce County in Washington State, with some operations in King, 

Kitsap, Thurston and Lewis counties. A map of the proposed area of operation is included which 

includes no-fly zones.

Ed Beck Photography LLC plans to operate a UAS, the 3D Robotics Solo, which is comprised of an

unmanned aircraft (UA) and a transportable ground station. The 3D Robotics Solo is referred to as a 

quad-copter with a gross weight of 3.3 pounds and a payload capacity of 1.1 pounds. It is equipped with 

four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 

55 mph. Ed Beck Photography LLC plans to attach a small ultra-lightweight GoPro 4 camera to this UA 

and operate the UA over various areas in Western Washington to include Pierce, King, Kitsap, Thurston 

and Lewis counties to enhance community awareness and augment real estate listing videos. Ed Beck 

Photography LLC makes the following representations of operational enhancements which he proposes 

to abide by to ensure this exemption will provide a level of safety at least equal to existing rules:

Ed Beck Photography LLC:

• Will only operate in reasonably safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; and

• Will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance.

• States that given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) 

and§ 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is 

warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 

and Section 333 of P.L. 112-95 (Section 333).

Petitioner requests an exemption from § 45.23 Marking of the aircraft because his UA will not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he states that twoinch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal 
lettering requirement. Regardless of this, Ed Beck Photography LLC states that he will mark his UAS in 

the largest possible lettering by placing the word "Experimental" on its fuselage as required by § 45.29(f) 

so that he or anyone assisting him as a spotter will see the markings.

The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1 ), 91.409(a)(2) and 91.417(a) and 

(b) Maintenance inspections may be required and should be granted since they only apply to aircraft 

with an airworthiness certificate. However, Ed Beck Photography LLC states as a safety precaution he 

will perform a preflight inspection of his UAS before each flight as outlined in his operating documents.

UAS Pilot in Command (PIC)

Ed Beck Photography LLC asserts that under§ 61.113 (a) and (b) private pilots are limited to 

noncommercial operations, however he can achieve an equivalent level of safety as achieved by current 

regulations because his UAS does not carry any pilots or passengers. Further while helpful, a commercial 

pilot license will not ensure remote control piloting skills. We believe that the risks of operating a UAS 

are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part 61, et seq., 

thus he requests an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.

Regarding UAS operational training, the Ed Beck Photography LLC will fly numerous practice flights in 

remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the 

characteristics of his UAS' performance under different temperature and weather conditions. He further 

states that he will practice computerized simulated flights to maintain adequate skills and response 

reflex time. The PIC for Ed Beck Photography LLC currently holds an FAA Private Pilot license and a valid 

driver’s license (see attached)

UAS Operating Parameters

Ed Beck Photography LLC will abide by the following additional operating conditions under this

exemption:

• Operate the UAS below 200 feet and within a radius distance of 1000 feet from the controller to 

both aid in direct line of sight visual observation;

• Operate the UAS for 3-7 minutes per flight;

• Land the UAS prior to the manufacturer's recommended minimum level of battery power;

• Operate the UAS only within visual line of sight (VLOS);

• Use the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then 

slowly lands if communication with the remote control pilot is lost;

• Conduct all operations under his own personal and flight safety protocols (including posting a 

warning sign reading: "Attention Aerial Photography in Progress- Remain Back 150 feet'') 

contained in the operating documents and will actively analyze flight data and other sources of 

information to constantly update and enhance his safety protocols;

• Contact respective airports if operations will be within 5 miles to advise them of his estimated

flight time, flight duration, elevation of flight and other pertinent information;

• Always obtain all necessary permissions prior to operation; and
• Have procedures in place to abort flights in the event of safety breaches or potential danger.

Ed Beck Photography LLC states that§ 91.7(a) prohibits the operation of an aircraft without an

airworthiness certificate. Ed Beck Photography LLC asserts that since there is currently no certificate

applicable to his operation, this regulation is inapplicable. 91.9(b)(2) requires an aircraft flight manual in 

the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this 

regulation is inapplicable. Ed Beck Photography LLC can maintain an equivalent level of safety by 

maintaining a safety/flight manual with the UAS ground station.

Public Interest

Aerial videography for geographical awareness and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. Granting this exemption to Ed Beck Photography LLC would allow us to provide 

this service at a much lower cost. Further small UAS will pose no threat to the public given its small size 

and lack of combustible fuel when compared to larger manned aircraft. Operation of this UAS will 

minimize ecological damage and promote economic growth by providing information to companies 

looking to relocate or build in the Puget Sound area.

Edward F. Beck

Owner, Chief Pilot

Ed Beck Photography LLC

1910 Brookmonte Dr SE

Puyallup WA 98372

253-831-8905

ed@edbeckphotography.com
Appendix

Solo Operating Parameters

Estimated flight time up to 25 minutes*

Default maximum altitude 150 ft. (46 m) above ground

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

Payload capacity 1 lb. (450 g)

Cruise speed 18 mph (8 m/s)

Maximum speed 33 mph (15 m/s)****

Wind speed limitation 25 mph (11 m/s)

Operating temperature 32° F - 113° F (0° C to 45° C)

*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.

**See Section 7.7 to adjust maximum altitude.

***Depending on environmental conditions

****This top speed corresponds to Solo when operating in Fly mode. Maximum speeds for advanced

modes may vary, see Section 7.1 for more information.

Solo Specifications

Autopilot: 3DR Pixhawk 2

Flight code: ArduPilot Copter

Control: 3DR Solo Controller

Wireless 

communication: 

3DR Link 1.0

Frequency: 2.4GHz

Height: 10 in. (25 cm)

Motor-to-motor 

dimension: 18 in. (26 cm)

Propulsion: 880 K 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: 

25minutes*

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 (2.5m/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 - 113° F (0° C - 45° C) Operating relative 

humidity: 0-85% RH

*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.

**Range varies with location, antenna orientation, background noise and multi-path.