July 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

EVE TeleSports LLC

Ryan Bell

27 West Adelaide Ave

Nashua, NH 03064

ryan.bell@evetelesports.com

Subject: EVE TeleSports Section 333 Exemption Summary grant candidate request

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR

91.7(a); 14 CFR 91.9(b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR

91.151(a); 14 CFR 91.203 (a) And (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (1) and

(2); 14 CFR 91.417(a) and (b).

Dear Sir or Madam:

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

CFR Part 11, EVE TeleSports LLC, operator of Small Unmanned Aircraft Systems (sUAS),

Commercial operator of sUAS, as described herein, which are equipped with camera(s) and sensors,

would operate in the manner described below. 

For the expressed purpose of assisting with a more rapid response to this request for exemption and to 

remain consistent with established precedence, EVE TeleSports LLC submits this petition in a format 

flow that is similar to Kadoo Aerial’s submission dated April 8, 2015, Section 333 Exemption #12113

granted July 22nd, 2015. Kadoo Aerial operations were found to align with EVE TeleSports intended 

operations. Except where explicitly identified (using italics), this submission is the same as submission 

#12113, and has been adapted to describe operations unique to EVE TeleSports. It is thought that the 

Administration’s familiarity with the content of that request will assist in the review and approval of this 

request for aerial photography and aerial data collection operations per “summary grant” process. 

EVE TeleSports LLC is pleased to operate in a manner consistent with the operational requests granted by 

Exemption #12113, with a focus on action sports filming. EVE TeleSports LCC operates 3D Robotics SOLO

Smart Drones. At its core, EVE TeleSports LLC offers an aerial photography / videography service. EVE 

TeleSports LLC’s vision is to offer services to clientele at specialty car shows, sanctioned racing events, 

yachting and sailing regatta’s, as well as at extreme sports events offering 'follow me', 'orbit’, and 'cable 
cam' services. EVE TeleSports provides first person view (FPV) and third person point of view (bird’s eye 

view) vantage points unavailable with traditional videography equipment which falls into the category of 

aerial data collection. 

The FPV experience is offered to clientele as part of a ‘ride along’ experience during some services and is 

in no way used to pilot sUAV. Similar to previously approved aerial data collection usages, the FPV 

equipment is a federated system (separate from the drones integrated control system) which transmits 

and records video feed. Pilotage of the sUAS will only be accomplished via unaided (corrective lenses 

and/or sunglasses excepted) visual contact between a pilot in command and an unmanned aircraft 

sufficient to maintain safe operational control of the aircraft, know its location, and be able to scan the 

airspace in which it is operating to see and avoid other air traffic or objects aloft or on the ground

without the aid of FPV. EVE TeleSports Pilot in Command (PIC) working with a Visual Operator will 

maintain direct view of flight operations and maintain Visual Line of Site (VLOS) remaining in full control 

at all times. As described by Exemption #12113, EVE TeleSports LLC will provide: 

 Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers with help of F.L.I.R. (Forward

Looking Infrared Camera) and/or thermal imaging cameras.

 Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster (i.e. First Person View)

 Aerial photography / videography of yachts and boats

 Aerial photography / videography of action sports such as skiing, mountain biking, dirt biking, 

kayaking and/or autocross racing.

EVE TeleSports LLC hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUAS’s, so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by Section 

333.

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety enhancements to the established operations in the industry presently using conventional 

aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.
The name and address of the applicant is:

EVE TeleSports LLC

Attn: Ryan Bell, GM/ sUAS Operator

Phone: 603-921-6100

Email: ryan.bell@evetelesports.com

Address: 27 West Adelaide, Ave

Nashua, NH 03064

Owner /Operator of 3DR SOLO Smart Drones

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

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

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. 333(c) (emphasis added) Applicant interprets this provision 
to place the duty on the Administrator to not only process applications for exemptions under section 

333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be 

determined that the conditions set forth herein do not fulfill the statutory requirements for approval.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under 40101 of the Act 

that includes sUAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702- 44716 of this title if the Administrator 

finds the exemption in the public interest. 49 U.S.C. 44701(f) See also 49 USC 44711(a); 49 USC 44704; 

14 CFR 91.203 (a) (1).

EVE TeleSports LLC, sUAS are multi-rotorcraft, weighting 55 or fewer lbs. including payload. They

operate, under normal conditions at a speed of no more than 55 mph and have the capability to hover, 

and move in the vertical and horizontal plane simultaneously. They will operate only in visual

line of sight and will operate only within a controlled area. Such operations will insure that the sUAS

will “not create a hazard to users of the national airspace system or the public.” Reform Act Section 333 

(b).

Given the small size of the sUAS involved and the restricted environment within which they will operate, 

the applicant projects the equivalent level of safety which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the 

UASs and the restricted areas in which the relevant sUAS will operate, approval of the application 

presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety

surrounding the proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with allowing UASs, the 

grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation proposed in conjunction with the limitations offer an equivalent or higher level of safety 

to persons and/or property as compared to using conventional aircraft for the same operations. The 

applicant proposes that the exemption requested herein apply to civil unmanned aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or higher level of safety to operations under the current regulatory structure because the 

proposed operations represent safety enhancement to the accepted safety of operations conducted 

with conventional aircraft. The limitations and conditions to which EVE TeleSports, LLC agrees to be 

bound when conducting commercial operations under an FAA issued exemption as set forth in the Flight 

Operations Manual (FOM) include (these parameters updated from requested parameters in #12113 of 

to reflect the FAAs approved operating parameters):
1. Operations authorized by this grant of exemption are limited to 3DR SOLO Smart Drone

when weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA 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, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO 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 VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations 

in accordance with the conditions and limitations stated in this grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents 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 or any law enforcement 

official upon request. The operator must also present updated and revised documents if 

it 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 an 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. 

8. 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 prior to conducting further operations under this exemption. 
Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance; overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. 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. The operator may not permit any PIC to operate unless the PIC demonstrates 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 persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, 

and experience-building) and determining the PIC’s ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under this exemption are 

permitted under the terms of this 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 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 
agreement with the airport management must be made available to the Administrator 

or any law enforcement official upon request. 

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 UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

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

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

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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 aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities 

at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner 

ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects 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. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 
27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. 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. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated by EVE TeleSports is less than 55 lbs fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and under the requirements and in compliance with 

local public safety requirements. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no additional threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials 

or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

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," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will, have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the UAS, two‐inch lettering will be impossible. The word “Experimental” will be 

placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by 

having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others 

working with the UAS will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), 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. EVE 

TeleSports, LLC will achieve an equivalent level of safety as achieved by current Regulations because the 

applicant’s sUAS do not carry any pilots or passengers nor property.

EVE TeleSports, LLC sUAS do not carry any pilots or passengers nor property therefore the petitioner is

requesting an exemption to 14 CFR 61.113(a) The severity of impact of realized risks attendant to the 

operation of a sUAS is far less than the impact of realized risk inherent in the commercial activities

outlined in 14 CFR 61. The level of safety provided by the requirements included in the Manual exceeds

that provided by a single individual holding a commercial pilot’s certificate operating a conventional

aircraft. The risks associated with the operation of the sUAS are reduced from the level of risk associated 

with commercial operations contemplated by Part 61 when drafted. Allowing operations of the sUAS as 

requested with a pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & 

(b).

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an 

equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.‐registered civil aircraft ... (2) for which an

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 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. 
The UAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry 

such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight 

manual at the ground control point where the pilot flying the UAS will have immediate access to it. The 

FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures

including but not limited to reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight as well as checking sUAS for any 

possible damage that might cause less than favorable flight conditions.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides 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. 

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by 

the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. 

As this exemption is for a UAS and the exemption requests authority to operate at altitudes up to 400

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 

400 AGL. It will be operated in a restricted area with security perimeter, where buildings and people will 

not be exposed to operations without their pre‐obtained consent. The equivalent level of safety will be 

achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight

will be taken without the permission of the property owner or local officials. Because of the advance
notice to the property owner and participants in the filming activity, all affected individuals will be 

aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs and the lack of flammable fuel, any risk associated with

these operations is far less than those presently presented with conventional aircraft operating at or

below 500 AGL. In addition, the low‐altitude operations of the UAS will ensure separation between the

sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires 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.” 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may 

be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check 

list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “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; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30

minute reserve requirement in 14 CFR §91.151, UAS flights would be prohibitive to the intended 

operations. Given the limitations on the UAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR 

conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with less than 25% 

battery power, does not engender the type of risks that Section 91.151(a) was intended to alleviate 

given the size and speed of the small UAS. Additionally, limiting UAS flights times would greatly reduce 

the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety 

can be achieved by limiting flights to 25% of battery power. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:
(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a)

of this section 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.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “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...,” and

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to 

the flight manual and operating handbook. An equivalent level of safety will be achieved because the 

UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited 

period of time. If mechanical issues arise the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be 

achieved because maintenance and inspections will be performed in accordance with the UAS 

Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in 

working order prior to initiating flight and perform required maintenance needed including regular 

software and firmware updates. EVE TeleSports will commence and conclude all operations using a 

preflight safety check list to ensure equivalent level of flight safety.

Pre-Flight Safety Check-List

Aircraft and Controller

Flight Battery Full Charge

Controller Battery Full Charge

Smart Phone battery Full Charge

Payload camera battery Full Charge
Teleporter Goggle battery Full Charge

SOLO Drone Firmware Latest Firmware version installed

SOLO Application Software Latest Application software installed

Propellers Securely attached, positions confirmed

Smart Phone Settings GPS Location Services ON, Bat Full charge

SOLO WiFi WiFi connection confirmed

Payload

GoPro Firmware Latest Firmware Version installed

GoPro Camera WiFi Confirm WiFi mode OFF

GoPro Camera Orientation Setting auto orientation setting ON

GoPro resolution setting Set to desired resolution

HDMI cable Connected

GoPro Record ON, red light flashing

Teleporter FPV camera Mounted securely, clear of props

Teleporter FPV camera Tx Antenna Mounted securely, clear of props

Teleporter FPV camera memory card Installed

Teleporter FPV camera Record ON, red light flashing

Operational Area

Operational Altitude Setting

Confirm Application altitude setting <= 400 

Ft AGL

Operational area / Airspace

> 5 nautical miles from airport reference 

point (ARP)

Identify Obstacles Confirm area clear for VLOS for PIC and VO

Area clear of non-participating observers clear 500 ft radius

PIC and VO positions Confirm VO and PIC within verbal range

Operating Documents Confirm Accessible by PIC or VO

UAV Home Position

clear 500 ft radius, private or controlledaccess property

UAV Return Home altitude Confirm sufficient to clear obstacles

Weather Report Clear for duration of Operation

Maintenance

Manufacturers recommended 

Maintenance, replacement, inspection Confirm current

First Flight since replacement of a flight 

critical component If Yes, perform functional test flight

Start Flight

SOLO Application Launch

SOLO Drone Power ON

controller Power ON

SOLO WiFi

connect to Sololink_####, password 

sololink

SOLO Application Click FLY SOLO, confirm video feed

Area clear of non-participating observers clear 500 ft radius
Hold FLY button Confirm rotors turning

Hold Fly button Take off to Hover

End Flight

Area clear of non-participating observers clear 500 ft radius

Land SOLO at home location Land

Propellers Rotation stopped

SOLO Drone Power OFF

Controller Power OFF

SOLO Application close application

GoPro recording Stop recording

Teleport FPV Camera recording Stop recording

GoPro Power OFF

Teleport FPV Camera Power OFF

Teleport Goggles Power OFF

Aircraft Specifications

3DR SOLO Smart Drone manufacturers user manual is available here:

http://3drobotics.com/wp-content/uploads/2015/08/v5_09_06_15.pdf

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 - 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.

Additional Information

The petitioner, Ryan Bell, is a former helicopter pilot with flight hours on military helicopters such as UH60M , S-92 Helibus, and RAH-66 Comanche simulators. Ryan has PIC time as a private pilot in Robinson R22 and Enstrom 280C. Ryan holds a current FAA airmen medical certificate and has passed the requisite 

aeronautical knowledge exam. Ryan also holds a membership in the Academy of Model Aeronautics 

(AMA #1082255) and is an active member in the local chapter, the Southern NH Flying Eagles RC club 

(#23063-32731). Ryan also holds a Top Secret Clearance which requires US Citizenship among other 

security qualification criteria applicable to the TSAs review. In addition, EVE TeleSports LLC intends to 

employ other FAA certified pilots such as Albert Bell, Private Pilot- Rotorcraft, for its sUAS operations.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. Filming will be of people who have also consented to being filmed or otherwise have 

agreed to be in the area where filming will take place. The grant of this exemption request will provide 

improved safety in day operations. Satisfaction of the criteria provided in Section 333 of the Reform Act 

of 2012‐size, weight, speed, and operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight as well as national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of applicant’s 

UAS.

Operation outside of the US

 Include a specific, direct statement requesting that the exemption apply outside the 

United States and state the reason(s) why you seek this authority.
EVE TeleSports requests that the FAA disallow, redact, deny and/or line item veto this portion of this 

exemption request if the precedent it would establish is cause for delay in granting initial operations 

in the US under the standard established operating parameters above. If it is deemed the request for 

OCONUS operations requires posting to the Federal Register for review and comment EVE TeleSports

requests that the FAA issue a summary grant and restrict EVE TeleSports initial operations to US only.

 If you want to be able to operate under your exemption outside the United States, you 

must specifically request this in your petition and give the FAA the reason for this use.

EVE TeleSports request authorization to conduct operations outside the United States, primarily in 

Canada, because of the numerous natural attractions such as ski resorts, hiking venues, rivers, lakes and 

coastal regions that EVE TeleSports can reach in a day’s drive from its Nashua, NH headquarters.

 Before the FAA extends your exemption for use outside the United States, it will verify that the 

exemption would be in compliance with the Standards of the International Civil Aviation 

Organization (ICAO). However, a foreign country still may not allow you to operate in that 

country.

EVE TeleSports believes that the rules and regulations it has agreed to operate within this petition are 

consistent with the measures described by the ICAO’s Remotely Piloted Aircraft Systems (RPAS) 

documents such as the Manual on Remotely Piloted Aircraft Systems, Rules of the Air and Aircraft 

Nationality and Registration Marks. In addition, EVE TeleSports will agree to operate at or below the 200 

ft AGL restriction dictated by the FAA’s blanket COA restrictions for all international operations.

Conclusions / Recommendations:

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed: Applicant seeks an exemption

from the following rules: 14 C.F.R. 21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. 61.113(a) & (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); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small

Unmanned Vehicle (55 lbs or less).

Due to the small size of the UAS and the controlled access private property area of operation described,

the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this 

application presents no national security issues and will enhance safety by reducing risk as compared to 

similar operations with conventionally piloted aircraft. The grant of the requested exemption is in the 

public interest due to the ability to safely fly and inspect where larger manned aircraft are unable to 

maneuver or restricted to fly below 500 ABL; and the ability to deploy a sUAS on site of a search and 

rescue with infrared and thermal imaging technology to help government and law enforcement officials 

locate persons in a timely manner. In the unlikely event of an in air flight failure during operations 

greater than 500 foot radius from non-participating personnel, the sUAS low weight (less than 55 

pounds) will minimize property damage compared to a larger 4,000lbs + manned aircraft carrying the 
equivalent equipment. Small UAS are powered by batteries verses a combustible material such as Jet A 

or other equivalent fuel carried on board jets and piston powered aircraft therefore lowering the impact 

associated with combustible fuel. Lightweight unmanned aircraft such as the 3DR SOLO Smart Drone

operate at slow speeds, close to the ground, and in controlled environments and are far safer than 

conventional operations conducted with helicopters operating in close proximity to the ground and 

people.

EVE TeleSports believes that the information provided satisfies the criteria in Section 333 of the Reform 

Act of 2012 and citation of the Kadoo Aerial’s submission dated April 8, 2015, Section 333 Exemption 

#12113 granted July 22nd, 2015, provides the necessary support for the approval of the requested 

summary grant 333 exemption allowing the commercial operation of the applicant’s sUAS.

EVE TeleSports believes that a level of safety equivalent to the current NAS standards as well as the ICAO

Remotely Piloted Aircraft Systems can be maintained when operating within the blanket COA 

restrictions, at or below the 200 ft AGL, and when the UAS is operated by the PIC in conjunction with a 

VO. If it is deemed that the request for OCONUS operations requires posting to the Federal Register for 

review and comment EVE TeleSports requests that the FAA issue a summary grant for initial US 

operations.