1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Ian Ryan & Associates, Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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) CONCERNING

COMMERCIAL OPERATION

OF 3DR Solo UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC

LAW 112-95)

Submitted on November 4, 2015

Laird R. Crawford

Ian Ryan & Associates, Inc.

1400 E. Touhy Ave. Suite 220

Des Plaines, IL 60018
2

TABLE OF CONTENTS

GLOSSARY OF

ABBREVIATIONS..................................................................................3

SUMMARY...........................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER.................................4

BACKGROUND.................................................................................4

BASIS FOR PETITION............................................................................4

NAME AND ADDRESS OF PETITIONER..................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Ian Ryan & Associates, Inc.

SEEKS EXEMPTION.........................................................................................6

THE EXTENT OF RELIEF Ian Ryan & Associates, Inc. SEEKS AND THE REASON

Ian Ryan & Associates, Inc. SEEKS THE

RELIEF...................................................................................................9

THE REASONS WHY GRANTING Ian Ryan & Associates, Inc.'s REQUEST WOULD

BE IN THE PUBLIC INTEREST

.............................................................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY......................................................................................13

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.........23

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT Ian Ryan & Associates, Inc. ’S REQUEST........................................23

CONCLUSION........................................................................................24

3DR Solo OPERATION MANUAL IS ATTACHED

GLOSSARY OF ABBREVIATIONS
3

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

SUMMARY
4

Ian Ryan & Associates, Inc. seeks exemption from the requirements of 14 C.F.R §§

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

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333

of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

Ian Ryan & Associates, Inc. to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography of real estate and

landscapes over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Ian Ryan & Associates, Inc. provides its clients with photography and videography of

properties for the purpose of displaying this media on websites. David Smith has

hundreds of hours Hobby RC flying experience and over 2 years flying Hobby RC

Helicopters with video and camera attachments. The objective of Ian Ryan & Associates,

Inc. and its aerial operations is to provide high quality imaging for a variety of

commercial, public, and residential uses, specifically targeting:

• Golf course and similar sports facility flyovers for display on websites and marketing

materials • Real-estate inspections of property under construction, for sale, or to

identify damage

BACKGROUND

Unmanned Aircraft System: 3DR Solo UAS

Ian Ryan & Associates, Inc. seeks an exemption to operate DJI systems for compensation

or hire within the NAS. The 3DR Solo is a vertical takeoff and landing (VTOL) Unmanned

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart

phone systems. The 3DR Solo has a maximum gross weight of 6 pounds 7.5 ounces, a

length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed

of approximately 42 knots. The 3DR Solo UA is equipped with four main rotors; driven

by Lithium Polymer battery powered electric motors.

BASIS FOR PETITION

Petitioner, Ian Ryan & Associates, Inc. pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate the 3DR Solo UAS in the National

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§

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

and 91.417(a) & (b).
5

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, Ian Ryan & Associates, Inc.'s operation of 3DR Solo UAS

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Ian Ryan & Associates, Inc. requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a) (2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

Ian Ryan & Associates, Inc. submits that the requested relief is proper since an equivalent level

of safety will be ensured. Ian Ryan & Associates, Inc. will use experienced personnel or

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using

the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log and 3DR Solo Instruction Manual). Furthermore, Ian Ryan & Associates, Inc.

will document and maintain all maintenance records for the 3DR Solo UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by Ian Ryan & Associates, Inc. to the extent

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as

well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

Ian Ryan & Associates, Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the 3DR Solo UAS does not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. As such, Ian Ryan & Associates, Inc. submits that it will ensure that

the 3DR Solo UA is in an airworthy condition, prior to every flight, by determining that the UAS

is in compliance with the operating documents (i.e., Monthly Maintenance Log and the 3DR

Solo Instruction Manual), and that the aircraft is in a condition for safe flight.

Ian Ryan & Associates, Inc. also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the 3DR Solo UA will not have a typical barometric altimeter on

board. However, altitude information of the 3DR Solo UA will be provided to the PIC via Global

Positioning System (GPS) equipment and radio communications telemetry data link, which

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with Ian Ryan & Associates, Inc.'s operation of the 3DR Solo UAS is

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to

Section 91.121.

Additionally, Ian Ryan & Associates, Inc. seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Ian Ryan & Associates, Inc.

submits that safety will not be affected by operation of the 3DR Solo UA during daylight hours

in visual meteorological conditions (VMC)
6

under visual flight rules (VFR), with enough battery power to fly for a total duration of

approximately 14.5 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Ian Ryan & Associates, Inc. provides the following

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

Laird R. Crawford Ian Ryan & Associates, Inc. 1400 E. Touhy Ave. Suite 220

Des Plaines, IL 60018 847-803-2050

B. The Specific Sections Of 14 C.F.R. From Which Ian Ryan & Associates, Inc. Seeks

Exemption.

1. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Section 61.113(a)

and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections

(a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an

aircraft that is carrying passengers or property for compensation or hire; nor may that person,

for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if—

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

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

2. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No

person may operate a civil aircraft unless it is in an airworthy condition.

3. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:
7

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

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

miles of the aircraft;

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

current reported altimeter setting of an appropriate available station; or

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

or an appropriate altimeter setting available before departure.

4. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states

the

following:

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

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

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

5. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirement Of Section 91.405(a).

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

or

operator of an aircraft—

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

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

repaired as prescribed in part 43 of this chapter[.]

6. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Section

91.407(a)(1)

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

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

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

maintenance, rebuilding, or alteration unless--

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

chapter[.]
8

7. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

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

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

within

the preceding 12 calendar months, it has had --

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

return to

service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of

this chapter.

8. Ian Ryan & Associates, Inc. Seeks Exemption From The Requirements Of Sections 91.417(a

And 91.417(b.

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

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

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

section:

(1) Records of the maintenance, preventive maintenance, and alteration and 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.
9

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

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

required by the inspection program under which the aircraft and its appliances are maintained.

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

for each, the method of compliance, the AD or safety directive number and revision date. If the

AD or safety directive involves recurring action, the time and date when the next action is

required.

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

airframe and currently installed engines, rotors, propellers, and appliances.

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

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

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

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

with the aircraft at the time the aircraft is sold.

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

shall be retained until the defects are repaired and the aircraft is approved for return to service.

(c) The Extent Of Relief Ian Ryan & Associates, Inc. Seeks And The Reason Ian Ryan &

Associates, Inc. Seeks The Relief.

1. Extent Of Relief Ian Ryan & Associates, Inc. Seeks And The Reason Ian Ryan & Associates,

Inc. Seeks Relief from

Section 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is

requested to the extent necessary to allow a PIC holding a private pilot or higher level

certificate, as well as a current and valid airman medical certificate, and who has met certain

flight-hour and currency requirements, to conduct the proposed UAS flight operations for

compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a)

and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not

carry passengers or property for compensation or hire.
10

As set forth more fully below, Ian Ryan & Associates, Inc. submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the 3DR Solo UAS unless

that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is

able to safely operate the 3DR Solo UAS in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency maneuvers, as

well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Ian Ryan & Associates, Inc. submits that all flights of the 3DR Solo UAS conducted by

the PIC pursuant to the grant of this Petition: (1) will be incidental to Ian Ryan & Associates,

Inc.'s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Ian Ryan & Associates, Inc. Seeks And The Reason Ian Ryan & Associates,

Inc. Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow Ian Ryan & Associates, Inc. to determine that the 3DR Solo UAS is in airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., the Ian Ryan & Associates, Inc. Aerial Operations Manual, Monthly

Maintenance Log, and the 3DR Solo Instruction Manual).

Ian Ryan & Associates, Inc. seeks the requested relief because the 3DR Solo UAS does not

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

Ian Ryan & Associates, Inc. will ensure that the 3DR Solo UAS is in airworthy condition based

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and the

3DR Solo Instruction Manual) prior to every flight, and further, determine that the aircraft are

in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Ian Ryan & Associates, Inc. Seeks And The Reason Ian Ryan & Associates,

Inc. Seeks Relief From Section 91.121.

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

operations of the 3DR Solo UAS, which utilize a barometric pressure sensor, GPS equipment,

and a radio communications telemetry data link to downlink altitude information from the UA

to the PIC at the ground control station (GCS). Since the FAA requires that any altitude

information concerning UAS operations be reported to air traffic control (ATC) in feet above

ground level (AGL), Ian Ryan & Associates, Inc. seeks the requested relief because the 3DR Solo

UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below.

As more fully set forth herein, an equivalent level of safety will be maintained since the 3DR

Solo UA's altitude information will be provided to the PIC via Global Positioning System (GPS)

equipment and radio
11

communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path.

4. Extent Of Relief Ian Ryan & Associates, Inc. Seeks And The Reason Ian Ryan & Associates,

Inc. Seeks Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered 3DR Solo UA during

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a

total duration of 14.5 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 4.5 minutes. Ian Ryan & Associates, Inc. seeks the

requested relief because without an exemption from Section 91.151(b), the flight time duration

of the battery powered 3DR Solo UA will severely constrain the practicality of any aerial video

or still photo flight operations that Ian Ryan & Associates, Inc. proposes to conduct pursuant to

this Petition.

Significantly, as set forth below, the technical specifications of the 3DR Solo UAS's operating

documents, and Ian Ryan & Associates, Inc. s proposed operating limitations, ensure that Ian

Ryan & Associates, Inc. will safely operate the battery powered 3DR Solo UA during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough

battery power to fly for a total duration of 14.5 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Ian Ryan & Associates, Inc. Seeks And The Reason Ian Ryan & Associates,

Inc. Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &

(b).

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

aircraft with an airworthiness certificate, Ian Ryan & Associates, Inc. requests relief from these

Sections because the3DR Solo UAS does not require an airworthiness certificate. As set forth

more fully below, the 3DR Solo UAS meets the conditions of FMRA Section 333 for operation

without an airworthiness certificate. Accordingly, Ian Ryan & Associates, Inc. will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UASs using

the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the

Ian Ryan & Associates, Inc. Aerial Operations Manual, Monthly Maintenance Log, and the 3DR

Solo Instruction Manual). Furthermore, Ian Ryan & Associates, Inc. will document and maintain

all maintenance records for the 3DR Solo UAS.

D. The Reasons Why Granting Ian Ryan & Associates, Inc. Request Would Be In The Public

Interest; That Is, How It Would Benefit The Public As A Whole.
12

Granting the present Petition will further the public interest by allowing Ian Ryan & Associates,

Inc. to safely, efficiently, and economically perform aerial video and photography of real estate,

and landscape over certain areas of the United States.

Additionally, use of the 3DR Solo UAS will decrease congestion of the NAS, reduce pollution,

and provide significant benefits to the economy. Notably, the benefits of Ian Ryan & Associates,

Inc.'s proposed operation of the 3DR Solo UAS will be realized without implicating any privacy

issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The 3DR Solo UA is battery powered and serves as a safe, efficient, and economical alternative

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

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR

Solo UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air

pollution, as well as increase the safety of life and property in the air and on the ground.

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

around airports caused by arriving and departing aircraft will be reduced. The 3DR Solo UA does

not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting

aerial video and photography missions would result in fewer aircraft that must be handled by

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The 3DR Solo UAS.

Conducting aerial acquisitions with the 3DR Solo UAS, instead of manned aircraft, will greatly

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

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

electric motors, the 3DR Solo UAS produces no air pollution, and is the most viable

environmentally conscious alternative to the cabin class, six cylinder internal combustion

engine aircraft that are typically utilized for aerial video and photography, while burning

approximately 20-30 gallons per hour of leaded aviation fuel. The 3DR Solo UA, while reducing

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are

propelled by battery powered electric motors, rather than an internal combustion engine.

By using the 3DR Solo UAS to perform aerial acquisitions, the substantial risk to life and

property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the 3DR Solo UA (gross weight of 6

pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a

maximum speed of approximately 42 knots and with no fuel on board), has less physical

potential for collateral damage to life and property on the ground, and in the air, compared to
13

the manned aircraft that typically conduct similar operations (weighing approximately 6,000

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180

gallons).

3. Performing Aerial Video and Photography Operations With The 3DR Solo UAS Will Benefit

The Economy.

In addition to being safe and efficient, the 3DR Solo UAS is also an economical alternative to

using manned aircraft to conduct similar aerial operations. As such, operation of the 3DR Solo

UAS will allow United States based companies, like Ian Ryan & Associates, Inc., to remain

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out

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

technology in order to remain competitive. Operating the battery powered 3DR Solo UAS is one

such technology that not only allows companies greater operational flexibility compared to

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

manned aircraft.

By operating the 3DR Solo UAS companies such as Ian Ryan & Associates, Inc., can remain

competitive and profitable, and therefore, provide greater job stability to employees and

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

performance of U.S. companies, through commercial use of the 3DR Solo UAS, provides a stable

workforce that increases consumer spending; improves local, state, and federal tax revenues;

and allows companies to invest in research and development in order to remain competitive

both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, Ian Ryan & Associates, Inc.'s proposed operation of the 3DR Solo UAS will not

implicate any privacy issues. Specifically, the 3DR Solo UAS will be operated only in compliance

with operating documents (i.e., the Ian Ryan & Associates, Inc. Aerial Operations Manual,

Monthly Maintenance Log, and the 3DR Solo Instruction Manual) which requires property

owner involvement as well as local law enforcement notification, and in accordance with the

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. §

91.119.

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

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

From Which Ian Ryan & Associates, Inc. Seeks Exemption.

1. Reasons Why the 3DR Solo UA Meet The Conditions Of The FAA Modernization and

Reform Act of 2012 (FMRA) Section 333.
14

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, Ian Ryan & Associates, Inc.'s operation of the 3DR Solo

UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

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

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states

the following, in part:

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

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

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

completion of the plan and rulemaking required by section 332 of this Act or the guidance

required by section 334 of this Act.

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

(a), the Secretary shall determine, at a minimum--

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

operational capability, proximity to airports and populated areas, and operation within visual

line of sight do not create a hazard to users of the national airspace system or the public or

pose a threat to national security; and

(2) 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 identified under paragraph (1).

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

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

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

national airspace system.

In seeking this exemption, Ian Ryan & Associates, Inc. submits that the 3DR Solo UAS can

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the 3DR Solo UAS; (b) the pilot certification requirement; and (c) the specific

operating limitations.

a. The Specifications Of the 3DR Solo UAS Demonstrates Its Safe Characteristics.

The 3DR Solo UAS does not create a hazard to users of the NAS or the public, or otherwise pose

a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of the 3DR Solo UAS.
15

The technical specifications of the 3DR Solo UAS is set forth by the 3DR Solo User Manual,

attached hereto.

ii. The 3DR Solo UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain

Within A Defined Operational Area.

The 3DR Solo UAS may be operated in both manual and fully autonomous flight modes. A

complete description of the flight and navigational modes of the 3DR Solo UAS is provided in

the 3DR Solo User Manual, attached hereto.

iii. The 3DR Solo UAS is Designed For Automatic Return To Home Point Or Hover In The

Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the 3DR Solo UA will remain stationary, in flight, for 3 seconds or

more. If, after 3 seconds, the 3DR Solo UA does not reacquire control link data from the GCS,

the UAs will assume that the Control Link is lost and the UAs will return to the home position

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of Failsafe Functions and the flight control software of the 3DR Solo UAS

is provided in the 3DR Solo User Manual, attached hereto.

b. Flight Operations Of the 3DR Solo UAS is Limited To The Line Of Sight Of A Certificated

Pilot in Command With A Safety Observer.

David Smith or a PIC approved by David Smith will be the only persons to act as a pilot in

command (PIC) of the 3DR Solo UAS. Additionally, a safety observer (SO) will assist in flights.

c. Flights Of the 3DR Solo UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Ian Ryan & Associates, Inc. proposes to commercially operate the

3DR Solo UAS for the special purpose of conducting aerial video and photography over certain

areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft

described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum

gross weight: and 3DR Solo Unmanned Aircraft Systems. Proposed operations of any other

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

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 35 knots.
16

4. 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.

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

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

lenses, as specified on the PIC’s FAA-issued airman medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able

to communicate verbally at all times. Electronic messaging or texting is not permitted during

flight

operations. The PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

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

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

the camera or other instruments.

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

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

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained in

the grant of exemption take precedence and must be followed. Otherwise, the operator must

follow the procedures as outlined in its operating documents. The operator may update or

revise its operating documents. It is the operator’s responsibility to track such revisions and

present updated and revised documents to the Administrator upon request. The operator must

also present updated and revised documents if it petitions for extension or amendment to the

grant of exemption. If the operator determines that any update or revision would affect the

basis upon which the FAA granted the exemption, then the operator must petition for

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

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

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

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

aircraft is prohibited from operating until the necessary maintenance has been performed and

the UAS is found to be in a condition for safe flight. The Ground Control Station must be

included in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.
17

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

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

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

records.

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

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

documents.

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

overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the aircraft

records, including total time in service, description of work accomplished, and the signature of

the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety

Bulletins.

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

taken against discrepancies discovered between inspections.

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

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

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

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles

and structures. PIC qualification flight hours must be logged in a manner consistent with 14

C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under

the terms of the exemption. However, training operations may only be conducted during

dedicated training sessions. During training, proficiency, and experience-building flights, all

persons not essential for flight operations are considered nonparticipants, and the PIC must

operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

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

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

required, a special request will be made at the FAA office closest to proposed area of

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

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

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

management is obtained, and the operation is conducted in accordance with a NOTAM as
18

required by the operator’s COA. The letter of agreement with the airport management must be

made available to the Administrator upon request.

20. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

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

21. If the UA loses communications or loses its GPS signal, it must return to a pre-determined

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

operating documents.

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

accordance with the operating documents.

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

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

and land the UA with 25% battery power remaining.

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

times. 25. The UA will not be operated by the PIC from any moving device or vehicle.

26. All aircraft operated in accordance with the exemption will be identified by serial number,

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings

in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. 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.

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

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

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

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

activities at all times.

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

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

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

structures unless:

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

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

persons remain under such protection. If a situation arises where nonparticipating persons
19

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

immediately and/or;

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

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

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

present an undue hazard, and;

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

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

32. 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.

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

boundaries of the operational area as defined by the applicable COA must be reported to the

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

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

Not Adversely Affect Safety.

Ian Ryan & Associates, Inc. submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR Solo

UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner consistent

with the exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Considering Ian Ryan & Associates, Inc.'s proposed area of operations, and the operating

limitations set forth- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the

airmanship skills necessary to safely operate the 3DR Solo UAS, Ian Ryan & Associates, Inc.

submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for Ian Ryan & Associates, Inc.'s specific

proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and

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

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

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Ian Ryan & Associates, Inc. will not allow any PIC to operate the 3DR Solo UAS unless that PIC

has demonstrated, by meeting minimum flight-hour requirements or the 3DR Solo UAS training
20

and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption). In addition to the hour requirements, the PIC must accomplish 3

takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety

during Ian Ryan & Associates, Inc.'s proposed operations. The Administrator has held that prior

documented flight experience that was obtained in compliance with applicable regulations

would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in

a manner consistent with 14 CFR 61.51(b), 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 to operations

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption. For clarification, the FAA

considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours

make and model time may be included in the 10 hours of multi-rotor time and the 10 hours

may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight-hour requirements in

Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to

safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented

flight experience that was obtained in compliance with applicable regulations would satisfy this

requirement. Training, proficiency, and experience-building flights can also be conducted under

the grant of exemption to accomplish the required flight time. During training, proficiency, and

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

accordance with 14 C.F.R 91.119.

Accordingly, Ian Ryan & Associates, Inc. will ensure safe operations by not allowing any PIC to

operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flight-hour

and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.
21

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

Adversely Affect Safety.

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

every flight, Ian Ryan & Associates, Inc. will ensure that the 3DR Solo UAS is in an airworthy

condition based upon the UAS’s compliance with its operating documents and as stated in the

conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

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

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

Adversely Affect Safety.

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

altitude information of the 3DR Solo UA will be provided to the PIC via GPS equipment and a

radio communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path and altitude. This altitude information, combined with Ian Ryan &

Associates, Inc.'s operation of the and 3DR Solo UAs within visual line of sight, at or below 400

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will

be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero

altitude initiation point is automatically established by the UASs at ground level.

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

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

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

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

Adversely Affect Safety.

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

Section 91.151(b) as a result of (1) the technical specifications of the 3DR Solo UAS; (2) the

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

operations. Accordingly, Ian Ryan & Associates, Inc. will ensure that it will safely operate the

battery powered 3DR Solo UA during daylight hours in VFR conditions, with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 3DR Solo UAS; the

limitations on the proposed flight operations; and the location of the proposed operations, will

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore,
22

safety will be ensured as the 3DR Solo UAS provides audible and visual warnings to the PIC at

the GCS when the UA experiences low battery voltage, the first warning occurring at

approximately 33% remaining battery power, and again at approximately 10% remaining

battery power. At the critically low battery level, the 3DR Solo UAS will descend and land

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of

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

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

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

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

8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

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

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

In seeking this exemption, Ian Ryan & Associates, Inc. submits that the equivalent level of safety

with regard to the regulatory maintenance and alteration requirements established by Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Ian Ryan

& Associates, Inc. will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UASs using the methods, techniques, and practices prescribed

in the operating documents (i.e., the Ian Ryan & Associates, Inc. Aerial Operations Manual,

Monthly Maintenance Log, and the 3DR Solo Instruction Manual). Furthermore, Ian Ryan &

Associates, Inc. will document and maintain all maintenance records for the 3DR Solo UAS.

Since the 3DR Solo UAS will be inspected as prescribed by the operating documents, JOHN 21

PENNICK will maintain the equivalent level of safety established by Sections 91.405(a),

91.409(a)(1), and 91.409(a)(2). A copy of the 3DR Solo User Manual is attached hereto.

Likewise, the exemption sought will not adversely affect safety because Ian Ryan & Associates,

Inc. will use trained technicians to perform maintenance, alterations or preventive maintenance

on the UAS using the methods, techniques, and practices prescribed by the operating

documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR Solo UAS will be

performed by trained technicians. Maintenance will be documented and maintained utilizing

the monthly maintenance log.
23

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Ian Ryan & Associates, Inc.'s proposed operating limitations, the operating

documents, and the technical aspects of the 3DR Solo UAS, Ian Ryan & Associates, Inc. submits

that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously

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

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

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

11161).

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

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

14 C.F.R. § 21.16 entitled Special Conditions, Ian Ryan & Associates, Inc. requests that the FAA

prescribe special conditions for the intended operation of the 3DR Solo UAS which contain such

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

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

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

special conditions will permit safe operation of the UAs for the limited purpose of conducting

aerial video and photography over certain areas of the United States for compensation or hire.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification in

accordance with any requirements that must be established for the safe operation of the UAS

in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the 3DR Solo UAS, since the airworthiness regulations of 14 C.F.R. Part

21 do not contain adequate or appropriate safety standards, due to the novel or unusual design

features of

the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate

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

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

conditions and amendments thereto for the product. The special conditions are issued in

accordance with Part 11 of this chapter and contain such safety standards for the aircraft,

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent

to that established in the regulations.

See 14 C.F.R. § 21.16.
24

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

special conditions for Ian Ryan & Associates, Inc.'s intended operation of the 3DR Solo UAS,

which contain such safety standards that the Administrator finds necessary to establish a level

of safety equivalent to that established by 14 C.F.R.

Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which

Ian Ryan & Associates, Inc. Seeks Exemption:

Ian Ryan & Associates, Inc. seeks exemption from the requirements of 14 C.F.R Sections

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

91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Ian Ryan & Associates, Inc. Seeks:

This exemption will permit Ian Ryan & Associates, Inc. to commercially operate an Unmanned

Aircraft System

(UAS) for the purpose of conducting aerial video and photography over certain areas of the

United

States.

•AnyAdditionalInformation,Views,OrArgumentsAvailableToSupportSiteswork.com

LLC's Request.

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

Section 333, which directs the Secretary of Transportation to determine if certain UAS may

operate safely in the NAS. As such, Ian Ryan & Associates, Inc.'s request for exemption may be

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth

above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Ian Ryan & Associates, Inc. will operate the 3DR Solo UAS safely in

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a

threat to national security.

CONCLUSION

As set forth herein, Ian Ryan & Associates, Inc. seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will
25

permit safe operation of the 3DR Solo UAS commercially, without an airworthiness certificate,

for the limited purpose of conducting aerial video and photography over certain areas of the

United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing

the interests of the public, by allowing Ian Ryan & Associates, Inc. to safely, efficiently, and

economically operate the 3DR Solo UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Ian Ryan & Associates, Inc. respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of

14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Ian Ryan & Associates, Inc. to operate the

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

certain areas of the United States.

Dated: June 22, 2015 Respectfully submitted,

Laird R. Crawford Ian Ryan & Associates, Inc. 1400 E. Touhy Ave. Suite 220

Des Plaines, IL 60018

847-803-2050

3DR Solo Information:

The 3DR Solo user manual is a pdf that exceeds the file upload size of

10MB. The link to the the user manual can be obtained at this link:

https://3drobotics.com/kb/solo/