Mike & Vicki Brennan 

dba: RainierDrones.com LLC 

430 Bare Road 

Ellensburg, WA 98926 

EMAIL: MGR@RainierDrones.com 

March 8, 2016 

U.S. Department of Transportation, Docket Operations 

West Building, Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

 Section 333 Petition Exemption Request 

Page 1 of 22
Salutations Madam or Sir: 

On this day of March 8, 2016... 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform 

Act") and 14 C.F.R. Part 11, Mike and Vicki Brennan dba: RainierDrones.com LLC, State 

of Washington UBI # 603-588-390, do seek an exemption from the Federal Aviation 

Regulations ("FARs") listed below to allow commercial operation of its UAV’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. 

Mike Brennan, co-owner, did the majority of his flight training at FlightSafety 

International, holds a Commercial Pilot Certificate, and fully understands the 

responsibility and serious nature of operating under strict professional standards in the 

National Airspace System and will oversee/manage RainierDrones.com LLC accordingly. 

RainierDrones.com LLC in this Petition for Exemption, seeks Relief from the following of 

Title 14 of the Code of Federal Regulations: 

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

The requested exemption would permit commercial operation of RainierDrones.com

LLC, to utilize 3D Robotics Solo UAV multi rotor aircraft, weighing less than 55 lbs. 

including cargo. The applications for these UAV devices would consist of still 

photographs and/or video taken by an onboard camera and associated data processing 

functions and used for aerial videography and photography for: 

• Real Estate Marketing 

• Agricultural/Crop Related Inspections 

• Agricultural Irrigation/Ditch Inspections 

• Outdoor Rural events, both public and private observing prior permission/approval 

from the appropriate agencies/individuals 

• Structural Inspections 

• Local, County, Law Enforcement, Search and Rescue as needed/on call to serve in 

the public interest as sanctioned by the appropriate agency 

Use of the UAV’s for the aforementioned purposes reduces the need to operate 

conventional aircraft or other equipment for the same purpose and provides high 

resolution digital imagery at a fraction of the cost of surveys and inspections using 

conventional means. The use of these UAV’s in our region of the Cascade Mountains of 

Page 2 of 22
Washington State, can also benefit SAR, Law Enforcement and the like in steep, 

inaccessible, off trail terrain. Inspections of structures and agricultural ditches can be 

performed without endangering the inspector utilizing conventional high risk devices 

such as ladders, lifts or other equipment. The overall economic as well as safety 

benefits of operating these UAV’s becomes quite apparent in all market segments 

described above. 

UAV Model to be utilized in RainierDrones.com LLC operations: 

3D Robotics Solo UAV: A 4 rotor ”Quad” VTOL, Electric Motor Driven, Battery 

Powered Aircraft. 

Estimated flight time: up to 25 minutes* 

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

Range: .5 mile (.8 km) 

Payload capacity: 1 lb. (450 g) 

Cruise speed: 18 mph (8 m/s) 

Maximum speed: 33 mph (15 m/s) 

Wind speed limitation: 25 mph (11 m/s) 

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

RainierDrones.com LLC seeks an exemption to operate 3D Robotics Solo Model Quad 

Copters commercially, for compensation or hire within the NAS of the United States of 

America. 

RainierDrones.com LLC, 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 3D Robotics UAV’s in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R. §§ 61.113(a), 

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

(2), and 91.417(a) & (b). 

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

the unmanned aircraft and its operation, RainierDrones.com LLC operation of the 3D 

Robotics UAV’s meet 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, RainierDrones.com LLC 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 

Page 3 of 22
requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. 

RainierDrones.com LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. RainierDrones.com LLC will use experienced personnel or 

technicians to perform maintenance, alterations, or preventative maintenance on the 

UAV’s using the methods, techniques, and practices prescribed in the operating 

documents (i.e., manual names). Furthermore, RainierDrones.com LLC will document 

and maintain all maintenance records for the UAV’s. 

Relief from certain requirements of Sections 61.113(a), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by RainierDrones.com LLC 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 flight- hour and currency requirements, that the PIC is able to safely 

operate the UAV’s in a manner consistent with this exemption, including normal 

procedures, abnormal procedures, emergency procedures and maintaining appropriate 

distances from people, vessels, vehicles, and structures. 

RainierDrones.com LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the UAV’s do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, RainierDrones.com LLC will 

ensure that the UAV’s are in an airworthy condition, prior to every flight, by determining 

that the UAV’s are in compliance with the operating documents (i.e., manual names), 

and that the aircrafts are in a condition for safe flight. RainierDrones.com LLC seeks 

relief from Section 91.119(c), entitled Minimum safe altitudes: General, because the 

proposed UAV’s must fly lower than 400’ above the surface to accomplish certain 

operations such as photography and infrastructure inspections. As such, 

RainierDrones.com LLC will ensure that operations that occur less than 400’ above the 

surface will remain at least 500’ away from all nonparticipating persons, vehicles, 

vessels, and structures unless a barrier exists to shield nonparticipating persons or 

RainierDrones.com LLC has the owner’s permission to operate near the vehicle, vessel, 

or structure. 

RainierDrones.com LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the UAV’s will not have a typical barometric 

altimeter onboard. However, altitude information of the UAV’s 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 RainierDrones.com LLC operation of the 

UAV’s within visual line of sight, at or below 400’ AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, RainierDrones.com LLC seeks an exemption from the requirements of 

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

RainierDrones.com LLC submits that safety will not be affected by operation of the 

UAV’s during daylight hours in visual meteorological conditions (VMC) under visual flight 

Page 4 of 22
rules (VFR), for a total duration not greater than that recommended by the 

manufacturer. 

In accordance with 14 C.F.R. § 11.81, RainierDrones.com LLC provides the following 

information in support of its petition for exemption: 

The name and address of the Petitioner is: 

Mike and Vicki Brennan 

430 Bare Road 

Ellensburg, Wa 98926

A point of contact for RainierDrones.com LLC is: 

Mgr@RainierDrones.com 

The Specific Sections of 14 C.F.R. From which RainierDrones.com LLC Seeks Exemption. 

 1. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

61.113(a). 

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

subsection (a) prescribes the following, in relevant part: 

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

of an aircraft that is carrying passengers or property for compensation or hire; 

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

aircraft. 

 2. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a) prescribes the 

following: 

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

 3. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.119(c). 

Section 91.119, entitled Minimum safe altitudes: General, subsection (c) 

prescribes the following, in relevant part: 

Page 5 of 22
(c) Except when necessary for takeoff or landing, no person may operate an aircraft 

over other than congested areas below 500 feet above the surface, except over open 

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

closer than 500 feet to any person, vessel, vehicle, or structure. 

4. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a) prescribes the following, in 

relevant part: 

(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. 

 5. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.7, entitled Fuel requirements for flight in VFR conditions, subsection 

(b) prescribes 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. 

 6. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a) prescribes 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[.] 

 7. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.407(a)(1). 

Page 6 of 22
Section 91.407, entitled Operation after maintenance, preventative maintenance, 

rebuilding, or alteration, subsection (a)(1) prescribes the following: 

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

preventative 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. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.409(a)(1) and 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a) prescribes 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, unless 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. 

9. RainierDrones.com LLC Seeks Exemption From The Requirements Of Section 

91.417(a) and 91.417(b). 

Section 91.417, entitled Maintenance records, subsection (a) and (b) prescribes 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. 

Page 7 of 22
(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

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

to be overhauled on a specified time basis. 

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

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.(v) The current status of applicable airworthiness directives 

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

safety directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

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

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

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

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

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

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

transferred with the aircraft at the time the aircraft is sold. 

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

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent Of Relief RainierDrones.com LLC Seeks And The Reason 

RainierDrones.com LLC Seeks The Relief. 

1. Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com

LLC Seeks Relief From Section 61.113(a). 

Relief from Section 61.113(a) 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 training and currency requirements, to conduct the proposed UAV

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 a 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. 

As set forth more entirely below, RainierDrones.com LLC submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate a UAV 

Page 8 of 22
unless that PIC has demonstrated, through OEM training and currency requirements, 

that the PIC is able to safely operate the aircraft in a manner consistent with the 

operations specifications as described in this exemption including normal procedures, 

abnormal procedures, and emergency procedures to include evasive maneuvering and 

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

Further, RainierDrones.com LLC submits that all flights of the UAV’s conducted by the 

PIC pursuant to the grant of this Petition (1) will be incidental to RainierDrones.com

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

Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC

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 RainierDrones.com LLC to determine that the operations UAV is 

in an airworthy condition prior to every flight by ensuring that the UAV is in compliance 

with the applicable operations and maintenance manuals, and that the UAV is in 

condition for safe flight. 

RainierDrones.com LLC seeks the requested relief because the proposed UAV’s do not 

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

Therefore, RainierDrones.com LLC will ensure that the UAV is in an airworthy condition 

based upon its compliance with the operating documents prior to every flight, and as 

stated in the conditions and limitations below. 

Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC

Seeks Relief From Section 91.121. 

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

operations of the proposed UAV, which utilize barometer and GPS equipment, to ensure 

that a ground level pressure setting will be established prior to each flight, and in order 

to report altitude to the PIC. 

RainierDrones.com LLC seeks the requested relief because the proposed UAV do not 

utilize a typical barometric altimeter that may be set as contemplated by Section 

91.121. As more fully set forth below, an equivalent level of safety will be maintained 

since the UAV’s are equipped with a barometer and GPS equipment, which will ensure 

that a ground level pressure setting will be established prior to each flight, and provides 

the PIC with altitude information of the UAV, above ground level (AGL), on the heads-up 

display of the GCS. 

Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com LLC 

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 UAV, during 

daylight hours in visual meteorological conditions under visual flight rules (VFR), to 

Page 9 of 22
continue for a total duration not greater than that recommended by the manufacturer 

for safe operation. 

RainierDrones.com LLC seeks the requested relief, because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered UAV will severely 

constrain the practicality of many of the operations RainierDrones.com LLC proposed to 

conduct pursuant to this Petition. 

5. Extent of Relief RainierDrones.com LLC Seeks And The Reason RainierDrones.com

LLC 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, RainierDrones.com LLC requests relief 

from these Sections because the UAV’s do not require an airworthiness certificate. As 

set forth more fully below, the selected UAV’s meet the conditions of Section 333 of the 

FMRA for operation with an airworthiness certificate. Accordingly, RainierDrones.com

LLC will perform maintenance, alterations, or preventative maintenance on the UAV’s as 

prescribed by the manufacturers’ maintenance documentation where applicable, or by 

returning the aircraft to the manufacturer when operator maintenance is not 

recommended. Furthermore, RainierDrones.com LLC will maintain maintenance 

logbooks for each UAV. 

D. Reasons Why Granting RainierDrones.com LLC’s Request Would Be In The Public 

Interest. 

Granting the present Petition will further the public interest by allowing 

RainierDrones.com LLC to safely, efficiently, and economically perform aerial 

photography, videography, agricultural inspections, property inspections and aerial 

mapping over areas of the United States. 

Additionally, use of the 3D Robotics Solo UAV’s will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of RainierDrones.com LLC’s proposed operation of UAV’s will be realized without 

implicating any privacy issues. 

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

The 3D Robotics Solo UAV’s are battery powered and serve 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 3D Robotics Solo UAV 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. 

Page 10 of 22
The 3D Robotics Solo UAV’s do 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, cruise, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency of the 3D Robotics Solo UAV’s. 

Conducting aerial image acquisitions with the 3D Robotics Solo UAV’s, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

and noise pollution generated during traditional aerial photography, videography, 

inspection, and agricultural mapping flight operations. By using battery power and 

electric motors, the 3D Robotics Solo UAV’s produce 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 10-20 gallons per hour of leaded aviation fuel. The 3D 

Robotics Solo UAV’s, while reducing the carbon footprint of aerial data acquisitions, also 

eliminates noise pollution, as the UAV’s are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the 3D Robotics Solo UAV’s to perform aerial image 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 3D Robotics Solo UA’s (all weighing less than 10 pounds at 

their maximum gross weights 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 the 

manned aircraft that typically conduct similar operations (weighing 3000-6000 pounds 

and carrying 50-100 gallons of fuel). 

3. Performing aerial image acquisitions with the 3D Robotics Solo UAV’s will benefit the 

Economy. In addition to being safe and efficient, the 3D Robotics Solo UAV’s are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the 3D Robotics Solo UAV’s will allow United States based companies, 

like RainierDrones.com LLC 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 

maintain competitive. Operating the battery powered 3D Robotics Solo UAV’s 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 3D Robotics Solo UAV’s, companies such as RainierDrones.com LLC 

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 3D Robotics Solo UAV’s provides a stable workforce that increases consumer 

Page 11 of 22
spending, improves 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, RainierDrones.com LLC’s proposed operations of the 3D Robotics Solo UAV’s 

will not implicate any privacy issues. Specifically, the Solo UAV’s will be operated only in 

compliance with limitations set forth in the Granting of this Petition and operating 

documents (i.e. 3DR Solo Flight Operations Manual) which guides operations around 

persons and property, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. Section 91.119. 

E. Reasons Why Granting RainierDrones.com LLC’s Request Would Not Adversely Affect 

Safety. 

1. Reasons Why The 3D Robotics Solo UAV’s Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FRMA) Section 333. 

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

the unmanned aircraft and their operation, RainierDrones.com LLC’s operations of the 

3D Robotics Solo UAV’s meet 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 UAV to operate without airworthiness certification 

and sets forth requirements for considering whether a UAV 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 

Page 12 of 22
 . (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, RainierDrones.com LLC submits that the included UAV’s can 

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

characteristics of these UAV’s; (b) the pilot certification requirement; and (c) the specific 

operating 3D Robotics Solo Safety Features 

The 3D Robotics Solo UAV’s also have many safety features to mitigate events like loss 

of link and loss of navigational capability. 

Although a degradation or loss of control link, and/or degradation or loss of the source 

of navigation is unlikely, it is a situation that is well planned for and therefore, a benign 

event. 

In the event of a loss of link, the aircraft will follow a user-selected procedure. The 

aircraft will proceed to the “home” position, which is set by the PIC prior to flight and 

can be changed in flight if necessary, at a set altitude. If link is not regained, the 

aircraft will initiate a decent and land at the designated “home” position. 

If the GPS solution is lost during flight, the PIC will still have full control of the aircraft 

and can maneuver it back to “home” for a safe landing. As the PIC always flies the UAV

in visual line of sight, it is immediately apparent if this situation occurs. 

The 3D Robotics Solo Controller has many built in alerts and safety features as well. 

Five features; pause, regain manual control, return home, land, and motor shutoff are 

available in case of emergency. The motor shutoff feature is a two-step procedure to 

prevent inadvertent motor shutoff. 

A complete description of the operation and specifications of the 3D Robotics Solo are 

provided in the Operator Manual. 

Page 13 of 22
 2. Flight Operations of the 3D Robotics Solo UAV’s Are limited to the line of sight of 

a Certificated Pilot In Command with a visual observer. 

RainierDrones.com LLC will only employ pilots who meet FAA Requirements: 

Possess and meet currency requirements for at least a sport pilot certificate 

Possess a valid third class or better FAA airman medical certificate 

• In the case of the upcoming proposed Provisions of Part 107, in which a proposed 

new type of:” Unmanned Aircraft Operator Certificate” with a Specific UAS 

Rating is put into effect, RainierDrones.com LLC will continue to require said 

UAO Certificate Holder to adhere to the same flight proficiency/hours in type 

as below. 

ALL RainierDrones.com LLC PIC’s Must Successfully complete 25 HOURS of 

OEM training “in type” on the SOLO UAV being flown and demonstrate 

proficiency on that SOLO UAV.

RainierDrones.com LLC will only utilize visual observers who are trained on 

the appropriate FAA rules and regulations required to perform their duties. 

Training records, flight time totals, and applicable flight currency records will 

be maintained by RainierDrones.com Co-Owner Mike Brennan.

 3. Flights of the 3D Robotics Solo UAV’s will be conducted pursuant to specific 

operating limitations. 

In seeking this exemption, RainierDrones.com LLC proposes to commercially 

operate the specified UAV’s for the special purpose of conducting real estate 

photography, outdoor videography, property inspections, agricultural related 

inspections, SAR/Law Enforcement Aid in the United States, pursuant to the 

following specific operating limitations: 

In studying past Section 333 Grants of exemption similar to our petition, we hereby 

propose to adhere to the following: 

 1. Operations by RainierDrones.com LLC are limited to the operation of 3D Robotics 

Solo UAV’s, weighing less than 55 pounds including payload. We understand that 

any other 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 will 

not be undertaken or permitted. 

 3 RainierDrones.com LLC UAV’s may not be operated at a speed exceeding 33 

knots. RainierDrones.com LLC will utilize either groundspeed or calibrated 

Page 14 of 22
airspeed to determine compliance with the 33 knot speed restriction. In no case 

will RainierDrones.com LLC UAV’s be operated at airspeeds greater than the 

maximum UAV operating airspeed recommended by the aircraft manufacturer. 

 4. RainierDrones.com LLC UAV’s must be operated at an altitude of no more than 

400 feet above ground level (AGL). Altitude must be reported in feet AGL. 

 5. RainierDrones.com LLC UAV’s must be operated within visual line of sight (VLOS) 

of the PIC at all times. This requires RainierDrones.com LLC 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 by RainierDrones.com LLC 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 will not be 

permitted during flight operations. The PIC will be designated before the flight 

and cannot transfer his or her designation for the duration of the flight. The PIC 

will ensure that the VO can perform the duties required of the VO. 

 7. RainierDrones.com LLC and all documents needed to operate the UAV’s 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 will be accessible during UAV operations and will be 

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

between the conditions and limitations in RainierDrones.com LLC exemption and 

the procedures outlined in the operating documents, the conditions and 

limitations by the FAA take precedence and must be followed. Otherwise, 

RainierDrones.com LLC operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating 

documents. It is understood that RainierDrones.com LLC 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. 

Page 15 of 22
 8. Any RainierDrones.com LLC UAV that has undergone maintenance or alterations 

that affect the UAV’s 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 RainierDrones.com LLC operator is responsible for maintaining and 

inspecting the UAV to ensure that it is in a condition for safe operation. 

 10. Prior to each flight, the RainierDrones.com LLC PIC must conduct a pre-flight 

inspection and determine the UAV 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 UAV, the aircraft is prohibited from operating 

until the necessary maintenance has been performed and the UAV is found to be 

in a condition for safe flight. 

 11. The operator must follow the UAV manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

 12. Each UAV operated by RainierDrones.com LLC must comply with all manufacturer 

safety bulletins. 

 13. RainierDrones.com LLC PIC must hold either an airline transport, commercial, 

private, recreational, sport pilot certificate or in the case of acceptance/

implementation of the proposed provision of Part 107, specific to the “Operator 

Certification and Responsibilities” section relating to the proposed “Unmanned 

Aircraft Operator Certificate”, with small UAS rating if applicable at the time of 

this petition being granted, whichever is applicable at the time of this petition 

being approved. For the sake of the current conditions, default to the current 

standing of: 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. 

 

Page 16 of 22
 14. RainierDrones.com LLC, will not permit any PIC to operate unless the PIC 

demonstrates the ability to safely operate the UAV in a manner consistent with 

how the UAV 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 UAV 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 UAV

with appropriate distance from nonparticipants in accordance with 14 CFR § 

91.119. 

 15. RainierDrones.com LLC operations will not be conducted at 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. RainierDrones.com LLC UAV’s will 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. RainierDrones.com LLC UAV’s will 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 any of RainierDrones.com LLC UAV’s lose communications or loses its GPS 

signal, the UAV must return to a pre-determined location within the private or 

controlled-access property. 

Page 17 of 22
 19. RainierDrones.com LLC PIC must abort the flight in the event of unpredicted 

obstacles or emergencies. 

 20. RainierDrones.com LLC PIC is prohibited from beginning a flight unless 

(considering wind and forecast weather conditions) there is enough available 

power for the UAV to conduct the intended operation and to operate after that 

for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater. 

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

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

 RainierDrones.com LLC may apply for a new or amended COA if it intends to: 

 Conduct operations that cannot be conducted under the terms of the COA. 

 23. 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. 

 24. 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 will be made available to the Administrator or any law 

enforcement official upon request. 

 25. RainierDrones.com LLC UAV’s must remain clear and give way to all manned 

aviation operations and activities at all times. 

 26. RainierDrones.com LLC UAV’s may not be operated by the PIC from any moving 

device or vehicle. 

 27. All Flight operations by RainierDrones.com LLC will 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 UAV 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 

Page 18 of 22
within 500 feet of the UAV, 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. 

28. All operations by RainierDrones.com LLC will 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. Any incident, accident, 

or flight operation that transgresses the lateral or vertical boundaries of the operational 

area as defined by the applicable COA will 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. 

It is further understood, unless otherwise specified, RainierDrones.com LLC, its 

associative UAV’s, the UAV PIC, and the UAV operations must comply with all applicable 

parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. 

4. Reasons Why An Exemption From The Requirements Of Section 61.113(a) Would Not 

Adversely Affect Safety. 

RainierDrones.com LLC submits that an equivalent level of safety established by Section 

61.113(a) will be maintained because no PIC will be allowed to operate the UAV unless 

that PIC has demonstrated, through the proper UAV training and currency 

requirements, that the PIC is able to safely operate the UAV in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining 

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

Considering RainierDrones.com LLC’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 UAV, RainierDrones.com LLC 

submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for 

RainierDrones.com LLC’s specific proposed flight operations. 

Page 19 of 22
Additionally, the FAA has previously granted relief from Section 61.113(a) specific to 

UAS, in circumstance 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). 

As in Exemption No. 11109, RainierDrones.com LLC will not allow any PIC to operate 

the UAV unless that PIC has demonstrated through the UAV training and currency 

requirements that the PIC is able to safely operate the UAV in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining 

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

 5. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 

Not Adversely Affect Safety. 

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

prior to every flight, RainierDrones.com LLC will ensure that the UAV is in an 

airworthy condition and safe for flight based upon the UAV’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 UAV, 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). 

 6. Reasons Why An Exemption From The Requirements Of Section 91.119(c) Would 

Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.119(c) will be maintained 

given the size, weight, and speed of the UAV as well as the location where it is 

operated. No flight will be taken without the required local and ATC coordination. 

Due to the advance notice to the property owner and participants in the aerial 

activity, all affected individuals will be aware of the planned UAV flight 

operations. 

Additionally, the FAA has previously granted relief from Section 91.119(c), 

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). 

 7. 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 all the UAV RainierDrones.com LLC proposes to operate are equipped 

with a digitally encoded barometric altimeter and GPS triangulation equipment, 

with a zero altitude initiation point being established prior to each flight. As such, 

the PIC on the UAV is provided the altitude of the UAV above ground level (AGL) 

via a heads-up display of the ground control station (GCS). 

Page 20 of 22
Additionally, the FAA has previously granted relief from Section 91.121, specific to UAV, 

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). 

 8. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would 

Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.151(b) will be 

maintained because the operator will always have detailed information on the 

charge and state of the battery, and preset battery failsafe’s will prevent any loss 

of flight control due to power loss. 

The ground control station (GCS) for each SOLO UAV provides a battery indicator 

on the heads-up display, which indicates the UAV’s current remaining battery 

power measure in volts, and thus provides the PIC with constant awareness of 

the real-time battery voltage during a flight. 

Additionally, the FAA has previously granted relief from Section 91.151(b), 

specific to UAV, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138). These 

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 UAV are considered. 

 9. Reasons Why An Exemption From The Requirements Of Section 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, RainierDrones.com LLC submits that an 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 RainierDrones.com LLC and the 

manufacturers of each aircraft, will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAV using the 

methods, techniques, and practices prescribed in the manufacturer’s 

maintenance manual. Furthermore, RainierDrones.com LLC will document and 

maintain all maintenance records for each of the individual aircraft. 

Since each UAV will be inspected as prescribed by the manufacturer’s 

maintenance manual, RainierDrones.com LLC will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 

Additionally, the FAA has previously granted relief from Section 91.151(b), specific to 

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

Exemption Nos. 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

11138). These 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 UAV are considered. 

Page 21 of 22
 F. Summary That Can Be Published In The Federal Register. 

The Rules From Which RainierDrones.com LLC Seeks Exemption: 

RainierDrones.com LLC seeks exemption from the requirements of 14 C.F.R. 

Sections 61.113(a), 91.7(a), 91.119(c), 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 RainierDrones.com LLC 

Seeks: 

This exemption will permit RainierDrones.com LLC to commercially operate 

Unmanned Aircraft Vehicles for the purpose of conducting photography, outdoor 

videography, property inspections, and agricultural inspections/mapping within 

the United States. 

 G. Any Additional Information, Views, Or Arguments Available To Support 

RainierDrones.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, RainierDrones.com LLC’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 UAV 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 UAV to operate 

without airworthiness certification. 

As discussed in detail above, RainierDrones.com LLC will operate the specified 

UAV’s 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, RainierDrones.com LLC seeks an exemption pursuant to 14 C.F.R. 

Section 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the 3D Robotics Solo UAV’s commercially, 

without an airworthiness certificate, for the limited purpose of conducting photography, 

outdoor videography, property inspection, and agricultural inspection/mapping within 

the stated operational guidelines. 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 RainierDrones.com LLC to 

safely, efficiently, and economically operate these UAV’s commercially within the NAS. 

Page 22 of 22