1 

### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATIONADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOREXEMPTION OF:

Ian Ryan & Associates, Inc. FORAN 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 600182



### TABLE OF CONTENTS GLOSSARY OF ABBREVIATIONS..................................................................................3 SUMMARY...........................................................................................4 INTRODUCTION AND INTERESTS OF PETITIONER

.................................4 BACKGROUND.................................................................................4 BASIS FORPETITION............................................................................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, ORARGUMENTS AVAILABLE TO SUPPORT Ian Ryan & Associates, Inc. ’S REQUEST........................................23 CONCLUSION........................................................................................24



### 3DR Solo OPERATION MANUAL IS ATTACHED

GLOSSARY OF ABBREVIATIONS3

AGL Above Ground Level AOI Area ofInterest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code ofFederal Regulations COA Certificate ofAuthorization FAA Federal AviationAdministration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss ofLink NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization andReformAct of2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA UnmannedAircraft UAS UnmannedAircraft System VFR Visual FlightRules VLOS Visual Line ofSite VMC Visual Meteorological Conditions VTOL Vertical Takeoffand Landing



### SUMMARY4



### 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 pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit Ian Ryan & Associates, Inc. to operate an Unmanned Aircraft System (UAS) forthe commercial purpose ofconducting aerial video and photography of real estate and landscapes over certain areas ofthe United States. 

### INTRODUCTION AND INTERESTS OF THE PETITIONER Ian Ryan & Associates, Inc. provides its clients with photography and videography of properties forthe purpose ofdisplaying 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, specificallytargeting:

• Golfcourse and similar sports facilityflyovers for display on websites and marketing materials • Real

-estate inspections of property under construction, for sale, orto 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 takeoffand 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 ofapproximately42 knots. The 3DR Solo UA is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 

### BASIS FORPETITION Petitioner, Ian Ryan & Associates, Inc. pursuantto the provisions ofthe 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 Administratorto 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 ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Ian Ryan & Associates, Inc.'s operation of3DR 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 relieffrom 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 applyto aircraft with an airworthiness certificate. Ian Ryan & Associates, Inc. submits that the requested relief is proper since an equivalent level ofsafetywill 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 forthe 3DR Solo UAS. Relieffrom certain requirements ofSection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Ian Ryan & Associates, Inc. to the extent necessaryto 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 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 relieffrom 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, priorto everyflight, by determiningthat 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 ofSection 91.121, entitled Altimeter Settings, as the 3DR Solo UA will not have a typical barometric altimeter on board. However, altitude information ofthe 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 UAto the GCS for active monitoring ofthe flight path. This altitude information, combined with Ian Ryan & Associates, Inc.'s operation ofthe 3DR Solo UAS is within visual line ofsight, at or below 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, Ian Ryan & Associates, Inc. seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel requirements forflight in VFR conditions. Ian Ryan & Associates, Inc. submits that safetywill not be affected by operation ofthe 3DR Solo UA during daylight hours in visual meteorological conditions (VMC)6

undervisual flight rules (VFR), with enough battery powerto flyfor a total duration of approximately 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthat 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 AndAddress OfThe Petitioner. The name and address ofthe Petitioner and point ofcontact is: Laird R. Crawford Ian Ryan & Associates, Inc. 1400 E. TouhyAve. Suite 220 Des Plaines, IL 60018 847
-803
-2050 **B.** The Specific Sections Of14 C.F.R. FromWhich **Ian Ryan**  **& Associates,**  **Inc.** Seeks Exemption. **1. Ian**  **Ryan &**  **Associates, Inc.**  Seeks ExemptionFrom The Requirements OfSection 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) ofan aircraft that is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC ofan 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 propertyfor compensation or hire. **2. Ian**  **Ryan &**  **Associates, Inc.**  Seeks ExemptionFrom The Requirements OfSection 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 ExemptionFrom The Requirements OfSection 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 orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating

-- (1) Below 18,000 feet MSL, to
-- (i) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 4. **Ian Ryan**  **& Associates,**  **Inc.** Seeks ExemptionFrom The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements forflight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 20 minutes. 5. Ian Ryan & Associates, Inc. Seeks ExemptionFrom The Requirement OfSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft
— (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 6. **Ian Ryan**  **& Associates,**  **Inc.** Seeks ExemptionFrom The Requirements OfSection 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 ofthis chapter[.]8

7. Ian Ryan & Associates, Inc. Seeks ExemptionFrom The Requirements OfSections 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) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by a person authorized by § 43.7 ofthis chapter; or (2) An inspection forthe issuance ofan airworthiness certificate in accordance with part 21 of this chapter. 8. **Ian Ryan**  **& Associates,**  **Inc.** Seeks ExemptionFrom The Requirements OfSections 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 forthe periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100
-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (includingthe airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approvingthe aircraft for return to service. (2) Records containingthe following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor.
(ii) The current status of life

-limited parts ofeach airframe, engine, propeller, rotor, and appliance.9

(iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required bythe inspection program under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by § 43.9(d) ofthis chapterfor each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records forthe periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by otherwork orfor 1 year afterthe work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. (c) The Extent OfRelief**Ian Ryan**  **& Associates,**  **Inc.** Seeks And The Reason **Ian Ryan**  **& Associates,**  **Inc.** Seeks The Relief. **1.** Extent OfRelief**Ian Ryan**  **& Associates,**  **Inc.** Seeks And The Reason **Ian Ryan**  **& Associates,**  **Inc.** Seeks Relief**from Section**  **61.113(a) and**  **(b).** Relieffrom Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessaryto 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 ofan 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 propertyfor compensation or hire.10

As set forth more fully below, Ian Ryan & Associates, Inc. submits that an equivalent level of safetywill 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, demonstratingthat 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 ofthe 3DR Solo UAS conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to Ian Ryan & Associates, Inc.'s business; and (2) will not carry passengers or propertyfor compensation or hire. 2. Extent OfRelief**Ian Ryan**  **& Associates,**  **Inc.** Seeks And The Reason **Ian Ryan**  **& Associates,**  **Inc.** Seeks ReliefFrom Section 91.7(a). Relieffrom 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 priorto everyflight 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) priorto everyflight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. 3. Extent OfRelief**Ian Ryan**  **& Associates,**  **Inc.** Seeks And The Reason **Ian Ryan**  **& Associates,**  **Inc.** Seeks ReliefFrom Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe 3DR Solo UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data linkto 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 airtraffic 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, ratherthan the local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessaryto comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafetywill be maintained since the 3DR Solo UA's altitude information will be provided to the PIC via Global Positioning System (GPS) equipment and radio11

communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path. 4. Extent OfRelief**Ian Ryan**  **& Associates,**  **Inc.** Seeks And The Reason **Ian Ryan**  **& Associates,**  **Inc.** Seeks ReliefFrom Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements forflight in VFR conditions, is requested to the extent required to allowflights ofthe battery powered 3DR Solo UA during daylight hours in visual meteorological conditions (VMC), undervisual 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 afterthat 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 ofthe battery powered 3DR Solo UA will severely constrain the practicality ofany 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 ofthe 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), undervisual flight rules (VFR), with enough battery powerto flyfor a total duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 4.5 minutes. 5. Extent OfRelief**Ian Ryan**  **& Associates,**  **Inc.** Seeks And The Reason **Ian Ryan**  **& Associates,**  **Inc.** Seeks ReliefFrom 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 applyto aircraft with an airworthiness certificate, Ian Ryan & Associates, Inc. requests relieffrom 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 recordsforthe 3DR Solo UAS. D. The Reasons Why Granting **Ian Ryan**  **& Associates,**  **Inc.** RequestWouldBe In The Public Interest; That Is, How It WouldBenefit The Public As A Whole.12

Granting the present Petition will furtherthe 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 ofthe United States.
Additionally, use ofthe 3DR Solo UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Ian Ryan & Associates, Inc.'s proposed operation ofthe 3DR Solo UAS will be realized without implicating any privacy issues. 1. The Public Will BenefitFrom Decreased Congestion OfTheNAS. 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 reducingthe amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa 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 takeoffor land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by airtraffic control duringthe ground, takeoff, departure, arrival, and landing phases offlight operations. 2. The Public Will BenefitFrom The SafetyAnd Efficiency OfThe 3DR Solo UAS. Conducting aerial acquisitions with the 3DR Solo UAS, instead of manned aircraft, will greatly benefit the public by drastically reducingthe levels ofair and noise pollution generated during traditional aerial video and still photographyflight 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 ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, ratherthan an internal combustion engine. By using the 3DR Solo UAS to perform aerial acquisitions, the substantial riskto 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 offlight crew members located onboard the aircraft, the 3DR Solo UA (gross weight of6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed ofapproximately42 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 to13

the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately42 feet, a length of 34feet, and a fuel capacity of 180 gallons).

3. PerformingAerial Video andPhotography 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 ofthe 3DR Solo UAS will allow United States based companies, like Ian Ryan & Associates, Inc., to remain competitive and contribute to growth ofthe 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 orderto remain competitive. Operatingthe battery powered 3DR Solo UAS is one such technologythat not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft. By operatingthe 3DR Solo UAS companies such as Ian Ryan & Associates, Inc., can remain competitive and profitable, and therefore, provide greaterjob stabilityto employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through commercial use ofthe 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 orderto remain competitive both in the United States and abroad. 4. There AreNo Privacy Issues. Similarto the manned aerial acquisition flight operations that have been conducted for decades, Ian Ryan & Associates, Inc.'s proposed operation ofthe 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, includingthe minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Granting The ExemptionWouldNotAdverselyAffect Safety, OrHow The ExemptionWouldProvide A Level OfSafetyAt Least Equal To ThatProvidedByThe Rule FromWhich **Ian Ryan**  **& Associates,**  **Inc.** Seeks Exemption. 1. Reasons Whythe 3DR Solo UA Meet The Conditions OfThe FAA Modernization and ReformAct of2012 (FMRA) Section 333.14

In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Ian Ryan & Associates, Inc.'s operation ofthe 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 authorityfor a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe 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 ofthis subtitle, and not laterthan 180 days afterthe date ofenactment ofthis Act, the Secretary ofTransportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rulemaking required by section 332 ofthis Act orthe guidance required by section 334 ofthis Act. (b) Assessment of Unmanned Aircraft Systems.
--In makingthe determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public or pose a threat to national security; and (2) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is required forthe operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- Ifthe Secretary determines underthis section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system. In seekingthis 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 ofthe 3DR Solo UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.
a. The Specifications Ofthe 3DR Solo UAS Demonstrates Its Safe Characteristics. The 3DR Solo UAS does not create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. i. Technical Specifications Ofthe 3DR Solo UAS.15

The technical specifications ofthe 3DR Solo UAS is set forth bythe 3DR Solo User Manual, attached hereto. ii. The 3DR Solo UAS Autonomous FlightAndNavigation Modes Enable The UAS To Remain WithinA Defined Operational Area. The 3DR Solo UAS may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe 3DR Solo UAS is provided in the 3DR Solo User Manual, attached hereto.

iii. The 3DR Solo UAS is DesignedForAutomatic Return To Home Point OrHover In The Event OfLoss OfThe Control Link OrNavigation. 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 ofthe 3DR Solo UAS is provided in the 3DR Solo User Manual, attached hereto. b. Flight Operations Ofthe 3DR Solo UAS is Limited To The Line OfSight OfA Certificated Pilot in CommandWithA Safety Observer. David Smith or a PIC approved by David Smith will be the only persons to act as a pilot in command (PIC) ofthe 3DR Solo UAS. Additionally, a safety observer (SO) will assist in flights.
c. Flights Ofthe 3DR Solo UAS Will Be ConductedPursuant To Specific Operating Limitations. In seekingthis exemption, Ian Ryan & Associates, Inc. proposes to commercially operate the 3DR Solo UAS forthe special purpose ofconducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized bythis grant ofexemption 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 ofany other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations underthis exemption will be limited to conducting operations forthe purpose ofaerial 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 bythe 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 ofsight (VLOS) ofthe PIC at all times. This requires the PICto be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC’s FAA
-issued airman medical certificate. 6. The use offirst person view (FPV) bythe PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfythe 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 ortexting is not permitted during flight

operations. The PIC must be designated before the flight and cannot transfer his or her designation forthe duration ofthe 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 assistingthe PIC with seeing and avoiding other airtraffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must followthe procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibilityto 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 ofexemption. Ifthe 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 ofexemption. The FAA’s UAS Integration Office (AFS

-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 10. Priorto each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe 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 ofa 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 ofthe operating documents. 13. The operator must followthe 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, includingtotal time in service, description ofwork accomplished, and the signature of the authorized person returningthe UAS to service. 15. Each UASs operated underthis exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The operator may not permit any PICto operate unless the PIC meets the operator’s qualification criteria and demonstrates the abilityto safely operate the UAS in a manner consistent with howthe UAS will be operated underthe 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 forthe purposes oftraining the operator’s PICs are permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience

-building flights, all persons not essential forflight 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 undervisual meteorological conditions (VMC). Ifflight 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 ofan airport reference point as denoted on a current FAA
-published aeronautical chart unless a letter ofagreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as18

required bythe operator’s COA. The letter ofagreement 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. Ifthe 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 powerto fly at normal cruising speed to the intended landing point and land the UAwith 25% battery power remaining. 24. The UA will remain clear and give wayto all manned aviation operations and activities at all times. 25. The UA will not be operated bythe PICfrom any moving device orvehicle.

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 ofthe UA must complywith the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewerthan 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS anytime 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 ofwayto all manned aviation operations and activities at all times. 30. The UAS may not be operated bythe PICfrom any moving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthan the PIC, SO, operatortrainees 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 ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons19

leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present an undue hazard, and;
c. Operations nearerto the PIC, SO, operatortrainees 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 propertywith 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, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined bythe 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 WhyAn ExemptionFrom The Requirements OfSection 61.113(a) And (b) Would NotAdverselyAffect Safety

. Ian Ryan & Associates, Inc. submits that the equivalent level ofsafety established bySection 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 ofoperations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessaryto safely operate the 3DR Solo UAS, Ian Ryan & Associates, Inc. submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessaryfor Ian Ryan & Associates, Inc.'s specific proposed flight operations. The FAA has previously granted relieffrom Section 61.113(a) and (b) specificto 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 PICto operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flight

-hour requirements orthe 3DR Solo UAS training20

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 oftotal time as a UAS rotorcraft pilot (with a minimum of 5 hours ofthose hours as a UAS pilot operatingthe same make and model of UAS to be used for operations underthe 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 ofsafety 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 priorto conducting operations forthe 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 oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

-rotor UAS. Priorto operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operatingthe same make and model of UAS to be used for operations underthe exemption. For clarification, the FAA

considers these minimum hour requirements to be inclusive ratherthan additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

-rotortime 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 FAAfinds that at a minimum, the flight

-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessaryto 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 satisfythis requirement. Training, proficiency, and experience

-building flights can also be conducted under the grant ofexemption to accomplish the required flight time. Duringtraining, proficiency, and experience

-buildingflights 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 PICto 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 WhyAn ExemptionFrom The Requirements OfSection 91.7(a) WouldNot AdverselyAffect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because priorto everyflight, 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 relieffrom 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 WhyAn ExemptionFrom The Requirements OfSection 91.121 WouldNot AdverselyAffect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe 3DR Solo UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with Ian Ryan & Associates, Inc.'s operation ofthe and 3DR Solo UAs within visual line ofsight, at or below 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiation point is automatically established bythe UASs at ground level.

The FAA has previously granted relieffrom Section 91.121 specificto 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 WhyAn ExemptionFrom The Requirements OfSection 91.151(b) WouldNot AdverselyAffect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications ofthe 3DR Solo UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe 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 powerto flyfor a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthatfor at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe 3DR Solo UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore,22

safetywill be ensured as the 3DR Solo UAS provides audible and visual warnings to the PIC at the GCS when the UA experiences low batteryvoltage, 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 bythe 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 relieffrom 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 WhyAn ExemptionFrom The Requirements OfSections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) WouldNotAdverselyAffect Safety. In seekingthis exemption, Ian Ryan & Associates, Inc. submits that the equivalent level ofsafety 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 usingthe 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 forthe 3DR Solo UAS
. Since the 3DR Solo UAS will be inspected as prescribed bythe operating documents, JOHN 21 PENNICK will maintain the equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe 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 usingthe methods, techniques, and practices prescribed bythe operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe 3DR Solo UAS will be performed bytrained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log
.23

Significantly, previous exemptions granted bythe 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 ofthe UAS are considered. In consideration of Ian Ryan & Associates, Inc.'s proposed operating limitations, the operating documents, and the technical aspects ofthe 3DR Solo UAS, Ian Ryan & Associates, Inc. submits that safetywill not be adversely affected bygranting 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 reliefspecific 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 MayPrescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe 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 forthe intended operation ofthe 3DR Solo UAS which contain such safety standards that the Administratorfinds necessaryto establish a level ofsafety 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 ofthe UAs forthe limited purpose ofconducting aerial video and photography over certain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authorityfor such UAS to operate without airworthiness certification in accordance with any requirements that must be established forthe safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation ofthe 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: Ifthe FAAfinds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto forthe product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards forthe aircraft, aircraft engine or propeller as the FAAfinds necessaryto establish a level ofsafety 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 ofthe 3DR Solo UAS, which contain such safety standards that the Administratorfinds necessaryto establish a level ofsafety 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 SummaryThat Can Be Published In The Federal Register, stating: The Rules FromWhich **Ian Ryan**  **& Associates,**  **Inc.** Seeks Exemption: Ian Ryan & Associates, Inc. seeks exemption fromthe requirements of14 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 BriefDescription OfTheNature OfThe Exemption **Ian Ryan**  **& Associates,**  **Inc.** Seeks: This exemptionwill permit Ian Ryan & Associates, Inc. to commerciallyoperate anUnmanned Aircraft System (UAS) forthe purpose ofconducting aerial video andphotographyover certain areas ofthe United States.

•Any AdditionalInformation,Views,OrArgumentsAvailableToSupport**Siteswork.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 ofTransportation to determine ifcertain 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 ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authorityfor 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 ofthe NAS, orthe 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 ofthe FAA Modernization and Reform Act of 2012 (FMRA), which will25

permit safe operation ofthe 3DR Solo UAS commercially, without an airworthiness certificate, forthe limited purpose of conducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAAAdministrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of 2012, while also advancing the interests ofthe 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 forthe purpose ofconducting aerial video and photography over certain areas ofthe United States. Dated: June 22, 2015 Respectfully submitted, Laird R. Crawford Ian Ryan & Associates, Inc. 1400 E. TouhyAve. Suite 220 Des Plaines, IL 60018 847
-803
-2050 3DR Solo Information: The 3DR Solo user manual is a pdfthat 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/