UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Darrick J. Pemberton

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

14 C.F.R §§ 61.23(a), 61.101(34) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 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), CONCERNING COMMERCIAL

OPERATION OF 3DR SOLO AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on August 25, 2015 

Darrick J. Pemberton

6261 Gillespie Street

Philadelphia, PA 19135

215 439 8888
1

Table of Contents

GLOSSARY OF ABBREVIATIONS .................................................................................................................... 2

SUMMARY............................................................................................................................................................ 3

INTRODUCTION AND INTERESTS OF THE PETITIONER............................................................................ 3

BACKGROUND .................................................................................................................................................... 3

BASIS FOR PETITION ......................................................................................................................................... 3

NameAnd Address Of The Petitioner. .................................................................................................................... 5

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption. .................................................... 5

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief........................................... 7

The Reasons Why Granting Applicant Request Would Be In The Public Interest; That Is, How It Would Benefit 

The Public As A Whole. ......................................................................................................................................... 9

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

Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Applicant Seeks 

Exemption............................................................................................................................................................. 10

CONCLUSION..................................................................................................................................................... 17

EXHIBIT A........................................................................................................................................................... 18

EXHIBIT B........................................................................................................................................................... 19
2

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
3

SUMMARY

Darrick J. Pemberton (Applicant) seeks exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.101(34) 

61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 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), to operate an Unmanned Aircraft System pursuant to Section 333 of 

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

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of 

to be used in television commercials, weather traffic and news reports, and sporting events over certain areas of 

the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Darrick J. Pemberton, I am 43 years old Certified Microsoft Systems Engineer. I work for Morgan 

Lewis and Bockius in Princeton, NJ and have been with the firm for over 10 years. I am also an avid 

photographer with over 20 years’ experience in all aspects of photography and see the need for new technology

to improve quality, reduce costs, and help provide a new viewpoint from traditional photography mediums.

I wish to provide high quality imaging for a variety of commercial and public uses, specifically targeting:

 Aerial Survey

 Commercial Photography

 Management of Construction Progress.

 Site Health and Safety Plan inspections

 Insure implementation of Environmental Controls such as storm water discharge requirements and 

pollution prevention mitigation

 Inspections of Commercial Real Estate

BACKGROUND

Unmanned Aircraft Systems: 3DR Solo, DJI Inspire 1 UASs

Applicant seeks an exemption to operate 3DR and DJI systems for compensation or hire within the NAS. The 

3DR Solo and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The 3DR Solo has a maximum gross 

weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 

inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 

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

of approximately 42 knots. The 3DR Solo and DJI Inspire 1UAs are equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors. 

The 3DR Solo and DJI Inspire 1 UAs that will be operated by Applicant will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Applicant, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the 

FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned 

Aircraft Systems, hereby petitions the Administrator to commercially operate the 3DR Solo, DJI Inspire 1 UASs 

in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.23(a), 

61.101(e4) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 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).
4

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

its operation, Applicant operation of 3DR Solo and DJI Inspire 1 UASs 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, Applicant requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an 

airworthiness certificate. 

Applicant submits that the requested relief is proper since an equivalent level of safety will be ensured. 

Applicant will use experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents 

(i.e., Monthly Maintenance Log, and 3DR Solo and DJI Inspire 1 Instruction Manual). Furthermore, Applicant

will document and maintain all maintenance records for the 3DR Solo and DJI Inspire 1 UASs. 

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

Pilot in command, is requested by Applicant 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 3DR Solo

and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency 

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

Applicant seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 3DR Solo and DJI 

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Applicant submits that he will ensure that the 3DR Solo and DJI Inspire 1UASs are in an airworthy 

condition, prior to every flight, by determining that the UASs are in compliance with the operating documents 

(i.e., Monthly Maintenance Log, and 3DR Solo and DJI Inspire 1 Instruction Manual), and that the aircraft are 

in a condition for safe flight. 

Applicant also seeks an exemption from the requirements of Section 91.119 (c), entitled Minimum Safe 

Altitudes: General, as the 3DR Solo and DJI Inspire 1 UAs operate at low altitudes of 400 feet or less.

Applicant also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the 

3DR Solo and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude 

information of the 3DR Solo and DJI Inspire 1UAs 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 Applicant’s operation of the 3DR 

Solo and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, Applicant seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Applicant submits that safety will not be affected by operation of the 

3DR Solo and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual 

flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Applicant provides the following information in support of its petition for 

exemption:
5

NameAnd Address Of The Petitioner. 

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

Darrick J. Pemberton

6261 Gillespie Street

Philadelphia, PA 19135

215 439 8888

Email: darrick.pemberton@gmail.com

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption. 

Applicant Seeks Exemption From The Requirements Of Section 61.23(a). Medical certificates: 

Requirement and duration. 

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section.

Applicant Seeks Exemption From The Requirements Of Section 61.101(e4) Recreational pilot privileges 

and limitations.

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in 

command of an aircraft— 

(iv) With retractable landing gear;

Applicant Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

prescribe the following, in relevant part: 

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

carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft. 

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

employment if—

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

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

Applicant Seeks Exemption From The Requirements Of Section 315 (a).

61.315 What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as 

specified in paragraph (c) of this section.

Applicant Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

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

Applicant Seeks Exemption From The Requirements Of Section 91.119 (c). 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:
6

Applicant Seeks Exemption From The Requirements Of Section 91.121. 

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

Applicant Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 

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

weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 20 minutes. 

Applicant Seeks Exemption From The Requirement Of Section 91.405(a).

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

an aircraft—

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

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 

43 of this chapter[.] 

Applicant Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

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

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

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

alteration unless--

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

Applicant Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

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

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

preceding 12 calendar months, it has had --

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

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

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

Applicant Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

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

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

shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, 

progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) 

and each engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 
7

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

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

specified time basis. 

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

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

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

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

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

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

currently installed engines, rotors, propellers, and appliances. 

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

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

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

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

the time the aircraft is sold. 

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

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

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.23(a). 

Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as 

provided in paragraphs (b) and (c) of this section. The PIC will not be operating a aircraft which is capable of 

carrying passengers or the pilot. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.101(e4). 

61.101 Recreational pilot privileges and limitations. (e) Except as provided in paragraphs (d) and (i) of this 

section, a recreational pilot may not act as pilot in command of an aircraft— (iv) With retractable landing gear;

as the DJI Inspire 1 has retractable landing gear which is integral to the operation of the camera. The landing 

gear lifts to allow 360 degree rotation of the camera without interference by the landing gear. This operation is 

ultimately safer than rotating the entire DJI Inspire 1 do the simplification of the rotation process.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 61.113(a) And (b). 

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

requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a 

current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to 

conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, 

for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The 

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

property for compensation or hire. 

As set forth more fully below, Applicant submits that an equivalent level of safety will be maintained because 

no PIC will be allowed to operate the 3DR Solo UAS or DJI Inspire 1 UAS unless that PIC has met certain 

flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the 3DR Solo

or DJI Inspire 1 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.
8

Further, Applicant submits that all flights of the 3DR Solo and DJI Inspire 1 UASs, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Applicant's business; and (2) will not carry 

passengers or property for compensation or hire. 

Extent Of Relief Applicant Seeks And The Reason Applicant 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 

Applicant to determine that the 3DR Solo and DJI Inspire 1 UASs are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Applicant Aerial 

Operations Manual, Monthly Maintenance Log, and 3DR Solo and DJI Inspire 1 Instruction Manual). 

Applicant seeks the requested relief because the 3DR Solo and DJI Inspire 1 UASs do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Applicant will ensure that 

the 3DR Solo and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and 3DR Solo and DJI Inspire 1 Instruction Manual) prior to every

flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.119 (c). 

Relief from Section 91.119 (c), entitled Minimum Safe Altitudes: General, as the 3DR Solo and DJI Inspire 1 

UAs operate at low altitudes of 400 feet or less.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 3DR 

Solo and DJI Inspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), Applicant seeks the requested relief 

because the 3DR Solo and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than 

the local barometric pressure or field altitude, before each flight. 

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

necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, 

an equivalent level of safety will be maintained since the 3DR Solo and DJI Inspire 1 UAs are equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS. 

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From Section 91.151(b). 

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

required to allow flights of the battery powered 3DR Solo and DJI Inspire 1 UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

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

duration of the battery powered 3DR Solo and DJI Inspire 1 UAs will severely constrain the practicality of any

aerial video or still photo flight operations that Applicant proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the 3DR Solo and DJI Inspire 1 UASs, the 3DR 

Solo and DJI Inspire 1 operating documents, and Applicant’s proposed operating limitations, ensure that 

Applicant will safely operate the battery powered 3DR Solo and DJI Inspire 1 UAs during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes.
9

Extent Of Relief Applicant Seeks And The Reason Applicant 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, Applicant requests relief from these Sections because the 3DR Solo and DJI Inspire 1 

UASs do not require airworthiness certificates. As set forth more fully below, the 3DR Solo and DJI Inspire 1 

UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly,

Applicant 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 

Applicant Aerial Operations Manual, Monthly Maintenance Log, and 3DR Solo and DJI Inspire 1 Instruction 

Manual). Furthermore, Applicant will document and maintain all maintenance records for the 3DR Solo and 

DJI Inspire 1 UASs. 

The Reasons Why Granting Applicant Request Would Be In The Public Interest; That Is, How It 

Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Applicant to safely, efficiently, and 

economically perform aerial video and photography of construction sites, real estate, and landscape over certain 

areas of the United States. 

Additionally, use of the 3DR Solo and DJI Inspire 1 UAS’s will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Applicant’s proposed 

operation of the 3DR Solo and DJI Inspire 1 UAS’s will be realized without implicating any privacy issues. 

The Public Will Benefit From Decreased Congestion Of The NAS. 

The 3DR Solo and DJI Inspire 1 UAs 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 3DR Solo or DJI 

Inspire 1 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 and DJI Inspire 1 UAs 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, arrival, and landing phases of flight operations.

The Public Will Benefit From The Safety And Efficiency Of The 3DR Solo and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the 3DR Solo and DJI Inspire 1 UASs, instead of manned aircraft, will 

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

traditional aerial video and still photography flight operations. By using battery power and electric motors, the 

3DR Solo and DJI Inspire 1 UASs 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 20-30 gallons per hour of leaded aviation fuel. The 3DR 

Solo and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise 

pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the 3DR Solo and DJI Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and 

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

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the 3DR Solo and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces 

and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 

inches respectively, widths of 16 inches and 17.7 inches respectively, 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 approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 
10

Performing Aerial Video and Photography Operations With The 3DR Solo and DJI Inspire 1 UASs Will 

Benefit The Economy. 

In addition to being safe and efficient, the 3DR Solo and DJI Inspire 1 UASs are also an economical alternative 

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

Inspire 1 UASs will allow United States based companies, like Applicant, to remain competitive and contribute 

to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. Operating the battery

powered 3DR Solo and DJI Inspire 1 UASs is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without the high operational 

cost of a traditional manned aircraft. 

By operating the 3DR Solo and DJI Inspire 1 UASs, companies such as Applicant, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the 3DR Solo and DJI Inspire 1 UASs, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad. 

There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Applicant’s 

proposed operation of the 3DR Solo and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, 

the 3DR Solo and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the 

Applicant Aerial Operations Manual, Monthly Maintenance Log, and 3DR Solo and DJI Inspire 1 Instruction 

Manual) which requires property owner involvement as well as local law enforcement notification, and in 

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

91.119. 

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

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

Which Applicant Seeks Exemption. 

Reasons Why The 3DR Solo and DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333. 

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

its operation, Applicant’s operation of the 3DR Solo and DJI Inspire 1 UASs 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 UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: 

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

date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this Act. 

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

Secretary shall determine, at a minimum--

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

capability, proximity to airports and populated areas, and operation within visual line of sight do not create a 

hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 

44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1). 
11

(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, Applicant submits that the 3DR Solo and DJI Inspire 1 UASs can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3DR Solo and DJI 

Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The 3DR Solo and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.

The 3DR Solo and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise 

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

i. Technical Specifications Of The 3DR Solo and DJI Inspire 1 UASs. 

The technical specifications of the 3DR Solo and DJI Inspire 1 UASs are set forth by the 3DR Solo

and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B. 

ii. The 3DR Solo and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The 

UASs To Remain Within A Defined Operational Area. 

The 3DR Solo and DJI Inspire 1 UASs may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the 3DR Solo and DJI Inspire 1 

UASs is provided at pages 19-30 and 36-38 of the 3DR Solo and pages 12-16 and 45-50 of the DJI 

Inspire 1 User Manuals, attached hereto as Exhibit C and D. 

iii. The 3DR Solo and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the 3DR Solo and DJI Inspire 1 UAs will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the 3DR Solo and DJI Inspire 1 UAs do 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 the Failsafe Functions of the 3DR Solo UAS are set forth at pages 19

through 21 and for the DJI Inspire 1 at pages 13 through 15 of the 3DR Solo and DJI Inspire 1 User 

Manuals, attached hereto as Exhibit C and D. 

iv. The 3DR Solo and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the 3DR Solo and DJI Inspire 1 GCS and 

flight control software is provided at page 49 of the 3DR Solo User Manual and pages 40 through 47 

of the DJI Inspire 1 User Manual. 3DR Solo and DJI Inspire 1 User Manuals are attached hereto as 

Exhibits C and D. 

b. Flight Operations Of 3DR Solo and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Applicant will only utilize certificated pilots who possess a current and valid airman medical certificate to act as 

a pilot in command (PIC) of the 3DR Solo and DJI Inspire 1 UASs. Additionally, a safety observer will assist 

all pilots during flight time. 

c. Flights Of 3DR Solo and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, Applicant proposes to commercially operate 3DR Solo and DJI Inspire 1 UASs for 

the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations:

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

in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: 

3DR Solo and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft 

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

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

aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.
12

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be in feet AGL. 

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

the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified 

on the PIC’s FAA-issued airman medical certificate. 

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

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

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

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

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

the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the 

operating documents. 

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

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

other instruments. 

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

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

limitations contained in the grant of exemption and the procedures outlined in the operating documents, 

the conditions and limitations contained in the grant of exemption take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. It is the operator’s responsibility to track 

such revisions and present updated and revised documents to the Administrator upon request. The 

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

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

upon which the FAA granted the exemption, then the operator must petition for amendment to its grant 

of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operating documents. 

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

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

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

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

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

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

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

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

replacement, inspection, and life limit requirements. 

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

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in

service, description of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

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

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

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 
13

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

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the 

UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes 

of training the operator’s PICs are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 C.F.R. § 91.119. 

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

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

special request will be made at the FAA office closest to proposed area of operations. Flights under 

special visual flight rules (SVFR) are not authorized. 

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

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

is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s 

COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request. 

21. 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. 

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

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

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

with the operating documents. 

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

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

land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

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

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

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

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

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

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

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

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

activities at all times. 

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

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

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: 

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

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

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

and are within 500 feet of the UA, flight operations must cease immediately and/or; 
14

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

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

risk of operating closer to those objects and determined that it does not present an undue hazard, and; 

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

hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted.

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

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely 

Affect Safety.

Applicant submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained 

because no PIC will be allowed to operate the 3DR Solo and DJI Inspire 1 UASs unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate 

the 3DR Solo or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

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

Considering Applicant’s proposed area of operations, and the operating limitations set forth-above; the parallel 

nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the 3DR Solo or DJI Inspire 1 

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

would not correlate to the airmanship skills necessary for Applicant’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Applicant will not allow any PIC to operate the 3DR Solo or DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the 3DR Solo or DJI Inspire 1 UAS training 

and currency requirements, that the PIC is able to safely operate the 3DR Solo or DJI Inspire 1 UAS in a 

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

appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 

hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption). In addition to the 

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

purposes). 

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

compliance with applicable regulations will ensure an equivalent level of safety during Applicant’s proposed 

operations. The Administrator has held that prior documented flight experience that was obtained in compliance 

with applicable regulations would ensure safe operations, stating as follows: 

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

picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 

14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to 

be used for operations under the exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 

hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In 

addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days 

(for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 

11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s 

proposed operations. The FAA also finds that prior documented flight experience that was obtained in 

compliance with applicable regulations would satisfy this requirement.
15

Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is 

required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Applicant will ensure safe operations by not allowing any PIC to operate the 3DR Solo or DJI 

Inspire 1 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 or DJI Inspire 1 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety. 

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

Applicant will ensure that the 3DR Solo or DJI Inspire 1 UAS is in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. 

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

Reasons Why An Exemption From The Requirements Of Section 91.119 (c) and91.121 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Sections 91.119 (c) and 91.121 will be maintained because the 

altitude information of the 3DR Solo and DJI Inspire 1 UAs will be provided to the PIC via GPS equipment and 

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

the flight path and altitude. This altitude information, combined with Applicant’s operation of the 3DR Solo and 

DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent 

to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. 

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

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect 

Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) 

as a result of (1) the technical specifications of the 3DR Solo and DJI Inspire 1 UASs; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Applicant will 

ensure that it will safely operate the battery powered 3DR Solo and DJI Inspire 1 UAs during daylight hours in 

VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of 

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

Here, as in Exemption No. 11109, the technical specifications of the 3DR Solo and DJI Inspire 1 UASs; the 

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

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 

3DR Solo and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% remainin g battery power, and 

again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom 

Vision+ and DJI Inspire 1 UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not 

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

Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from 

Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

Reasons Why An Exemption From The Requirements Of Sections
16

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, Applicant submits that the equivalent level of safety with regard to the regulatory 

maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b) will be met because Applicant will use trained technicians to perform maintenance, 

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

the operating documents (i.e., the Applicant Aerial Operations Manual, Monthly Maintenance Log, and 3DR 

Solo and DJI Inspire 1 Instruction Manual). Furthermore, Applicant will document and maintain all 

maintenance records for the 3DR Solo and DJI Inspire 1 UASs. 

Since the 3DR Solo and DJI Inspire 1 UASs will be inspected as prescribed by the operating documents, 

Applicant will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the 3DR Solo and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D; a 

copy of the 3DR Solo and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Applicant will use trained technicians 

to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 

91.417(a) and 91.417(b), because all maintenance of the 3DR Solo and DJI Inspire 1 UASs will be performed 

by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. 

In consideration of Applicant’s proposed operating limitations, the operating documents, and the technical 

aspects of the 3DR Solo and DJI Inspire 1 UASs, Applicant submits that safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and 

(b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to 

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

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 

21.16 entitled Special Conditions, Applicant requests that the FAA prescribe special conditions for the intended 

operation of the 3DR Solo and DJI Inspire 1 UASs, which contain such safety standards that the Administrator 

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of 

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

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the 3DR Solo and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. 

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

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

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

safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the 

aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards 

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

to that established in the regulations. 
17

See 14 C.F.R. § 21.16.

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

conditions for the Applicant intended operation of the 3DR Solo and DJI Inspire 1 UASs, which contain such 

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

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

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

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

Applicant Seeks Exemption: 

Applicant seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 

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

A Brief Description Of The Nature Of The Exemption Applicant Seeks: 

This exemption will permit Applicant to commercially operate an Unmanned Aircraft System (UAS) for the 

purpose of conducting aerial video and photography over certain areas of the United States.

 Any Additional Information, Views, Or Arguments Available To Support Applicant’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, Applicant’s request for exemption may be granted pursuant to the authority of 

FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification. 

As discussed in detail above, Applicant will operate the 3DR Solo and DJI Inspire 1 UASs 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, Applicant seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3DR Solo and DJI 

Inspire 1 UASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator 

will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing Applicant to safely, efficiently, and economically operate the 

3DR Solo and DJI Inspire 1 UASs commercially within the NAS. 

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

Act of 2012, Section 333, Applicant 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 the Applicant to operate the 3DR Solo and 

DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over certain areas 

of the United States.

Respectfully submitted,

Darrick J. Pemberton

6261 Gillespie Street

Philadelphia, PA 19135

darrick.pemberton@gmail.com

215 439-8888
18

EXHIBIT A

SOLO – TECHNICAL SPECS

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4

Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

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

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10′′ diameter 4.5′′ pitch self-tightening (24 cm diameter 144 cm pitch); glass-reinforced nylon

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or laters.

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skill. 

Listed flight time applies to elevations less than 2,000 ft above sea level.

**Depending on environmental conditions; controller is expandable, allowing us or third parties to amp up the 

range in the future.

Solo Smart Battery:

Rechargeable lithium polymer (Li-Po)

5200 mAh

14.8 Vdc

Weight: 1 lb. (.5 kg)

Solo Gimbal:

Three-axis stabilization

Fully compatible with 3DR Solo and GoPro HERO3+ and HERO4; camera charging and stabilization only with 

HERO3

HDMI video output

Wireless software upgrade through Solo

Controllable range: 0° to -90° pitch
19

EXHIBIT B

INSPIRE 1 – TECHNICAL SPECS

Aircraft

Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range
20

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Gimbal

Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size
21

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller

Name

C1

Operating Frequency
22

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger

Model

A14-100P1A

Voltage

26.3 V

Rated Power
23

100 W

Battery (Standard)

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional)

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V
24

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Positioning

Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

DJI GO App

Mobile Device System Requirements

iOS 8.0 or later, Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad maini 2, iPad 

mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. 

This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

* Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google 

Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as testing and development continues.