APPENDIX A

RE: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations – APPENDIX TO REQUEST FOR EXEMPTION (DOCUMENT ID: FAA-2007-

0001-0001 TRACKING NUMBER: 1JZ-8KYN-4HFQ)

This appendix serves to provide additional supporting information and documentation to the request

submitted by Taylor Thomas on September 5th, 2015. The aforementioned request is Document ID:

FAA-2007-0001-0001 with Tracking Number: 1jz-8kyn-4hfq. 

Please include the information below in the consideration for approval of the request for exemption

under Section 333.

I. ● 14 C.F.R. 21 

This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we

then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for

airworthiness certificate in general, citing the fact that the UAV does not carry persons, fuel,

and is small an lightweight which supports the statement that the UAV is as safe or safer than a

conventional manned aircraft operating for the same purposes.

● 14 C.F.R 45.23 and 14 C.F.R 45.29

It is outline in these sections that an aircraft must display "N" and the aircraft's number in letters

be at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL"

in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. Since it

has been requested that the UAV be exempted from 14 C.F.R 21, these requirements and other

formatting requirements would not be necessary.

● 14 C.F.R. 61.3 

This section describes the need for the Pilot in Command (PIC) to keep the pilot certificate

readily accessible in the aircraft when exercising the privileges of that pilot certificate or

authorization. However, since the UAV is unmanned and the UAV is too small to hold a pilot

certificate, it is requested that this requirement be exempted for the Solo UAV.

● 14 C.F.R. 61.113(a)&(b) 

Private pilots are limited to non-commercial operations. Taylor Thomas can achieve an

equivalent level of safety as achieved by current Regulations. Taylor Thomas, the PIC, currently

possesses a Private Pilot License (No. 3414817) and will possess a current FAA Third Class

Medical at time of commercial operation of the UAV. Taylor Thomas will meet the flight review

requirements specified in 14 CFR 61.56.

● 14 C.F.R. 91.7(b) 

The PIC will be responsible for determining if the UAV is in safe condition for operation, and

will adhere to the requirements laid out in 14 C.F.R 91.7 (b) with the additional consideration

that the UAV is operational without a PIC onboard the aircraft. Therefore, the requirements that

the “pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or

structural conditions occur” will occur outside of the aircraft using a combination of manual and

automated responses, as the UAV is not capable of carrying the PIC and possesses capabilities
to detect errors in conjunction with PIC.

● 14 C.F.R. 91.9(b)(2) 

This section describes the requirement to have, within the aircraft, an approved Airplane or

Rotorcraft manual, approved manual material, markings, and placards, or any combination

thereof.” Since the UAV is too small to physically contain these aforementioned items, they will

be kept in a location outside of the UAV that is accessible to the PIC. 

● 14 C.F.R. 91.109(a) 

This section describes the requirement for a set of fully functioning dual controls for flight

instruction. Since the UAV does not have on-board controls, and is operated using onboard

automated technology, it is not feasible for redundant controls to be present. However, should

the UAV be used for flight instruction, a flight simulator will be used prior to physical flights.

Also, Taylor Thomas will remain the PIC for any potential flights.

● 14 C.F.R. 91.119 

This section describes the minimum safe altitudes for flights. As the UAV is significantly

smaller than a traditional manned aircraft, these requirements are not applicable. However, the

UAV will be operated in a manner that is safe in adherence with 14 C.F.R 91.119 (a). As the

maximum allowable altitude requested in this exemption is below the minimums listed, Taylor

Thomas requests exemption from 14 C.F.R 91.119.

● 14 C.F.R. 91.151(a) 

This section describes the fuel requirements for VFR daytime and night time flights. Since the

maximum flight duration of the UAV (up to 25 minutes) is less than the flight times listed (30

minutes for VFR day, 45 minutes for VFR night), Taylor Thomas requests exemption from this

requirement.

● 14 C.F.R. 91.203(a)&(b) 

This section describes the requirement for a valid airworthiness certificate and registration be

located in the cabin of the aircraft unless a special use permit is displayed. It is requested that

the UAV not require an airworthiness certificate, and the fact that there is no cabin to contain

the items listed in this section, it is requested that Taylor Thomas be exempted from this

requirement for commercial operation of the Solo UAV.

● 14 C.F.R. Subpart E (91.401-417) 

It is requested that Taylor Thomas be exempted from this section for commercial operation of

the 3DR Solo UAV. Taylor Thomas will complete all authorized component replacements as

deemed required for operation of UAV. The manufacturer will complete any maintenance or

repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post

flight and maintenance procedures should provide an acceptable level of safety for the

operations performed and is consistent with those of previous grants. A maintenance logbook

will be kept up to date and will be physically located with the PIC during operation of the UAV.

II. UAV TECHNICAL INFORMATION

Smart Battery The battery connects to Solo’s battery bay. Solo’s power button is located on the

battery; Solo can only be powered when the battery is connected.

Motors and Propellers Solo’s arms are labeled one through four on the ends of the arms. Motors
on arms #1 and #2 spin counterclockwise and use clockwise-tightening propellers with silver

tops. Motors on arms #3 and #4 spin clockwise and use counterclockwise-tightening propellers

with black tops.

Orientation LEDs Each arm contains an LED for ground-to-air directional awareness; when

armed for flight, the two front arms (#1 and #3) display white, and the two rear arms (#2 and

#4) display red. This LED scheme mimics the headlight and taillight style of a car. 

Fixed Camera Mount and HDMI Cable Solo includes a GoPro® The Frame fixed mount to

mount a GoPro® HERO camera. The HDMI cable connects to the GoPro® to output video

during flight.

Operating Parameters: The following operating parameters apply to Solo. Always operate Solo

within these parameters. Solo’s performance and behaviors may vary significantly conditions

violate the parameters listed below. 

Estimated flight time up to 25 minutes

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

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

Payload capacity 1 lb. (450 g) 

Cruise speed 18 mph (8 m/s) 

Maximum speed 33 mph (15 m/s)

Wind speed limitation 25 mph (11 m/s)

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

Autopilot: Solo uses a Pixhawk 2 autopilot running ArduPilot Copter software. ArduPilot is

open-source flight control based on the MAVlink communication protocol. Pixhawk 2 runs an

ARM Cortex-M4 STM32F427 processor with 2 MB of flash memory and 256 KB of RAM.

Combined with an array of CAN, I2C, SPI, PWM, and UART interfaces, Pixhawk 2 uses a suite

of onboard sensors to calculate Solo’s orientation and motion in flight. This data is input into

ArduPilot’s inertial navigation and position estimation algorithms and combined with control

inputs to send commands to Solo’s propulsion system. 

Propulsion: Solo uses four brushless 880 Kv motors and four self-tightening propellers for

propulsion. For control and aerodynamic efficiency, two motors spin clockwise and two motors

spin counterclockwise. Navigation in the air is achieved by mixing propulsion of the four

motors to actuate flight control along the roll, pitch, and yaw axes. Each of the four motors is

numbered by the marking on the arm. These numbers correspond to the autopilot calculations

for these commands and are used for indicating motor replacement procedures. Each motor is

controlled by an ESC (Electronic Speed Controller) that regulates the rotation of the motors to

achieve the speed commanded by the autopilot.

III. SAFETY and EMERGENCY FEATURES OF UAV

This section serves to provides in-depth details regarding the 3D Robotics Solo UAV safety and 

emergency features. 

A. Pause 

The controller’s Pause button allows you to stop Solo mid-air. Solo will hover at the paused 
location until given another command. Use the Pause button to stop Solo from hitting an 

obstacle or to re-orient Solo for navigation. Press Pause during Return Home or Land to pause 

Solo and stop the landing. Pause is available only with GPS lock. 

B. Regain Manual Control 

Keep the controller easily accessible at all times during flight, including during Smart Shots, 

and be prepared to regain manual control at any time. To return to standard flight during Smart 

Shots, Return Home, or Land, press the Fly button. 

C. Return Home 

If Solo acquired GPS lock prior to takeoff, press the controller’s Home button to return Solo to 

the launch point and land. Use return home after receiving a low battery notification or to end 

your flight easily. Solo will not avoid obstacles while returning home; always verify that the 

return path is clear before activating Return Home.

D. Land 

To land Solo at its current position, press and hold the Fly button. Lift the throttle at any time to 

exit the landing procedure. If Solo does not have GPS lock, there will be no automatic 

positioning as Solo descends, and drifting may occur depending on environmental conditions. 

E. Motor Shutoff 

In the event that Solo’s motors do not stop after landing or for an emergency in-flight kill 

switch, Solo includes an emergency motor shutoff procedure. To shut off the motors at any time,

either in flight or on the ground, hold the A, B, and Pause buttons at the same time. An initial 

screen will appear on the controller to confirm the shutoff command; continue to hold A, B, and

Pause buttons to activate motor shutoff. Use the emergency motor shutoff only as a last resort.

IV. COMPARABLE UAVS WITH EXISTING EXEMPTIONS

Previous exemptions have been granted for 3D Robotics UAVs including Exemption No.

12320, Exemption No. 12488, Exemption No. 12194, Exemption No. 11617, and Exemption

No. 12368 among others.

V. PRE-FLIGHT CHECKLIST

The checklist presented below will be used prior to each flight to ensure safe operation

conditions of the UAV. This checklist will be used by the Pilot in Command (PIC) in addition to

other safety tools to ensure safe operation of UAV. Portions of this checklist are presented in the

3D Robotics Solo User's Manual, which is included in its entirety Appendix B of this

Exemption Request.

Before flying, check the following conditions. 

A. Location » Your current location and environmental conditions are suitable for flight. » Solo 

is on a level surface at a clear launch point a sufficient distance from yourself and others. 

Don’t fly Solo in extreme weather conditions such as rain, high winds, snow, or fog. Extreme 

weather conditions can permanently damage Solo or cause instability in flight. Before flying, 

determine the boundaries of the safe flying area at your location. Be aware of any risks, 
including bodies of water, structures, trees, power lines, etc, and designate a few areas where 

you can land Solo in case of an unsafe situation. Throughout your flight, be prepared to recover

Solo manually or use an emergency procedure if Solo flies outside the safe flying area. 

B. Ensure current weather and FAA Notices to Airmen are obtained.

C. Components » The propellers are correctly attached. » The propellers can spin smoothly and

without obstruction when turned. » No components on Solo appear loose or damaged.Power » 

The controller is powered on with at least 50% charge. » Solo is powered on with a fully 

charged battery.

D. Video » The Solo app is connected to Solo and streaming video. » The GoPro® is 

recording.Always operate Solo within your visual line of sight (VLOS).