Sky Drone Shots LLC Petition for Exemption to FAA Section 333

James Dunn

Sky Drone Shots LLC 

96 Creek Rd Lumberton, NJ 

305-898-3304

Jamesrcdunn@gmail.com

SUMMARY

James Dunn seeks exemption from Section 333 of the FAA Reform Act of the Federal

Aviation Regulations from part 21, Certification procedures for products and parts, Subpart H – 

Airworthiness Certificates, and the following sections of the Code of Federal Regulations, 14 C.F.R §§ 

45.23(b), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151 (a) and (b), 91.203(a) and (b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a) and (b). James Dunn seeks exemption in 

order to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit James Dunn to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of real estate photography, building exterior inspection, 

landscape photography, and conducting aerial video and photography for tourism agencies, rural 

homeowners, and farms.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is James Dunn and I am establishing a small business in South New Jersey specializing in 

aerial video and photography services utilizing Unmanned Aircraft Systems. I am writing pursuant to the 

FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to 

request that James Dunn of Sky Drone Shots - owner of an unmanned aircraft system (UAS) - be 

granted exemption from the Federal Aviation Regulations (FARS) listed within so that I may operate my 

UAS commercially in airspace regulated by the Federal Aviation Administration.
The objective of James Dunn’s aerial video and photography services is to provide high quality imaging 

for a variety of commercial, public, and residential uses, specifically targeting:

• Real Estate Photography

• Tourism agencies

• Agricultural operations

• Building exterior inspections

• Documenting rural properties for insurance purposes/sentimental reasons

• Construction projects.

• Increase public knowledge of UAS and promote safe UAS EQUIPMENT

Unmanned Aircraft System: 3D Robotics (3DR) SOLO

James Dunn seeks an exemption to operate a 3DR SOLO for compensation or hire within the NAS.

The 3DR SOLO is a quad copter vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing a tablet computer.

Appendices:

1 - 3DR Solos User Manual (PDF) http://3drobotics.com/kb/solo-user-manual 

2 - Technical Specifications

3 - Preflight Checklist

BASIS FOR PETITION

Petitioner, James Dunn, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 

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

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 3DR 

SOLO UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 

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

91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned 
aircraft and its operation, James Dunn’s operation of the 3DR SOLO UAS meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H.

Accordingly, James Dunn requests relief from 14 C.F.R. §§ 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.

James Dunn submits that the requested relief is proper since an equivalent level of safety will be 

ensured. James Dunn 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 User Manual). Furthermore,James 

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

Relief from certain requirements of 14 C.F.R.§ 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by James Dunn 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 UAS in a manner consistent with this exemption, including evasive 

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

structures.

James Dunn seeks relief from 14 C.F.R. § 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, James Dunn submits that he will ensure that the 3DR SOLO UAS is in an airworthy 

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

documents (i.e., Monthly Maintenance Log, and the 3DR SOLO User Manual), and that the aircraft is in a 

condition for safe flight.

James Dunn also seeks an exemption from the requirements of 14 C.F.R. § 91.121, entitled Altimeter 

Settings, as the 3DR SOLO UAS will not have a typical barometric altimeter onboard. However, altitude 
information of the 3DR SOLO UAS 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 

James Dunn’s operation of the 3DR SOLO UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to 14 C.F.R. § 91.121.

Additionally, James Dunn seeks an exemption from the requirements of 14 C.F.R. § 91.151(b), entitled 

Fuel requirements for flight in VFR conditions. James Dunn submits that safety will not be affected by 

operation of the 3DR SOLO 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, James Dunn provides the following information in support of its 

petition for exemption:

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

James Dunn

Sky Drone Shots LLC 

96 Creek Rd Lumberton, NJ 

305-898-3304

B. The Specific Sections Of 14 C.F.R. From Which James Dunn Seeks Exemption.

1. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R. § 61.113(a) and (b) entitled 

Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, 

in relevant part:

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

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

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

or employment if—

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

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

2. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R.§ 91.7(a), 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. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R. § 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.

4. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R. § 91.151(b), 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 13.5 minutes.

5. James Dunn Seeks Exemption From The Requirement Of 14 C.F.R. § 91.405(a), entitled Maintenance 

required, subsection (a), states the following: Each owner or operator of an aircraft—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

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

prescribed in part 43 of this chapter [.]

6. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R. § 91.407(a)(1), 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[.]

7. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R. §§ 91.409(a)(1) and (2), entitled 

Inspections, subsection (a), states the following:

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

the preceding 12 calendar months, it has had --

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

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

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

chapter .

8. James Dunn Seeks Exemption From The Requirements Of 14 C.F.R. §§ 91.417(a) and (b), entitled 

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

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

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

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

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

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

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

(2) Records containing the following information:

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

status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

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

on a specified time basis.

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

the inspection program under which the aircraft and its appliances are maintained. (v) The current status 

of applicable airworthiness directives (AD) and safety directives including, for each, the method of 

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

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

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

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

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

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

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

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

aircraft at the time the aircraft is sold.

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

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

C. The Extent Of Relief James Dunn Seeks And The Reason James Dunn Seeks The Relief.

1. Extent Of Relief James Dunn Seeks and the Reason James Dunn Seeks Relief From 14 C.F.R. §§ 

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, James Dunn submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the 3DR SOLO UAS unless 

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

safely operate the 3DR SOLO UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.

Further, James Dunn submits that all flights of the 3DR SOLO UAS, conducted by the PIC pursuant to 

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

passengers or property for compensation or hire.

2. Extent Of Relief James Dunn Seeks and the Reason James Dunn Seeks Relief From 14 C.F.R. § 

91.7(a).

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

James Dunn to determine that the 3DR SOLO UAS is in airworthy condition prior to every flight by 

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

SOLO Instruction Manual).

James Dunn 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, James Dunn 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 3DR SOLO User Manual) prior to every flight, and further, determine that 

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

3. Extent Of Relief James Dunn Seeks and the Reason James Dunn Seeks Relief From 14 C.F.R. § 
91.121.

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

3DR SOLO UAS, which utilizes 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), James Dunn seeks the 

requested relief because the 3DR SOLO UAS 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 UAS is 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.

4. Extent Of Relief James Dunn Seeks and the Reason James Dunn Seeks Relief From 14 C.F.R. § 

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 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. James Dunn seeks the requested relief because without an exemption from Section 91.151(b), 

the flight time duration of the battery powered 3DR SOLO UAS will severely constrain the practicality of 

any aerial video or still photo flight operations that James Dunn proposes to conduct pursuant to this 

Petition.

Significantly, as set forth below, the technical specifications of the 3DR SOLO UAS, the 3DR SOLO UAS 

operating documents, and James Dunn’ proposed operating limitations, ensure that James Dunn will 
safely operate the battery powered 3DR SOLO 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.

5. Extent Of Relief James Dunn Seeks and the Reason James Dunn Seeks Relief From 14 C.F.R. §§ 

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, James Dunn requests relief from these Sections because the 3DR 

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, James Dunn will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the 3DR SOLO UAS using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., Maintenance Log, and 3DR 

SOLO UAS User Manual). Furthermore, James Dunn will document and maintain all maintenance 

records for the 3DR SOLO UAS.

D. The Reasons Why Granting James Dunn 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 James Dunn 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 UAS will decrease congestion 

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

James Dunn’ proposed operation of the 3DR SOLO UAS will be realized without implicating any privacy 

issues.

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

The 3DR SOLO UAS is battery powered and serves as a safe, efficient, and economical alternative to 

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 
aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR SOLO UAS would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the 

safety of life and property in the air and on the ground.

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

airports caused by arriving and departing aircraft will be reduced. The 3DR SOLO UAS does not require 

an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations.

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

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

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

video and still photography flight operations. By using battery power and electric motors, the 3DR SOLO 

UAS produces no air pollution, and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The 3DR SOLO 

UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

3DR SOLO is propelled by battery powered electric motors, rather than an internal combustion engine.

By using the 3DR SOLO UAS to perform aerial acquisitions, the substantial risk to life and property in the 

air and on the ground, which is usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the (weighing 3.9 pounds and measuring approx 18" square and 10" high, 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).

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

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

manned aircraft to conduct similar aerial operations. As such, operation of the 3DR SOLO UAS will allow 

United States based companies, like James Dunn, to remain competitive and contribute to growth of the 

U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

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

adopt new and alternative technology in order to remain competitive. Operating the battery powered 3DR 

SOLO UAS is one such technology that not only allows companies greater operational flexibility 

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

manned aircraft.

By operating the 3DR SOLO UAS, companies such as James Dunn, can remain competitive and 

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

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

commercial use of the 3DR SOLO UAS, provides a stable workforce that increases consumer spending; 

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

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

4. There Are No Privacy Issues.

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

Dunn’ proposed operation of the 3DR SOLO UAS will not implicate any privacy issues. Specifically, the 

3DR SOLO UAS will be operated only in compliance with operating documents (i.e., Maintenance Log, 

3DR User Manual) which require property owners' involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119.

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

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

James Dunn Seeks Exemption.
1. Reasons Why The 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, James Dunn’s operation of the 3DR SOLO UAS meets the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and 

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

public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 states the following, in part:

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

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

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

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

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

Secretary shall determine, at a minimum--

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

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

create a hazard to users of the national airspace system or the public or pose

a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1).

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

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

establish requirements for the safe operation of such aircraft systems in the national airspace system. In 

seeking this exemption, James Dunn submits that the 3DR SOLO UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3DR SOLO UAS; (b) 
the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The 3DR SOLO UAS Demonstrate Its Safe Characteristics.

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

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

i. Technical Specifications Of 3DR SOLO UAS. The technical specifications of the 3DR SOLO UAS are 

set forth by the Specifications listed in Appendix 2.

ii. The 3DR SOLO UAS Autonomous Flight And Navigation Modes Enable the 3DR SOLO UAS To 

Remain Within A Defined Operational Area. The 3DR SOLO UAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and navigational modes of the 3DR 

SOLO UAS is provided in the User Manual, referenced in Appendix 1.

iii. The 3DR SOLO UAS Is Designed For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the UAs will remain stationary, in flight, for 3 seconds or more.

If, after 3 seconds, the 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 

UAS are described in the User Manual, referenced in Appendix 1.

iv. The GCS And Its Operation.

A complete description of the operation and specifications of the GCS and flight control software is 

provided in the User Manual, referenced in Appendix 1.

b. Flight Operations Of UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A 

Safety Observer. James Dunn 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 UAS. Additionally, a safety observer will assist all pilots during flight time.

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

In seeking this exemption, James Dunn proposes to commercially operate 3DR SOLO UAS for the 
special purpose of conducting aerial video and photography over certain areas of United States, pursuant 

to the following specific operating limitations:

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

operating documents, rotorcraft 3DR SOLO UAS weighing less than 55 pounds maximum gross weight: 

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 UA may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents 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 3DR SOLO UAS 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.

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;

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 14 C.F.R. § 91.119(a).

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

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

representative will be obtained for each flight to be conducted.

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

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

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

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

2. Reasons Why An Exemption From The Requirements Of 14 C.F.R. §§ 61.113(a) and (b) Would Not 

Adversely Affect Safety.

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

maintained because no PIC will be allowed to operate the 3DR SOLO UAS unless that PIC has 

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

operate the UAS in a manner consistent with the exemption, including evasive and emergency 
maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering James Dunn’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 

UAS, James Dunn submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for James Dunn’ 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). James Dunn will not allow any PIC to operate the UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or UAS training and currency 

requirements, that the PIC is able to safely operate the 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 James Dunn’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 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 
hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the exemption. For clarification, the FAA 

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

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

total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 

takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with applicable regulations 

would satisfy this requirement.

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

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

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

Exemption No. 11138 

Accordingly, James Dunn will ensure safe operations by not allowing any PIC to operate the UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the UAS in a manner consistent with the exemption, including evasive and 

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

structures.

3. Reasons Why An Exemption From The Requirements Of 14 C.F.R. § 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, James Dunn will ensure that the UAS is in an airworthy condition based upon the UAS’s 

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

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances 
similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of 14 C.F.R. § 91.121 Would Not Adversely 

Affect Safety.

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

information of the UA will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with James Dunn’s operation of the within visual line of sight, 

at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed onboard the aircraft.

Prior to each flight, a zero altitude initiation point is automatically established by the 3DR SOLO UAS at 

ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in 

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

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of 14 C.F.R. § 91.151(b) Would Not Adversely 

Affect Safety.

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

91.151(b) as a result of (1) the technical specifications of the 3DR SOLO UAS; (2) the limitations on the 

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

Dunn will ensure that it will safely operate the battery powered UA during daylight hours in VFR 

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

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

in Exemption No. 11109, the technical specifications of the 3DR SOLO UAS; the limitations on the 

proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of 
safety established by Section 91.151(b). Furthermore, safety will be ensured as the 3DR SOLO UAS 

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% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, the 3DR SOLO UAS will 

descend and land automatically.

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

not adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed 

in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

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

11161).

6. Reasons Why An Exemption From The Requirements Of 14 C.F.R. §§ 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, James Dunn 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 James Dunn will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the 3DR SOLO UAS using the 

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

Maintenance Log). Furthermore, James Dunn will document and maintain all maintenance records for 

the 3DR SOLO UAS. Since the 3DR SOLO UAS will be inspected as prescribed by the operating 

documents, James Dunn 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 User Manual is attached hereto as Exhibit C. Likewise, the 

exemption sought will not

adversely affect safety because James Dunn will use trained technicians to perform maintenance, 
alterations or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents. Furthermore, the exemption sought would maintain an 

equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the 3DR SOLO UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the 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 James 

Dunn’s proposed operating limitations, the operating documents, and the technical aspects of the 3DR 

SOLO UAS, James Dunn submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

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

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

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, James Dunn requests that the FAA prescribe special 

conditions for the intended operation of the 3DR SOLO UAS, which contain such safety standards that 

the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the 

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

States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

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

accordance with any requirements that must be established for the safe operation of the UAS in the NAS. 
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation 

of the 3DR SOLO UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 

21.16, entitled Special Conditions, states the following:

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

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

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

amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds 

necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 

21.16.

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

conditions forSky Drone Shots intended operation of the 3DR SOLO UAS, which contain such safety 

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

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

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

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

Dunn Seeks Exemption:

James Dunn 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 James Dunn Seeks:

This exemption will permit James Dunn to commercially operate an Unmanned Aircraft System (UAS) for 

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

G. Any Additional Information, Views, Or Arguments Available To Support James Dunn’ 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, James Dunn’ 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, James Dunn will operate the 3DR SOLO UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, James Dunn 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 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

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

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing James Dunn 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, James Dunn respectfully requests that the Administrator grant this 

Petition 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), and permit Sky Drone 

Shots to operate the 3DR SOLO UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.
Dated: November 10, 2015 

Respectfully submitted, 

James Dunn

James Dunn

James Dunn

Sky Drone Shots LLC

96 Creek Rd 

Lumberton, NJ 08048

Jamesrcdunn@gmail.com

Appendices:

1 - 3DR Sols User Manual (PDF) http://3drobotics.com/kb/solo-user-manual 2 - Technical Specifications

3 - Preflight Checklist

APPENDIX – 1 3DR Sols User Manual (PDF) http://3drobotics.com/kb/solo-user-manual

APPENDIX – 2 TECHNICAL SPECIFICATIONS

Sky Drone Shots uses only the safe and reliable 3DR SOLO UAS.

3D Robotics is an industry leader in small UAS production. The 3DR SOLO is loaded with state of the art 

software enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set altitude and speed as 

well as limit flight to a predetermined and set distance. In addition, software provides real-time altitude 

and location information to the PIC via the linked monitor (tablet device).

Solo is a quad-rotor aerial vehicle powered by the 3DR Pixhawk 2 autopilot system and APM:Copter 

flight control software.

Solo communicates with the controller and Solo app over the 3DR Link secure Wi-Fi connection. 
Autopilot: 3DR Pixhawk 2

Flight code: ArduPilot Copter

Control: 3DR Solo Controller

Wireless communication: 3DR Link 1.0

Frequency: 2.4 GHz

Height: 10 in. (25 cm)

Motor-to-motor dimension: 18 in. (26 cm)

Propulsion: 880 KV motors, two clockwise rotating motors and

two counterclockwise rotating motors

Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm)

Weight with battery: 3.3 lbs. (1.5 kg)

Controller battery life: 3 hours

Extended controller battery life: 6 hours

Controller battery: Li-ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery)

Power: Electric (rechargeable lithium polymer battery)

Battery: Lithium polymer, 5200 mAh, 14.8 Vdc

Battery weight: 1 lb. (.5 kg)

Estimated flight time: 25 minutes*

Maximum altitude: 328 ft. (100 m)

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

Payload capacity: 1.1 lbs. (500 g)

Cruise speed: 5.7 mph (2.5 m/s)

Maximum speed: 55 mph (25.5 m/s)

Maximum climb rate: 11 mph (5.0 m/s)

Maximum descent rate: 5.5 mph (2.5 m/s)

Headwind limitation: 25 mph (11 m/s)
Crosswind limitation: 25 mph (11 m/s)

Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4

Full compatibility with GoPro® HERO 3+ or 4

Solo app compatibility: iOS 8.0 or later / Android 4.3 or later

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

Operating relative humidity: 0-85% RH

*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. **Range varies with 

location, antenna orientation, background noise and multi-path.

Appendix 3 - Preflight Checklist

Before flying, check the following conditions.

4.1.1 Location

Your current location and environmental conditions are suitable for flight. (Section 3.1)

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

3.1)

4.1.2 Components

The propellers are correctly attached. (Section 2.4)

The propellers can spin smoothly and without obstruction when turned. No components on Solo appear 

loose or damaged.

4.1.3 Power

The controller is powered on with at least 50% charge. (Section 2.3) Solo is powered on with a fully 

charged battery. (Section 2.2)

4.1.4 Video (Optional)

The Solo app is connected to Solo and streaming video. (Section 2.6) The GoPro® is recording.