Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

October 20,2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. Part 61.113(a) &

(b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 

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

Dear Sir or Madam, 

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

and 14 C.F.R. Part 11, SOLID A.P., operators of Small Unmanned Aircraft SYSTEMS (“sUASs”) 

equipped to conduct aerial photography and cinematography for commercial and residential 

real estate and closed set special events, hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as 

such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as requires by Section 333.

As described more fully below, the request exemption would permit the operation of small, 

unmanned, and redundant sUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access and 4) would provide safe operations and affordability to the existing real estate and closed---set special event industries currently using 

conventional aircraft. Approval of this exemption would thereby enhance safety, promote 

industry growth and fair competition through afford-ability of aerial photography and 

cinematography and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “... establish requirements for the safe operation of such aircraft systems 

in the national airspace system.” Section 333 of the Reform Act.t.

The	name	and	address	of	the	applicant	is:

SOLID A.P.

Attn:Marc Christopher Wong

Ph:818 419 8742

Email:mcw@solidap.com

Address:16333 Septo St, North Hills CA 91343
Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

Regulations	from	which	the	exemption	is	requested:	

14C.F.R.Part21

14C.F.R.45.23(b)

14C.F.R.61.3

14C.F.R.91.7(a)

14C.F.R.91.9(b)(2)

14C.F.R.91.103

14C.F.R.91.109

14C.F.R.91.119

14C.F.R.91.121

14C.F.R.91.151(a)

14C.F.R.91.203(a)&(b)

14FR	§	91.205(b)		

14FR	§	91.215

14C.F.R.91.405(a)

14C.F.R.407(a)(1)

14C.F.R.409(a)(2)

14C.F.R.417(a)&(b)

This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in	passing	Section	

333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	Transportation	to	

consider whether	certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	

airspace	system	(NAS)	before	completion	of	the	rule	making	required	under	Section	332	of	

the	Reform	Act.	In	making	this	determination,	the	Secretary	is	required	to	determine	which	

types	of	UASs	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	

national	security	in	light	of	the	following:	

• The	UAS’s	size,	weight,	speed	and	operational capability;

• Operation	of	the	UAS	in	close	proximity	to	airports	and	populated areas;and

• Operation of the UAS within visual line of sight of the operator.

Reform	Act	§ 333	(a).	Lastly,	id	the	Secretary	determines	that	such	vehicles	“may	operate	

safely	in	the	national	airspace	system,	the	Secretary	shall	establish	requirements	for	the	safe	

operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	§333(c).		

The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	exemptions.	This	

statutory	authority	by	its	terms	includes	exempting	civil	aircraft,	as	the	term	is	defined	

under	§40101	of	the	Act,	that	includes	sUASs,	from	the	requirement	that	all	civil	aircraft	

must	have	a	current	airworthiness	certificate.	

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	prescribed	

under	subsection	(a)	or	(b)	of	this	section	or	any	sections	44702	-	44716	of	this	title	if	the	

Administrator	finds	the	exemption	in	the	public	interest.	49	U.S.C.	§44701(f)	See	also	

49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91.203	(a)	(1).	

Flight	Vehicle:	
Ø The	sUAS	will	weigh	less	than	55	lbs.

Ø Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.

Ø Maximum	total	flight	time	for	each	operational	flight	will	be	30	minutes	or	less.

Ø Flights	will	be	terminated	at	25%	battery	power	reserve	should	that	occur	prior	to

the	30	minute	limit.

Ø Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	or,	not	more	than

200	feet	above	an elevated	platform	for	which	filming	is	planned.

Ø Minimum	crew	for	each	operation	will	consist	of	the	sUAS	Pilot,	the	Visual	Observer,

and	the	Camera Operator.

Ø sUAS	Pilot	will	also	meet	the	flight	review	requirements	specified	in	14	C.F.R	61.56	in

an	aircraftwhich	the	Pilot	is	rated	on	his	or	her	pilot	certificate.

Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

SOLID A.P.	proposes	to	use	4	sUASs;	1)	DJI	Inspire	1,2)	DJI	PHANTOM	3	Advanced, 3) DJI Naza 

Controlled F450 Class Multi-rotor & 4) DJI Naza Controlled F330 Class Multi-rotor. All	of	

these	aircraft ve	four	rotors	and	four	motors	in	a	quadcopter	configuration	(X4). Both

sUASs	weigh	less	than	55	lbs.	including	payload.	They	operate,	under	normal	conditions at

speed	of	no	more	than	50	knots	and	have	the	capability	to	hover,	and	move	in	the vertical	and	

horizontal	plane	simultaneously.	All	sUASs	are	equipped	with	GPS	and	autos return	function	

to	the	predetermined	safe	landing	area	as	well	as	allowing	reading	of magnetic	interference	

that	can	cause	loss	off	GPS	signal.	The	sUASs	will	operate	only	in	line

of	sight	and	will	operate	only	within	a	sterile	closed set	area	of	a	residential	or	 commercial

listingoraclosed set	special	event.	Such	operations	will	insure	that	the	sUASs	will	“not

create	a	hazard	to	users	of	the	national	airspace	system	or	the	public.”	(Reform	Act	Section

333	(b)).

Given	the	small	size	of	the	sUASs	involved	and	the	restricted	sterile	environment	within	

which	they	will	operate,	the	applicant	falls	squarely	within	that	zone	of	safety	(an	equivalent	

level	of	safety)	in	which	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow	

commercial	operations	of	UASs	to	commence	immediately. Also	due	to	the	size	of	the	UASs	

and	the	restricted	areas	in	which	the	relevant	sUASs	will	operate,	approval	of	the	application

presents	no	national	security	issue.	Given	the	clear	direction	in	Section	333	of	the	Reform	

Act,	the	authority	contained	in	the	Federal	Aviation	Act,	as	amended;	the	strong	equivalent

level	of	safety	surrounding	the	proposed	operations,	and	the	significant	public	benefit,

including	enhanced	safety,	reduction	in	environmental	impacts,	including	reduced	emissions	

associated	with	allowing	UASs	for	movie	and	television	operations,	the	grant	of	the	requested	

exemptions	is	in	the	public	interest.	Accordingly,	the	applicant	respectfully	requests	that	the	

FAA	grant	the	requested	exemption	without	delay.	

AIRCRAFT AND	EQUIVALENT	LEVEL	OF	SAFETY	

SOLID A.P. proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	have	the	

characteristics	and	that	operate	with	the	limitations	listed	herein.	These	limitations	provide	

for	at	least	an	equivalent	or	even	higher	level	of	safety	to	operationsunder	the	current	

regulatory	structure	because	the	proposed	operations	represent	a	safety	enhancement	to	the	

already	safe	aerial	photography	and	cinematography	filming	operations	conducted	with	

conventionalircraft.

These	limitations	and	conditions	to	which	SOLID A.P. agrees	to	be	bound	when	conducting

commercial	operations	under	an	FAA	issued	exemption	include:	
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14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)	

Subpart,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	

the	issuance	of	airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	

and	limited	operating	area	associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an	

exemption	from	Part	21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety	

under	Part	11	and	Section	333	of	the	Reform	Act.The	Federal	Aviation	Act	(49	U.S.C.§44701

(f))nd	Section33	of	the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the	

requirement	for	an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	

operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	particular	UAS.

In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	an	

airworthiness	certificate,	in	the	restricted	environment	and	under	the	conditions	proposed	

will	at	leastafe,rafer,an	a	conventionalrcraftfixeding	or	rotorcraft)

operatingithnirworthiness	certificateithouthe	restrictionsnd	conditions

proposed.

14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft	

The	regulation	requires:	

When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration	number	is	

displayed	on	limited,	restricted	or	light-sport	category	aircraft	or	experimental	or	

provisionally	certificated	aircraft,	the	operator	must	also	display	on	that	aircraft	nearach

entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more	than	

Ø The	sUAS	will	only	operate	within	a	confined	sterile	closed-set	area	with	a	set	safety

perimeter,	the	boundaries	of	which	will	be	determined	by	production	personnel	and

the	sUAS	PIC	based	on	the	site-specific	filming	activities	and	speed	of	the	sUAS

required	for	the	operation,	and	coordinated	with	the	jurisdictional	FAA	FSDO	and

local	government	officials	as	applicable.

Ø A	briefing	will	be	conducted	in	regards	to	the	planned	sUAS	operations	prior	to	each

day’s	production	activities.	It	will	be	mandatory	that	all	personnel	who	will	be

performing	duties	within	the	boundaries	of	the	safety	perimeter	be	present	for	this

briefing.

Ø The	sUAS	Pilot	and/or	Aerial	Coordinator	will	ensure	this	safety	perimeter	that	only

consenting	production	personnel	will	be	allowed	within	100	feet	of	the	sUAS

operation	by	not	permitting	anyone	who	had	not	been	briefed	or	whom	is	not

involved	in	production	to	be	in	the	closed-set	area.

Ø Observer	and	PIC	will	at	all	times	be	able	to	communicate	by	voice	and/or	two	way

radio	communication	system.

Ø Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained.

Ø If	applicable,	all	required	permissions	and	permits	will	be	obtained	from	territorial,

state,	county	or	city	jurisdictions,	including	local	law	enforcements,	fire,	or	other

appropriate	governmental	agencies.

Ø If	the	sUAS	loses	communications	or	loses	its	GPS	signal,	the	sUAS	will	have	the

capability	to	return	to	a	pre-determined	location	within	the	Security	Perimeter	and

land	safely.

Ø The	sUAS	will	have	the	capability	to	abort	flight	in	case	of	unpredicted	obstacles	or

emergencies.
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6 inches high, the words "limited," "restricted," "light---sport," "experimental," or 

"provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as 

the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“experimental” can be placed. Given the size of the sUAS, two inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with 

§45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as

required by §45.92 (f) where the pilot, observer and others working with the sUAS will see

the identification of the sUAS as “Experimental”. The FAA has issued the following

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition.As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the Manual for maintenance

and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an

equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.---registered civil aircraft ...

The sUAS, given its size and configuration has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no

room or capacity to carry such an item on the aircraft.The equivalent level of safety will be

maintained by keeping the flight manual at the ground control point where the pilot flying

the sUAS will have immediate access to it.The FAA has issued the following exemptions to

this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167,

10167A, 10602, 32827, and 10700.

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft

Flight Manual, approved manual material, markings, and placards, or any combination

thereof.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure

the safety of flight.As FAA approved rotorcraft flight manuals will not be provided for the

aircraft an exemption will be needed. An equivalent level of safety will be set forth by the

pre---flight checklist as set forth in the Flight Operations Manual.The PIC will take all actions

including reviewing weather, flight battery requirements, landing and takeoff distances,

aircraft performance data and setting the pre---determined safe landing area in case of loss

of GPS communication before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioningg
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dual	controls.	sUASs	and	remotely piloted	aircraft, by their	design do	not	have	fully

functional	dual	controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that	

communicates	with	the	aircraft	via	radio	communications. The	FAA	has	approved	

exemptions	for	flight	training	without	fully functional	dual	controls	for	a	number	of	aircraft	

and	for	flight	instruction	in	experimental	aircraft. See Exemption Nos.5778K	&	9862A.The	

equivalent	level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	

carried	in

the	aircraft	and	by	the	size	and	speed	of	the	aircraft.	

14	C.F.R.	§91.119:	Minimum	safe	altitudes	

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft. Section	91.119	(d)	

allows	helicopters	to	be	operated	at	less	than the	minimums	prescribed,	provided	the

person	operating	the	helicopter	complies	with	any	route	or	altitudes	prescribed	for	

helicopters	by	the FAA.As	this	exemption	is	for	a	sUAS	that	is	a	helicopter	and	the exemption	

requests	authority	to	operate at	altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	

elevated	platform	from	which	filming	is	planned,	an	exemption	may	be	needed	to	allow	such	

operations. The	sUAS	will	never	operate	at	higher	than	400	AGL.	It	will	however	be	operated	

in a	restricted	area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed	

to	operations	without their	pre-obtained	consent.	

The equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the UAS	as	

well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of	

the	property	owner	or	local	officials.	Because	of	the	advance	notice	to	the	property	owner	

and	participants	in	the	filming	activity,	all	affected individuals	will	be	aware	of	the	planned	

flight	operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	far	

more	than	the	maximum	55lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any	risk	

associated	with	these	operations	is far	less	than	those	presently	presented	with	

conventional	aircraft	operating at	or	below	500	AGL	in	aerial	photography	and	

cinematography	industry. In addition,	the	low-	altitude	operations	of	the	sUAS	will	ensure	

separation	between	these	sUAS	operations	and	the	operations	of	conventional	aircraft	that	

must	comply	with	Section	91.119.	

14	C.F.R.	§91.121	Altimeter	Settings	

This	regulation	requires	each	person operating	an	aircraft	to	maintain	cruising	altitude	by	

reference	to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure	airport	or	an	

appropriate	altimeter	setting	available	before	departure.”	As	the	sUAS	may	not	have	a	

barometric	altimeter,	but	instead	a	GPS altitude read	out, an exemption may be	needed. An

equivalent	level	of	safety	will	be	achieved	by	the	operator,	pursuant	to	the	Pre	Flight	Check	

list,	confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	

flight.	

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions	

Section	91.151	(a)	prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	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	–	(1)

During	the	day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	

least	45	minutes.”	
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The	battery	powering	the	sUAS	provides	approximately	40	minutes	of	powered	flight.	To

meet	the	30	minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	would	be	limited	

to	approximately	10	minutes	in	length.	Given	the	limitations	on	the	UAS’s	proposed	flight	

area	and	the	location	of	its	proposed	operations	within	a	predetermined	area,	a	longer	time	

frame	for	flight	in	daylight	or	night	VFR	conditions	is	reasonable.	

SOLID A.P.	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	

prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	to	operate	

without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	tightly	controlled	

area	where	only	people	and	property	owners	or	official	representatives	who	have	signed	

waivers	will	be	allowed,	with	less	than	30	minutes	of	reserve	fuel,	does	not	engender	the	

type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	of	the	

small	UAS.	Additionally,	limiting	sUAS	flights	to	10	minutes	would	greatly	reduce	the	utility	

for	which	the	exemption	will	be	granted.	

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	

minutes	or	25%	of	battery	power	whichever	happens	first.	This	restriction	would	be	more	

than	adequate	to	return	the	sUAS	to	its	planned	landing	zone	from	anywhere	in	its	limited	

operating	area.	

Similar	exemptions	have	been	granted	to	other	operations,	including	Exemptions	2689F,	

5745,	10673,	and	10808.	

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration	

The	regulation	provides	in	pertinent	part:	

(a) Except	as	provided	in	§	91.715,	no	person	may	operate	a	civil	aircraft	unless	it	has

within	it	the	following:

(1) An	appropriate	and	current	airworthiness	certificate.	.	.	.

(b) No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	required	by

paragraph	(a)	of	this	section	or	a	special	flight	authorization	issued	under	§91.715	is

displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.

The	UAS	fully	loaded	weighs	no	more	than	55	lbs	and	is	operated	without	an	onboard

pilot.As	such,	there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or

to	display	them	on	the	sUAS.

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground

control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to	them,	to	the

extent	they	are	applicable	to	the	sUAS.The	FAA	has	issued	numerous	exemptions	to	this

regulation.	A	representative	sample	of	other	exceptions	includes	Exemption	Nos.	9565,

9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.

14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections	

These	regulations	require	that	an	aircraft	operator	or	owner	“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...,”	and	others	shall	inspect	or	maintain	the	aircraft	in	

compliance	with	Part	43.	Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an	

airworthiness	certificate,	these	sections	will	not	apply	to	the	applicant.	Maintenance	will	be	

accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	handbook.	An	
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equivalent	level	of	safety	will	be	achieved	because	these	small	UASs	are	very	limited	in	size	

and	will	carry	a	small	payload	and	operate	only	in	restricted	areas	for	limited	periods	of	

time.	If	mechanical	issues	arise	the	UAS	can	land	immediately	and	will	be	operating	from	no	

higher	than	400	feet	AGL.The	operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	

initiating	flight,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance	

performed.	Moreover,	the	operator	is	the	person	most	familiar	with	the	aircraft	and	best	

suited	to	maintain	the	aircraft	in	an	airworthy	condition	to	provide	the	equivalent	level	of	

safety.	

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	in	the	

Federal	Register,	should	it	be	determined	that	publication	is	needed:	

Applicant	seeks	an	exemption	from	the	following	rules:	

14	C.F.R.	§21,	subpart	H;	14	C.F.R	45.23(b);14	C.F.R.	§§	61.113(	a)	&	(b);91.7	(a);	91.9	(b)	

(2);91.103(b);91.109;	91.119;	91.121;	91.151(a);91.203(a)	and	(b);	91.405	(a);	91.407	(a)	

(1);	91.409	(a)	(2);	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate	commercially	a	small	

unmanned	vehicle	(55lbs	or	less)	in	aerial	photography	and	cinematography	for	residential	

and	commercial	real	estate	and	closed-set	special	events.	

Approval	of	exemptions	allowing	commercial	operations	of	sUASs	for	aerial	photography	

and	cinematography	for	real	estate	and	close-set	special	events	will	enhance	safety	by	

reducing	risk.	Conventional	real	estate	aerial	photography	and	cinematography	use	jet	or	

piston	powered	aircraft	which	carry	large	amounts	of	combustible	fuel	posing	increased	

risk.	Conversely,	sUASs	carry	no	combustible	fuel,	weigh	only	55	lbs.	or	less	comparatively	

to	3,000+	lbs.	of	a	conventional	aircraft,	are	much	more	easily	maneuverable	and	do	not	

ferry	to	and	from	the	production	location.	Additionally,	flying	at	or	below	400	AGL	sUAS	will	

be	no	factor	with	fixed	wing	and	rotor	wing	aircraft.	

The	operation	of	small	UASs,	weighting	less	than	55	lbs.,	conducted	in	the	strict	conditions	

outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of	the	

exemptions	requested	herein,	including	exempting	the	applicant	from	the	requirements	of	

Part	21	and	allowing	commercial	operations.	These	lightweight	aircraft	operate	at	slow	

speeds,	close	to	the	ground,	and	in	a	sterile	environment	and,	as	a	result,	are	far	safer	than	

conventional	operations	conducted	with	traditional	aircraft	which	pose	a	safety	risk.	There	

are	no	personnel	on	board	the	sUASs	and	therefore	the	likelihood	of	death	or	serious	bodily	

injury	is	significantly	diminished.	All	flights	will	occur	over	private	or	controlled	access	

property	with	the	property	owner’s	prior	consent	and	knowledge.	Filming	will	be	of	people	

who	have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where	

filming	will	take	place.	SOLID A.P.	will	provide	an	equivalent	or	better	level	of	safety	as	that	

achieved	under	the	current	FAR’s.	

Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

Appendix 

FAR section Subject Justification 

14 CFR § 

45.23(b) 

Requirement to display registration 

number on vehicle Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification requirements and 

procedures 

Designed for manned aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 61.3 Requirement for pilot certificate 

Part 61 requirements designed for manned aircraft, 

not sUAS; petition describes training for sUAS 

operator 

14 CFR § 91.7 

(a) Airworthiness requirement Designed for manned aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.9 

(b) (2)

Requirement for manual to be 

available in the cockpit No one aboard to read manual 

14 CFR § 

91.103(b) 

Requirement for crew members to be 

onboard Unmanned vehicle 

14 CFR § 

91.109 

Requirement for dual controls during 

flight instruction No one aboard to operate controls 

14 CFR § 

91.119 Minimum altitudes for safe flight Safety requires operation below these altitudes 

14 CFR § 

91.121 Altimeter settings No one aboard to read altimeter 

14 CFR § 

91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 

91.203 (a) & (b) 

Requirement for registration and 

airworthiness certificates to be 

onboard 

No one aboard to read certificates 

14 CFR § 

91.205(b) Cockpit instruments No one aboard to read 

Requirement Instruments 

14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; will be operated 

below ATC radar coverage 

14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; not suitable for off-theshelf sUAS 

14 CFR § 91.407(a) 

(1) 

Inspection approval 

requirements 

Designed for manned aircraft; not suitable for off-theshelf sUAS 

14 CFR § 91.409 (a) 

(2) Airworthiness inspection Designed for manned aircraft; not suitable for off-theshelf sUAS 

14 CFR § 91.417 (a) Maintenance records Designed for manned aircraft; not suitable for off-the-
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& (b) requirements shelf sUAS 
sUAS AIRCRAFT SPECIFICATIONS 

DJI Inspire 1 

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

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Power Spectral Density

9.06mW/MHz

Gimbal

Model

ZENMUSE X3

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

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±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

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)

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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

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

100 W

Battery (Standard)

Name

Intelligent Flight Battery

Model

TB47

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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

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

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Operating Range

0-250 cm

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DJI Phantom 3 Advanced

\\Aircraft

Weight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

 Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

 Horizontal: +/- 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

Camera

Sensor

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range

100-3200 (video) 100-1600 (photo)

Shutter Speed

8s -1/8000s

Image Max Size

4000 x 3000

Still Photography Modes

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time-lapse

Video Recording Modes

Phantom 3 Professional

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

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 2.7K: 2704 x1520p 24/25/30 (29.97)

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

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

Max Bitrate Of Video Storage

Phantom 3 Professional

60 Mbps

Phantom 3 Advanced

40 Mbps

Supported File Formats

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature

0°C to 40°C

Gimbal

Controllable Range

Pitch -90° to +30°

Stabilization

3-axis (pitch, roll, yaw)

Vision Positioning

Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

50 cm-300 cm

Operating Range

50 cm-300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote Controller

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

Video Output Port

USB

Operating Temperature

0°C- 40°C

Battery

6000 mAh LiPo 2S

Mobile Device Holder

For tablet or phone

Receiver Sensitivity (1%PER)

-101 dBm ±2 dBm

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Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Battery Charger

Voltage

17.4 V

Rated Power

Phantom 3 Professional

 100 W

Phantom 3 Advanced

 57 W

Intelligent Flight Battery

Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g

Max Flight Time

Approximately 23 minutes

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W

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DJI F330 & F450 Class Multi-Rotors

F330

Model

Flame Wheel 330 (F330)

Frame Weight

156g

Diagonal Wheelbase

330mm

Takeoff Weight

600g ~ 1200g

Recommended Propeller

8 × 4.5in

Recommended Battery

3S~4S LiPo

Recommended Motor

22 × 12mm (Stator size)

Recommended ESC

15A OPTO

F450

Model

Flame Wheel 450 (F450)

Frame Weight

282g

Diagonal Wheelbase

450mm

Takeoff Weight

800g ~ 1600g

Recommended Propeller

10 × 3.8in ; 8 × 4.5in

Recommended Battery

3S~4S LiPo

Recommended Motor

22 × 15mm or 22 × 12mm

Recommended ESC

15A OPTO

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DJI Naza V2 Flight Controller (F450 & F330 Class Controller) 

Basic Performance

Supported Multi-Rotor

Quad-rotor I4, X4

Hex-rotor I6, X6, IY6, Y6

Octo-rotor I8,V8,X8

Supported ESC Output

400Hz refresh frequency

Recommended Transmitter

PCM or 2.4GHz with minimum 4 channels

Working Voltage Range

MC:4.8V~5.5V

VU Input: 7.4V ~ 26.0 V

(recommend 2S ~ 6S LiPo)

Output(V-SEN port red wire): 3A@5V

(burst current:7.5A)

Power Consumption

MAX: 1.5W(0.3A@5V)

Normal:0.6W(0.12A@5V)

Operating Temperature

-10°C ~ 50°C

Assistant Software System Requirement

Windows XP sp3 / Windows 7 / Windows 8

Flight Performance

Hovering Accuracy(GPS Mode)

Vertical:±0.8m

Horizontal:±2.5m

Max Yaw Angular Velocity

200°/s

Max Tilt Angle

35°

Ascent / Descent

6m/s,4.5m/s

Hardware

Weight

MC:27g

PMU:28g

GPS:27g

LED:13g

Dimensions

MC: 45.5mm x 32.5mm x 18.5mm

PMU: 39.5mm x 27.5mm x 10.0mm

GPS & Compass 46mm(diameter)x10mm

LED: 25mm x 25mm x 7.0mm

Built-In Functions

Multiple Autopilot Control Mode

Enhanced Fail-safe

Low Voltage Protection

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S-Bus Receiver Support

PPM Receiver Support

Independent PMU Module

2-axle Gimbal Support

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