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

October 2 0

, 2 015
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 Par t 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 afford

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

Regulations	from	which	the	exemption	is	requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61. 3 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b)
14 FR	§	91.205(b) 14 FR	§	91.215 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.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 w het her	cert a in	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	th e	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	si ght	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	alti tude	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	air craft which	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 F 450 Class Multi-rotor & 4) DJI Naza Controlled F 330 Class Multi-rotor. All of these air craft ve four	rotors	and	four	motors	in	a	quadcopter	configuration	(X4). Both sUASs	weigh	l ess	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	equ ipped	with	GPS	and auto s 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 residen tial	or commercial listing or a closed 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	ap plication 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	eq uivalent 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**

**AN** D	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	equivalen t	or	even	higher	level	of	safety	to	oper ations under	the	current regulatory	structure	because	the	proposed	operations	represent	a	safety	enhancement	to	the already	safe	aerial	photography	and	cinematography	filming	operations	conduct ed	with conventional ircraft.

These	limitations	and	conditions	to	which SOLID A.P. agr ees	to	be	bound	when conducting commercial	operations	under	an	FAA	issued	exemption	include:Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

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	Sect ion 33	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	le ast  afe, r afer, an	a	c onventional rcraft fixed ing	or	rot orcraft) operating ith n irwort hiness	cert ificate ithout he	rest rictions nd	condit ions proposed.

14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft The	regul at ion	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	ne ar ach 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	perimete r	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	produc tion	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	requi red	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.Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

6 inches high, the w ords "limited," "restricted," "light---sport," "experimental," or

" p r ovisional," as applic a b l e

. Even though the sUAS will have no airworth i n e ss certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “exper imental” can be placed. Given the s i ze of the sUAS, two inch lettering will b e impossible. The word “ Experimental” will b e p l a ced on the fuselage i n compliance with §45.29 (f). The equivalent level of safety will be provid ed 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 “Experi mental”. The FAA has i s s ued the following exemptions to this regulation to Exemptio n s Nos. 10700, 8738, 10167 and 10167A. **14 C.F.R. §91.7(a): Civil aircraft airwor thiness.**  The regulation requir e s t hat no person may operate a civil aircraf t unless it is in airwo r thy condition.As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist f or determining airwo r thiness. Given the size of the aircraft and the require ments contained in the Manual for maintenance and use of safety check lists prior to ea ch flight, as set for t h in Sections J, L a n d Q, an equivalent level of s a f

e ty will be provided. **14 C.F.R. § 91.9 (b) (2): Civil Aircraft F**  **l ight Manual in the Aircraft.**  Section 91.9 (b) (2) provides: No person may operate a U .S.---registered civ i l a i rcraft ... The sUAS, given its size and configuration has no ability or place to carry such a f l i ght manual on the aircraf

t , not only because t here is no pilot on b oard, but because the r e i s no room or capacity to carry such an item on the aircraft.The eq uivalent level of safety will be maintained by keeping the flight manual a t the ground control point where the pilot flying the sUAS will have immediate access to it .The FAA has issued t he following exempti ons to this regulation: Exem ption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. (2) For which an Airpl a n e 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 placard s, or any combination thereof. **14 C.F.R. § 91.103: Preflight action** This regulation requi r e s each pilot in comman d t o take certain action s b efore flight to insure the safety of flight .As FAA approved rot orcraft flight manua l s will not be provided for the aircraft an exemption will be needed. An e q uivalent level of sa f ety will be set forth by the pre---flight checklis t a s set forth in the F l i ght Operations Manual.The PIC will take a l l a ctions including reviewing weather, flight batt e r y requirements, land i n g and takeoff distances, aircraft performance data and setting the pre---determined s afe landing area in case of loss of GPS communication befor e initiation of flight. **14 C.F.R. §91.109: Flight instruction:** Section 91.103 provid es that no person may operate a civil aircraft (except a mann ed free balloon) that is bein g used for flight in s t r uction unless that a i r craft has fully func t i oning gMarc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

dual controls.	sUASs and	re motely p i lo te d aircraft, by their de sig n do	no t have	fu lly 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

exe mpti ons for fli gh t traini n g	wi th ou t	fu lly func tio n al dual	controls	for	a	number	of	aircraft and	for fli gh t	instru cti on	in	e xp e rime n tal	airc raft. S e e Exe mptio n No s. 5778K	& 9862A.The

e q uiv alent	level	of	sa fety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be carried	in the	aircraft	and	by t he	size	and	speed	of t he	aircraft.

14 C.F.R. §91.1 19:	M inimum	safe alt itudes Section	91.119	establishes	safe	altitudes for	operation	of	civil	aircraft. Section	91.119	(d) al lows	helicopters	to	be	o p e rate d	at	le ss	than the	mi n i mu ms	pre scribed,	provided th e p e rson	o p e rating	the	helicopter	c omp lies	with	any	route	or	altitudes	prescribed	for he li cop te rs	by th e FAA.As	th i s e xe mpti on	is for	a	sU AS	th at i s	a heli co p te r	an d	the e xemption

re qu e sts	auth ori ty to	o p e rate 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 i n a	re stricted	area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed
t o	operations	without t heir	pre

- obtained	consent. T he e q uivalent	level	of	safety	will	be	achieved	given	the	size,	weight, speed	of th e U AS	as well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of
t he	property	owner	or	local	officials.	Because	of	the	advance	notice	to	the	property	owner and participants	in	the	filming	activity,	all	affect ed i n d i v i d uals	will	be	aware	of	the	planned fl i gh t	operations.	Compared	to	fligh t operatio n s wi th	ai rc raft or rotorcraft	we i gh ti n g	far

mo re	than the	maximu m	55lbs.	p ro p osed he re in	and the lack of	flammable	fuel,	any	risk

a ssociated	with	these	operations	is f ar less	than	those	presently	presented	with
convent i onal	ai rcraft	o pe rating at or below	500	AGL	in	aerial	photography	and cinemato grap hy	industry. I n addition,	the	low-	altitude	operations	of	the	sUAS	will	ensure separation	between	these	sUAS	operations and	the	operations	of	conventional	aircraft	that

mu st comp ly wi th	Secti on	91.119.

14	C .F .R. §91.1 21	Alt imeter Se t t ings Thi s re gulati on	requ i res e ac h	person operating	an	airc raft	to	maintain cruisin g	alti tude	by

re ference	to	an	alti me ter th at	i s se t “.

.. t o	the	elevation	of	the	departure	airport	or	an
appro p riate	altimeter	setting	available	before	departure.”	As	the	sUAS	may	not	have	a baro metric	altimeter,	bu t	inste ad a	GP S altitu de read ou t, an e xe mptio n may be	nee de d. An

e q uiv alent	level	of	safety	will be	achieved	by	the	operator,	pursuant	to	the	Pre	Flight	Check lis t,	confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before flight. 14 C .F .R. §	91.1 51( a ):	Fuel	Requirements	for	Flight	in	VFR Condit ions Section	91.151	(a)	pro hibits	an	individual	from	beginning	“a	flight	in	an	airplane	under VFR conditions	unless	(consideri ng	wind	and	forecast	weather	conditions)	there	is	enough	fuel to	f ly	to	th e fi rst	po i nt	o f i nte n de d	lan ding ,	an d,	assu ming n ormal	cruising	speed	– (1 ) D uring the	day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at lea st	45	minutes.”Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

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 fram e	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	o perate withou t	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	tightly	c ontrolled 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	e ngender th e 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
ope rating	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 wi thin	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	passenge rs	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	oth ers	shall	inspect	or	maintain	the	aircraft	in compliance	with	Part	43.	Given	that	these	section	and	Part	43	apply	only	to	a ircraft	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.	AnMarc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com

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	maintenan ce 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	provi ded	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	reside ntial 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.	Co nventional	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	a llowing	commercial	operations.	T hese	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. T here 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. w ill	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 off

the

- shelf sUAS

14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for mann ed aircraft, not sUAS; petition describes training for sUAS operator 14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not suitable for off

the

- shelf sUAS 14 CFR § 91.9 (b) (2) Requirement for manual to be available in the co ckpit 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

R equirement I nstruments

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

- the

shelf sUAS 14 CFR § 91.407(a) (1) Inspection approval requirements De signed for manned aircraft; not suitable for off

- the

shelf sUAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for off

- the

shelf sUAS 14 CFR § 91.417 (a) Maintenance records Designed f or manned aircraft; not suitable for off

- the

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

& (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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com±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 shoo ting: 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 Storag e 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comSupported 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 mon ths: 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comCapacity 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comOperating Range 0

- 250 cm Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comDJI 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.com 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/ex FAT

 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comTransmitter 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comDJI F 330 & F 450 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comDJI 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 Marc Christopher Wong - C: +1 818 419 8742 - mcw@solidap.comS

- B us Receiver Support PPM Receiver Support Independent PMU Module 2

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