Russell Hughes, DBA: Staplehawk Productions

1500 Foster Dr

Cedar Park, TX 78613

512.947.2715

Email staplehawk@gmail.com

PETITION FOR RELIEF OF REQUIREMENT OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS, 

SPECIFICALLY AS AUTHORIZED UNDER THE F.A.A. MODERNIZATION AND REFORM ACT OF 2012, 

SECTION 333; SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS.

Russell Hughes, DBA as Staplehawk Productions, seeks exemptions from Title 14 of the Code of 

Federal Regulations: 61.113 (a) and (b); 91.7 (a); 91.119; 91.121; 91.151.151 (a); 91.405 (a); 91.407 (a) 

(1); 91.409 (a) (1) and (2); 91.417 (a) and (b), in order to operate a 3DR Solo UAS. This exemption will 

allow Staplehawk Productions to operate an unmanned aerial vehicle commercially for the purposes 

of conducting aerial video and still photography in the Real Estate, film and commercial video markets 

of Texas. These still images and videos will provide commercial services of aerial videos. Staplehawk 

Productions is a real estate, film and commercial video aerial photography company producing high 

quality results for clients who want videos for real estate, film and commercial video purposes 

throughout the Texas markets. Staplehawk Productions will be using a high tech 3DR Solo quad copter 

to commercially capture video stills and film while working on private and public properties for the 

purpose of aerial video services. Staplehawk Productions will employ both a pilot and utilize a visual 

observer to maintain a visual line-of-sight between the quad copter and the pilot UAV operator, who 

will have a solid understanding of the location and surroundings and integrate and demonstrate 

technical knowledge, reason and common sense.

The 3DR Solo UAV:

The Solo Quadcopter from 3D Robotics features aerial imaging-specific flight modes including 

Cablecam mode and Follow Me. A quad-rotor configuration, flight stability and autonomous flying are 

enabled thanks to a twin computer flight control system. The flight controller relies on GPS for 

navigational coordinates, plus uses data from gyros, accelerators, and other sensors to keep the 

aircraft safely flying.It's Maximum Speed is 55 mph. It's Maximum Altitude 400' / 121.9 m AGL. Flight 

Time is up to 25 minutes (20 with camera and Solo Gimbal)

3DR Solo Flight Control System:

Software is APM flight control software with integrated GPS. The Handheld Transmitter Frequency is 

Not specified by manufacturer currently. The Battery Chemistry is Lithium-polymer with a Capacity of 

5200 mAh, Voltage: 14.8 VDC. The Wi-Fi Range is listed as up to 2640' / 805 m (depending on 

environment). 
3DR Solo Components:

Rotors 4 x 10 x 4.5" / 25.4 x 11.4 cm self-tightening props. The motors maintain Velocity Constant: 

880 kV.#

3DR Solo UAV specs:

The Battery Chemistry is Lithium-polymer with a Capacity 5200 mAh, Voltage: 14.8 VDC. It's Running 

Lights are Customizable color LEDs to assist orientation. Dimensions Not specified by manufacturer, 

but small in size. It's Weight Unladen is 3.3 lb / 1.5 kg, With Solo Gimbal and GoPro: 4 lb / 1.8 kg. 

BASIS FOR PETITION

Staplehawk Productions, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. SS 

11.61) and the F.A.A. Modernization and Reformed Act of 2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to operate the 3DR Solo UAS within 

the National Airspace System, and for an exemption from the requirements of 14 CFR SS 61.113 (a) 

and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (2), 91.417 (a) 

and (b).

NAME AND ADDRESS OF THE PETITIONER

Russell Hughes

Staplehawk Productions

1500 Foster Dr.

Cedar Park, TX 78613

russsssman@gmail.com

Staplehawk Productions Requests Relief from the Following Sections of 14 C.F.R.

• Sections 61.113, entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) 

and (b).

• Section 91.7, entitled Civil airworthiness subsection (a).

• Section 91.119 entitled Minimum Safe Altitudes, General.

• Section 91.121, entitled Altimeter Settings.

• Section 91.151 entitled Fuel requirements for flight in VFR conditions.

• Section 91.405, entitled Maintenance required.

• Section 91.407 (a) (1), entitled Operation after maintenance, preventative maintenance, rebuilding, 
or alteration.

• Section 91.409 entitled Inspections.

• Section 91 the .417 entitled Maintenance Records.

Extent of relief that Staplehawk Productions seeks regarding section 61.113 (a) and (b) Private pilot 

privileges and limitations: Pilot in Command, Subsections (a) and (b) prescribed the following, in 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. Relief from section 

61.113 (a) and (b) is requested to allow a PIC holding a current private pilot’s certificate to operate the 

3DR Solo. The flight would be complemented by a visual observer who will, along with the pilot, 

maintain visual line of sight with the 3DR Solo at all times. All operations will be conducted as per 

Staplehawk Productions business related operations. The 3DR Solo is not able to carry passengers. 

Extent of relief that Staplehawk Productions seeks in regards to section 91.7(a), Civil Airworthiness; 

Relief from section 91.7(a), is requested to allow Staplehawk Productions to determine the air 

worthiness of the 3DR Solo. Extent of relief that Staplehawk Productions seeks in regards to section 

91.119, Minimum Safe Altitudes; General. Relief from 91.119 is requested to allow operations of the 

3dr Solo at altitudes not to exceed 400 feet AGL, over private property or at a distance at or greater 

than five nautical miles from the nearest airport as depicted on current aeronautical charts. 

Staplehawk Productions also wishes to be granted exemptions to operate at an altitude not more 

than 50 feet AGL or below tree level between one and five nautical miles from the nearest airport as 

depicted on current aeronautical charts. Extent of relief that Staplehawk Productions seeks from 

91.121, (a) , Altimeter Settings Extent of relief from 91.121 is requested because the3DR Solo utilizes 

an Electronic GPS with a barometric sensor. Extent of relief that Staplehawk Productions seeks in 

regard to section 91.151(a), Fuel Requirements for Flight in VFR Conditions. Relief from 91.151(b), is 

requested to the extent that allows Staplehawk Productions to operate the 3DR Solo up to a point 

that there is enough power to fly at normal cruising speed to the landing point and land the vehicle 

with 25% battery power remaining. Note: a low battery alarm on the operating console for the 3DR 

Solo is equipped with a shaker mechanism to warn the pilot of a low battery condition. Extent of relief 

that Staplehawk Productions seeks in regards to sections 91.405(a), 91.407(a)(1), 91 .409 point(a)(1) 

and (a)(2), 91.4179 1.417 (a) and (b). These are all associated with an airworthiness certificate. There 

are currently no airworthiness certificates for small UAVs.

BENEFITS GAINED VIA RELIEF FOR Staplehawk Productions from the above stated Federal Regulations:
A. Use of the small UAV will allow for quicker and timelier aerial video, aerial video and photos of 

properties as contracted for.

B. Use of the small UAV will allow for more cost effective aerial videos and photography as the cost to 

operate a small UAV is fractional compared to the cost of operating a full size aircraft for aerial 

photography.

C. Use of the small UAV will lessen the use of full size aircraft for some aerial photography missions 

and therefore give a somewhat greater safety ratio for the use of aerial photography.

D. use of the small UAV will not burn fuel thereby becoming far more environmentally friendly on 

emissions than a fullsize aircraft.

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE REQUESTED EXEMPTIONS:

• Standard operating procedures prior to launch will include a preflight checklist of the vehicle and a 

visual inspection of area to be surveyed at ground level will be performed.

• Flight operations will be conducted by a two man crew consisting of the PIC and the Visual Observer. 

All operations will be conducted with a clear line of sight between the UAV and the team.

• Staplehawk Productions will only operate the UAV over private or public property with the 

permission of the property owner or the governing body and will maintain a safe distance from any 

structures, people or vehicles. This petition is being made pursuant to the FAA Modernization and 

Reform Act of 2012, Section 333, which directs the Secretary of Transportation to determine if any 

UAS may safely operate in the National Airspace. The petitioner, Russell Hughes, will be the primary 

and only PIC in command of the 3DR Solo. Staplehawk Productions will operate all aircraft granted for 

use by the exemption as directed by the operating manual provided with the 3DR Solo by the 

manufacturer.

Summary

As set forth previously Staplehawk Productions seeks an exemption pursuant to 14 CFR: 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of 

3DR Solo UAS commercially within the film, real estate and commercial video markets. The 

Administrator will be assisting small business by granting this petition. The new 3DR Solo UAV is 

designed with multiple fail safes to ensure even further public safety measures.

Respectfully Submitted,

Russell Hughes

1500 Foster Dr.

Cedar Park, TX 78613
C: 512-947-2715

staplehawk@gmail.com