July

9, 2015 Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey

Ave, SE Washington, DC 20590

RE: BLI SSFULLY DONE REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTI ONS 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) CONCERNING COMMERCIAL OPERATION OF 3DR Solo UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZA TI ON AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)
Hue Lam Founder/Owner Blissfully Done 9307 New Hampshire Ave Silver Spring MD 20903 240

- 381

- 7772 blissfullydone@gmail.com**TABLE OF CONTENTS** Page

GLOSSARYABBREVIATIONS............................................................................. 3 SUMMAMY..............................................................................................................4
IN TRODUCTION AND INTERESTS PETI TI ONER.............................................4 BACKGROUND.......................................................................................................4 BASI S FOR PETITION............................................................. ...............................5 NAME AND ADDRESS OF PETITIONER............................................................6 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH BLISSFULLY DONE SEEKS EXEMPTI ON...............................................................................................7 THE EXTENT OF RELIEF BLI SSFULLY DONE LLC SEEKS AND THE REASON BLISSFULLY DONE SEEKS T HE RELIEF................

...... ....... .........10 THE REASON S WHY GRANTING BLISSFULLY DONE’S REQUEST WOULD BE IN THE PUBLIC IN TEREST ..

.. ................................................. .................. .....12 THE REASONS WHY GRANTING THE EXEMPTI ON TO BLISSFULLY DONE WOULD NO T ADVERSELY AFFECT SAFETY.........

...... ............................ .. ...14 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER.. ...25 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT BLI SSFULLY DONE REQUEST.....

. ....... .................... .............. 25 CONCLUSION........................

.................. ........................................................ .....28 APPENDI CES................................ ............................................... 29**GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety Observer SOP Standard Operating Proc edures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem V FR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing**SUMMARY**

BLISSFULLY DONE seeks 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), to operate an Unmanned Aircraft Sy stem ( 3DR SOLO ) pursuant to Section 333 of the FAA Modernization and Re form Act of 2012 (FMRA). This exempt ion will permit BLISSFULLY DONE to operate an Unmanned Aircraft S ys tem (UAS) for the commercial purpose of conducting aerial video and photograph y of events , residential and commercial real estate, civil landscapes , appraisal and roof inspection over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** BLISSFULLY DONE provide their clients with expertise and knowledge in advanced technologies and solutions to increase efficiency , productivity and effectiveness. T he objective of BLISSFULLY DONE is to provide high quality imaging for a variety

of commercial, public and residenti al uses, specifically targeting:

 Aerial event photograph y

 Motion Picture Filming

 Appraisals

 Real

- estate marketing

 Aerial acquisitions used for inspections of public and private structures

**BACKGROUND** Unmanned Aircraft Sy stems: 3DR Solo The BLISSFULLY DONE seeks an exemption to operate 3DR Solo system for compensation or hire within the NAS. The 3DR Solo is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. The 3DR Solo has a maximum gross weight of approximately 3.3lbs . while having a dimension of 4x10x4.5’’ wi th a maximum speed of approximately 55mph and a maximum flying height of 400'. The 3DR Solo is equipped with four main rotors; driven by L ithium Poly

mer battery powered electric motors.The 3DR Solo UAS that will be operated b y BLISSFULLY DONE will be reg istered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.
**BASIS FOR PETITION** Petitioner, BLISSF ULLY DONE , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to comme rciall y operate the 3DR Solo UAS in the National Airspace Sy stem (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 conside ration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, BLISSFULLY DONE operation of 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. Accordingl y, BLISSFULLY DONE requests relief from Sections 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 onl y apply to aircraft with an airworthiness certificate. BLISSFULLY DONE submits that the requested relief is proper since an equivalent level of safety will be ensured. BLISSFULLY DONE will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 3DR Solo In struction Manual). Furthermore, BLISSFULLY DONE will document and maintain all maintenance records for the 3DR Solo UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pil ot in command, is requested b y BLISSFULLY DONE to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the 3DR Solo UAS in a 6 manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures

. BLISSFULLY DONE seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 3DR Solo UAS do not require an airworthiness certificate in accordance with 14C.F.R. Part 21, Subpart H. As such, BLISSFULLY DONE will ensure that the 3DR Solo UAS

are in an airworth y condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and 3DR Solo Instruction Manual), and that the aircraft are in a condition for safe flight. BLISSFULLY DONE also seeks an exemption from the requirements of Section 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 PI C 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 BLI SSFULLY DON E’ 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 Section 91.121. Additionally , BLISSFULLY DONE seeks an exemption from the requirements of Section 91.151(b), entitled Fue l requirements for flight in VFR conditions. BLISSFULLY DONE 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 powe r to fl y 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, BLISSFULLY DONE provides the followi ng information in support of its petition for exemption:
**A. Name and Address of**  **BLISSFULLY DONE Owner/Operator**  HUE T. LAM 9307 New Hampshire Ave Silver Spring MD 20903 240

- 381

- 7772 blissfullydone@gmail.com
**B. The Specific Sections Of 14 C.F.R.**  **From Which BLISSFULLY DONE Seeks**  Exemption. 1. BLISSFULLY DONE Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, 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 (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that pers on, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or employment if

— (1) The flight is only

incidental to that business or employ ment; an d (2) The aircraft does not carry passengers or property

for compensation or hire. **2. BLISSFULLY DONE Seeks Exemption From The Requirements Of Section**  **91.7(a).** Section 91.7, 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.
**3. BLISSFULLY DONE**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 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, b y 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 na utical 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. BLISSFULLY DONE**  **Seeks Exemption From The Requirements Of Section**  **91.151(b).**Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b ) No person may begin a flight in a rotorcraft under VF R 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 20 minutes.
**5. BLISSFULLY DONE**  **Seeks Exemption From The Requirement Of Section**  **91.405(a).** Section 91.405, 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. BLISSFULLY DONE**  **Seeks Exemption From The Requirements Of Section**  **91.407(a)(1)** Section 91.407, ent itled 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 b y a person authorized under § 43.7 of this chapter.
**7. BLISSFULLY DONE**  **Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, 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 ha s 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. BLISSFULLY DONE**  **Seeks Exemption From The Requirem**  **ents Of Sections 91.417(a) And 91.417(b).** Section 91.417, 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 ti me 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 aspecified 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 b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and a ppliances. (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 aircr aft 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 retain ed until the defects are repaired and the aircraft is approved for return to service.
**C. The**  **Exte nt**  **Of Relief**  **BLISSFULLY DONE**  **Seeks An**  **d The**  **Reason BLISSFULLY**  **DONE Seeks The Relief.** 

**1. Exte**  **nt Of**  **Relief BLISSFULLY**  **DONE Seeks**  **An d**  **The Reason**  **BLISSFULLY DONE**  **Seeks Relief From Section 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 PI C of an aircraft in connection with any business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.
As set forth more fully

b elow, BLISSFULLY DONE subm its that an equivalent level of safety will be maintained because no PI C will be allowed to operate the 3DR Solo UAS un less that PIC has met certain flight

- hour and currency requirements, demons trating that the PI C is able to safel y operate either the 3DR Solo UAS in a manner co nsistent with the operations specifications as described in this e xemption, including evasive an d emergency m aneuvers, as well as maintaining app ropriate distances from people, vessels, vehicles and structures. Further, BLISSFULLY DONE s ubmits that all flights of the 3DR Solo UAS , condu cted by the PI C pursuant to the grant of this P etition: (1) will be incidental to BLISSFULLY DONE’ s business; and (2) will not c arry passengers or property for compensation or hire.

**2. Exte nt Of Relief BLISSFULLY DONE**  **Seeks And The Reason BLISSFULLY**  **DONE Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow BLISSFULLY DONE to determine that the 3DR Solo UAS is in airworth y con dition prior to every flight by ensuring that the UAS is i n compliance with the operating documents (i.e., BLISSFULLY DONE Aerial Operations Manual, Monthly Maintenance Lo g, and 3DR Solo In struction Manual). BLISSFULLY DONE seeks the requested relief because the 3DR Solo UAS do not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, BLISSFULLY DONE will ensure that the 3DR Solo UAS is in airworthy condi tion based upon its compliance with the operating documents (i.e., Monthly Mai ntenance Log, and 3DR Solo Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the co nditions and limitations below.**3. Extent**  **Of Relief**  **BLISSFULLY DONE**  **Seeks And**  **The Reason**  **BLISSFULLY DONE**  **Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 3DR Solo UAS , which utilize a barometric pressure sensor, GPS equipment, and a radio commun ications telemetry data link to downlink altitude information from the UA to the PI C at the ground co ntrol station (GCS). Since the FAA require s that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), BLISSFULLY DON E 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 so ught to the extent necessary

to comply with the applicable conditions and limitations stated below. As more fully

set forth herein, an equ ivalent level of safety will be maintained since the 3DR Solo UAS is equipped with a barometri c pressure sensor and GPS equipme nt, which automaticall y Ensures that a ground level pressure setting will be established prior to ea ch flight, and provides the PI C with altitude information of the UA on the heads

- up dis play of the GCS.
**4. Extent**  **Of Relief**  **BLISSFULLY DON**  **Seeks And**  **The Reason**  **BLISSFULLY DONE**  **Seeks Relief From Section 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 landin g and , assuming normal cruising speed, to fl y after that for at least 4.5 minutes. BLISSFULLY DONE 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 BLISSFULLY DONE proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the 3DR Solo UAS , the 3D R Solo UAS operating documents, and BLISSFULLY DONE’s proposed operating limitations, ensure that BLISSFU LLY DONE will safel y operate the battery powered 3DR Solo UAS during daylight hours in visual meteoro logical conditions (VMC), under visual flight r ules (VFR), with enough battery power to fly for a to tal duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.**5. Extent Of Relief BLISSFULLY DONE**  **Seeks And T he Reason**  **BLISSFULLY DONE**  **Seeks Relief From Sections 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) onl y apply to aircraft with an airworthiness certif icate, BLISSFULLY DONE requests relief from these Sections because the 3DR Solo UAS do not require airworthiness certif icates. As set forth more full y below, the 3DR Solo UAS meet s the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, BLISSFULLY DONE will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the BLISSFULLY DONE Aerial Operations Manual, Monthly Maintenance Log, and 3DR Solo In struction Manual). Furthermore, BLISSFULLY DONE will document and maintain all maintenance records for the 3 DR Solo UAS

. **D. The Reasons**  **Why Granting BLISSF ULLY DONE**  **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 b y allowing BLISSFULLY DONE to safel y, efficientl y, and economicall y perform aerial video and photography of construction sites, events , real estate, and landscape o ver certain areas of the Unite d States. Additionally , use of the 3DR Solo UAS will decrease con gestion of the NAS, reduce pollution, and provide significant benefi ts to the econom y. Notably, the benefits of BLISSFULLY DONE ’s proposed operation of the 3DR Solo UAS will be realized without implicating any p ri vacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The 3DR Solo UAS is batte ry powered and serve s 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 aeri al 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, b y reduci ng 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 do 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 flightoperations.

**2. The Public Will Benefit From The Safety And Effi ciency Of The 3DR Solo UAS.**  Conducting aerial acquisitions with the 3DR Solo UAS instead of manned aircraft, will greatl y benefit the public b y drastically reducing the levels of air and noise pollution generated during traditional aerial vid eo and stil l photograph y flight operati ons. By using battery

power and electric motors, the 3DR Solo UAS produce s no air pollution, and is the most viable environmentally

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft th at are ty

picall y 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 eli minates noise pollution, as the UA is propelled b y battery powered electric motors, rather th an an internal combustion engine. By using the 3DR Solo UAS to p erform 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 c rew members located onboard the aircraft, the 3DR Solo UAS (weighi ng less than 10 pounds and with no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 fe et, a length of 34 feet, and a fuel capacity of 180 gallons).

**2. 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 t o using manned aircraft to conduc t similar aerial operations. As such, operation of the 3DR Solo UAS will allow United States based companies, like BLISSFULLY DONE , to remain competitive and contribute to growth of the U.S. economy . Specificall y, with the rising cost of aviation fuel and the Environmental Protection Ag ency (“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 onl y 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 BLISSFULLY DONE , 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. econom y. Improved f inancial performance of U.S. companies, through commercial use of the 3DR Solo UAS , provides astable workforce that increases consumer spending; improves local, state, and federal tax

revenues; and allows comp anies 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, BLISSFULLY DONE ’ s proposed operation of the 3DR Solo UA S will not implicate any privacy

issues. Specifically , the 3DR Solo UAS will be o perated onl y in compliance with operating documents (i.e., the BLISSFULLY DONE Aerial Operations Manual, Monthly Maintenance Lo g, and 3DR Solo In struction Manual) which requires property owner i nvolvement as well as local law enforcement notification, and in accordance with th e Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why G ranting 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 Rul**  **e From Which BLISSFULLY DONE Seeks Exemption.**  **1. Reasons Why The 3DR Solo UAS 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, BLISSFULLY DONE ’ s operation of the 3DR Solo UAS meet the condition s 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, a nd 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 unma nned 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 air

space system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, BLISSFULLY DONE submits that the 3DR Solo UAS can operate safel y in the NAS pursuant t o F MRA 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 Demons trate Its Safe Characteristics.**  The 3DR Solo UAS do 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 The 3DR Solo UAS**  The technical specifications of the 3DR Solo UAS is set forth by the 3DR Solo UAS User Manual , att ached hereto as Appendix A

.

**ii. The**  **3DR Solo UAS Autonomous Flight**  **And Navigation Modes Enable The**  **UASs To Remain Within A Defined Operational Area.**  The 3DR Solo UAS may be op erated in both manual and fully autonomous flight modes. A complete description of the f light and navigational modes of the 3DR Solo UAS is provided in the 3DR Solo UAS User Manual , atta ched hereto as Appendix A.**iii. The 3DR Solo UAS Is**  **Designed For Aut**  **om atic Return To Home Poin**  **t Or Hover In The Event Of Loss**  **Of The Control Link Or Navigation.** When the Control L ink is lost, the 3DR Solo UAS will remain stati onary , in flight, for 3 seconds or more. If, after 3 seconds, the 3DR Solo UAS do not reacquire c ontrol link data from the GCS, the UAs will assume that the Control L ink 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 3DR Solo UAS is provided in the 3DR Solo UAS User Manual , attached hereto as Appendix A.

**iv. The 3DR Solo**  **GCS And Its Operation.** A complete description of the operation and specifications of the 3DR Solo GCS and flight control software is provided in the 3DR Solo User Manual , att ached hereto as Appendix A. **b. Flight Operations Of 3DR Solo UAS Is**  **Li mited To The Line Of Sight Of A**  **Cer tificated Pilot in Command With**  **A Safety Observer.** BLISSFULLY D ONE LLC operators operating under this exemption will be the only operators to act as a pilot in command (PI C) of the 3DR Solo UAS . Additionally , a safety observer will assist him during flight time. **c. Flights Of 3DR Solo UAS**  **Will Be Conducted Pursuant**  **To Specific Operating Limitations.**  In seeking this exemption, BLISSFULLY DONE 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 UASs weighing less than 55 pounds maximum gross weight: 3DR Solo UAS

. Proposed operations of an y 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 UAs may

not b e flown at an indicated airspeed exceeding 35 knots.4. The UA must be operated at an altitude of no more than 400 feet above

ground level (AGL). 5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate. 6. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . The SO and PIC must be able to communicate verbally at all times. 7. Electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C 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 PI C 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 Admi nistrator 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 prec edence 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 updat ed 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 affe ct 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 do cuments. 10. Prior to each flight the PI C 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 thenecessary 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 properl y 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 PI C who conducts the functional test flight mu st 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 operat or 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 op erating 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 UASs 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 operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y 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 onl y be conducted during dedicated training sessions. During training, proficiency , and experi ence - building flights, all persons not essential for flight operations areconsidered nonparticipants, and the PI C must operate the UA with appropriate

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 18. UAS operations may

not be cond

ucted 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. 19. 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. 20. 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 PI C. 21. 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. 22. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23. The PI C 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. 24. 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. 25. 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 theAdministrator or any law enforcement official upon request.

26. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 27. The UAS may

not be operated b y the PIC from any moving device or vehicle. 28. 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. I f 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 PI C 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 PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 29. 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. 30. 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 Section 61.113(a) And (b) Would Not Adversely Affect Safety.**  BLISSFULLY DONE submi ts 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 PI C has d emonstrated, b y meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the 3DR Solo UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering BLISSFULLY DONE ’s proposed area of operations, and the operating limitations set forth

- above; the p arallel nature of private pilot aeronautical knowledge requirements to those of commercial pilo t requirements (See Exemption No. 11062); and the airmanship skills necessary to safel y operate the 3DR Solo UAS, BLI SSFULLY DONE submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airm anship skills necessary for BLISSFULLY DONE ’s 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). BLISSFULLY DONE will n ot allow any PIC to operate the 3 DR Solo UAS unless that P IC has demonstrated, by meeting minimum flight

- hour requirements or the 3DR Solo UAS training and currency

requirements, that the PI C is able to safel y operate the 3DR Solo UAS in a manner consistent with this exemption, including evasive and emergency m aneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures. Specificall y, the PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (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 BLISSFULLY DONE ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained incompliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for th e purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 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 mu lti

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build profi ciency in the skills necessary to safel y 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, proficie ncy, 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. Accordingl y, BLISSFULLY DONE will ensure safe operations by not allowing an y P IC to operate the 3DR Solo UA S unless that PI C has demonstrated, by meeting m inimum flight

- hour and currency requirements, that the PI C is able to safely operate the 3DR Solo UAS in a manner consistent with the exemption, including evasive and emergency M aneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

**3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every

flight, BLISSFULLY DONE will ensure that the 3 DR Solo UAS is in an air worth y condition based upon the UAS’s compliance with its operating documents and as stated in the conditio ns and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in ci rcumstances 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 Ex emption From The Requirements Of Section 91.121**  **Would Not Adversely Affect Safety.** The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the 3DR Solo UAS will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring o f the flight path and altitude. This altitude information, combined with BLISSFULLY DONE ’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 Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the Aircraft. Prior to each flight, a zero alti tude initiation point is a utomatically

established b y the UASs 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. 1 1062, 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 Section 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 propos ed flight operations. Accordingly , BLISSFULLY DONE will ensure that it will safely operate the battery powered 3DR Solo UAS 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 fl y 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 b y 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 3DR Solo UAS provide audible and visual warnings to the PI C 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 criticall y l ow battery level, the 3DR Solo UAS will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151establish that safety is not adversel y affected when the technical characteristics and

operating limit ations 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, 111 58, 11159, 11160, 11161).

**6. Reasons Why An Exemption From The Requirements Of Sections 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, BLISSFULLY DONE submits that the equ ivalent 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 BLISSFULLY DONE will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and p ractices prescribed in the operating documents (i.e., the BLISSFULY DONE Aerial Operations Manual, Monthly Maintenance Lo g, and 3DR Solo Instruction Manual). Furthermore, BLISSFULLY DONE will do cument and maintain all maintenance records for the 3DR Solo UAS

. Since the 3DR Solo UAS will be inspected as prescribed b y the operating documents, BLISSFULLY DONE LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 1.409(a)(2). A cop y of the 3DR Solo User Manuals are attached hereto as Appendix A

. Likewise, the exemption sought will not adversel y affect safety becau se BLISSFULLY DONE 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 l evel of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR Solo UAS will be pe rformed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significant ly , previous exemptions granted b y 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 adversel y affected when the technical characteristics and operating limitations of the UAS are considered.In consideration of BLISSFULLY DONE ’s proposed operating limitations, the operating

documents, and the technical aspects of the 3DR Solo UAS , BLISSFULLY DONE 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 previousl y granted relief specific to UAS in circumstances similar, in all mat erial 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 S afe 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, BLISSFU LLY DONE requests that the FAA prescribe special conditions for the intended operation of the 3 DR 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 wi ll permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y 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 air worthiness certification in accordance with an y requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special c onditions 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 featur es 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 for Leading Edge’s 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 es tablished 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).

 **A Summary That Can Be Published In The Federal Register, stating: The** 

**Rule s From Which BLISSFULLY DONE**  **Seeks Exemption:** BLISSFULLY DONE 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 BLISSFULLY DONE**  **Seeks:** This exemption will permit BLISSFULLY DONE to commercially operate an Unmanned Aircraft System (UAS) for the purpo se of conducting aerial video and photography over certain areas of the United States. **• Any Additional Information, Views, Or Arguments Available To Support**  **BLISSFULL Y DONE**  **’s 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 C ertain UAS may

operate safel y in the NAS. As such, BLISSFULLY DONE ’s requ est 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 othe rwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in d etail above, BLISSFULLY DONE will operate the 3DR Solo UAS 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 f orth herein, BLISSFULLY DONE seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Mo dernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3DR Solo UAS commerciall y, 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

allow ing BLISSFULLY DONE to safe ly , efficientl y, and economi call y operate the 3DR Solo UAS commerciall y within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, BLISSFULLY DONE respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.450(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit L eading Edge to operate the 3DR Solo UAS commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States. Dated July

9, 2015 Respectfully

submitted, HUE T. LAM BLISSFULLY DONE FOUNDER/OWNER/OPERATOR 9307 New Hampshire Ave Silver Spring MD 20903 \240

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- 7772 Blissfullydone@gmail.com Appendices:
A

– 3DR Solo Manual