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: BLISSFULLY DONE

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS

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) CONCERNING COMMERCIAL OPERATION OF 3DR Solo

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION 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 

INTRODUCTION AND INTERESTS PETITIONER.............................................4 

BACKGROUND.......................................................................................................4 

BASIS FOR PETITION............................................................................................5 

NAME AND ADDRESS OF PETITIONER............................................................6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BLISSFULLY DONE 

SEEKS EXEMPTION...............................................................................................7 

THE EXTENT OF RELIEF BLISSFULLY DONE LLC SEEKS AND THE 

REASON BLISSFULLY DONE SEEKS THE RELIEF......................................10 

THE REASONS WHY GRANTING BLISSFULLY DONE’S REQUEST WOULD 

BE IN THE PUBLIC INTEREST ............................................................................12 

THE REASONS WHY GRANTING THE EXEMPTION TO BLISSFULLY DONE 

WOULD NOT ADVERSELY AFFECT SAFETY................................................14 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.....25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT BLISSFULLY DONE REQUEST...............................................25 

CONCLUSION.......................................................................................................28

APPENDICES............................................................................... 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 System 

NOTAM Notice to Airman 

PIC Pilot In Command Section 333 

FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System V

FR Visual Flight Rules 

VLOS Visual Line 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 System (3DR SOLO) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit BLISSFULLY 

DONE to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography 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. The objective 

of BLISSFULLY DONE is to provide high quality imaging for a variety of commercial, public 

and residential uses, specifically targeting:

 Aerial event photography

 Motion Picture Filming

 Appraisals

 Real-estate marketing

 Aerial acquisitions used for inspections of public and private structures

BACKGROUND

Unmanned Aircraft Systems: 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 systems. 

The 3DR Solo has a maximum gross weight of approximately 3.3lbs. while having a dimension 

of 4x10x4.5’’ with a maximum speed of approximately 55mph and a maximum flying height of 

400'. The 3DR Solo is equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors.
The 3DR Solo UAS that will be operated by BLISSFULLY DONE will be registered 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, BLISSFULLY 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 Systems, hereby petitions the Administrator to 

commercially operate the 3DR Solo UAS in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, 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. 

Accordingly, 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 only 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 Instruction 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: Pilot in command, is requested by BLISSFULLY DONE to the extent necessary

to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as 

an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a 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 14 
C.F.R. Part 21, Subpart H. As such, BLISSFULLY DONE will ensure that the 3DR Solo UAS

are in an airworthy 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 PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with 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. 

Additionally, BLISSFULLY DONE seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel 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

power to fly for a total duration of approximately 13.5 minutes to the first point of intended 

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

In accordance with 14 C.F.R. § 11.81, BLISSFULLY DONE provides the following 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 (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act 

as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft 

in connection with any business or employment if—

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

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

compensation or hire. 

2. 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, by reference to an 

altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along 

the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in 

paragraph (a)(1)(i) of this section, the current reported 

altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the 

elevation of the departure airport or an appropriate 

altimeter setting available before departure.

4. 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 VFR conditions

unless (considering wind and forecast weather conditions) there is enough

fuel to fly to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 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, entitled Operation after maintenance, preventive

maintenance, rebuilding, or alteration, subsection (a)(1), states the

following:

(a) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration

unless—

(1) It has been approved for return to service by a person

authorized under § 43.7 of this chapter.

7. 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 has been approved for return to service by a person

authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness

certificate in accordance with part 21 of this chapter.

8. BLISSFULLY DONE Seeks Exemption

From The Requirements 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 time in service of the airframe, each engine,

each propeller, and each rotor.

(ii) The current status of life-limited parts of each

airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on

the aircraft which are required to be overhauled on a
specified time basis.

(iv) The current inspection status of the aircraft,

including the time since the last inspection required by

the inspection program under which the aircraft and its

appliances are maintained.

(v) The current status of applicable airworthiness directives

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

of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves

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

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this

chapter for each major alteration to the airframe and

currently installed engines, rotors, propellers, and

appliances.

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

periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall 

be retained until the work is repeated or superseded by other work 

or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall 

be retained and transferred with the aircraft at the time the aircraft 

is sold.

(3) A list of defects furnished to a registered owner or operator

under § 43.11 of this chapter shall be retained until the defects

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

C. The Extent Of Relief BLISSFULLY DONE Seeks And The Reason BLISSFULLY 

DONE Seeks The Relief.

1. Extent Of Relief BLISSFULLY DONE Seeks And 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 PIC of an aircraft in connection with

any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for compensation

or hire.

As set forth more fully below, BLISSFULLY DONE submits that an equivalent level of safety 

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

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

safely operate either the 3DR Solo UAS in a manner consistent with the operations specifications 

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

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, BLISSFULLY DONE submits that all flights of the 3DR Solo UAS, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to BLISSFULLY DONE’s 

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent 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 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., BLISSFULLY DONE Aerial Operations Manual, Monthly

Maintenance Log, and 3DR Solo Instruction Manual).

BLISSFULLY DONE seeks the requested relief because the 3DR Solo UAS do not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

BLISSFULLY DONE will ensure that the 3DR Solo UAS is in airworthy condition based upon 

its compliance with the operating documents (i.e., Monthly Maintenance Log, and 3DR Solo

Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition

for safe flight, as stated in the conditions and limitations below.
3. Extent Of Relief 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 communications telemetry data link to downlink altitude information from the UA to 

the PIC at the ground control station (GCS). Since the FAA requires that any altitude information

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), BLISSFULLY DONE seeks the requested relief because the 3DR Solo UAS

Altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or 

Field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the 3DR Solo

UAS is equipped with a barometric pressure sensor and GPS equipment, which automatically 

Ensures that a ground level pressure setting will be established prior to each flight, and provides 

the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief 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 landing and, assuming normal 

cruising speed, to fly 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.

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

Solo UAS operating documents, and BLISSFULLY DONE’s proposed operating 

limitations, ensure that BLISSFULLY DONE will safely operate the battery powered 3DR 

Solo UAS during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes.
5. Extent Of Relief BLISSFULLY DONE Seeks And The 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) only

apply to aircraft with an airworthiness certificate, BLISSFULLY DONE requests relief

from these Sections because the 3DR Solo UAS do not require airworthiness certificates. As set 

forth more fully below, the 3DR Solo UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, 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 Instruction Manual). Furthermore, BLISSFULLY DONE will document and 

maintain all maintenance records for the 3 DR Solo UAS.

D. The Reasons Why Granting BLISSFULLY 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 by allowing BLISSFULLY DONE 

to safely, efficiently, and economically perform aerial video and photography of 

construction sites, events, real estate, and landscape over certain areas of the United States.

Additionally, use of the 3DR Solo UAS will decrease congestion of the NAS, reduce pollution,

and provide significant benefits to the economy. Notably, the benefits of BLISSFULLY DONE’s

proposed operation of the 3DR Solo UAS will be realized without implicating any privacy

issues.

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

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

to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR 

Solo UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground.

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

around airports caused by arriving and departing aircraft will be reduced. The 3DR Solo UAS 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 flight
operations.

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

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

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

traditional aerial video and still photography flight operations. By using battery power and 

electric motors, the 3DR Solo UAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

aircraft that are typically utilized for aerial video and photography, while burning approximately

20-30 gallons per hour of leaded aviation fuel. The 3DR Solo UAS, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the 3DR Solo UAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the 3DR Solo UAS (weighing less than 10 

pounds and with no fuel on board), has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned aircraft that typically conduct 

similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

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 to 

using manned aircraft to conduct 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. Specifically, with the rising cost

of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and

alternative technology in order to remain competitive. Operating the battery powered 3DR Solo 

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

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

traditional manned aircraft.

By operating the 3DR Solo UAS, companies such as 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. economy. Improved financial

performance of U.S. companies, through commercial use of the 3DR Solo UAS, provides a 
stable workforce that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, BLISSFULLY DONE’s proposed operation of the 3DR Solo UAS will not implicate 

any privacy issues. Specifically, the 3DR Solo UAS will be operated only in compliance with 

operating documents (i.e., the BLISSFULLY DONE Aerial Operations Manual, Monthly

Maintenance Log, and 3DR Solo Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

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

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which 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 conditions of FMRA Section 333, and will not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users of

the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA

Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

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

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

section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination

under subsection (a), the Secretary shall determine, at a minimum--
(1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create

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

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems

identified under paragraph (1).

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

section that certain unmanned aircraft systems may operate safely in the

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

operation of such aircraft systems in the national airspace system.

In seeking this exemption, BLISSFULLY DONE submits that the 3DR Solo UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the 3DR Solo UAS; (b) the pilot certification requirement; and (c) the specific 

operating limitations.

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

The 3DR Solo UAS 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, attached 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 operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the 3DR Solo UAS is provided in

the 3DR Solo UAS User Manual, attached hereto as Appendix A.
iii. The 3DR Solo UAS Is Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the 3DR Solo UAS will remain stationary, in flight, for 3 seconds

or more. If, after 3 seconds, the 3DR Solo UAS do not reacquire control link data from the GCS, 

the UAs will assume that the Control Link is lost and the UAs will return to the home position 

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the 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, attached hereto as Appendix A.

b. Flight Operations Of 3DR Solo UAS Is Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

BLISSFULLY DONE LLC operators operating under this exemption will be the only operators 

to act as a pilot in command (PIC) 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 any other aircraft will require a new petition or a petition to amend this 

grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

3. The UAs may not be 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 PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued airman

medical certificate.

6. All operations must utilize a safety observer (SO). The SO may be used to

satisfy the VLOS requirement as long as the PIC always maintains VLOS

capability. The SO and PIC must be able to communicate verbally at all times.

7. Electronic messaging or texting is not permitted during flight operations.

The PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the SO can

perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with

seeing and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible

during UAS operations and made available to the Administrator upon request. If

a discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the
necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component,

must undergo a functional test flight. The PIC who conducts the functional test

flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record

keeping requirements, in accordance with the operating documents.

Maintenance, inspection, alterations, and status of replacement/overhaul

component parts must be noted in the aircraft records, including total time in

service, description of work accomplished, and the signature of the authorized

person returning the UAS to service.

15. Each 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 PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted

under the terms of the exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and

experience-building flights, all persons not essential for flight operations are
considered nonparticipants, and the PIC must operate the UA with appropriate

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

18. UAS operations may not be conducted during night, as defined in 14 C.F.R.

§ 1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

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 PIC.

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 PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

23. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power

remaining.

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 the
Administrator or any law enforcement official upon request.

26. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

27. The UAS may not be operated by 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. If a situation arises where

nonparticipating persons leave such protection and are within 500

feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where

the owner/controller of such vessels, vehicles or structures has

granted permission and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it

does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential

persons do not present an undue hazard to those persons per §

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 submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR Solo 

UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the 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 parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the 3DR Solo UAS, BLISSFULLY DONE

submits that the additional manned airmanship experience of a commercially certificated

pilot would not correlate to the airmanship 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 not allow any PIC to operate the 3 DR Solo UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the 3DR Solo UAS 

training and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5

hours of those hours as a UAS pilot operating the same make and model of UAS to be used

for operations under the exemption). In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that

was obtained in compliance with applicable regulations will ensure an equivalent level of

safety during BLISSFULLY DONE’s proposed operations.

The Administrator has held that prior documented flight experience that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 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 multi-rotor UAS. Prior to operations under Exemption No. 11062, the

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

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather than additive; i.e. 5 hours make and model time may be

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

total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). The FAA finds that at a minimum, the flight-hour requirements in

Exemption No. 11062 are appropriate to practice and build proficiency in the skills

necessary to safely conduct the petitioner’s proposed operations. The FAA also finds

that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

experience-building flights can also be conducted under the grant of exemption to

accomplish the required flight time. During training, proficiency, and experience

building flights the PIC is required to operate the UA with appropriate distances in

accordance with 14 C.F.R 91.119.

Accordingly, BLISSFULLY DONE will ensure safe operations by not allowing any PIC to 

operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate the 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.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because

prior to every flight, BLISSFULLY DONE will ensure that the 3 DR Solo UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS,

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,
11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

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

the altitude information of the 3DR Solo UAS will be provided to the PIC via GPS equipment 

and a radio communications telemetry data link, which downlinks from the UA to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined with 

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 by GPS equipment installed onboard the Aircraft. Prior to each 

flight, a zero altitude initiation point is automatically established by 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. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of 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 proposed 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 fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the 3DR Solo UAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, will 

ensure an equivalent level of safety established by 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 PIC at 

the GCS when the UAs experiences low battery voltage, the first warning occurring at 

approximately 33% remaining battery power, and again at approximately 10% remaining battery

power. At the critically low battery level, the 3DR Solo UAS will descend and land 

automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151
establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief

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

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

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of 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 equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because 

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 operating documents (i.e., the BLISSFULY DONE Aerial Operations Manual, Monthly

Maintenance Log, and 3DR Solo Instruction Manual). Furthermore, BLISSFULLY DONE will 

document and maintain all maintenance records for the 3DR Solo UAS.

Since the 3DR Solo UAS will be inspected as prescribed by the operating documents, 

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 copy of the 3DR Solo User Manuals are attached 

hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because 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 level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

3DR Solo UAS will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b) establish that safety is not

adversely affected when the technical characteristics and operating limitations of the UAS

are considered.
In consideration of 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 previously granted relief specific to UAS in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

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

11157, 11158, 11159, 11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, BLISSFULLY DONE requests 

that the FAA prescribe special conditions for the intended operation of the 3DR Solo UAS,

which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) 

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

& (b). Such special conditions will permit safe operation of the UAs for the limited purpose of 

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

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

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

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

certification in accordance with any requirements that must be established for the safe operation 

of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the 3DR Solo UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

contain adequate or appropriate safety standards, due to the novel or unusual design features of 

the aircraft. Section 21.16, entitled Special Conditions, states the following:

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

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in

the regulations.
See 14 C.F.R. § 21.16.

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

prescribe special conditions 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 established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) 

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

& (b).

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

Rules 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 purpose of conducting aerial video and 

photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To

Support BLISSFULLY 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

Certain UAS may operate safely in the NAS. As such, BLISSFULLY DONE’s 

request for exemption may be granted pursuant to the authority of FMRA Section 333 

and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, 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 forth herein, BLISSFULLY DONE seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the 3DR Solo UAS commercially, without an airworthiness certificate, for the 

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

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing BLISSFULLY DONE to safely, efficiently, and economically operate 

the 3DR Solo UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, 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 Leading Edge to operate the 3DR Solo 

UAS commercially 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\240-381-7772

Blissfullydone@gmail.com

Appendices:

A – 3DR Solo Manual