Christopher	S.	Hebert

2308	Century	Park	Blvd.

Austin,	TX		78727

512-388-3745	(Home)

email:	chris.s.hebert@gmail.com	

U.S.	Department	of	Transportation,	Docket Operations

West	Building	Ground	Floor,	Room	w12-140

1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590	

Dear	Recipient,

In	accordance	with	the	FAA’s	Guidelines	for	Submitting	a	Petition	for	Exemption	

under	section	333	of	the	FAA	Modernization	and	Reform Act	of	2012,	I	Christopher	Hebert,	

referred	to	as	the	petitioner,	kindly	request	exemption	from	the	following	sections	of	

Title	14,	Code	of	Federal	Regulations	§§	

14	C.F.R.	61.113(a)	

14	C.F.R.	61.113(b)	

14	C.F.R.	91.119(c)	

14	C.F.R.	91.121	

14	C.F.R.	91.151(a)	

14	C.F.R.	91.405(a)	

14	C.F.R.	91.407(a)(1)	

14	C.F.R.	91.409	(a)(1)	

14	C.F.R.	91.409(a)(2)	

14	C.F.R.	91.417(a)	&	(b)	

I	the	Petitioner	seek	relief	from	the	listed	regulations	in	order	to	operate	small unmanned	

aircraft	systems	(UAS)	commercially	in	airspace	regulated	by	the	Federal	Aviation	

Administration	(FAA)	for	the	purposes	of	aerial	photography,	cinematography,	videography	and	

other	aerial	operations	that	can	be	performed	safely	and	more	cost	effectively	with	the	use	of	

small	UAS	at	low	altitude	within	the	U.S.	national	airspace	system	as	compared	to	a	manned	

aircraft.	Safe	UAS	operations conducted	within	FAA	guidelines	will	support	local	business	and	
create	positive awareness	in	the	community	by	providing	UAS	alternatives	to	previous	methods	

of	larger,	more	dangerous	aircrafts.	Compensated	tasks	will	be	conducted	only	at	the request	of	

and	with	authorization	and	permission	of	clients	or	their	authorized	agents in	compliance	with	

privacy	Laws	and	FAA	Regulations.	In	addition,	only	the authorized	individual/Operator,	

Christopher	Hebert	will	conduct	UAS	flights	within	and	under	the	conditions	outlined	herein	or	

as	may	be	established	by	the	FAA	as	required	by	Section	333.	

The	FARs

I,	the	petitioner	seek	exemption	from	the	above	mentioned	FARs	for	the	following	reasons:

61.113(a)	&	(b)	

The	petitioner	requests	relief	in	order	to	facilitate	the	utilization	of	an	experienced	

UAS	operator	with	the	addition	of	a	trained	observer.	All	pre-flight	inspection,	maintenance	and	

flight	logs	will	be	saved	and	made	available	to	the	FAA	and	Secretary	of	Transportation	(SoT)	for	

review;	with	the	purpose	of	safely	integrating	civil	UAS	operation	in	the	National Airspace	

System.	The	petitioner	will	conduct flights	as	the	authorized	UAS	Operator.	The	UA	controlled	

by	the	Operator	will perform	at	altitudes	well	below	the	permissible	limits	for	other	civil	

aircrafts,	eliminating	the	risk	to	other	aircrafts.	

91.119(c)	

As	discussed	in	Exemption	11138	(DOUGLASTRUDEAU),	operations	conducted	closer	than	500	

feet	to	the	ground	may	require	that	the	UAS	be	operated	closer	than	500	feet	to	essential	

persons,	or	objects	that	would	not	be	possible	without	additional relief.	The	petitioner	requests	

modification,	waiver	or	exemption	and	clarification	concerning	the	terms	“congested	areas”	

and	“densely	populated”.	The	petitioner	requests	waiver	for	this	condition	to	allow	reasonable	

and	responsible	operations	in	areas	of	subdivisions	and	neighborhoods	if	required.	The	

petitioner	will	primarily	operate	the	UAS	between	ground	level	and	400	feet.	The	UAS	will	be	

operated	over	designated	properties	with	the	consent	of	the	local	municipality	or	their	

designated	agent	and	while	maintaining	a	safe	distance	from	persons.	The	petitioner	will	

compile flight	data	from	the	logs.	This	data	may	assist	the	FAA	in	development	of	regulations

for	commercial	operations	in	low-risk,	controlled	environments.	

91.121	

As	discussed	in	Exemption	11138	(DOUGLASTRUDEAU)	is	inapplicable	since	the UAS	does	not	

have	an	altimeter	and	instead	utilizes	electronic	GPS	with	a	barometric sensor	for	altitude	

information.	Altitude	information	is	generated	by	the	UA	on	board	computing	system,	its	then	

received	and	displayed	at	the	operators	ground	station.	
91.151(a)	

As	discussed	in	Exemption	11136	(ADVANCEDAVIATION	SOLUTIONS	LLC)	prior	relief	has	been	

granted	for	manned	aircraft	to	operate	at	less	than	the	prescribed	minimums,	including	

Exemption	Nos.	2689,	5745,	and	10650.	In	addition,	similar	UAS	specific	relief	has	been	granted	

in	Exemption	Nos.	8811,	10808,	and	10673	for	daytime,	VFR	conditions.	The	UAS	provides	

battery	power	remaining	in	percent	to	the	PIC.	The	UA	batteries	provide	approximately	25

minutes	of	powered	flight.	Information	provided	in	the	operating	documents	discusses	

procedures	regarding	remaining	battery	power	management.	Those	documents	contain	a	

condition	in	which	the	PIC	will	initiate	a	landing	procedure	when	battery	remaining	reaches	a	

specified	level.	Given	the	limitations	on	proposed	operations	and	the	location	of	those	

proposed	operations,	The	FAA	found	that	a	reduced	minimum	power	reserve	for	flight	in	

Daytime VFR	conditions	was	reasonable.	

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

As	discussed	in	Exemption	11138	(DOUGLASTRUDEAU),	The	petitioner	proposes to	inspect	and	

ensure	that	the	UAS	is	in	a	condition	for	safe	flight	in	accordance	with	the	operating	

documents.	The	FAA	found	that	adherence	to	the	petitioner’s	operating	documents	and	the	

conditions	and	limitations	specified,	describing	the	requirements for	maintenance,	inspection,	

and	record-keeping,	were	sufficient	to	ensure	that	safety	would	not	be	adversely	affected.	

Areas	of	interests	for	UAS	commercial	use	

Aerial	video	and	or	photography	for	real	estate,	architecture,	agriculture,	land	surveying,	

engineering,	television,	cinematography,	and	news	media.	Aerial inspections	and or	

photography	of	residential	or	commercial	structures,	utility	infrastructures	including	but	not	

limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.	In	addition,	live	streaming	aerial	

video	in	efforts	assist	in	search	and	rescue	operations	ONLY	at	the	legal	authorization	of	local	

authorities	or	government.	

The	UAS

The	petitioner	seeks	exemption	to	operate	a	UA	Multifunctional	Quad-rotor	Systems	by	

3DR (Solo)	for	compensation	or	hire within	the	National Airspace	System.	The	3DR	Solo	is	a

highly	successful	consumer	grade	small	rotor	crafts	in	the	quadcopter	configuration.	They	are

vertical	takeoff	and	landing	(VTOL)	UAS	with	a	Ground	Control	Station	(GCS)	utilizing	an	

electronic	tablet or	cellular	smart	phone.	The	system contains internal	measuring	units (IMU)	

with	integrated	barometric	sensors	augmented	with	global	positioning	systems	(GPS)	to	

maintain	their	geospatial	orientation	and	position.	Real	time	video	control	station	allows	the	

operator	and/or	PIC	to	monitor	battery	level, GPS	signal	strength,	altitude,	distance	from	PIC,	

camera	imagery,	and	control	camera	angle.	Integrated	failsafe mode	Return	to	Home	aid	and	
assist	operations	for	either	loss	of	RC	or	GPS	signal.		The onboard	flight	controllers	will	warn	the	

pilot	via	telemetry	and	external	lighting	cues	before	reaching	a	low	battery	state.	The	UAS	has	

the	capability	to	abort	flights	and	return	to	home	safely	in	case	of	any	unpredicted	obstacles	or	

emergencies.	

3DR	Solo

Height:	10in	/	25cm

Width	(motor	to	motor):		18in	/	26cm

Weight (with	battery	installed):	3.30lb /	15kg

Intelligent	Flight	Battery:	5200mAh	25min	Flight Time

Max	Flight	Speed:		55mph

Operating	Frequency:	2.4GHz	ISM

Key	Features:

Live	real-time	flight	data

Intelligent	Orientation	Control	(IOC),	GPS,	and	Return	to	home	failsafe

Self-tightening	Propellers

Dynamic	home	point	orientation

Intelligent	Flight	Battery	includes	capacity	data,	over	charge/discharge	protection,	maintenance	

data.	
Risk	Mitigation

Aerial	Safety	is	of	the	utmost	concern.	I	the	petitioner	have	reviewed	FAA exemptions	

reference’s	1-3	Conditions	and	Limitations	section	and	believes	that	the procedures	specified	

therein	are	reasonable	and	will	be	utilized	in	order	to	manage and	mitigate	risk	and	ensure	

public	safety.	A	preflight	checklist	is	being	developed	and	employed	to	ensure	that	the	UA	

airworthiness	and	will	be	verified	before	each	launch.	Airworthiness	will	be	maintained	by	

performance	of	routine	inspections before	each	flight,	maintaining	flight	and	maintenance	logs.	

These	documents	will	be made	available	upon	request	to	assist	in	future	implementation	of	

safety	standards	and	regulations.	The	petitioner	will	only	operate	the	UAS	over	designated	

properties	with	the	clients	consent.	Flight	plans	will	be	predetermined	to	limit	the	UASs	flight	

time and	limit	safety	concerns.	The	petitioner	will	take	into	account	distance	from	persons and	

potential	flight	obstacles	prior	to	operating	the	UAS.	UAS	operations	will	always be	within	VLOS	

of	the	PIC	and	the	observer.	The	petitioner/Operator	will	carry	suitable	insurance	for	the	

protection	of	the	Operator	and	the	Public	thus	providing	positive	and	responsible	UAS	

operations	in	the	community.	

Developing	Flight	Check	List	

On	hand	3DR	Solo official	manuals	and	procedures

Reference	B4UFLY	Smartphone App

Optimal	weather	conditions	have	been	verified	

Location	scouting	including	landing	and	takeoff	distance

Establish	reasonable	low	altitudes	to	ensure	safety	of	civil	aircrafts

Obtain	consent	of	all	persons	involved	in	filming	including	land	and	property	owners

Visual	Inspection	of	aircraft

Prepare	flight	logs

Flight	battery	and	transmitter	battery	at	full	charge

Propellers	are	in	proper	airworthy	conditions	and	are	securely	locked	and	mounted

Perform	sensor	and	compass	calibration

3DR Ground	Station	activated	

Clear	uninterrupted	communication	between	UAS	and	remote

Visually	inspect	and	ensure	all	motors	are	running	properly	and	rotate	evenly

Ascend	10ft	for	control	inspections:	Forward,	Back,	Left,	Right,	Hover

Visually	inspect	for	controlled	flight	performance along	with	ground	station	data

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

Maximum	flight	time	for	each	operational	flight	will	be	no	more	than	30	minutes

Flights	will	be	terminated	at	no	less	than	25%	battery	power	reserve	should	that	occur	prior	to	

the	30-minute limit

Flights	will	be	operated	at	an	altitude	below	400	feet AGL,	and	not	more	than	200	feet above	an	

elevated	platform	from	which	filming	is	planned

Upon	completion	of	flight	operations	perform	visual	inspection	

Record	all	flight	data	into	the	Flight	Logs

Perform	regular	scheduled	maintenance
Public	interest	

Choice	of	UAS	over	a	manned	aircraft	would	enhance	safety	and	reduce	the environmental	

impact	as	compared	to	similar	operations	conducted	with	manned	aircraft	of	greater	

proportions,	carrying	a	crew	and	flammable	fuel.	Additionally,	the use	of	the	UAS	in	order	to	

facilitate	commerce	could	lead	to	economic	growth.	Operations	for	this	petition	will	enable	

service	for	property	owners	or	their	designees seeking	an	enhanced	perspective	for	

characteristics,	amenities,	and	benefits	of	their	desired	photographic	subjects	that	cannot	be	

displayed	through	ground	level videography/photography.	Crop	surveying	applications	could	

lead	to	decreased	use	of	pesticides	and	fertilizer	and	conservation	of	water	as	well	as	increased	

crop	yields	and	decreased	costs.	Aerial	surveying	and	inspections	can	increase	planning	

efficiency,	improve	resource	estimations,	and	reduce	risks	to	personnel	and	property.	The

petitioner	will	provide	clients	with	photographic	data	for	these	purposes	on	a	‘for	hire’ basis	

acting	as	an	independent	contractor.	Flight	data	including	UA	flight	time,	Control	Unit	operation	

time,	incident,	accident,	and	details	concerning	any	deviations from	normal	operations	will	be	

available	upon	request	for	use	in	collecting	data regarding	the	use	of	UAS	as	part	of	these	

applications.	

Conclusion

The	petitioner	is	requesting	this	exemption	for	the	purposes	of	aerial	photography,	

cinematography,	and	videography.	The	petitioner	wishes	to	provide	safe	and	reliable services	

for	businesses	such	as	but	not	limited	to,	real	estate,	architecture,	agriculture,	land	surveying,	

engineering,	television,	cinematography,	and	news	gathering.	By	providing	safe	deployments	

and	cost	effective	operations	through	UAS	the	petitioner	offering	a	much	needed	and	desired	

service	in	the	community.	The	petitioner	can	ensure	adherence	to	standards	and	protocols	and	

can	develop	and	refine	generally	applicable	safety	guidelines	and	processes.	The	primary	

purpose	of	seeking	this exemption	is	to	obtain	the	capability	to	offer	UAS	services	while	

remaining	in	compliance	with	FAA	regulations.	The	petitioner	has	over	3 years	of	experience	in	

the UAS	and	radio	control	model	aircraft	hobbies	and	wishes	to	move	forward	in	this ever	

growing	industry.	

Respectfully	Submitted,	

Christopher	Hebert