1

September 8, 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: PRECISE CONCEPTS

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THECODE

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 LAW112-95)

Harry Samaniego

President

Precise Concepts

2234 N. FEDERAL HWY - SUITE 389

BOCA RATON, FL 33431

P-561-452-5859

harry@preciseconcepts.com
2

TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS. .................................................................................3

SUMMARY.......................................................................................................................... 4

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

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

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

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

Page

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE PRECISE CONCEPTS 

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

THE EXTENT OF RELIEF THE PRECISE CONCEPTS SEEKS AND THE REASON THE

PRECISE CONCEPTS SEEKS THE RELIEF..................................................................10

THE REASONS WHY GRANTING THE PRECISE CONCEPTS’S REQUEST WOULD BE 

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

THE REASONS WHY GRANTING THE EXEMPTION TO THE PRECISE CONCEPTS 

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERALREGISTER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE PRECISE CONCEPTS’S REQUEST... .................................................. 25

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

APPENDICES......................................................................................... 26
3

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

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Precise Concepts hereafter referred to as The PRECISE CONCEPTS 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 (DJI Phantom 3) pursuant to Section 333 of the FAA 

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

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

conducting aerial video and photography of construction sites, residential and commercial real

estate, civil landscapes and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THEPETITIONER

The PRECISE CONCEPTS has for over thirty-five years provided their clients (which include

private sector businesses and non-profits, along with local state and federal agencies) with

expertise and knowledge in video and multimedia marketing, advertising, public relations and 

training using advanced technologies and solutions. The PRECISE CONCEPTS has worked on

thousands of productions over the past 35 years in all types of locations with a perfect client

and employee safety record. In the past we have supplied our clients aerial video and 

photography using commercial aircraft. The objective of The PRECISE CONCEPTS and our 

Unmanned Aircraft System (3dr Solo) aerial operations is to provide a more affordable, highquality production system for a variety of governmental, commercial, public, and residential 

uses, specifically targeting

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Weddings

• Commercials

My staff has safely flown small RC electric quad copters recreationally for approximately 2years 

without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, UAS

The PRECISE CONCEPTS seeks an exemption to operate 3DR Solo system for compensation. 

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 3.9 lb. while having a diagonal dimension 

of 23.2”, a maximum speed of approximately 16.4’fps and a maximum flying height of 400'.

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

electric motors.
5

The 3DR Solo that will be operated by The PRECISE CONCEPTS 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, The PRECISE CONCEPTS, 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 DJI Phantom 3, UAS in the National AirspaceSystem

(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, The PRECISE CONCEPTS 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, The PRECISE CONCEPTS 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.

The PRECISE CONCEPTS submits that the requested relief is proper since an equivalent level 

of safety will be ensured. The PRECISE CONCEPTS will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and 3DR Solo Instruction Manual). Furthermore, The PRECISE 

CONCEPTS 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 The PRECISE CONCEPTS 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 flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom UAS in a

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

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

The PRECISE CONCEPTS 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, The PRECISE CONCEPTS submits 

that they will ensure that the 3DR Solo UAS is in an airworthy condition, prior to every

flight, by determining that the UAS 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.
6

The PRECISE CONCEPTS 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 The PRECISE CONCEPTS’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, The PRECISE CONCEPTS seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. The PRECISE CONCEPTS 

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 23 minutes. Battery power indicators are

also able to show exactly how much battery power is left, as well as how much time is 

needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, The PRECISE CONCEPTS provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

Harry Samaniego

President

Precise Concepts

2234 N. FEDERAL HWY - SUITE 389

BOCA RATON, FL 33431

P-561-452-5859

harry@preciseconcepts.com
7

B. The Specific Sections Of 14 C.F.R. From Which The PRECISE CONCEPTS Seeks 

Exemption.

1. The PRECISE CONCEPTS 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. The PRECISE CONCEPTS 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. The PRECISE CONCEPTS Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, inpart:

(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.
8

4. The PRECISE CONCEPTS 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. The PRECISE CONCEPTS 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. The PRECISE CONCEPTS 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. The PRECISE CONCEPTS 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.
9

8. The PRECISE CONCEPTS 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.
10

(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 The PRECISE CONCEPTS Seeks And The Reason The PRECISE 

CONCEPTS Seeks The Relief.

1. Extent Of Relief The PRECISE CONCEPTS Seeks And The Reason The PRECISE 

CONCEPTS 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, The PRECISE CONCEPTS 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, The PRECISE CONCEPTS 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 The

PRECISE CONCEPTS’s business; and (2) will not carry passengers or property for

compensation or hire.
11

2. Extent Of Relief The PRECISE CONCEPTS Seeks And The Reason The PRECISE 

CONCEPTS 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 The PRECISE CONCEPTS to determine that the 3DR Solo UAS are in

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

operating documents (i.e., the PRECISE CONCEPTS Aerial Operations Manual, Monthly 

Maintenance Log, and 3DR Solo Instruction Manual).

The PRECISE CONCEPTS 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, The 

PRECISE CONCEPTS will ensure that the 3DR Solo UAS are in airworthy condition based

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Phantom 3) 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 The PRECISE CONCEPTS Seeks And The Reason The PRECISE 

CONCEPTS 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), The PRECISE CONCEPTS seeks the requested relief because the 3DR 

Solo UA’s 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 are 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 The PRECISE CONCEPTS Seeks And The Reason The PRECISE 

CONCEPTS 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 23 minutes. The PRECISE CONCEPTS seeks the requested relief because

without an exemption from Section 91.151(b), the flight time duration of the
12

battery powered 3DR Solo UAS will severely constrain the practicality of any aerial video or 

still photo flight operations that The PRECISE CONCEPTS proposes to conduct pursuant to this

Petition.

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

Solo operating documents, and The PRECISE CONCEPTS’s proposed operating limitations,

ensure that The PRECISE CONCEPTS 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 23 minutes.

5. Extent Of Relief The PRECISE CONCEPTS Seeks And The Reason The PRECISE 

CONCEPTS 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, The PRECISE CONCEPTS 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 meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, The PRECISE CONCEPTS will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using

the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the

The PRECISE CONCEPTS Aerial Operations Manual, Monthly Maintenance Log, and 3DR 

Solo Instruction Manual). Furthermore, The PRECISE CONCEPTS will document and maintain 

all maintenance records for the 3DR Solo UAS.

D. The Reasons Why Granting The PRECISE CONCEPTS 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 The PRECISE 

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

construction sites, real estate, events and civic landscape over certain areas of the UnitedStates.

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 The PRECISE 

CONCEPTS’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 are battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the
13

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 SoloUAS 

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 produce 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 UAS are 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 approximately

2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, 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).

3. 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 are 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 The PRECISE CONCEPTS, 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 DJI Phantom 3 UAS 

is one such technology that not only allows companies greater operational
14

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 The PRECISE CONCEPTS, 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,

The PRECISE CONCEPTS’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 PRECISE CONCEPTS 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 The PRECISE CONCEPTS 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, The PRECISE CONCEPTS’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.
15

(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, The PRECISE CONCEPTS 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 SoloUAS does 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 SoloUAS are set forth by the 3DR SoloUser Manual, 

attached hereto as Appendix A.

ii. The 3DR Solo UAS Global Positioning Modes Enable The UAS To Remain 

Within A Defined Operational Area.

The 3DR Solo UAS may be operated in both manual and global positioning flight modes. A 

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

pages 11 of the 3DR Solo User Manual attached hereto as Appendix A.

iii. The 3DR Solo UAS Are Designed For Automatic Return To HomePoint 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 does not reacquire control link data

from the GCS, the UAS will assume that the Control Link is lost and the will return to the home

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.
16

A complete description of the Failsafe Functions of the 3DR Solo UAS are set forth at pages 12 

through 14 of the 3DR Solo 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 at pages 23 through 29 of the 3DR Solo User Manual. 3DR Solo

User Manual is 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.

The PRECISE CONCEPTS video production staff will be the only persons to act as a pilot in

command (PIC) of the 3DR Solo UAS. Additionally, a safety observer will assist him at all times 

during flight time.

c. Flights Of 3DR Solo UAS Will Be Conducted Pursuant To SpecificOperating 

Limitations.

In seeking this exemption, The PRECISE CONCEPTS proposes to commercially operate 3DR 

SoloUAS 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 UAS weighing less than 55 

pounds maximum gross weight: 3DR SoloUnmanned Aircraft Systems. 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 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be

in feet 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. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.
17

7. 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. 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.
18

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 UAS 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 PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. 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.

19. 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.

20. 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.

21. 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.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.
19

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies

in accordance with the operating documents.

24. 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.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

26. 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.

28. 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.

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

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. 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;
20

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).

32. 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.

33. 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.

The PRECISE CONCEPTS 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 DJI Phantom

3 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 The PRECISE CONCEPTS’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, The PRECISE CONCEPTS 

submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for The PRECISE CONCEPTS’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).

The PRECISE CONCEPTS will not allow any PIC to operate the 3DR 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
21

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 The PRECISE CONCEPTS’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 asfollows:

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.

Exemption No. 11138 at page 15.

Accordingly, The PRECISE CONCEPTS will ensure safe operations by not allowing any PIC to

operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flighthour 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.
22

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

every flight, The PRECISE CONCEPTS will ensure that the 3DR SoloUAS 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 SoloUAS 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 The

PRECISE CONCEPTS’s operation of the 3DR SoloUAS within visual line of sight, at or below

500 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 UAS 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 SoloUAS; (2) the

limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, The PRECISE CONCEPTS will ensure that it will safely operate the

battery powered 3DR Sol oUAS during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 3DR SoloUAS; 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
23

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, The PRECISE CONCEPTS 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 

The PRECISE CONCEPTS will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the operating documents (i.e., the PRECISE CONCEPTS Aerial Operations Manual, Monthly

Maintenance Log, and 3DR Solo Instruction Manual). Furthermore, The PRECISE CONCEPTS

will document and maintain all maintenance records for the 3DR SoloUAS.

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

PRECISE CONCEPTS will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 3DR Solo User Manuals are attached

hereto as Appendix A and B; a copy of the 3DR Solo UAS Maintenance LOG is attached 

hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because The PRECISE 

CONCEPTS 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.
24

In consideration of The PRECISE CONCEPTS’s proposed operating limitations, the operating 

documents, and the technical aspects of the 3DR Solo UAS, The PRECISE CONCEPTS 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, The PRECISE CONCEPTS requests that

the FAA prescribe special conditions for the intended operation of the 3DR SoloUAS, 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 SoloUAS, 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
25

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 The PRECISE CONCEPTS Seeks Exemption:

The PRECISE CONCEPTS 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 The PRECISE CONCEPTS

Seeks:

This exemption will permit The PRECISE CONCEPTS 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

The PRECISE CONCEPTS’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, The PRECISE CONCEPTS’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, The PRECISE CONCEPTS will operate the 3DR SOLO UAS

safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to nationalsecurity.

CONCLUSION

As set forth herein, The PRECISE CONCEPTS 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 The PRECISE CONCEPTS to safely, 

efficiently, and economically operate the 3DR Solo UAS commercially within the NAS.
26

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

Modernization and Reform Act of 2012, Section 333, The PRECISE CONCEPTS

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), 

91.405(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: 

September 8, 

2015

Respectfully

submitted,

Harry

Samaniego

President

Precise Concepts

2234 N. FEDERAL HWY - SUITE 

389

BOCA RATON, FL 33431

P-561-452-5859

harry@preciseconcepts.com

Appendices:

A – Link to 3DR SoloManual: Click on link below 

http://3drobotics.com/wpcontent/uploads/2015/08/v5_08_21_15.pdf