~HALIDE SOLUTIONS 

14 November 2015 

Section 333 Petition for Exemption to Allow Commercial Use of Unmanned Aircraft System 

U.S. Department of Transportation, 

Docket Operations West Building Ground Floor, 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Petitioner: 

Halide Solutions LLC 

Attn: Sara Pandiyan 

534 Appaloosa Avenue 

Shakopee MN 55379 

Email: Sara.Pandiyan@halidesmart.com 

Website: www.halidesmart.com 

Dear Sir/Madam: 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal · 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 

CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 

CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b) and any other rules the FAA deems necessary, to enable Halide Solutions LLC to 

operate unmanned aircraft systems ("UAS") for aerial video and/or photography and training as 

mentioned below using DJI Phantom Ill Quad copter, DJI Phantom Ill Advanced, DJI Phantom Ill 

Professional, 3DR Solo and Yuneec QSOO+ . Because this petition is similar in all material respects to 

previously-granted Section 333 petitions, Halide Solutions LLC requests expedited approval pursuant to 

the FAA's summary grant process. 

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~ HALID.E SOLUTIONS 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

CFR Part 11, Halide Solutions LLC, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its UAS, so long as such operations are conducted 

within and under the conditions outlined herein or as my be established by the FAA as required by 

Section 333. 

Commercial operation UAS, as described herein, which are equipped with cameras and sensors, would 

operate in the following manner: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional and marketing activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners 

or local government authority. 

4. Aerial video/photography or providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government has requested 

it by contract or donation. 

5. The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of UAS for the purpose of the safe operation 

of UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the 

persons and property. 

As described fully below, the requested exemption would permit the operation of sUAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using conventional 

aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to " .... establish requirements for the safe 

operation of such aircraft systems in the national airspace system." 

The name and address of the applicant: Halide Solutions LLC Attn:Sara Pandiyan 

Ph: 763.350.7751 Email: Sara.Pandiyan@halidesmart.com Address: 534 Appaloosa Avenue, Shakopee 

MN55379 

Device: DJI Phantom Ill Quad copter, DJI Phantom Ill Advanced, DJI Phantom Ill Professional, 3DR Solo, 

Yuneec Q500+ 

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and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh less than 55lbs. 

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

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% 

battery power reserve or 30 minutes of flight time whichever occurs first. 

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist ofthe UAS Pilot the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

6. The UAS pilot will be a designated Pilot in Command (PIC) and hold a current Third or higher Class 

Medical Certificate, along with a valid state driver's license. If the PIC feels another operator to be 

qualified with the necessary skills to be PIC & possess a Third or higher Class Medical and a valid state 

driver's license, that person may be designated PIC provided they have a minimum of 20 hours of flight 

time with the UAS. 

7. A briefing will be performed regarding the planned UAS operations prior to each day's flight consisting 

of all the days' production activities. 

8. The operator will obtain verbal/written consent of all persons involved with the planned operation 

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the 

radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required 

under the FOM. With the advanced permission of the FSDO, operations at closer range may be 

approved. 

9. The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the 

particular UAS to be operated. 

10. The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

11. Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

12. If the UAS loses communications or loses GPS signal, the UAS will have the capability to return to a 

pre-determined location within a designated location and land autonomously. 

13. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

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•associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft} operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 551bs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and 

designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled 

and monitored by both the operator and under the requirements and in compliance with local public 

safety requirements. The FAA will have advance notice of all operations. These safety enhancements 

provide a greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of 

these same criteria demonstrates that there is no credible threat to national security posed by the UAS, 

due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be 

placed. Given the size of the UAS, two-inch lettering will be impossible. The word "Experimental" will be 

placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the 

UAS as "Experimental." 

14 C.F.R. § 61.113 (a}: Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. Our UAS do 

not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 

61.113(a). Although helpful, a pilot's license will not ensure remote control piloting skills. The risks 

attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities 

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outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to the safe 

operation of the UAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The UAS, given its size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where the pilot flying 

the UAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level 

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

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may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 

400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100' above the 

highest point on the structure. It will however be operated in a restricted area with security perimeter, 

where buildings and people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these small- UAS operations and the operations 

of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 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- (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 

minutes in length. Given the limitations on the UAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight 

VFR conditions is reasonable. 

Applicant believes that an e·xemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does 

not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed 

of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for 

which the exemption will be granted. Applicant believes that an equivalent level of safety can be 

achieved by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone from anywhere 

in its limited operating area. 

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14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration . 

The regulation provides in pertinent part: 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) An appropriate and current airworthiness certificate. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to 

the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner "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 ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to 

the flight manual and operating handbook. An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in restricted areas for 

limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual 

(AOM). As provided in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed. 

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PUBLIC INTEREST 

The Reasons Why Granting Halide Solutions, LLC's Request Would Be In The Public Interest; That Is, 

How It Would Benefit The Public As A Whole. 

Consistent with the requirements of 14 C.F.R. 11.81(d), Petitioner offers the following reasons why 

granting this petition for exemption is in the public interest, i.e., how granting it would benefit the public 

as a whole. 

Granting the present Petition will further the public interest by allowing Halide Solutions, LLC to safely, 

efficiently, and economically perform aerial video and photography within the NAS. Additionally, use of 

the UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy 

• The operation significantly improves safety and reduces risk by alleviating' human exposure to 

danger associated with current aerial video and photography, namely, full-size helicopters. 

Manned helicopters performing aerial video and photography can experience accidents and 

fatalities. The public's interest is furthered by reducing human exposure to death or serious 

injury associated with manned aircraft performing such aerial video or photography. 

• Petitioner's small UASs are battery powered and create no emissions. If Petitioner's UAS 

crashes, there is no fuel to ignite and/or explode. Any impact of Petitioner's lightweight UASs is, 

obviously, far less than a full size helicopter. The public's interest is furthered by minimizing 

ecological impact of an accident and by reducing human exposure to potentially harmful 

emissions associated with manned aircraft. 

• Aerial video and photography are valuable tools for aerial inspections. However, problems with 

safety, cost, statistical integrity, and logistics continue to impede aerial surveys and inspections 

from conventional manned aircraft. The use of small UAS addresses these problems and is a 

powerful tool for performing a wide range of roofing inspection applications. The public as a 

whole will benefit from the safer and more cost effective aerial inspection services that small 

UAS operations provide. 

• In addition to being safe and efficient, the UASs are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the UASs will allow 

United States based companies, like Halide Solutions, LLC's, 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 UASs 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 

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UASs, companies such as Halide Solutions, LLC's, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth ofthe U.S. economy. Improved financial performance of U.S. companies, 

through commercial use ofthe UASs, 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 in the United States. 

• The Public Will Benefit From Decreased Congestion Of The NAS. The requested UASs 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 amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of UASs 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 requested UASs 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. 

• Conducting aerial acquisitions with the UASs, 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 UASs produce no air pollution, and are 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 UASs, while reducing the carbon footprint of aerial acquisitions, also 

eliminate noise pollution, as the UAs are propelled by battery powered electric motors, rather 

than an internal combustion engine. By using the UASs 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 on board the aircraft, the UASs 

have 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). 

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CONCLUSION & REQUEST FOR APPROVAL 

Because this petition is similar in material respects to previous petitions the FAA has granted, Halide 

Solutions LLC requests that the FAA issue a summary grant of exemption pursuant to the agency's 

expedited summary grant process. Specifically, the public interest and safety benefits Halide Solution 

LLC operations will achieve are materially similar to those recognized in Grants of Exemption Nos. 13519 

to Bird Eye Photography LLC (see Docket No. FAA-2015-3546), 13532 to Ghostriders Aerial Photography 

LLC (see Docket No. FAA-2015-2787), 13513 to DT Aerial Photography (see Docket No. FAA-2015-

3504), and 13199 to Creative Dog Media, LLC (see Docket No. FAA-2015-3113). Halide Solutions LLC will 

adhere to a series of operating parameters that will offer the same level of safety as the conditions the 

FAA currently requires in its summary grants. 

Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate 

justification for the grant of the requested exemptions allowing the commercial operation of the 

applicant's UASs. 

Sincerely, f ~ 

Ha~ionsLLC Attn: Sara Pandiyan 

534 Appaloosa Ave 

Shakopee MN 55379 

763.350.7751 

Sara.Pandiyan@halidesmart.com 

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