JDT Solid Solutions LLC

99 Fern Valley Road

Brandon, MS 39042

601-955-4819

jdtsolidsolutions@gmail.com 

Dear Sir or Madam: 

This petition is being submitted on my behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), 

and 14 C.F.R. Part 11, JDT Solid Solutions LLC, operator of Small Unmanned Aircraft 

Systems (sUAS), hereby applies for an exemption from the Federal Aviation Regulations 

(FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the 

Federal Aviation Administration (FAA) so long as such operations are conducted with and 

under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

The requested exemption would permit JDT Solid Solutions LLC to pursue its commercial 

interests in providing services to clients using a small advanced sUAS in the following areas: 

Real Estate, Marketing, Land Management/Surveying, and Special Events. JDT Solid Solutions 

LLC states that all sUAS flights will occur over private or controlled access property and will 

do so with the property owner's consent and knowledge and that only people who have 

consented or otherwise have agreed to be within the UAS’ radius during filming and 

photography applications. 

JDT Solid Solutions LLC has demonstrated the ability to safely and effectively fly the sUAS

which will be used for all commercial and private purposes. JDT Solid Solutions LLC complies 

with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and 

environmental restrictions or limitations in reference to the operations of sUAS. 

All flights will occur in ordinance with any state or local laws regarding privacy. 

JDT Solid Solutions LLC, is seeking the exemption because of being committed to complying 

with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. JDT 

Solid Solutions LLC agrees to operate the sUAS in the manner described, and for the purposes 

that described. Without the exemption request granted, JDT Solid Solutions LLC would be 

unable to safely and effectively conduct business, and it is the business’s intention to comply

with the FAA and obtain an exemption of the following regulations. 

The following contains a list of regulations from which JDT Solid Solutions LLC is seeking 

exemption, and a complete list of responsibilities JDT Solid Solutions LLC assume as operator; 

it also contains information regarding the aircraft, public benefit and safety features, and similar 

petitions requests granted. 
Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 -91.417 

Pilot and Aircraft Specifics 

JDT Solid Solutions LLC’s UASs are rotorcraft, weighting 55 or fewer lbs. including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate at altitudes of no more than 400 feet, and only in line of sight. JDT Solid Solutions LLC

will be using 3DRobotics Y-6 multirotor and X-8 multirotor aircraft, henceforth referred to as 

“The Aircraft.” They will operate only within the areas and under the conditions as described in 

the Aircraft Flight Manuals. Operations in compliance with these manuals will insure that the 

sUAS will “not create a hazard to users of the national airspace system or the public” and that 

the aircraft will operate in compliance with the conditions set forth in this application. 

In support of this application, JDT Solid Solutions LLC is submitting the following manuals: 

• 14 Channel Computer System 14 SG Instruction Manual (Exhibit 1) 

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES 

1. Operations authorized by this grant of exemption are limited to “The Aircraft” when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than 

the maximum UA operating airspeed recommended by the aircraft manufacturer. 

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

Altitude must be reported in feet AGL. 
5. The UA 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 or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The VO 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 VO 

can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during 

UAS operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and 4 limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein 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 or any law enforcement official upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an 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. 

8. 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 prior to conducting further operations under this exemption. Functional test flights 

may only be conducted by a PIC with a VO and must remain at least 500 feet from other 

people. The functional test flight must be conducted in such a manner so as to not pose an 

undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 
10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is 

in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. 5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

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

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training 

the operator’s PICs and VOs (training, proficiency, and experience-building) and determining 

the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption are permitted under the terms of this 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 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight 

rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with 

an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart, unless a letter of agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official upon 

request. 

17. 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 
operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be 

conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new 

or amended COA if it intends to conduct operations that cannot be conducted under the terms 

of the attached COA. 6 

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in 

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance 

with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at 

all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects 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. The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission from 

property owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

28. 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. 

SIMILAR EXEMPTIONS 

They are similar in all/or many material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, 11213, 11204, and 11206
Public Benefit and Safety

Unmanned Aircraft System SUAVs are often seen as superior to helicopters as an aerial video 

gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced 

noise and as such, a much smaller environmental impact which promotes public safety JDT 

Solid Solutions LLC is petitioning for an exemption to operate a Previously specified aircraft 

with a built-in stabilized HD camera and GPS safety features which limit its ability to limit the 

height it flies above ground level (AGL), and to limit the radius of the distance it flies from the 

operator. Also, it has a failsafe function that is triggered in the event communication is lost 

between the sUAS and the main controller transmitter. At that time, the sUAS will return to its 

point of takeoff and land safety. If the connection is restored, the PIC can regain control of 

flight and land manually. 

These specifications meet with the Model Aircraft Operating Standards as set below: 

 The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and 

will operate at sites that are `sufficient distance' from populated areas within the sterile 

area described in the FOPM. Such operations will ensure that the sUAS will "not create 

a hazard to users of the national airspace system or the public." 

 When flying the sUAS within three (3) miles of an airport, airport operators will be 

notified and the operator will give the right-of-way to avoid flying in the proximity of 

full-scale aircraft. Maximum flight time for each operation will be 30 minutes. 

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve 

flight time to safely land the sUAS. 

 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 

feet AGL, and not more than 200 feet above an elevated platform from which 

videography is planned. 

 Minimum crew for each operation shall consist of: sUAS pilot and a visual sUAS

observer. 

 The sUAS operated by the petitioner weighs less than 25 pounds, including all payload 

(i.e. camera, lens, and stabilized gimbal). 

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

Respectfully submitted,

JDT Solid Solutions LLC