UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRAT ION WASHINGTON , D C

Regulator y D ocket No. _____ _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: JAVIERRUIZ FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b). 91.7(a). 91.121. 91.15Hb). 91.405(a). 91.407(a)(l), 91.409(a)(l) & (a)(2). AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF A TAROT FY650 UAS AND 3DR SOLO UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)
Submitted on May 29,20 1 5
J avier Ruiz 1690 SW 27 Avenue Aot 705 Miami. Florida 33 14 5 954-772-2644TA B LE OF C O NTENTS 

### Page GLOSSARY OF ABBREV I ATIONS
............... . ........ .. .... .. ....................... .. ................................................... 3 SUMMARY

. .......... . .................. . ...... . ............................. . ......... . . .. ...... . . . .. . .. . . . ...... . . .. .............4 INTROD UCTION AND INTERESTS OF PETITIONER
................ .... ...... .. .................... .4 BACKGROUND................................................................................................................ 5 BAS IS FOR PETITION .......................................................... . ................... . ..... . ................ . . . .... . ............. .

### S NAME AND ADDRESS OF PETITIONER........................................................... ? THE S PECIFIC SECTIONS OF 14 C

.F.R. FROM WHICH JAVIER RUIZ SEEKS EXEMPTION ..................... . .. .. . ...... . ............ .. .......... .. ..... . .... . . . .... . . . ... . .. . ... .. .8 THE EXTENT OF RELIEF PETITIONER SEEKS AND THE REASON PETITIONER SEEKS THE RELIEF

.... . . ............ . . .. .... ... . . ..... .. ................. 11 THE REASONS WHY GRANTING PETITIONER REQUEST WOULD BE IN THE PUBLI C INTEREST

.. . . . . . . ... . ................. .. .... ............. ............................... 14 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ....................... . .... .. . . ..... . .............. . .. . ... . ...... . ........... . .... . ..... . ..... . .. . .. .... .... . . . I? CONCLUSION

. ...................................... . .................... . ............ . ..... . .... .... .. . .... .. ........ . ... . ... 29AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

# so SOP UA UAS VFR VLOS VMC VTOL 

### GLOSSAR Y O F AB BREVIATI O NS Above Ground Level Area of Intere st Air Traffic Control Air Traffic Organization Aerial Vehicl e Code of Federal Regulations Certificate of Authorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Globa l Positioning System Loss of Link National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of 20 12 (FMRA) Safety Ob server Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line of Site Visua l Meteorological Conditions Vertical Takeoff and LandingSUMMARY Petitioner 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)(l) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit Petitioner to operate Unmanned Aircraft System(s) (UAS) for the commercial purpose of conducting aerial video and photography to be u sed in weddings , special events, sporting events, inspection purposes , real estate and other events which are conducive to this type of activity over certain areas of the United S ta tes.
INTRODUCTION AND INTERESTS OF THE PETITIONER My name is Javier Ruiz, I am 29 years old , and am a practicing attorney in the State of Florida. My areas of interests include amateur photography, flying, and designing and construction of custom made UAS. My objective is to start my own company to provide customers with aerial video and photography services in a variety of commercial and public uses , specifically targeting the following :
• Utilization for v isual inspection of eq uipment and buildings.
• Video for Real Estate assessments
• Wedding and Special Events.
• Coverage of Sporting Events.BACKGROUND Unmanned Aircraft Systems: Custom Made Tarot FY650 ("FY650"), and 3DR Solo UAS's Petition seeks an exemption to operate 3DR systems for compensation or hire within the NAS. The FY650 and 3DR Solo (not yet released) are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet, smart phone systems and monitors. The FY650 has a maximum gross weight of approximately 6 pounds , while having a length of 26 inches, width of 26 inches, height of 8 .5 inches, and a maximum speed of approximately 30 knots. The 3DR Solo has a maximum gross weight of3.9 pounds , a length of 18 inches, width of 18 inches , height of 10 inches, and a maximum speed of approximately 48 knots. The FY650 and 3DR Solo UAVs are equipped with four main rotors; driven by Lithium Polymer battery powered e lectric motor s. The FY650 and 3DR Solo UAVs that will be operated by Petitioner will be registered in accordance with 49 U.S.C. 44103 , Registra tion 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 Registra tion Marking.

BASIS FOR PETITION Petitioner, Javier Ruiz , pursuant to the provi sions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA) , Section 333, Special Rul es

for Ce rtain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the FY650 and 3DR Solo UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a) , 91.121 , 91.151(b), 91.405(a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b).In consideration of the speed , weight, s ize, and limited operating area associated with the unmanned aircraft and its operation, operation ofthe FY650 and 3DR Solo UAVs UASs meets the conditions ofFMRA Section 333 and therefore, will not require an ai rwort h iness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly , Petitioner requests relief from Sections 91.405(a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sec tions set forth requirements for maintenance that only app l y to aircraft with an airworthiness certificate. Petitioner submits that the reque sted relief is proper since an equivalent level of safety will be ensured. Petitioner will use experienced personnel or technicians to perform maintenance , alterations , or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e

. , Monthly Maintenance Log, and 3DR Solo Manual). Furthermore, Petitio ner will document and maintain all maintenance records for ofthe FY650 and 3DR Solo UA S s. R e lie f from certain requir ement s of Section 61.113(a) and (b) , entitled Private pilotprivil eges and limitations: Pilot in command, is requested by Petitioner to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher leve l certificate, as well as an airman medica l certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements , that the PIC is able to safely operate of the FY650 and 3DR Solo UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from peopl e, vessels, vehicles and structures. Petitioner seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the FY650 and 3DR Solo UASs do not require an airworthiness certificate in acco rdance with 14 C.F

. R. Part 21, Subpart H

. As such, Petitioner submits that he will ensure that the FY650 and 3DR Solo UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e ., Monthly Maintenance Log, and 3DR Solo Manual ), and that the aircraft are in acondition for safe flight. Petitioner also seeks an exemption from the requirements of Section 9 1 .12 1 , entitled Altimeter Settings, as FY650 and 3DR Solo UASs will not have a typical barometric alt imeter onboard. However, alt itude information FY650 and 3DR Solo UASs will be provided to the PIC via Global Positioning System (GPS) equipment and rad io communications telemetry data link, which downlinks from the UAS to the GCS for act i ve mon itoring of the flight path. This altitude information , combined with Petitioner ' s operation of FY650 and 3DR Solo UASs within visual line of sight, at or below 500 feet AGL, will ensure a leve l of safety equiva l ent to Section 91. 121. Addi tionally, Petitioner seeks an exemption from the requirements of Section 91.15 1 (b), entit led Fuel requiremen t s for flight in VFR conditions. Peti tioner submits that safety will not be affected by operation ofFY650 and 3DR Solo UASs during daylight hours in visual meteorological conditions (VMC) under v is ual flight ru les (VFR), with enough battery power to fly for a total duration of approximately 19 minutes. In accordance with 14 C.F .R. 

### § 11.81 , Petitioner provides the fo ll owing informa tion in support of its petition for exemption:



### A

. Nam e And Addr ess Of T he P etitioner . The name and address of the Petitioner and point ofcontact is: Javier Rui z 1690 SW 27th Avenue Aot 705 M iami. F lorida 33 145 954-772-2644 Email: Javier

_ruiz @ me.com



### B. T he Sp ecific S ection s Of 14 C

. F .R. F rom Which P et itioner Seeks Exemption . 1. P etition er Seeks Exemption F rom T he R equirements Of Section 61.11 3(a) And (b)

. Section 61

. 113 , entitled Private pi lot privi leges and limitations: Pilot in command ,subsections (a) and (b) prescribe the following, in relevant part: (a) No oerson who holds a orivate oi l ot certificate may act as a oilot in command (PIC) of an aircraft that i s carrying oassengers or orooertv for comoensation or hire; nor may that person, for compensation or hire , act as PIC of an aircraft. (b) A orivate oilot may. for comoensation 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 . Peti t ion e r See ks Exempt io n F rom T he R e quire me nts Of S ectio n 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 . Petitio ne r Seeks Exemptio n F ro m T he R eq uirements Of Section 91 . 12 1. Section 91.121, entitled Altimeter settings, subsection (a) , states the following, in part: (a) Each oerson ooerating 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

-- (!) Be low 1 8 , 000 feet MSL, to-- (i) The current reoorted altimeter setting of a station along the route and within 100 nautica l miles of the aircraft; (ii) If there is no station within the area orescribed in oara!!I'aoh (a)(l)(i) of this section. the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equiooed with a radio

. the elevation of the deoarture ai roort or an appropriate altimeter setting available before departure.
4. Petitio ne r Seeks Exemption F ro m T he Requiremen ts Of Sect i on 91.1 5 1( b ) . Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No oerson mav bef!in a flif!ht in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first ooint of intended landinz and, assuming normal cruising speed, to fly after that for at least 20 minutes

. 5. Petitioner Seeks Exemption From The Requirement Of Section 91.405(a) . Section 9 1.405, entitled Maintenance required, subsection (a), states the fo ll owi ng: Each owner or operator of an aircraft

- (a) Shall have that aircraft insoected as orescribed in suboart E ofthis oart and shall between requi red insoections. exceot as provided in oaragraoh (c) of this section, have di screpancies repaired as prescribed in part 43 of this chapter[ .] 6 . Petitioner Seeks Exemption From The Requirements Of Section 91.407(a)(l) Section 91.407, e ntitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, sub section (a)( l) , states the following : (a) No oerson may operate any aircraft that has und ergone maintenance , preventive maintenance, rebuilding , or a lteration unless-- ( 1) It h as been aooroved for return to service by a person authorized under§ 4 3.7 of this chapter[.]
7. Petitioner Seeks Exemotion From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled Insp ec tions, subsection (a), states the following : (a) Except as orovided in paragraph (c) of this section

. no per son may operate an aircraft unless , within the p r eceding 1 2 calendar months, it has had

-- (1) An annual inspection in accordance w ith oart 43 of this chanter and has been approved for return to service by a person autho rized by § 43.7 of thi s chapter; or (2) An inspection for the issuance of an air worthiness certific ate in accordance with part 2 1 of thi s c hapter.
8. Petitioner 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) Exceot for work performed in accordance with 

### && 91.41 1 and 91.413. each regi s tered owner or ooerator shall keep the fo ll owing records for the periods spec ifie d in paragraph (b) of this section: (1) Records of the maintenance

. preventive maintenance. and alteration and reco rd s of the 1 00- ho ur . annual. progressive. and other required or approved insoections. as aporoor iat e. for each aircraft (including the airframe) and each engine, prope ll er, 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 ofthe 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 serv ice of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limit ed 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 bas is. (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) Cop ie s ofthe forms prescribed by 

### & 43.9(d) of this chapter for each maior alteration to the airframe and currently installed engines, rotors , propellers, and app liances. (b) The owner or operator shall retain the following records for the periods prescribed: ( 1) The reco rd s specified in paragraph (a )(1) ofthis 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 i s so ld

. (3) A li st of defects furnished to a registered owner or operator under 

### &43.11 ofthi s chapter s hall be retained until the defects are repaired and the aircraft is approved for return to service.


### C. The Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks The Relief. 1. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilotprivileges and limitations : Pilot in command, is reque sted to the extent nece ssary to allow a PIC holding
a private pilot or higher level certificate , as well as a current and valid airman medicalcertificate, 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 limitation s set forth in Section 61.113(a) and (b) sta te that a pri vate 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, Petitioner submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the FY650 and 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 FY650 or 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 , ve ss el s, vehicle s and structure s. Further, Petitioner submits that a ll flights of the FY650 and 3DR Solo UASs , conducted by the PIC pursuant to the grant ofthis Petition: (1) w ill be incidental to Petitioner's business; and (2) will not carry passengers or property for compensation or hire.



### 2. Extent Of Relief Petitioner Seeks And The Reason Petitioner 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 Petitioner to determine that the FY650 and 3DR Solo UASs
are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e. , Monthly Maintenance Log, and 3DR Solo Manual). Petitioner seeks the reque sted relief because the FY650 and 3DR Solo UASs do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21 , Subpart H.Therefore , Petitioner will en s ure th at the FY650 and 3DR Solo UA S s are in airworthy condition based upon its compliance wi th the operating documents ( i.e. , Monthly Maintenance Log, and 3DR Solo Manual) prior to every flight, and further , determine that the aircraft are in condit ion for safe fli ght , as stated in the conditi o ns and limitations below.



### 3

. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief From Section 91.121.
Reli ef from Section 91.12 1 , entitled Altimeter settin gs, may be required to allow flight operation s of the FY650 and 3DR So lo UASs, which utilize a barometric pressure sensor, GP S equipment, and a radio communi cations telemetry data link to downlink
a ltitude information from the UA to the PIC at th e ground co ntro l sta tion (GCS). Since the FAA requires that any altitude informati on concerni ng UAS operations be reported to air traffic control (ATC) in feet above gro und leve l (AGL) , Petiti oner seeks the requested relief because the FY650 and 3DR Solo UASs altimeter may be set on the ground to zero feet AGL, r ather than the loca l bar ometric pr essure or field altitude , before each flight. Con si dering the limited altitude of the proposed operation s , relief from 14 CFR 9 1.1 2 1 i s sought to the ex tent necessary to comp ly with the app lic ab le conditi on s and limi tations s tated b elow . As more fully set forth he re in , an equivalent level of safety will be maintained since the the FY650 and 3DR So lo UASs are equipped with a barometric pressure senso r and GPS eq u ipment , which autom atica ll y ensures that a ground level pressure setting will be estab li s hed prior to each flight, and provides the PIC with altitude information of the UA o n the heads-up display of the GCS.


### 4. Extent Of Relief Petitioner Seeks And The Rea so n Petitioner Seeks R elief From Section 91.15l(b).
Re lief from Section 91.15 1 (b) entitled Fuel r equi rements for flight in VFR conditions , is requested to the extent required to allow flights of the battery poweredFY650 and 3DR Solo UASs during dayl i ght hours i n v i sual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 19 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 3 minutes

. Petitioner seeks the requested relief because without an exemption from Section 91.151(b) , the flight time duration of the battery powered FY650 and 3DR Solo UASs will severely constrain the practicality of any aerial video or still photo flight operations that Petitioner proposes to conduct pursuant to this Petition. Significantly , as set forth below , the technical specifications ofthe FY650 and 3DR So lo UASs, and the 3DR operat i ng manual , ensure that Petitioner will safely operate the battery powered FY650 and 3DR Solo UASs during daylight hours in visual
meteorological conditions (VMC) , under visual flight rules (VFR) , with enough battery power to fly for a total duration of 19 minutes to the first point of intended landing and, assuming norma l cruising speed , to fly after that for at least 3 minutes.
5 . Ex t ent O f R elief Petiti on er Seeks And T he Reaso n Pe tition er Seeks R elief F rom Sectio ns 91. 40S (a), 91. 40 7(a)( l ), 9 1 .4 09 (a)(l) & ( a)(2), A n d 9 1.41 7(a) & (b).
Since Sections 91.405(a) , 91.407(a) (l ) , 91.409(a)(l ) & (a) (2), and 91.417(a) & ( b) only app ly to aircraft with an airworthiness certificate , Petitioner requests relief from these Sect ions because the FY650 and 3DR Solo UASs do not require airworthiness certificates. As set forth more fully be low , the FY650 and 3DR Solo UASs s meet the conditions ofFMRA Section 333 for operation witho ut an airworthiness certificate. Accordingly, Petitioner wi ll use trained techn i c ians to perform maintenance , alterations , or preventive maintenance on the UASs us i ng general ly accepted maintenance methods. Furthermore , Petitioner will document and maintain al l maintenance records for the FY650 and 3DR Solo UASs.

D . T he Re as on s W h v G rantin e P e tition e r Reau es t W ould B e In Th e Public I nteres t ; That I s, How It W ould B en efit T h e Public As A W hol e .Granting the pr esent Petiti on wi ll further the public interest b y allowing Petitioner to safely , effici entl y, and economica lly perform aerial video and photography of construction sites, real estate , land sca p e, sporting events and other social events over certain areas ofthe United States. Additionally, use of the FY650 and 3DR Solo UASs will decrease congestion of the NA S , reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Petiti oner's proposed operation of the FY650 and 3DR Solo UASs will be realized without implicating any privacy issues

. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The the FY650 and 3 DR Solo UASs a re batt ery powered and serve as a safe, efficient, and eco nomical alternative to the manned aircraft tradition ally utilized to obtain aerial imagery. By reducing the amount of manned ai rcraft needed to perform aerial acqu isitions, an exempti on allowing the use of the FY650 and 3DR Solo UASs wo uld r educe the amount of manned air c r

aft in the NAS, reduce noi se and air pollution, as well as increase the safety of lif e and property in the air and on the ground. Furthermore, by reducin g the numb er of manned ai rcraft operating in the NAS , co nges tion around airports caused by arriving and departing aircraft will be reduced. The FY650 and 3DR Solo 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 fli ght operations.
2 . The Public Will Benefit From The Safety And Efficiency Of The FY650 and 3DR Solo UASs
Co ndu cting aerial acquisitions with the FY650 and 3DR Solo UASs, instead of manned aircraft , w ill grea tly be nefit the public by drasticall y r educin g the le vels of air and noise polluti on generated during traditional aerial video and still photography flightoperations. By u sing battery power and electric motors, t the FY650 and 3DR Solo UASs produce no air pollution, and is the most viab le environmentally con scious alternative to the cabin c lass, six cylind er internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of lea ded aviation fuel. The FY650 and 3DR Solo UASs, 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 comb u stion engine. By using the FY650 and 3DR Solo UASs to perform aerial acquisitions , the sub stanti al 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 FY650 and 3DR Solo UASs , have less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned ai rcraft that typically con duct similar operations (weighing approximately 6,000 pounds wit h a wingspan of approximately 42 feet , a length of 34 feet, and a fuel capacity of 180 ga ll ons).



### 3. Performine Aerial Video and Photoeranhv Onerations With the FY650 and 3DR Solo UASs Will Benefit The Economy. In addition to being safe and efficient, the FY650 and 3DR Solo UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations

. As s uch, operation ofthe FY650 and 3DR Solo UASs wi ll allow United States based op erators of these systems to remain competitive and contribute to growth ofthe U

. S. econo my. Specifically, wit h the ri sing cost of aviation fue l and the Environmental Protection Agency ("EPA") regulatory actions p hasing 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 FY650 and 3DR Solo UASs is onesuch technology that not only allows companies greater operationa l flexibility compared to m anned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. 

### 4. Th er e Are No Priv ac y I ss u es . Simil ar to the manned aerial acquisition flight operations that have been conducted for decades , Petitioner's proposed operation oft the FY650 and 3DR So lo UASs will not impl icate any privacy issues

. Specifically, the FY650 and 3DR So lo UASs will be
op erated only in compliance with operating documents , which requires property owner invo l vement as well as local law enforcement notification, and in ac c ordance wit h the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F. R

. §9 1. 119.



### E

. Th e Rea s on s W h v G r a ntin 2: T h e Exe motion W ould N ot Ad verselv Affect S af ety, Or How The E xemotion Would Provid e A Leve l Of Safetv At Least E q u al T o That Prov id ed B y 

### T h e Rul e F rom Which P etition er Seeks Ex emption. 1. 

### Rea s on s Whv th e FY 650 and 3 DR S olo UASs Meet T he Condition s Of Th e F AA M odernization and Reform Act of 2012 (FMRA) Section 333

. In consideration of the size , weight, speed, and limited operatin g area associated wit h t h e unmanned aircraft and its operation , Petitioner's operation of the FY650 and 3 DR Solo UASs meet the condi tions ofFMRA Section 333, and wi ll n ot 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 airworthi n ess certifica ti on and sets forth requirements for considering whether a UAS will create a hazard to users ofth e NAS or th e p ub lic, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General

. --Notwithstandinf! anv other reQuirement of this subtitle. and not later than 1 80 davs after the date of enactment of this Act. t h e Secre tarv of Transoortation shall determine if certain unmanned aircraft svstems mav overate safelv in the national airsoace svstem before comoletion of the olan and rulemakinf! reQuired by section 332 of this Act or the guidance required by section 334 of this Act.(b) Assessment of UnmannedAircraft Svstems. --In mak im! the determination under subsection (a) , the Secretary shall determine, at a minimum

- - (1) which tvoes of unmanned aircraft svstems. if anv. as a result of their size. weight. soeed. ooerational caoabilitv. oroximitv to airoorts and pooulated areas. and ooeration within visual line of sight do not create a hazard to use r s of the national airspace system or the public orpose 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 reauiredfor the ooeration of unmanned aircraft systems identified underparagraph (1 ). (c) Reauirements for Safe Ooeration.--Ifthe Secretarv determines under this section that certain unmanned aircraft svstems mav overate safelv in the national airsoace svstem. the Secretarv shall establish reauirements for the safe operation of such aircraft systems in the national airspace system. In seek ing thi s exe mpti on , Petiti oner s ubmits that the the FY650 and 3DR So lo UASs c an operate safe ly in the NAS purs uant to FMRA Section 333, as demonstrated by: (a) the characteri stic s of the FY650 and 3 DR So lo UASs; (b) the pilot certification
requir ement ; and (c) t h e specific opera ti ng l i mitations. 

### a. The Soecification s Of the FY 650 and 3DR Sol o UASs Demon stra te Its Safe Characteris tic s . The FY650 and 3DR Solo UASs do not crea te a hazard to users of the NAS or the public, or otherwise pose a threat to national security co ns idering its size, weight , speed, and operatio nal capabi lity

. 

### i. Technical S pecification s OfT the F Y650 and 3DR Solo U ASs

. The technical specifications of the FY650 and 3DR Solo UASs are set fort h in Exhibit A and B

.
ii

. 

### T h e F Y650 and 3DR S olo UAS s Autonomou s F lieht And Navieation Mode s E nable The UAS s To Remain Within A Defined Operational Are a . The FY650 and 3 D R So lo UASs may be operated in b ot h manual and fu lly auto no mo u s fli ght modes.iii. The FY650 and 3DR Solo UASs Are Desi!!ned For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.
When the Contro l Link is lost, the FY650 and 3DR Solo UASs will remain stat ionary, in flight , for 3 seconds or more. I f the UAS'do not reacquire control link data from the GCS, the UAs will assume that the Control Link i s lost and the UAs will return to the ho me position (i.e., failsafe mode) v ia GPS, and will descend to the takeoff position and shut down . b. Fli!!hts Of the FY650 and 3DR Solo UASs Will Be Conducted Pursuant To Specific Operating Limitations.
In seeking this exemption, Petitioner propo ses to commercially the FY650 and 3DR Solo UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the fo ll owing specific operating limitation s: 1

. Operations authorized bv thi s grant of exemption will be limited to the following aircraft described in the operating documents. rotorcraft UASs we i g hing les s than 55 pounds maximum gross we ight: FY650 and 3DR Solo Unmanned Aircraft Svstems. Proposed operations of any other aircraft will requir e a new petition or a petition to amend this grant. 2. UAS operations under this exempti o n 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 500 feet above ground level (AGL). as indicated bv the procedures specified in the operating documents unless a special reauest is made and approved by A TC. All altitudes reported to ATC mu st be in feet AGL. 5. The UAs must be operate d within visual line of sight (VLOS) ofthe PIC at all times

. This reauire s the PIC to be able to use human vision unaided bv any dev ice other than corrective lenses, as specified on the PI C's FAA

- issued airman medical certificate. 6. The u se offirst person view (FPV) by the PIC or saf ety observer (SO) is not permitted. 7. A ll operations must utilize a s afetv observer (SO). The SO mav be used to sati sfy the VLOS requirement as long as th e PIC always maintains VLOScaoabilitv. 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 oerform 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 ooerating documents and the grant of exemotion must be accessible during UAS operations and made available to the Administrator uoon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemotion and the procedures outlined in the ooerating documents. the conditions and limitations contained in the grant of exempt i on take precedence and must be followed. Ot herwise. the ooerator must follow the procedures as outlined in its ooerating documents. The ooerator may update or revise its ooerating documents. It is the ooerator ' s responsibility to track such revisions and oresent updated and revised documents to the Administrator upon request. The ooerator must also present uodated and revised documents if it petitions for extension or amendment to the grant of exemotion

. If the operator determines that any uodate or revision would affect the basis upon which the FAA granted the exemotion. then the ooerator must oetition for amendment to its grant ofexemotion. The FAA ' s UAS Inte gration Office (AFS -8 0) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must insoect 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 ooerating 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 insoection. 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 characteri stics. e.g. replacement of a flight critical comoonent. must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The ore-flight inspection must account for all potential discrepancies. e.g. inooerable components. items. or equipment. not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer ' s aircraftlcomoonent. maintenance , overhau l, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance. inspections. and record keeping requirements. in accordance with the operating documents. Maintenance. insoection. alterations. and status ofreplacement/overhaul component parts must be noted in the aircraft records. including total time in service. description of work accompli shed , and the signature of the authorized person returning the UAS to service.15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins

. 16

. The authorized person must make an entrv in the aircraft record of the corrective action taken against discrepancies discovered between inspections

. 17. The PIC must po sses s at least a private pilot certificate and at least a current third- class medical certificate. 18. The operator ma v not permit anv PIC to operate unless the PIC meets the operator 's qualification criteria and demonstrates the ab ilitv to safe lv 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. 

### &

61.5l(b). Flights for the purpo ses of training the operator's PICs are permitted under the terms of the exemotion. However. training operations may onlv be conducted during dedicated training sessions. During training. proficiency. and experience-building flight s . all persons not essential for

**fli~ht** 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 mav not be conducted during night. as defmed in 14 C.F.R. 

### & 1.1. All operations must be conducted under visual meteorological conditions (VMC)

. If flight at night is required

. a soecial 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 i s 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 reque st. 21. The UA may not be operated less than 500 feet below or less than 2 .000 feet horizontally from a cloud or when visibi lit y is le ss than 3 statute miles from the PIC

. 22. If the UA loses communications or loses its GPS signal. it must return to a ore- determined location within the olanned operating area and land or be recovered in accordance with the operating documents. 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 anyoperations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOT AM) 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 (N- Number) 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 safetv assessment ofthe risk of operating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PIC. SO. operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 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

. Anv incident. accident. or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COAmust 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

. go v . 2. Reasons Whv An Exemotion From The Reouirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Petitioner submits that the equivalent level of safety established by Sec tion 61. 11 3(a) and (b) will be maintained becau s e no PIC will be allowed to operate the FY650 and 3DR Solo UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements , that the PIC is able to saf e ly operate the FY650 and 3DR Solo UASs in a manner consistent with the exemption, including evasive and emergency maneuvers and ma in

taining appropria te di stance s from people , vessels , vehicle s and s tructures. Considering Petitioners proposed area of operations , and the operating limitations set forth-above, Petitioner submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills nece s sary for Petitioners 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. Exemptio n Nos. 11062, 11063 , 11064, 11065 , 11066, 11067 , 11080, 111 09 , 11110, 1111 2 , 11136 , 11138 , 111 50 , 11153,11156 , 11158 , 11159,11160, 11161). Specifically , the PIC must have accumulated and logged , in a manner consistent with 14 C.F.R. 

### § 61.51(b) , 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must acco mpli sh 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 com pliance with applicable regulations will ens ure anequivalent level of safety during Petitioners proposed operations

. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062. the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations)

. the PIC must have accumulated and logged. in a manner consistent with 14 CFR 61.5l(b). 25 hours oftotal 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 pi lot operating the same make and model ofUAS to be used for oper ations 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 1 0 hours of multi -rotor time and the 1 0 hours may be included in the total25 hours ofUAS 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 flighthour 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 satisfv this requirement. Training. proficiency. and exoerience-bui ldin g flights can also be conducted under the grant of exemption to accomolish the required flight time. During training

. proficiencY. and exoerience-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, Petitioner will ensure safe operations by not allowing any PIC to operate the FY650 and 3DR Solo UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the FY650 and 3DR Solo UASs in a manner consiste nt with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vesse ls, vehicles and structures.
3. Reasons Whv An Exemotion From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Petitioner will ensure that the FY650 and 3DR Solo UASsis in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitat i ons herein. Additionally , the FAA has prev iousl y granted relief from Section 91.7 (a) specific to UAS, 

### in circumstances similar, in all mat erial re spects, to those pre sented herein (e

. g. ExemptionNos. 11062, 11063,11064 , 11065,11066 , 11067 , 11080 , 11109 , 11110, 11112, 11136 , 11138, 11150 , 11153, 11156 , 11157 , 11158 , 11159 , 11160 , 11161).
4. Reasons Whv An Exemotion From The Requirements Of Section 91.121 Would Not Adversely Affect Safety . The equivalent level of safety establi shed by Section 91.121 will be maintained because the altitude information of the FY650 and 3 DR Solo UASs will be provided to the PIC via GPS equipment and a radio communication s telemetry data link , w hich downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altit ude information, combined with Petitioners operati on the FY650 and 3DR Solo UA S s with in v i sual line of s ight, at or below 500 feet AGL , will ensure a level of safety
equiva lent to Section 91. 1 21. The altitude information will be generated b y GPS equ ipm ent installed onboard the ai rcraft. Prior to each fli ght, a zero altitude initiati on point i s automa tically estab l ished by the UASs at ground level. The FAA has p reviously granted relief from Section 91. 1 2 1 specific to UAS , 

### in circumstances similar, in all ma teria l respects , to those presented herein (e.g

. Exemption Nos. 11062 , 11063, 11064 , 11065 , 11066 , 11067 , 11080 , 11109 , 11112 , 11136 , 11138 , 11150 , 11153 , 11156 , 111 57, 11158 , 11159 , 11160 , 111 61).
5. Reasons Whv An Exemotion From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.
A grant of thi s exemption would ensure an equivalent level of safety established by 14 C

. F .R. Section 9 1.151 (b) as a re su lt of ( 1) the technical specifications of the FY 650 and 3DR Solo UASs; (2) the limitations on the proposed flight operations ; and (3) thelocation of the proposed flight operations. Accordingly , Petitioner will ensure that it will safely operate the battery powered FY650 and 3DR Solo UASs during da yl ight hours in VFR conditions , with enough battery power to fly for a total duration of 19 minutes to the first p oi nt of intended landing and , assuming normal cruising speed, to fly after that for at least 3 minutes. Significantly, previou s exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operat ing limitati ons of the UAS are considered

. Relief has been granted for manned aircraft to operate at less than the minimum s pr escribed in Section 9 1. 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 h erein (e.g. Exemption Nos. 8811 , 10808 , 10673 , 11042, 11062 , 110 63, 11064 ,1 1 065, 1 1066,11067 , 1 1080,11109 , 11110 , 11136 , 11138 , 11150, 111 53, 1115 6 , 1115 7, 111 58 , 111 59,11 1 60, 11161).
6 . Reasons Whv An Exemotion From The Rea uirements Of Sections 91.405(a). 91.407(a)(l). 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, Petitioner submits that the equivalent level of safety wit h regard to the regu latory maintenance and alterati on requirements estab li shed by Sections 9 1.405 (a) , 91.407(a)(1) , 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met beca use Petitioner wi ll use t rained technicians to perform maintenance , alterations , or preventive maintenance on the UASs ' using the methods , techniques, and practice s described above. Furthermore , Petitioner will document and maintain all maintenance record s fo r the FY650 and 3DR Solo UASs. Since the FY650 and 3DR Solo UASs will be inspected as described above , Petitioner wi ll m ain tain the equ iva lent leve l of safety esta bl ished by Sections 91.405(a), 9 1.409(a)( 1), and 9 1.409 (a)(2).Likewise, the exemption sought will ·not adversely affect safety because Petitioner will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods , techniques, and practices described above 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 FY650 and 3DR Solo UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log

. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Petitioner ' s proposed operating limitations, the operating documents, and the technical aspects of the FY650 and 3DR Solo UASs , Petitioner submits that safety will not be adversely affected by granting exemption from 14 C

.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.4 17 (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 , Petitioner requests that the FAA prescribe special conditions for the intended operation ofthe FY650 and 3DR Solo UASs , 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 safeoperation of the UAs for the limited purpose ofconducting 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 ofthe NAS or the pub lic , 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 FY650 and 3DR Solo UASs, 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 aporooriate safetv standards for an aircraft. aircraft engine, or propeller because of a novel or unu s ual design feature ofthe 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 ofthis 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. § 2 1.1 6. 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 ofthe FY650 and 3DR Solo UASs, which contain such safety standards that the Administrator finds necessary to estab li sh a level of safety equivalent to that established by 14 C.F .R. Part 21 , Subpart H , and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121 , 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417 (a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: TheRules From Which Petitioner Seeks Exemption: Petitioner seeks exemvtion from the reQuirements of 14 C. F. R Sections 6J

. Jl3(a)&(b)

. 91

. 7(a). 91.121, 91.151 (b), 91.405(a), 91.40 7( a)(J ), 91.409(a)(J) & (a)(2) , and 91

. 41 7(a) & (b). A Brief Description Of The Nature Of The Exemption Petitioner Seeks: This exemvtion willvermit Petitioner to commerciallv ov e rate an U nmanned Aircraft Svstem (UAS) for the vurvose of conductim! aerial video and photography over ce rtain areas of th e United States

. • Anv Additional Information, Views, Or Arguments Ava ilable To Support Petitioner's Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretar y of Transportation to determine if certain UAS may operate safely in the NAS. A s s uch , Javier Ruiz 's reque st for exemption
may be granted pursuant to the auth ori ty ofFMRA 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
cr

eate a h aza rd to us ers 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 airworthine ss certification. As di scussed in detail above , Petitioner will operate the the FY650 and 3DR Solo UASs safely in the NAS, without creating a hazard to users ofthe NAS, or the public , or otherwise pose a threat to n atio nal security.

CONCLUSIONAs set forth herein, Petitioner seeks an exemption pursuant to 14 C.F.R. 

### § 11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the the FY650 and 3DR Solo UASs 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 of2012, while also advancing the interests ofthe public , by allowing Petitioner to safely , efficiently, and economically operate the FY650 and 3DR Solo UASs commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, Petitioner 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) , and permit Leading Edge to operate the FY650 and 3DR Solo UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: Apri l 25, 2015

Respectfully submitted ,



# ~

·er R:;:(;:;itioner
__ _ 690 SW 27 Avenue Aot 705 Miami. Florida 33145 954-772-2644Appendices: A

- FY650 Specifications Data Sheet B- 3DR Solo Specifications Data SheetAPPENDIX

- A FY650 TECHNICAL SPECIFICATIONS Petitioner onlv utilizes safe and reliable UASs. The flight controller (FC) is a Pixhawk designed bv 3DR. 3DR is an industrv leader in s mall UAS production. 3DR UASs are loaded with ground breaking softwar e enabling the u ser to set parameters which ensure safetv. Parameters can also be set to limit fl ight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set di stance. In addition. 3DR software provides real-time altitude and location information to the PIC via the linked monitor (s mart phone /tablet de vices) Flight time: 19 minute s Range : 1 miles
Max speed: 34.5 mph
Max altitude: 400 ft per FAA regulation , u ser adju stabl e Autopilot (Flight Controller): Pixhawk Software: APM:Copter Communication: Telemetry Module Weight: 6 pound s Dimensions : 8.5 in

. tall , 26 in. motor-to-motor
Flight battery: Lithium polymer 4000 mAh 14.8 Vdc Lithium polymer 8000 mAh 14

. 8 VdcAPPENDIX-B 3DR SOLO TECHNICAL SPECIFICATIONS Petitioner onlv utili zes safe and reliable UASs. 3DR i s an industry leader in small UAS production. 3DR UASs are loaded with ground break in g software enabling the u ser to set parameters which ensure safetv. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limi t flight to a predetermined and set distance

. In addition. 3D R software provides real-time altitud e and location information to the PIC v ia the linked monitor (smart phone/ tablet devices) Flight ti me : 20 minute s with payload* Range: .5 miles
Ma x speed: 55 mph
Max altitude: 400 ft perF AA regulati on , user adjustable Autopilot: Pixhawk 2 Software: APM: Copter Communication : 3DR Link secure WiFi network Frequency: 2.4 GHz Weight: 3.9 lbs.
Dimensions: 10 in. tall , 18 in. motor-to-motor Flight battery: Lithium polymer 5200 mAh 14.8 Vdc