UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket 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 15 

Javier Ruiz 

1690 SW 27 Avenue 

Aot 705 

Miami. Florida 33 145 

954-772-2644 
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

ABBREVIATIONS ............................................................................................................ 3 

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

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

BACKGROUND ................................................................................................................ 5 

BASIS FOR 

PETITION ........................................................................................................................... S 

NAME AND ADDRESS OF PETITIONER ........................................................... ? 

THE SPECIFIC 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 PUBLIC INTEREST .. .. .. ..... .................................................................... 14 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT 

SAFETY ................................................................................................................ I? 

CONCLUSION ................................................................................................................. 29 
AGL 

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 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of 20 12 (FMRA) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
SUMMARY 

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 used 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 States. 

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 visual inspection of equipment 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 electric motors. 

The FY650 and 3DR Solo UAVs that will be operated by Petitioner will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Javier Ruiz, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 

(FMRA), Section 333, Special Rules for Certain 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, size, and limited operating area associated 

with the unmanned aircraft and its operation, operation of the FY650 and 3DR Solo 

UAVs UASs meets the conditions ofFMRA Section 333 and therefore, will not require 

an airworthiness 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 sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Petitioner submits that the requested 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, Petitioner will document and 

maintain all maintenance records for of the FY650 and 3DR Solo UASs. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges 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 level 

certificate, as well as an airman medical 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 

people, 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 

accordance 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 a 
condition for safe flight. 

Petitioner also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as FY650 and 3DR Solo UASs will not have a typical 

barometric altimeter onboard. However, altitude information FY650 and 3DR Solo UASs 

will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UAS to the GCS for 

active monitoring 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 level of safety equivalent to Section 91. 121. 

Additionally, Petitioner seeks an exemption from the requirements of Section 

91.151 (b), entitled Fuel requirements for flight in VFR conditions. Petitioner submits that 

safety will not be affected by operation ofFY650 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 approximately 19 minutes. 

In accordance with 14 C.F .R. § 11.81, Petitioner provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Javier Ruiz 

1690 SW 27th A venue 

Aot 705 

Miami. Florida 33 145 

954-772-2644 

Email: Javier_ruiz@me.com 

B. The Specific Sections Of 14 C.F.R. From Which Petitioner Seeks Exemption. 

1. 

A

Petitioner Seeks Exemption From The Requirements Of Section 61.113(a) nd (b). 

Section 61 .113, entitled Private pilot privileges and limitations: Pilot in command, 
subsections (a) and (b) prescribe the following, in relevant part: 

(a) No oerson who holds a orivate oilot certificate may act as a oilot in command 

(PIC) of an aircraft that is 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. Petitioner Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91 .7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Petitioner Seeks Exemption From The Requirements Of Section 91.121. 

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--

(!) Below 18,000 feet MSL, to--

(i) The current reoorted altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area 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 airoort or an appropriate altimeter setting available 

before departure. 

4. Petitioner Seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection 

(b), states the following: 

(b) No 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 fly 
to 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 91.405, entitled Maintenance required, subsection (a), states the 

following: Each owner or operator of an aircraft-

( a) Shall have that aircraft insoected as orescribed in suboart E ofthis oart and 

shall between required insoections. exceot as provided in oaragraoh (c) of this 

section, have discrepancies 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, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), states the following: 

(a) No oerson may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless--

(1) It has been aooroved for return to service by a person authorized under§ 

43.7 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 Inspections, subsection (a), states the following: 

(a) Except as orovided in paragraph (c) of this section. no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with oart 43 of this chanter and has 

been approved for return to service by a person authorized by § 43.7 of 

this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

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 

registered owner or ooerator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance. preventive maintenance. and alteration and 

records of the 1 00-hour. annual. progressive. and other required or 

approved insoections. as aporooriate. for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 
The records must include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature. and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft. including the time since 

the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including. for each. the method of compliance. the 

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by & 43.9(d) of this chapter for each 

maior alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a )(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after 

the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under & 43.11 

of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

C. The Extent Of Relief 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 pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding 

a private pilot or higher level certificate, as well as a current and valid airman medical 
certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, 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, vessels, vehicles and structures. 

Further, Petitioner submits that all flights of the FY650 and 3DR Solo UASs, 

conducted by the PIC pursuant to the grant of this Petition: (1) will 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 requested 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 ensure that the FY650 and 3DR Solo UASs are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and 3DR Solo Manual) prior to every flight, and further, determine 

that the aircraft are in condition for safe flight, as stated in the conditions and limitations 

below. 

3. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the FY650 and 3DR Solo UASs, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). Since 

the FAA requires that any altitude information concerning UAS operations be reported to 

air traffic control (ATC) in feet above ground level (AGL), Petitioner seeks the requested 

relief because the FY650 and 3DR Solo UASs altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the the FY650 and 3DR Solo UASs are equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief From Section 91.15l(b). 

Relief from Section 91.15 1 (b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 
FY650 and 3DR Solo UASs during daylight hours in visual 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 of the FY650 and 

3DR Solo UASs, and the 3DR operating 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 normal cruising speed, to fly after that for at least 3 minutes. 

5. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief 

From Sections 91.40S(a), 91.407(a)(l ), 91.409(a)(l) & (a)(2), And 91.417(a) 

& (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Petitioner requests relief from 

these Sections because the FY650 and 3DR Solo UASs do not require airworthiness 

certificates. As set forth more fully below, the FY650 and 3DR Solo UASs s meet the 

conditions ofFMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Petitioner will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UASs using generally accepted maintenance methods. 

Furthermore, Petitioner will document and maintain all maintenance records for the 

FY650 and 3DR Solo UASs. 

D. The Reasons Whv Grantine Petitioner Reauest Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole. 
Granting the present Petition will further the public interest by allowing Petitioner 

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

construction sites, real estate, landscape, sporting events and other social events over 

certain areas of the United States. 

Additionally, use of the FY650 and 3DR Solo UASs will decrease congestion of 

the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the 

benefits of Petitioner'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 3DR Solo 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 the FY650 and 3DR Solo 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 

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 flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The FY650 

and 3DR Solo UASs 

Conducting aerial acquisitions with the FY650 and 3DR Solo 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, t the FY650 and 3DR Solo UASs 

produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The 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 combustion engine. 

By using the FY650 and 3DR Solo 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 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 

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds 

with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons). 

3. 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 

such, operation of the FY650 and 3DR Solo UASs will allow United States based 

operators of these systems 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 FY650 and 3DR Solo 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. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Petitioner's proposed operation oft the FY650 and 3DR Solo UASs will not 

implicate any privacy issues. Specifically, the FY650 and 3DR Solo UASs will be 

operated only in compliance with operating documents, which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the 

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

§91.119. 

E. The Reasons Whv Gr antin2: The Exemotion Would Not Adverselv Affect Safety, Or How The Exemotion Would Provide A Level Of Safetv At Least Equal To 

That Provided By The Rule From Which Petitioner Seeks Exemption. 

1. Reasons Whv the FY650 and 3DR Solo UASs Meet The Conditions Of The 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Petitioner's operation of the FY650 and 

3DR Solo UASs meet the conditions ofFMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstandinf! anv other reQuirement of this subtitle. and not 

later than 180 davs after the date of enactment of this Act. the Secretarv 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 Unmanned Aircraft Svstems. --In makim! 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 users of the national airspace system or the public or pose 

a threat to national security; and 

(2) whether a certificate of waiver. certificate of authorization. or 

airworthiness certification under section 44704 of title 49. United 

States Code. is reauired for the ooeration of unmanned aircraft 

systems identified under paragraph (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 seeking this exemption, Petitioner submits that the the FY650 and 3DR Solo 

UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 

(a) the characteristics of the FY650 and 3DR Solo UASs; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

a. The Soecifications Of the FY650 and 3DR Solo UASs Demonstrate Its Safe Characteristics. 

The FY650 and 3DR Solo UASs do not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, speed, 

and operational capability. 

i. Technical Specifications OfT the FY650 and 3DR Solo UASs. 

The technical specifications of the FY650 and 3DR Solo UASs are set forth in 

Exhibit A and B. 

ii. The FY650 and 3DR Solo UASs Autonomous Flieht And Navieation Modes Enable The UASs To Remain Within A Defined 

Operational Area. 

The FY650 and 3DR Solo UASs may be operated in both manual and fully 

autonomous flight 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 Control Link is lost, the FY650 and 3DR Solo UASs will remain 

stationary, in flight, for 3 seconds or more. If the UAS'do not reacquire control link data 

from the GCS, the UAs will assume that the Control Link is lost and the UAs will return 

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

position and shutdown. 

b. Fli!!hts Of the FY650 and 3DR Solo UASs Will Be Conducted Pursuant 

To Specific Operating Limitations. 

In seeking this exemption, Petitioner proposes 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 following specific operating limitations: 

1. Operations authorized bv this grant of exemption will be limited to the 

following aircraft described in the operating documents. rotorcraft UASs weighing less than 55 pounds maximum gross weight: FY650 and 3DR Solo 

Unmanned Aircraft Svstems. Proposed operations of any other aircraft will 

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

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 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 must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) ofthe PIC at all 

times. This reauires the PIC to be able to use human vision unaided bv any 

device other than corrective lenses, as specified on the PIC's FAA-issued 

airman medical certificate. 

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

permitted. 

7. All operations must utilize a safetv observer (SO). The SO mav be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS 
caoabilitv. 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 exemption take precedence 

and must be followed. Otherwise. 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 Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must 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 characteristics. 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 of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraftlcomoonent. 

maintenance, overhaul, 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 of replacement/overhaul component parts 

must be noted in the aircraft records. including total time in service. 

description of work accomplished, and the signature of the authorized person 

returning the UAS to service. 
15. Each 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 possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator mav not permit anv PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the abilitv to safelv 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 purposes 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 flights. 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 is obtained. and the operation is 

conducted in accordance with a NOT AM as required by the operator's COA. 

The letter of agreement with the airport management must be made available 

to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2.000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from 

the PIC. 

22. If the UA loses communications or loses its GPS signal. it must return to a 

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 any 
operations 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 of the 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 COA 
must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

2. Reasons 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 Section 

61. 11 3(a) and (b) will be maintained because 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 safely operate the FY650 

and 3DR Solo UASs in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

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 necessary 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. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 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 of total 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 accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 
equivalent level of safety during 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 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

Pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062. the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model ofUAS to be used for operations under the 

exemption. For clarification. the FAA considers these minimum hour 

requirements to be inclusive rather than additive: i.e. 5 hours make and model 

time may be included in the 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-building 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 consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, 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 UASs 
is in an airworthy condition based upon the UAS's compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

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 established by Section 91.121 will be maintained 

because the altitude information of the FY650 and 3DR Solo UASs will be provided to 

the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with Petitioners operation the FY650 and 3DR Solo 

UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91. 121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 111 57, 11158, 11159, 11160, 11161). 

5. Reasons Whv An Exemotion From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established 

by 14 C.F .R. Section 91.151 (b) as a result of ( 1) the technical specifications of the FY 650 

and 3DR Solo UASs; (2) the limitations on the proposed flight operations; and (3) the 
location of the proposed flight operations. Accordingly, Petitioner will ensure that it will 

safely operate the battery powered FY650 and 3DR Solo UASs during daylight hours in 

VFR conditions, with enough battery power to fly 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. 

Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical characteristics 

and operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151 , including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811 , 10808, 10673, 11042, 

11062, 11063, 11064,1 1065, 11066,11067, 11080,11109, 11110, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 111 59,11 160, 11161). 

6. Reasons Whv An Exemotion From The Reauirements 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 

with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met 

because Petitioner will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs' using the methods, techniques, and practices 

described above. Furthermore, Petitioner will document and maintain all maintenance 

records for the FY650 and 3DR Solo UASs. 

Since the FY650 and 3DR Solo UASs will be inspected as described above, 

Petitioner will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(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 91.417(a) and (b). The 

FAA has previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,11138, 11150, 11153,11156, 

11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA) and 14 C.F .R. § 21.16 entitled Special Conditions, Petitioner requests that 

the FAA prescribe special conditions for the intended operation of the 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 safe 
operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification in accordance 

with any requirements that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R.§ 21.16, for operation of the 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 unusual design feature of the aircraft. aircraft engine or propeller. he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft. aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the 

FAA may prescribe special conditions for Leading Edge's intended operation of the 

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 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: The 
Rules 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), 91.407(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 erate an Unmanned 

Aircraft Svstem (UAS) for the vurvose of conductim! aerial video and 

photography over certain areas of the United States. 

• Anv Additional Information, Views, Or Arguments Available To Support 

Petitioner's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, Javier Ruiz's request for exemption 

may be granted pursuant to the authority 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 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without 

airworthiness certification. 

As discussed in detail above, Petitioner will operate the the FY650 and 3DR Solo 

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

otherwise pose a threat to national security. 

CONCLUSION 
As 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: April 25, 2015 

Respectfully submitted, 

~ · er R:;:(;:;itioner __ _ 

690 SW 27 Avenue 

Aot 705 

Miami. Florida 33145 

954-772-2644 
Appendices: 

A - FY650 Specifications Data Sheet 

B- 3DR Solo Specifications Data Sheet 
APPENDIX - 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 small UAS production. 3DR UASs are 

loaded with ground breaking software enabling the user 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 limit flight to a predetermined and set distance. In addition. 3DR 

software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices) 

Flight time: 19 minutes 

Range: 1 miles 

Max speed: 34.5 mph 

Max altitude: 400 ft per FAA regulation, user adjustable 

Autopilot (Flight Controller): Pixhawk 

Software: APM:Copter 

Communication: Telemetry Module 

Weight: 6 pounds 

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 Vdc 
APPENDIX-B 

3DR SOLO TECHNICAL SPECIFICATIONS 

Petitioner onlv utilizes safe and reliable UASs. 3DR is an industry leader in small UAS 

production. 3DR UASs are loaded with ground breaking software enabling the user 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 limit flight to a predetermined and set 

distance. In addition. 3DR software provides real-time altitude and location information 

to the PIC via the linked monitor (smart phone/tablet devices) 

Flight time: 20 minutes with payload* 

Range: .5 miles 

Max speed: 55 mph 

Max altitude: 400 ft perF AA regulation, 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