FEBRUARY 15th, 2016

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Madam, Sir,

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

C.F.R. Part 11, Michael D. Crow and Associates ("Crow"), an operator of the # 3DRobotics Solo 

Unmanned Aircraft System ("Solo") seeks an exemption from the Federal Aviation Regulations 

("FARs") listed below:

• 14 C.F.R. 21

• 14 C.F.R. 45.23 • 14 C.F.R 45.29

• 14 C.F.R. 61.133(a) • 14 C.F.R. 91.7(b)

• 14 C.F.R. 91.9(b)(2) • 14 C.F.R. 91.109(a) • 14 C.F.R. 91.119

• 14 C.F.R. 91.151 (a)

• 14 C.F.R. 91.203(a) & (b)

• 14 CFR Subpart E (91.401 -91 .417)

The requested exemption would authorize commercial operations for the Solo for mapping and survey 

applications. These operations will be subject to strict operating requirements and conditions defined 

by the Safety Code of the Academy of Model Aeronautics (see Annex B), in order to ensure at least an 

equivalent level of safety to currently authorized operations for manned aircrafts.

The Solo will be operated by an individual who fulfills the following requirements:

• Has successfully passed a manufacturer's training program for the Solo ; • Has a commercial pilot 

certificate;

• Has an AMA membership.

1. CHARACTERISTICS OF THE AIRCRAFT

The Solo is a small (18” motor to motor, multirotor aircraft) an ultra-light (maximum take-off weight 

of 4.2 pounds) platform made of molded plastic that performs precision aerial mapping missions thanks

to the on-board GPS and the related flight management software (mission planner) that allows the 

operator to plan safely and efficiently a mission in 3D, and then monitor it in real-time. Thanks to the 

attached camera, the Solo takes a collection of high-definition still images that are used later to 

generate maps and contour lines of the surveyed area.

The 3 main characteristics of the Solo are:

a. Electric-powered

The Solo is electric powered. A brushless motor technology makes it reliable. 

b. Semi-automatic flight

The artificial intelligence incorporated within the Solo autopilot system continuously analyzes data 

from the Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects of the 

flight under the supervision of the operator.

c. Option for Manual control

Additionally, the Solo provides an override capability that allows the operator to take manual actions 

of the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated 
operations and take manual control of the aircraft should it become necessary to respond emergent 

circumstances, thanks to the remote controller provided with the system.

2. APPLICATIONS Surveying and mapping for:

Federal and Local Flood Control

Federal, State, and Local Disaster Management Landfills

Mining

Utilities

Agriculture

Golf Courses

Construction Sites

APPLICABLE LEGAL STANDARD UNDER SECTION 333 a.

Airworthiness assessment of the Solo 

Conducting commercial operations with the 3DR Solo, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated during traditional 

commercial aviation operations. 

The Solo operates on battery power and electric motors. These aircraft produce no air 

pollution, and are the most viable environmentally conscious alternative to cabin class, 

internal combustion aircraft that are typically utilized in commercial operations

.

SUAS also reduce noise pollution, as the electric motors produce far less noise

.

By using these aircraft to perform commercial aerial operations, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the aircraft, this aircraft 

weighs less than 55pounds at their maximum gross weight, and therefore have less physical 

potential for collateral damage to life and property on the ground, and in the air,

compared to 

typical manned aircraft

• Operations to be conducted over private, controlled-access, or public property where approved;

• Permission from the land owner/authority required before commencing any flight; • Operations over 

congested areas shall be avoided;

• Operations must not interfere with manned aircraft operations, must yield the right of way to

manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) 

• Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at

all times;

• VLOS guaranteed with a GPS geo-fence for operator of 0.5 miles

• Flight ceiling pre-programed at 400 feet;

• All operations conducted within 5 miles from an airport shall only be initiated after verbal 

coordination with the airport authority, or air traffic control when a control tower is present at the 

airport;

• All operations shall comply with required permissions and permits established by territorial, state, 

county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental 

agencies.

• The Solo operations will be compliant with existing safety procedures inherent to the activities of the
related company.

c. Crow Operator Requirements

• Has successfully passed a manufacturer's training program for the Solo ; • Has an AMA membership;

• Holds a pilot certificate

3. CONCLUSION

Crow sees a great need for inexpensive yet highly detailed aerial mapping information. With the Solo , 

Crow will be able to help local governments achieve greater efficiency and cost savings in managing 

drainage, landfills, urban forests, and disasters. In addition, with a Solo , Crow can expand its 

surveying services for existing customers in Utilities and Mining, and new markets such as Agriculture.

The result of this technology for everyone will increase profits and create more jobs.

Sincerely,

Marshall Batten

Michael D. Crow & Associates Inc

104 West Reynolds St Suite 1

Plant City Fl 33563

Phone # 813-754-0505

Email: marshall@flsurveyor.com

ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Crow requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the Solo :

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

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the Solo , its very light 

weight and the limited (the maximum take-off weight is 4.2 pounds) operating area associated with its 

utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart

H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the 

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

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

involved.

In this case, an analysis of these different criteria demonstrates that the Solo operated without an 

airworthiness certificate, under the conditions proposed in that exemption, will be at least as safe, or 

safer, than a conventional aircraft with an airworthiness certificate. A risk assessment for operations 

with the Solo , which demonstrates that assertion, was submitted as part of this application.

Indeed, the Solo weighs less than 4.2 pounds, maximum take-off weight. It is made of molded plastic, 

does not carry a pilot or passenger, does not carry flammable fuel, and will operate exclusively within 

an area pre-disclosed and in compliance with conditions set forth herein. Operations under this 

exemption will be tightly controlled and monitored by the operator through the constant 

communication link and the ground station. Moreover, a geo-fence and a flight ceiling will be defined 

by the operator before each flight to make sure the Solo will not go beyond the defined flight envelop.

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 
letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entrance to the cockpit, or pilot station.

Given the size of the Solo (18 inches), this requirement is impossible to match.

The equivalent level of safety will be achieved by Crow the upper part of the Solo stick with a copy of

the AMA membership of the operator in charge. The AMA agrees to provide 2 original copies of the 

AMA license to every Solo operator.

Moreover, each operator will display at the ground station a high contrast flag or banner that contains 

the words "Unmanned Aircraft System Ground Station" in letters 3 inches high or greater. Since the 

aircraft will operate within 1/2 NM of the ground station, the banner should be visible to anyone that 

observes the aircraft and chooses to investigate its point of origin.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

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

Should the exemption be granted Crows commercial operation of the Solo without an airworthiness 

certificate, no standard exists for airworthiness of the Solo . Given the size of the aircraft 

An equivalent level of safety will be achieved by insuring compliance with the 3DRobotics manuals 

prior to each flight.

14 C.F.R. § 91.9: Civil aircraft flight manual and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, the documentation would 

not be available to the crew.

The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the Solo 

transportation box.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is used for flight instruction 

unless that aircraft has fully functioning dual controls."

Flight instruction will be accomplished through an elaborated training program,. The equivalent level 

of safety and training will be achieved by the manufacturer providing the training and through the use 

of experienced and qualified operators familiar with the Solo .

14 CFR § 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum 

of 400 feet AGL, the Solo cannot comply with this requirement.

The equivalent level of safety will be achieved because the Solo will only fly over private property 

with the permission of the landowner. The operator will define before every flight a working area 

radius and a flight area ceiling, preventing the Solo to go beyond the flight area.

The landowner and the persons who may be on the ground in the flight area will be briefed of the 

expected route of flight and the associated risks to persons and property on the ground. Due to the 

small size of the Solo and the material with which the Solo is built, the hazard to persons, vessels, 

vehicles, and structures is not comparable to manned aircraft and should be considered in granting the 

exemption.

Moreover, the aircraft will not be operated over congested areas nor over any open-air assembly of 

persons. The aircraft will be operated at an altitude if a power unit fails, an emergency without undue 

hazard to persons or property on the surface.

14 CFR 91.121 - Altimeter settings

This section requires that each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 

18,000 feet MSL to:
• The current reported altimeter setting of a station the route and within 100 nautical miles of the 

aircraft;

• If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station;

• In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure.

To provide an equivalent level of safety,

the Solo autopilot calculates the reference altitude (ground level) with the on-board GPS The GPS 

provides reliable information for the auto pilot to make corrections to the altitude. 

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

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30

minutes.

Given the area of operation for the Solo , Crow believes that an equivalent level of safety is already 

achieved with the specific procedure preventing the Solo to accept a take-off order if the battery level 

is below a given value. Moreover, 3DR has integrated "low" and "critical" battery level and 

implemented a "return to Home" (and "Go Land") actions in these situations.

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

This regulation provides as follows:

No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate.

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

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

entrance so that it is legible to passengers or crew.

The Solo weighs only 4.2 pounds (max take-off weight). As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. In addition, there is no pilot or 

passengers on board the aircraft.

To obtain an equivalent level of safety and meet the intent of 91.203, Crow propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the operator at the ground 

control station in the Solo box and available for inspection upon request. In order to identify the 

aircraft, Crow proposes that a copy of the AMA membership of the operator will be permanently 

affixed to the Solo on the upper side of the body.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance

and inspection. Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness 

certificate. Section 91.417(a) requires the owner or operator to keep records showing certain 

maintenance work that has Solo accomplished by certificated mechanics, under Part 43, or licensed 

pilots and records of approval of the aircraft for return to service.

Crow proposes that the maintenance of the Solo will be accomplished by the owner/operator 

according to the user manual, such as Exhibit 1, provided by 3Drobotics. An equivalent level of safety 

will be achieved because the Solo is small in size, it is not a complex mechanical device, it will carry 

no external payload, and it will operate only in restricted predetermined areas. Moreover, the operator 

is the person most familiar with the aircraft and is suited to maintain the aircraft in an airworthy 

condition and to ensure an equivalent level of safety. Finally, before every flight, the Solo runs 

automatically a sequence of pre-flight tests to make sure that every sensor and every critical part is 

running properly. If a problem is detected, the Solo will not be able to be switched-on and a message 

error is displayed on the main screen of the solo app. The operator can then refer to the maintenance 

manual to troubleshoot this issue. Several parts of the Solo are easily interchangeable (propellers), 
which allows the operator to make sure the propulsion system is always airworthy when a mission is 

initiated.

ANNEX B: ACADEMY OF MODEL AERONAUTICS SAFETY REQUIREMENTS

http://www.modelaircraft.org/files/105.pdf

http://www.modelaircraft.org/files/540-D.pdf

http://www.modelaircraft.org/files/560.pdf

Exhibit 1: https://3dr.com/wp-content/uploads/2016/01/v8_01_05_16.pdf