1

November 17, 2015

Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

RE: DRONE PRO LLC REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL OPERATION OF 3DR SO LO

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Brett Puffer

CEO/FOUNDER

Drone Pro LLC 1005 Glen Place Dr. Apt 6 Duluth, MN 55806 (c) 952.994.3622 brettpuffer@gmail.com2 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

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

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

BACKGROUND................................................................................................................... .4

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DRONE PRO LLC SEEKS

EXEMPTION................................................................... .........................................7

THE EXTENT OF RELIEF DRONE PRO LLC SEEKS AND THE REASON DRONE PRO LLC

SEEKS THE RELIEF..............................................................10

THE REASONS WHY GRANTING DRONE PRO LLC ’S REQUEST WOULD BE IN THE

PUBLIC INTEREST ............................................................................................12

THE REASONS WH Y GRANTING THE EXEMPTION TO DRONE PRO LLC WOULD NOT

ADVERSELY AFFECT SAFETY.......................................................... ....14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARG UMENTS AVAILABLE TO

SUPPORT DRONE PRO LLC ’S REQUEST..................................................25

CONCLUSION................ .....................................................................................................25

APPENDICES......................................................................................... 263

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

RF Radio Frequency

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 SUMMARY

Drone Pro LLC hereafter referred to as DRONE PRO LLC 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (3) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit DRONE PRO LLC to operate a n Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States.

INTRODUCTION AND IN TERESTS OF THE PETITIONER

DRONE PRO LLC has for the past 6 years provided clients with expertise and knowledge in video

and mu ltimedia marketing, advertising and public relations . DRONE PRO LLC has worked on

various productions over the past 6 years in al l types of locations with a perfect client and employee safety record. In the past, DRONE PRO LLC has supplied clients with aerial video and photography using commercial aircraft. The objective of DRONE PRO LLC and our Unmanned Aircraft System (3DR SOLO) aerial operations is to provide a more affordable, high

- quality production system for a variety of governmental, commercial, public, and residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real

- estate marketing

• Econo mic development

• Civic landmarks

• Special event coverage

• Private and governmental training

• Inspections

DRONE PRO LLC has safely flown small RC electric quadcopters and airplanes recreationally for approxi mately 2 years without incident and have logged a minimum of 40 hours on an RC flight

s imulator in the past year 2 years

.

BACKGROUND

Unmanned Aircraft Systems: 3DR SOLO, UAS

DRONE PRO LLC seeks an exemption to operate 3DR SOLO system for compensation or hire

within the NAS. The 3DR SOLO is vertical t akeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The 3DR SOLO has a maximum gross weight of approximately 3.9 lb. while having a diagonal dimension

of 18 ”, a maximum sp eed of approximately 55 m ph and a maximum flying height of 400'. The5

3DR SOLO is equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors.

The 3DR SOLO that will be operated by DRONE PRO LLC will be registered in accordan ce 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, DRONE PRO LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the 3DR SOLO, UAS 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, DRONE PRO LLC operation of 3DR SOLO UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthine ss certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, DRONE PRO LLC 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 o nly apply to aircraft with an airworthiness certificate.

DRONE PRO LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. DRONE PRO LLC will use experienced personnel or technicians to perform maintenance, al terations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 3DR SOLO Instruction Manual). Furthermore, DRONE PRO LLC will document and maintain all

m aintenance records for the 3DR SOLO UAS.

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

limitations: Pilot in command , is requested by DRONE PRO LLC 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 the 3DR SOLO UAS in a manner c onsistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

DRONE PRO LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the 3DR SOLO UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DRONE PRO LLC submits that they will ensure that the 3DR SOLO UAS is in an airworthy condition, prior to every flight, by determining tha t the UAS are in compliance6

with the operating documents (i.e., Monthly Maintenance Log, and 3DR SOLO Instruction

Ma nual), and that the aircraft is in a condition for safe flight.

DRONE PRO LLC also seeks an exemption from the requirements of Section 91. 121, entitled Altimeter Settings , as the 3DR SOLO UAS will not have a typical barometric altimeter onboard. However, altitude information of the 3DR SOLO UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with DRONE PRO LLC’s operation of the 3DR SOLO UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, DRONE PRO LLC seeks an exemption from the requirements of Section 91.151(b),

entitled Fuel requirements for flight in VFR conditions . DRONE PRO LLC submits that safety will not be affected by operation of the 3DR SOLO UAS 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 23 minutes. Battery power indicators are also able to

sh ow exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, DRONE PRO LLC 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:

Brett Puffer

CEO/FOUNDER

Drone Pro LLC 1005 Glen Place Dr. Apt 6 Duluth, MN 55806

(c) 952.994.3622

brettpuffer@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which DRONE PRO LLC Seeks Exemption.

1. DRONE PRO LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) p rescribe the following, in relevant part:7 (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) 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.

2. DRONE PRO LLC 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. DRONE PRO LLC Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) 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

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

--

(i) The current reported 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 prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station;

or

(iii) In the ca se of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. DRONE PRO LLC 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 person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the fir st point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.8

5. DRONE PRO LLC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), sta tes the following: Each owner or operator of an aircraft

—
(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repai red as prescribed in part 43 of this chapter[.]

6. DRONE PRO LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding,

or alteration

, subsection (a)( 1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapt er[.]

7. DRONE PRO LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided 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 part 43 of this chapter 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. DRONE PRO LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , sub sections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator 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 100

- hour, annual, progressive, and other required or approved inspections,9 as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appl iance 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 app roving 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,

pr opeller, 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 inspectio n 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 directiv e 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 major alteration to the airframe and currently i nstalled 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 servic e.10

C. The Extent Of Relief DRONE PRO LLC Seeks And The Reason DRONE PRO LLC Seeks
The Relief.

1. Extent Of Relief DRONE PRO LLC Seeks And The Reason DRONE PRO LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) en titled 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 f light

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 be low, DRONE PRO LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the 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 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, DRONE PRO LLC submits that all flights of the 3DR SOLO UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to DRONE PRO LLC’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief DRONE PRO LLC Seeks And The Reason DRONE PRO LLC 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 DRONE PRO LLC to determine that the 3DR SOLO UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., DRONE PRO LLC Aerial Operations M anual, Monthly Maintenance Log, and 3DR SOLO Instruction Manual).

DRONE PRO LLC seeks the requested relief because the 3DR SOLO UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DRONE

PRO LLC will ensure that the 3DR SOLO UAS is 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 is in condition for safe fli ght,

as stated in the conditions and limitations below.11

3. Extent Of Relief DRONE PRO LLC Seeks And The Reason DRONE PRO LLC Seeks
Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operat ions of the 3DR SOLO UAS, 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), DRONE PRO LLC seeks the requested relief because the 3DR SOLO UA’s altimeter may be set on the ground to zero feet AGL, rather than t he 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 b elow. As more fully set forth herein, an equivalent level of safety will be maint ained since the 3DR SOLO

UAS is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be establis hed 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 DRONE PRO LLC Seeks And The Reason DRONE PRO LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b ) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered 3DR SOLO UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a tota l duration of 23 minutes. DRONE PRO LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered 3DR SOLO UAS will severely constrain the practicality of any aerial video or still photo flight operations that DRONE PRO LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR SOLO UAS, the 3DR SOLO operating documents, and DRONE PRO LLC’s proposed operating limitations , ensure that DRONE PRO LLC will safely operate the battery powered 3DR SOLO UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 23 minutes.

5. Extent Of Relief DRONE PRO LLC Seeks And The Reason DRONE PRO LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, DRONE PRO LLC requests relief from these Sections

because the 3DR SOLO UAS do es not require airworthiness certificates. As set forth more fully below, the 3DR SOLO UAS meet s the conditions of FMRA Section 33 3 for operation without an12

airworthiness certificate. Accordingly, DRONE PRO LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS opera ting documents (i.e., DRONE PRO LLC Aerial Operations Manual, Monthly Maintenance Log, and 3DR SOLO Instruction Manual). Furthermore, DRONE PRO LLC will document and maintain all maintenance records for the 3DR

SOLO UAS.

D. The Reasons Why Granting DRO NE PRO LLC Request 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 DRONE PRO LLC to safely, efficiently, and economically perform aerial vide o and photography of construction sites, real estate, events and civic landscape over certain areas of the United States.

Additionally, use of the 3DR SOLO UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of DRONE PRO LLC’s proposed operation of the 3DR SOLO UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The 3DR SOLO UAS is battery powered and serve s 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 a 3DR SOLO UAS 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 operatin g in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 3DR SOLO UAS do es not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions w ould 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 3DR SOLO UAS.

Conducting a erial acquisitions with the 3DR SOLO UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the 3DR SOLO UAS 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 3DR SOLO UAS, while reducing the carbon footprint of aerial13

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric

mo tors, rather than an internal combustion engine.

By using the 3DR SOLO UAS 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 operati ons, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 3DR SOLO UAS (weighing approximately

3.9 pounds at their maximum gross weight with diagonal dimension of 18 inches, an d with no fuel on board), has 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 o f approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The 3DR SOLO UAS Will Benefit The Economy.

In addition to being safe and efficient, the 3DR SO LO UAS is also an e conomical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 3DR SOLO UAS will allow United States based companies, like DRONE PRO LLC, to remain competitive and contribute to growth of the U.S. economy. Sp ecifically, 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 competiti ve. Operating the battery powered 3DR SOLO is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the 3DR SOLO UAS, companies such as DRONE PRO LLC, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved fin ancial performance of U.S. companies, through commercial use of the 3DR SOLO UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in o rder to remain competitive both in the United

States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, DRONE PRO LLC’s proposed operation of the 3DR SOLO UAS will not implicate any privacy issues. Specifically, the 3DR SOLO UAS will be operated only in compliance with operating documents (i.e., DRONE PRO LLC Aerial Operations Manual, Monthly Maintenance Log, and 3DR SOLO Instruction Manual) 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. § 91.119.14

E. The Reasons Why Granting The Exemption Would Not Adversely Aff ect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which DRONE PRO LLC Seeks Exemption.

1. Reasons Why The 3DR SOLO UAS Meet s 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, DRONE PRO LLC’s operation of the 3DR SOLO UAS meet s the conditions of FMRA 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 fo r 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.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the nationa l airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secret ary shall determine, at a minimum

--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a h azard 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 r equired for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace

sys tem, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, DRONE PRO LLC submits that the 3DR SOLO UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3DR SOLO UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The 3DR SOLO UAS Demonstrate Its Safe Characteristics.15

The 3DR SOLO UAS does 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 Of The 3DR SOLO UAS.

The technical specifications of t he 3DR SOLO UAS are set forth by the 3DR SOLO User Manual,

attached hereto as Appendix A.

ii. The 3DR SOLO UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area.

The 3DR SOLO UAS may be operated in both manual and global p ositioning flight modes. A complete description of the flight and navigational modes of the 3DR SOLO UAS is provided at pages 37 through 48 of the 3DR SOLO User Manual attached hereto as Appendix A.

iii. The 3DR SOLO UAS Is Designed For Automatic Return To Ho me Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the 3DR SOLO UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. If the signa l is recovered while returning home, the PIC is provided the option to regain manual control.

A complete description of the Failsafe Functions of the 3DR SOLO UAS are set forth at pages 45 of the 3DR SOLO User Manual, attached hereto as Appendix A.

iv. T he 3DR SOLO GCS And Its Operation.

SOLO communicates with the controller and app software over the 3DR Link secure Wi

- Fi

connection of 2.4 GH z

. A complete description of the operation and specifications

, details about

the flight control software , and FCC compliance (Part 15) information is pro vid ed in the 3DR SOLO User Manual. 3DR SOLO User Manual is attached hereto as Appendix A.

11.3.1 U.S.

– FCC (Federal Communication Commission)

3DR Solo FCC: 2ADYD

- S111A

3DR Solo Controller FCC: 2ADYD

- AT11A

b. Flight Operations Of 3DR SOLO UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

DRONE PRO LLC video production staff will be the only persons to act as a pilot in command (PIC) of the 3DR SOLO UAS. Additionall y, a safety observer will assist him at all times during flight time.

c. Flights Of 3DR SOLO UAS Will Be Conducted Pursuant To Specific Operating
Limitations.

In seeking this exemption, DRONE PRO LLC proposes to commercially operate 3DR SOLO

UAS for the s pecial purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations.16 1. Operations authorized by this grant of exemption will be limited to the following

aircraft described i n the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: 3DR SOLO Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations unde r 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 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must

be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical

certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. 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 perform 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 op erating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedure s outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may upda te or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision17 would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect 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 operating 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 th e preflight inspection. 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 critic al component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, 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, inspection, alterations, and status of replacement/overhaul component parts must

be noted in the aircraft re cords, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to

service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry 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 cer tificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption,

inclu ding 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. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption.18 However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight o perations 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 may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operation s must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special 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 wi th 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 request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cl oud 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 pre

determined location within the planned operating area and land or be recovered in accordance with the opera ting 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 condu cting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in acco rdance 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 accordan ce 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.19 27. Before conducting operations, the radio frequency spectrum used for operation and

control o f 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, v ehicles, 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 protecti on. 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 safety 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, operato r 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. Per mission from land owner/controller or authorized representative will be obtained for each flight

to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the ap plicable 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 Why An E xemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.20

DRONE PRO LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR SOLO UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency r equirements, that the PIC is able to safely operate the 3DR SOLO UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering DRO NE PRO LLC’s proposed area of operations, and the operating limitations set

forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the 3DR SOLO UAS, DRONE PRO LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for DRONE PRO LLC’s specific proposed flight o perations.

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, 11 110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

DRONE PRO LLC will not allow any PIC to operate the 3DR SOLO UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the 3DR SOLO UAS training and

cu rrency requirements, that the PIC is able to safely operate the 3DR SOLO UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Specif ically, 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 us ed 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 experien ce that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during DRONE PRO LLC’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with app licable 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 61.51(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 of UAS 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 10 hours of multi

- rotor time and the 10 hours may be21

included in the total 25 hours of UAS 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 flight

- hour 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 fi nds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- 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, DRONE PRO LLC will ensure safe operations by not allowing any PIC to operate the 3DR SOLO UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the 3DR SOLO UAS i n a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adverse ly Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, DRONE PRO LLC will ensure that the 3DR SOLO UAS is in an airworthy condition based upon the UAS’s compliance with its operat ing 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. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The e quivalent level of safety established by Section 91.121 will be maintained because the altitude information of the 3DR SOLO UAS 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 DRONE PRO LLC’s operation of the 3DR SOLO UAS 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 be22

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from S ection 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, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption 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 3DR SOLO UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, DRONE PRO LLC will ensure that it will safely operate the battery powered 3DR SOLO UAS during daylight hours in VFR conditions, with enough battery power to fly for a total

duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 3DR SOLO UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 3DR SOLO UAS provide audible and visual warnings to the PIC at

the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 25 % remaining battery power, and again at approxim ately 10% remaining battery power. At the critically low battery level, the 3DR SOLO UAS will descend and land automatically.

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, 11065, 11066, 11067, 11080, 11109 , 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely
Affect Safe ty.

In seeking this exemption, DRONE PRO LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections23

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) wil l be met because DRONE PRO LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribe d in the operating documents ( DRONE PRO LLC Aerial Operations Manual ). Furthermore, DRONE PRO LLC will

document and maintain all maintenanc e records for the 3DR SOLO UAS in a monthly log.

Since the 3DR SOLO UAS will be inspected as prescribed by the operating documents, DRONE PRO LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2 ). A copy of the 3DR SOLO User Manual is att ached hereto as Appendix A

. Likewise, the exemption sought will not adversely affect safety because DRONE PRO LLC will

use trained technici ans to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

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 3DR SOLO UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions grant ed 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 DRONE PRO LLC’s proposed operating limitations, the operating documents, and the technical aspects of the 3DR SOLO UAS, DRONE PRO LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)( 1) 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, 11 109, 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, DRONE PRO LLC requests that the FAA prescribe special conditions for the intended operation of the 3DR SOLO UAS, 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), 91.40 9(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.24

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the 3DR SOLO UAS, since the airworthines s 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 airworthi ness regulations of this subchapter do not contain adequate or appropriate safety 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 con ditions 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 DRONE PRO LLC’s intended operation of the 3DR SOLO UAS, 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 DRONE PRO LLC Seeks Exemption:

DRONE PRO LLC seeks exemption from the requirements of 14 C.F.R Sectio ns 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 Brief Description Of The Nature Of The Exemption DRONE PRO LLC

Seeks:

This exemption will permit DRONE PRO LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support DRONE PRO LLC’s Request.

This Petition is m ade pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, DRONE PRO LLC’s request for exemption may be granted pursua nt to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.25

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 s ecurity; and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, DRONE PRO LLC will operate the 3DR SOLO UAS safely in the NAS, without creating a hazard to users of the NAS, or the p ublic, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, DRONE PRO LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operati on of the 3DR SOLO UAS 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 C ongressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing DRONE PRO LLC to safely, efficiently, and economically operate the 3DR SOLO UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, DRONE PRO LLC 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a ) & (b), and permit DRONE PRO LLC to operate the 3DR SOLO UAS commercially for the purpose of conducting aerial video and photography over certain are as of the

United States. Dated: November 11, 2015

Respectfully submitted,

Brett Puffer

CEO/FOUNDER

Drone Pro LLC 1005 Glen Place Dr. Apt 6 Duluth, MN 55806 (c) 952.994.3622 brettpuffer@gmail.com

Appendices :

A

– Link to 3DR SOLO Manual: Click on link below

https://3drobotics.com/wp

- content/uploads/2015/10/v7_10_20_15.pdf26