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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 SOLO

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.com
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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 WHY 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 ARGUMENTS AVAILABLE TO 

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

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

APPENDICES......................................................................................... 26
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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 Landing 
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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 an 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 INTERESTS OF THE PETITIONER

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

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

various productions over the past 6 years in all 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 

• Economic 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 

approximately 2 years without incident and have logged a minimum of 40 hours on an RC flight 

simulator 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 takeoff 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 speed of approximately 55 mph and a maximum flying height of 400'. The 
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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 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, 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 airworthiness 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 only 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, alterations, 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 

maintenance 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 consistent 

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 that the UAS are in compliance 
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with the operating documents (i.e., Monthly Maintenance Log, and 3DR SOLO Instruction 

Manual), 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 

show 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) prescribe the following, in relevant part: 
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(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 case 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 

first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 20 minutes. 
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5. DRONE PRO LLC 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 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 repaired 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 chapter[.] 

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, subsections (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, 
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as appropriate, 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 

major 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. 
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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) 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 flighthour 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, 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 Manual, 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 flight, 

as stated in the conditions and limitations below.
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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 operations 

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 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 3DR SOLO 

UAS is 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 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 total 

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 apply to 

aircraft with an airworthiness certificate, DRONE PRO LLC requests relief from these Sections 

because the 3DR SOLO UAS does not require airworthiness certificates. As set forth more fully 

below, the 3DR SOLO UAS meets the conditions of FMRA Section 333 for operation without an 
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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 operating 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 DRONE 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 video 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 serves 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 operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The 3DR SOLO UAS does 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 3DR SOLO UAS. 

Conducting aerial 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 aerial 
13

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

motors, 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 operations, 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, and 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 of 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 SOLO UAS is also an economical 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. 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 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 financial 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 order 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 Affect 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 Meets 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 meets

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 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.--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 national 

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 Secretary 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 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 required 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 

system, 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.
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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 the 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 positioning 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 Home 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 signal 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. The 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 GHz. A complete description of the operation and specifications, details about 

the flight control software, and FCC compliance (Part 15) information is provided 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. Additionally, 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 special 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 in 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 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 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 operating 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 procedures 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 update or revise its operating documents. 

It is the operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator 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 revision 
17

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 the 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 critical 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 records, 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 thirdclass medical certificate. 

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, 

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. § 61.51(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 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 may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations 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 with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the 

Administrator upon 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 predetermined location within the planned 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 

(NOTAM) 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. 
19

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 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, 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. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption 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 requirements, 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 DRONE 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 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, 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 

currency 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. 

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 

DRONE PRO LLC’s 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 61.51(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 be 
21

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 finds 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 in 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 

Adversely 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 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. 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 equivalent 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 be 
22

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 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, 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 approximately 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 Safety. 

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 Sections 
23

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will 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 prescribed in the operating 

documents (DRONE PRO LLC Aerial Operations Manual). Furthermore, DRONE PRO LLC will 

document and maintain all maintenance 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 attached hereto as 

Appendix A.

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

use trained technicians 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 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 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, 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, 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), 91.409(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. 
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 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 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 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 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 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 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 made 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 pursuant 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 security; 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 public, 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 

operation 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 Congressional 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 areas 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.pdf
26