3D Aerial Solutions LLC 

4 725 Constitutional Court 

Dayton, OH 45440 

Phone: (937) 510-6836 

October 8th, 2015 

3)) AERIAL 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of2012 and Part 11 of 

the Federal Aviation Regulations from: 14 CFR 61.23(a) & (c); 14 CFR 61.101 (e) (4) & (5); 

14 CFR 61.113 (a); 14 CFR 61.315 (a); 14 CFR 91.7 (a); 14 CFR 91.119 (c); 14 CFR 91.121; 

14 CFR 91.151 (a) (1); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1) & 

(2); 14 CFR 91.417 (a) & (b) 

Dear Sir or Madam: 

Pursuant to·Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 C.F.R. Part 11, 3D Aerial Solutions LLC (3DA) herein after also known as the operator, 

is an operator of small Unmanned Aircraft Systems (UAS). 3D A is an Ohio-based company that 

provides specialized expertise in creating and tailoring Unmanned Air System technology 

solutions for industrial and public applications. 3D A requests this exemptions in order to pursue 

UAS applications in the following areas: 

• Aerial surveying, mapping and data collection 

• Remote sensing 

• Educational and research operations 

• Wildlife and forestry monitoring 

• Aid in disaster and emergency management and monitoring, civil first response, 

communications relay, search and rescue, monitoring fire hazards, cleanup effort 

supervision, damage assessment and estimation 

• Aid civil engineering: waterways and shipping, forestry, fishery protection, pollution 

control and air sampling and crop performance 

• Railroad and motor vehicle road inspection 

• Telecommunications infrastructure inspection 

• Utility, Energy systems and electrical engineering inspections and asset management 

• Agricultural surveying and produce field management 

• Livestock management and accountability 

• . · Construction site inspections and monitoring 

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• Oil and gas pipeline inspection/patrolling and oil-field inspection 

• Real estate and marketing 

• Aerial event security, surveillance and crowd management 

• Aerial imagery evidence for property insurance claims 

• Structure Inspection 

3DA hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to 

allow commercial operation of their U A, with full understanding that operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333. As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive UAS under controlled conditions in the 

National Airspace System (NAS) regulated by the Federal Aviation Administration (FAA). 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to " ... establish requirements for 

the safe operation of such aircraft systems in the national airspace system." Section 333(c) 

of the Reform Act. 

The name and address of the applicant is: 

3D Aerial Solutions LLC 

Attn: Bret R. Givens 

4 725 Constitutional Court 

Dayton, OH 45440 

Phone: (937) 510-6836 

Email: bgivens@3daerial.com 

Regulations from which the exemption is requested: 

• 14 CFR 61.23 (a) & (c) - Medical certificates: Requirements and duration 

• 14 CFR 61.1 01 (e) ( 4 ), ( 5) & ( 6) - Recreational pilot privileges and limitations 

• 14 CFR 61.113 (a) - Private pilot privileges and limitations: Pilot in command 

• 14 CFR 61.315 (c) (2), (3), ( 5) & (7) - What are the privileges and limits of my sport pilot 

certificate? 

• 14 CFR 91.7 (a)- Civil aircraft airworthiness 

• 14 CFR 91.119 (c) -Minimum safe altitudes: General 

• 14 CFR 91.121- Altimeter settings 

• 14 CFR 91.151 (a) (1) (2)- Fuel requirements for flights in Visual Flight Rules (VFR) 

conditions 

• 14 CFR 91.405 (a)- Maintenance required 

•14 CFR 91.407 (a) (1)- Operation after maintenance, preventative maintenance, rebuilding, and 

alteration 

• 14 CFR 91.409 (a) (1) & (2)- Inspections 

• 14 CFR 91.417 (a) & (b)- Maintenance records 

Regulatory Basis for Exemption Request 

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This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of U AS do 

not create a hazard to users of the NAS or the public or pose a threat to national security in light 

of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the U AS in close proximity to airports and populated areas 

• Operation ofthe UAS within visual line of sight ofthe operator. 

The aircraft intended for use for the operator includes the DJI Phantom 2, DJI Phantom 2 

Vision+, DJI Phantom 3, DJI Matrice 100, Sensefly Exom, 3DRobotics X8, 3DRobotics Y6, & 

3DRobotics Solo. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system." Id. §333(c) (emphasis added). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, which includes UAS, from the requirement that all civil aircraft must have a 

current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator 

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 

USC §44704; 14 CFR §91.203 (a) (1). 

3D Aerial Solutions LLC's UAS are rotorcraft, weighting 55 or fewer pounds including payload. 

The UAS operate under normal conditions at a speed of no more than 50 knots and have the 

capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will 

be operated only in line of siggt and will b~ operated ~mly 'Yithin a predetermined and protected 

flight area under the permission of the property representative. The UAS will be operated under 

the below listed limitations and conditions to which the operator agrees to be bound when 

conducting commercial operations under an FAA issued exemption, as well as any other 

limitations the FAA may place on future operations. Such operations will insure that the UAS 

will "not create a hazard to users of the national airspace system or the public as per the Reform 

Act Section 333 (b). 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; The strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, including enhanced safety, reduction in 

environmental impacts, including reduced emissions associated with allowing UAS for aerial 

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data collection, the grant of the requested exemptions is in the public interest. Accordingly, the 

applicant respectfully requests that the FAA grant the requested exemption without delay. 

The FAA has issued grants of exemption in circumstances similar in material respects to those 

presented in this petition. In Exemptions Nos. 12990, 11280, 11279, 11278, 11275, 11273, 

11271, 11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, 11109 

Aircraft and Equivalent Level of Safety 

14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). 

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

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

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular UAS. In all cases, an analysis ofthese criteria demonstrates that 

the UAS operated without an airworthiness certificate, in the restricted environment and under 

the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing 

or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

The UAS to be operated hereunder are rotorcraft weighing less than 55 pounds including 

payload, carries neither a pilot nor passenger. Carries no explosive materials or flammable liquid 

fuels, and operates exclusively within visual line of sight of the pilot in command (PIC) and a 

visual observer (VO). They operate at a speed ofless than 50 knots and have the capability to 

hover and move in the vertical and horizontal plane simultaneously within a predetermined and 

protected flight area as described below. Such operations will insure that the UASs will not 

create a hazard to the users of the national airspace system. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements, to provide security for the 

area of operation. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UA, due to its size, speed of operation, location of 

operation, lack of explosive materialsor flaml1!~21~ lig!!!dJuels, and inability to carry a 

substantial external load. 

The Secretary of Transportation has previously determined that these aircraft meets the 

conditions of Section 3 3 3. Therefore, the FAA has found that request of relief from 14 CFR part 

21, and any associated noise certification and testing requirements of part 36, is not necessary. 

This has been stated in exemptions to this regulation in Exemptions Nos. 12990, 11280, 11279, 

11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250 and 11230 

The applicant proposes that the exemption requested herein apply to aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

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8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with aVO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. lfthe 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 U AS is found to 

be in a condition for safe flight. 

11. The operator must follow the U AS manufacturer; s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under the exemption must comply with all manufacturer's safety 

bulletins. 

13. A PIC must hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a 

valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC must also meet the flight 

review requirements specified in 14 CPR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CPR§ 61.51(b). 

Flights for the purposes of training the operator's PICs and VOs (training, proficiency, 

and experience building) and determining the PIC's ability to safely operate the UAS in a 

manner consistent with how the U AS will be operated under this exemption are permitted 

under the terms of the exemption. 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 UAS with appropriate distance from nonparticipants in 

accordance with 14 CPR § 91.119. 

15. "VAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. " - Relief from this 

restriction prohibiting night flight. 3DAerial would like the ability to perform roof 

inspections on large commercial buildings with flat roofs. In warmer 

seasons/climates, spots of a roof that are leaking have collected water that retains 

the day's heat for a few hours longer than the rest of the roof that has not been 

compromised. The traditional method for locating leaks, or wet spots on large flat 

roofs is to use a handheld thermal imaging camera shortly after nightfall and have 

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the technician walk the roof to identify leaks. While many safety features are in 

place, every year, several people become distracted and accidentally walk off an 

edge in the dark resulting in serious injury or death. This is a very dangerous job 

that commercial roofing companies would like to make much safer and even save 

lives by using UASs. Since the thermal imaging needs to be done shortly after 

sunset, and after several hours does not yield results, 3DAerial is requesting only 

partial relief from this limitation and seeking permission to operate up to 4 hours 

after sunset. 3D Aerial will still maintain visual flight rules and only fly under VFR 

conditions and altitude lower than 100 ft. to top of inspection site. 

16. The U AS may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center ofthe airport symbol as denoted on the current FAA published 

aeronautical chart, unless a letter of agreement with that airport's management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request. 

17. The UAS 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. 

18. If the UAS loses communications or loses its GPS signal, the UAS must return to a 

predetermined location within the private or controlled access property. 

19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UAS to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N- 6 

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight ofthe UAS and 

any documents required under 14 CFR §§ ~91.9 and91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

24. The UAS must remain clear and give way to all manned aviation operations and activities 

at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UAS and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

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and in a protected flight area under the permission of the property representative, and all flights 

are planned and coordinated in advance. 

Relief from restriction prohibiting night flight. 3D Aerial would like the ability to perform roof 

inspections on large commercial buildings with flat roofs. In warmer seasons/climates, spots of a 

roof that are leaking have collected water that retains the day's heat for a few hours longer than 

the rest of the roof that has not been compromised. The traditional method for locating leaks, or 

wet spots on large flat roofs is to use a handheld thermal imaging camera shortly after nightfall 

and have the technician walk the roof to identify leaks. While many safety features are in place, 

every year, several people become distracted and accidentally walk off an edge in the dark 

resulting in serious injury or death. This is a very dangerous job that commercial roofing 

companies would like to make much safer and even save lives by using UASs. Since the thermal 

imaging needs to be done shortly after sunset, and after several hours does not yield results, 

3D Aerial is requesting only partial relief from this limitation and seeking permission to operate 

up to 4 hours after sunset. 3D Aerial will still maintain visual flight rules and only fly under VFR 

conditions and altitude lower than 100 ft. to top of inspection site. 

The FAA has issued the following exemptions of this regulation: Exemption Nos. 12990, 11278, 

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. 

This section limits private pilots to non-commercial operations and that they may not act as pilot 

in command of an aircraft that is carrying passengers or property for compensation or hire. 

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely 

controlled with no living thing on board. The area of operation will be predetermined and in a 

protected flight area under the permission of the property representative, and all flights are 

planned and coordinated in advance. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 12990, 11278, 

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 61.315 (c) (2) (3) (5) (7): What are the privileges and limits of my sport pilot 

certificate? 

This section limits sport pilots to non-commercial operations and that they may not act as pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire, or in the 

furtherance of a business. They also may not carry more than one passenger, fly at night, and 

under other restrictions that are outside of the scope of intended flights of the UAS. Unlike a 

conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with 

no living thing on board. The area of operation will be predetermined and in a protected flight 

area under the permission of the property representative, and all flights are planned and 

coordinated in advance. 

Relief from restriction prohibiting night flight. 3DAerial would like the ability to perform roof 

inspections on large commercial buildings with flat roofs. In warmer seasons/climates, spots of a 

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will ensure separation between these small- UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119. 

The FAA has issued the following exemptions to this regulation: Exemptions Nos. 12990, 

11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.121: Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the manufacturer's published procedures and live 

flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. In the event that the GPS altitude read out system becomes none 

functional during flight, the UAS will also have a pre-programmed maximum flight limit of 400 

feet programmed into them so that they may not fly above unapproved altitude limits. The FAA 

has issued the following exemptions to this regulation: 

Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.151(a) (1) (2): Fuel Requirements for Flight in VFR Conditions. 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 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- (1) During the day, 

to fly after that for at least 30 minutes; Or (2) at night, to fly after that for at least 45 minutes." 

The LiPo battery powering the DJI Phantom 2 & DJI Phantom Vision +,DJI Phantom III, 

SenseFly Exom, 3DRobotics X8,3DRobotics Y6 and 3DRobotics Solo UAS provides less then 

25 minutes of powered flight. While the DJI Matrice 100 will support flights up to 40 minutes 

with a second LiPo battery. The PIC will not begin a flight unless there is enough available 

power for the U AS to conduct the intended operation and to operate after that leaving at least 

20% battery or with the reserve power recommended by the manufacturer if greater. Applicant 

believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions, 

and that flight with less than 45 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. 

Similar exemptions have been granted to other operations, including Exemptions Nos. 12990, 

11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this 

chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given 

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that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. 

An equivalent level of safety will be achieved because these small UASs are very limited in size 

and will carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 

200 feet AGL and within VLOS of the PIC and VO. Prior to each flight, the PIC must conduct a 

pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight 

inspection must account for all potential discrepancies, e.g. inoperable components, items, or 

equipment. 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 operator must follow the UAS 

manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components. 

The FAA has issued the following exemptions to this regulation: Exemptions Nos. 12990, 

11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

Privacy 

All flights will occur over private or controlled access property with the property representative 

or owner's prior consent and knowledge. Filming will be of people who have also consented to 

being filmed or otherwise have agreed to be in the area where filming will take place. 

All flights will occur in accordance with any state or local laws regarding privacy. 

Additional Views, Information & Summary 

3D Aerial Solutions LLC has collective experience over 20 years in unmanned aircraft flight 

operations for military and civilian use. 3D Aerial Solutions currently holds a valid private pilot 

certificate as well as a 333 Exemption (#11193) for fixed wing operations of the Sensefly Ebee 

platform. We understand that safety is paramount, but we also know that integrating and 

operating in congested airspace along with manned aircraft is possible without incident. 

3D Aerial Solutions LLC was established November 2013. 

3D Aerial Solutions LLC support public outreach and education through the sponsorship of the 

Dayton Drone Users Group. 

As a public benefit 3D Aerial Solutions LLC will advance: 

• Research into future safety guidelines for the use ofUAS, 

• Reduction in dangers by limiting the use of larger rotorcraft or fixed wing aircraft, 

• Reducing carbon emissions, & 

• Advancement of science through advanced data collection 

********* 

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Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 CFR 61.23(a) & (c); 14 CFR 61.101 (e) (4) & (5); 14 CFR 61.113 (a); 14 CFR 61.315 (a); 

14 CFR 91.7 (a); 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR 91.151 (a) (1); 14 CFR 91.405 

(a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1) & (2) and 14 CFR 91.417 (a) & (b) to 

operate commercially a small unmanned vehicle (55pounds or less) for the purpose of aerial 

surveying, mapping and data collection; Remote sensing; Educational and research operations; 

Wildlife and forestry monitoring; Aid in disaster and emergency management and monitoring, 

civil first response, communications relay, search and rescue, monitoring fire hazards, cleanup 

effort supervision, damage assessment and estimation; Aid civil engineering: waterways and 

shipping, forestry, fishery protection, pollution control and air sampling and crop performance; 

Railroad and motor vehicle road inspection; Telecommunications infrastructure inspection; 

Utility, energy systems and electrical engineering inspections and asset management; 

Agricultural surveying and produce field management; Livestock management and 

accountability; Structure Inspection; Construction site inspections and monitoring; oil and gas 

pipeline inspection/patrolling and oil-field inspection; Real estate and marketing; Aerial event 

security, surveillance and crowd management and aerial imagery evidence for property insurance 

claims. 

Approval of exemptions allowing commercial operations ofUAS in the listed industries will 

enhance safety by reducing risk. Conventional flight operations using jet, piston or multi-engine 

powered aircraft occasionally operate at extremely low altitudes to complete some of the 

requested uses and in extreme proximity to people and structures. This presents associated risks 

as these vehicles weigh in excess of 3,000 pounds and carry large amounts of jet A or other fuel. 

Such aircraft must fly to and from the mission location. In contrast, a UAS weighing fewer than 

55 pounds, powered by batteries, virtually eliminates all ofthe above risks given the UAS's 

reduced mass and lack of combustible fuel carried on board. The UAS is carried to the mission 

site. The UAS will carry no passengers or crew, therefore, the UAS will not expose them to the 

risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 pounds, conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground but under 400 feet AGL, and within visual line of sight of the pilot in command and a 

visual observer. As a result, the small UASs are far safer than conventional flight operations 

conducted with large manned aircraft. 

Satisfaction of the criteria provided in Section 333 ofthe Reform Act of2012--size, weight, 

speed, operating capabilities, proximity to airports and populated areas, operation within visual 

~ine of sight, n~tional security and the significant public benefit as well as the positive economic 

Impacts -provide more than adequate justification for the grant of the requested exemptions 

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allowing commercial operation of applicant's UAS. Granting 3D Aerial Solutions LLC the 

above exemptions will allow for the expansion ofUAS systems into the future, in a professional, 

safety conscious culture steeped in the tradition of Aviation. 3D Aerial Solutions LLC 

respectfully requests that the FAA grant its exception without delay, The FAA bas the authority 

to issue the exemption sought by 3D Aerial Solutions LLC pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act"). 

Since~el ~- , /J 1f· () --- . ~--

UJ {jC j ----- Bret R. Give 

3D Aerial Solutions LLC, 

President 

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