DSP – Section 333 Exemption Request Page 1 of 3

Submitted for consideration on January 5, 2016 by:

Howard Rogers

Dairy Solutions Plus

P.O. Box 1914

Modesto, CA 95353-1914

209 402-5747

howard.rogers@comcast.net

Scope:

Enhance and augment business services provided to clients by using the 3DR Solo Unmanned Aircraft 

System to conduct aerial photography and videography for the purposes of: crop and herd monitoring; 

building and infrastructure inspections including, but not limited to building exteriors, bridges, towers, 

solar farms, pipelines and power lines; construction site inspection; real estate inspection and 

marketing.

UAV 3DR Solo:

The 3DR Solo is a quad-rotor Unmanned Aircraft System (UAS) The 3DR Solo has:

 A maximum gross weight of approximately 4 pounds

 A length of 18.1 inches and width of 18.1 inches

 Height of 10.2 inches

 Maximum speed of approximately 33 mph

 Equipped with four main rotors; driven by lithium polymer battery-powered electric motors

 Return Home Feature (Built in Safety)

The 3DR Solo that will be operated by Dairy Solutions Plus will be registered in accordance with 49 U.S.C. 

44103, Registration of Aircraft, as well as 14 CFR Part 47, Aircraft Registration, and marked in 

accordance with 14 CFR Part 45, Identification and Registration Markings.

The 3DR Solo that will be operated by Dairy Solutions Plus also utilizes a mobile ground station. The UAS 

features a safety Return Home function that, in the event of a signal loss, will return the Unmanned 

Aircraft (UA) to a preset position and safely land the UA. The Return Home feature can also be triggered 

manually. The remote connects to your phone or tablet, and a 1080p HD view of everything your 

camera sees as you fly is displayed live.

This immersive view streams to you in absolute clarity, enabling safe flying. From takeoff to landing, the 

3DR Solo responds to commands while automatically handling the most complex aspects of safe, stable 

flight.

Request:

Dairy Solutions Plus seeks an exemption to operate 3DR Solo systems for compensation or hire within 

the U.S. The 3DR Solo quad-rotors are vertical takeoff and landing (VTOL). These UAS’s use a Ground 

Control Station (GCS), displaying the live camera feed on an electronic tablet or smartphone.

Petition:

I request an exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113 (a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and 

(2); 91.417(a) and (b).
DSP – Section 333 Exemption Request Page 2 of 3

The Extent of Relief that Dairy Solutions Plus seeks:

1. Extent of Relief that Dairy Solutions Plus seeks regarding Section 61.113(a) Private Pilot Privileges and 

Limitations. Relief from Section 61.113 (a) is requested to allow a Pilot in Command (PIC) holding a 

current Private Pilots Certificate to operate the 3DR Solo for Dairy Solutions Plus business operations. 

The flights would be complimented by a Visual Observer who, along with the Pilot, will maintain Visual 

Line of Sight with the UA at all times. The 3DR Solo is not able to carry passengers.

2. Extent of Relief that Dairy Solutions Plus seeks in regards to Section 91.7(a) Civil Aircraft 

Airworthiness. Relief from Section 91.7(a) is requested to allow Dairy Solutions Plus to determine

airworthiness of the 3DR Solo. As part of this determination the following will be adhered to:

a. Prior to each 3DR Solo flight the PIC will inspect the UA to ensure it is in a condition that will be 

conducive for safe flight. The ground control station area will be included in the above inspection.

b. Dairy Solutions Plus will follow the 3DR Solo's aircraft/component, maintenance, overhaul, 

replacement, inspection and life limit requirements.

c. Dairy Solutions Plus will comply with all 3DR Solo manufacturer Safety Bulletins.

3. Extent of Relief that Dairy Solutions Plus seeks in regards to Section 91.119 Minimum Safe Altitudes.

General relief from 91.119 is requested to allow Dairy Solutions Plus to operate the 3DR Solo at altitudes 

not to exceed 400’ AGL over private property at a distance at or greater than 5NM from the nearest

airport as depicted on current Aeronautical Charts. Dairy Solutions Plus also wishes to be granted 

exemption to operate at an altitude not greater than 50’ AGL (below tree level) between 1NM and 5NM 

from the nearest airport as depicted on current Aeronautical Charts.

Dairy Solutions Plus will adhere to the following in order to maintain an acceptable level of safety 

associated with operations over private property:

(a) Dairy Solutions Plus will display signs in the immediate vicinity of operations stating: “Aerial 

Photography in Progress. Use Caution.”

(b) Dairy Solutions Plus will not allow the 3DR Solo to operate at a speed greater than 33 mph.

(c) Dairy Solutions Plus will require the UAS operator (PIC) to be fully trained on the 3DR Solo by 

adhering to the recommendations contained within the 3DR Solo’s operating manual.

(d) Dairy Solutions Plus will have accumulated and logged for PIC, in a manner consistent with 14 CFR 

61.51(b), a minimum of 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. In addition the operator will have logged a minimum of 5 hours as 

a UAS pilot operating the make and model UAS that Dairy Solutions Plus operates.

(e) Dairy Solutions Plus’s PIC will be familiar with and able to manually institute the 3DR Solo’s Return 

Home feature. This feature aborts a flight operation and automatically returns the UAS to a 

predetermined GPS safe point.

(f) Dairy Solutions Plus will not operate 3DR Solo over private property without first finding a suitable 

alternate landing spot on the property.

(g) Dairy Solutions Plus’s PIC will abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

(h) Dairy Solutions Plus will utilize a two-person flight team consisting of the Pilot in Command (PIC) and 

a Visual Observer (VO). This team will maintain visual line of sight with the 3DR Solo at all times and 

remain within hearing of one another.

(i) Dairy Solutions Plus’s PIC will not permit flight around vessels, vehicles and structures without 

permission from the owner.
DSP – Section 333 Exemption Request Page 3 of 3

4. Extent of Relief that Dairy Solutions Plus seeks in regards to Section 91.121 Altimeter Settings. 

Relief from 91.121 is requested because the 3DR Solo utilizes electronic GPS with a barometric sensor.

In order to maintain an equal level of safety that 91.121 requires, the PIC of the UAS will abort the flight 

in the events that the UA loses communications with the GPS signal.

5. Extent of Relief that Dairy Solutions Plus seeks in regards to Section 91.151(a)(1) Fuel Requirements 

for Flight in VFR Conditions. Relief from 91.151(a) is requested to the extent that allows Dairy Solutions 

Plus to operate the 3DR Solo up to a point (considering wind and forecast weather conditions) that there 

is enough battery power to fly at normal cruising speed to the intended landing point and land the UA 

with a minimum of 20% battery power remaining.

6. Extent of Relief that Dairy Solutions Plus seeks in regards to Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1), and (a)(2), 91.417(a) and (b). These are all associated with Airworthiness certificate

Relief from 91.405(a), 91.407(a)(1), and (a)(2). 91.417(a) and (b) is requested to the extent that allows 

Dairy Solutions Plus to operate the 3DR Solo as necessary. These sections are all related to airworthiness

certificates of aircraft. There is not currently an airworthiness certificate for small UAS’s. Dairy Solutions 

Plus would comply in full to any conditions and limitations that the Administrator would place in order 

to receive an approved Grant of Exemption.

Public Interest:

Aerial videography has been around for a long time through manned fixed wing aircraft and helicopters, 

but for most small business owners it has been cost prohibitive. Granting this exemption to Dairy 

Solutions Plus for operation of 3DR Solo UAS would allow us to provide these services at a much lower 

cost. The unmanned 3DR Solo will pose no threat to the public, given its small size and lack of 

combustible fuel, when compared to manned aircraft. 3DR Solo use provides safe, efficient aerial data

collection giving clients specific, accurate, timely, cost effective information.

Conclusion:

As set forth herein, Dairy Solutions Plus 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 for commercial use.

The Administrator will be assisting small business by granting this petition. In accordance with the FAA 

Modernization and Reform Act of 2012, Dairy Solutions Plus respectfully requests that the FAA 

Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a); 91.7(a); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 

91.417(a) and (b).

Thank you in advanced for your consideration,

Howard L. Rogers

Dairy Solutions Plus

howard.rogers@comcast.net

209-402-5747