28 January 2016

Federal Aviation Administration US Department ofTransportation DocketManagement System 1200 NewJerseyAve. S.E. Washington, D.C. 20590 

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Cincinnati Electronics

7500 Innovation Way

Mason, OH 45040 513-573-6100 Fax: 513-573-6741 www.L-3Com .cornice i' \

InReply, Please Refer to Letter #GLMOVHD01282016

Subject: L-3 Communications Cincinnati Electronics Exemption Request for Section 333 ofFAA Modernization and Reform Act of2012

Dear Sir orMadam,

L-3 Communications Cincinnati Electronics (L-3 CE) 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (UAS) pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permitL-3 CE to operate a UAS for the purpose ofconducting aerial video and photography over certain areas ofthe United States.



### Use and Interests ofthe petitioner The objective ofL-3 CE's aerial video and photography operations is to provide high quality imaging for a variety of defense related product development.


### Background The Infrared Products Division ofL-3 Cincinnati Electronics (L-3 CE) is a leading manufacturer ofiR imaging systems and surveillance products whichprovide best in class detection, identification and classification for US military. Based on more than 40 years experience in the design, development, and integration ofIR devices inthe defense/military and commercial sectors, L-3 CE's IRthermal imaging technology delivers superior performance and reliability.

L-3 CE sensors and thermal imaging systems empower ournational security on every level. Our technologies increase situational awareness, enhance surveillance capabilities, and aid in the detection and deterrence ofpotential threats. The provenperformance and reliability ofour systems improves the safety ofour military forces and homeland securityprofessionals. In conflict zones, our highperformance systems empowerthe warfighter with real-time intelligence for dominant maneuver and precision engagement.

L-3 CE seeks an exemption to operate 3D Robotics Solo, Turbo Ace Infinity 6 and Turbo Ace Infinity 9 multi-rotor aircraft within the national air space (NAS). The 3D Robotics Solo (3DRSOLO), Turbo Ace Infinity 6 (INFINITY6), Turbo Ace Infinity 9 (INFINITY9), and DJI Inspire 1 (INSPIRE) are each vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet, smart phone systems or laptop computer. Each aircraft to be operatedbyL-3 CE will be registered in accordance with49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part47,AircraftRegistration, and marked in accordance with 14 C.F.R. Part45, Identification andRegistration Marking.

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Basis For Petition Petitioner, L-3 CE, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, SpecialRules for Certain UnmannedAircraft Systems, herebypetitions the Administrator to commercially operate the 3DRSOLO, INFINITY6, INFINITY9, and INSPIRE UAS inthe NAS, and for an exemptionfrom 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, L-3 CE's operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, L-3 CE requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only applyto aircraft with an airworthiness certificate.

L-3 CE submits that the requested reliefis proper since an equivalent level ofsafety will be ensured. L-3 CE will

use experiencedpersonnel ortechnicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed inthe operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE Instruction Manuals). Furthermore, L-3 CE will document and maintain all maintenance records for the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS.

Relieffrom certainrequirements ofSection 61.113(a) and (b), entitledPrivatepilotprivileges and limitations: Pilot in command, is requestedbyL-3 CE to the extent necessary to allow a Pilot inCommand (PIC) holding a private pilot orhigher level certificate, as well as an airman medical certificate, and who has demonstrated, bymeeting minimum flight- hour and currencyrequirements, that the PIC is able to safely operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs in a manner consistent with this exemption, including evasive and emergency
maneuvers and maintaining appropriate distances from people, aircraft, vehicles and structures.

L-3 CE seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, L-3 CE submits that we will ensure that the U AS is in an airworthy condition, priorto every flight, by determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE Instruction Manuals), and that the aircraft are in a condition for safe flight.

L-3 CE also seeks an exemption from the requirements ofSection 91.121, entitledAltimeterSettings, as the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will not have a typical barometric altimeter onboard. However, altitude information of3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will beprovidedto the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring ofthe flight path. This altitude information, combined with L-3 CE's operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS within visual line ofsight,
at orbelow 500 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, L-3 CE seeks an exemption from the requirements ofSection 91.151 (b), entitledFuel requirements for flight in VFR conditions. L-3 CE submits that safety will not be affected byoperation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs during daylight hours invisual meteorological conditions (VMC) under visual flight rules (VFR), with enoughbatterypowerto fly for a total duration ofapproximately 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, L-3 CEprovides the following information in support ofits petition for exemption:



### 1. Name And Address OfThe Petitioner. L-3 Cincinnati Electronics 7500 Innovation Way Mason, Oh45040



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2. The Specific Sections Of 14 C.F.R. FromWhich L-3 CE Seeks Exemption. A L-3 CE Seeks Exemption From The Requirements Of Section 61.J13(a) and (b). Section 61.Jl3, entitledPrivate pilotprivileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a privatepilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers orpropertyfor compensation orhire; nor may that person, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation orhire, act as PIC ofan aircraft in connection with any business Or employment if-- (1) The flight is only incidental to thatbusiness or employment; and (2) The aircraft does not carry passengers orproperty for compensation orhire.

B L-3 CE SeeksExemption From The Requirements Of Section 91. 7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: No person mayoperate a civil aircraftunless it is in an airworthy condition.

C L-3 CE Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Eachperson operating an aircraft shall maintainthe cruising altitude orflight level ofthat aircraft, as the case maybe,byreference to an altimeter that is set, when operating-- (i) Below 18,000 feet MSL, to-- (ii) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (iii) Ifthere is no station within the area prescribed inparagraph (a)(l)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. ·

D L-3 CE 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 maybegin a flight in a rotorcraftunder VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

E L-3 CE SeeksExemption From The Requirement OfSection 91.405(a). Section 91.405, entitledMaintenance required, subsection (a), states the following: Each owner oroperator ofan aircraft-- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter[.]

F L-3 CE Seeks Exemption From The Requirements Of Section 91.407(a)(l) Section 91.407, entitled Operation after maintenance,preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterationunless-- (i) Ithas been approved for return to service bya person authorized under§ 43.7 ofthis chapter.

G L-3 CESeeksExemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had--



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(I) An annual inspection in accordance with part43 ofthis chapter andhas been approved for return to service by a person authorized by§ 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance withpart 21 ofthis chapter.



### H L-3 CE 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 workperformed in accordance with§§ 91.411 and 91.413, eachregistered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (orreference to data acceptable to the Administrator) ofthe workperformed; and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, eachengine, eachpropeller, and eachrotor. 

### (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The currentinspection status ofthe aircraft, including the time since the last inspectionrequired bythe inspection programunder which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribedby§ 43.9(d) ofthis 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)(l) ofthis section shall be retained until the work is repeated or superseded by other work or for 1year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under§ 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.



### 3. The Extent OfRelief

### L-3 CE Seeks And The Reason L-3 

### CE Seeks The Relief. 

### I Extent OfReliefL-3 CE SeeksAnd The ReasonL-3 CE SeeksRelief From Section 61.113(a) And(b). Relieffrom Section 61.113(a) and (b) entitled

### Privatepilotprivileges and limitations: Pilot in command, is requested to the extent necessaryto allow a PIC holding a private pilot orhigher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currencyrequirements, to conduct the proposed UAS flight operations for compensation orhire. This reliefis requested since the limitations set forth in Section 61.1 13(a) and (b) state that a private pilot may, for compensation orhire, act as PIC ofan aircraft in connection with anybusiness or employment if: (1) The flight is onlyincidental to thatbusiness or employment; and (2) The aircraft does not carrypassengers or property for compensation or hire. As set forth more fully below, L-3 CE submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the UAS unless that PIC has met certain flight hour and currencyrequirements, demonstrating that the PIC is able to safely operate the 3DRSOLO, INFINITY6 INFINITY9 and INSPIRE UASs in a manner consistent with the operations specifications as described inthis exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, L-3 CE submits that all flights each 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE, conductedbythe PIC pursuant to the grant ofthis Petition: (1) will be incidental to L-3 CE business; and (2) will not carrypassengers
orproperty for compensation orhire. ·



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J 

### Extent OfReliefL-3 CE SeeksAnd The Reason L-3 CESeeks Relief From Section 91. 7(a). Relieffrom Section 91.7 (a) entitled 

### Civil aircraft airworthiness, is requested to the extent required to allow L-3 CE
to determine that the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs is in airworthy conditionpriorto every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE InstructionManuals). L-3 CE seeks the requested reliefbecause the 3DRSOLO, INFINITY6, INFINITY9 andINSPIRE UASs does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, L-3 CE will ensure that the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs are in an airworthy conditionbasedupon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE Instruction Manuals) priorto every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.



### K Extent OfReliefL-3 CESeeksAnd The Reason L-3 CE Seeks Relief From Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, mayberequired to allow flight operations ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data linkto downlink altitude information from the UAS to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations bereported to air traffic control (ATC) in feet above ground level (AGL), L-3 CE seeks the requested reliefbecause 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS's altimeter maybe set onthe ground to zero feet AGL, rather thanthe local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 C.F.R. 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 ofsafety will be maintained since the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established priorto each flight, and provides the PIC with altitude information ofthe UAS onthe heads-up display ofthe GCS.



### L ·Extent OfReliefL-3 CE SeeksAnd The Reason L-3 CESeeks**Reli~fFrom** 

### Section 91.151(b). Relieffrom Section 91.151 (b) entitled Fuel requirements for flight in VFRconditions, is requested to the extent required to allow flights ofthe batterypowered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. L-3 CE seeks the requested reliefbecause without an exemption from Section 91.151 (b), the flight time duration ofthe batterypowered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will severely constrain the practicality ofany aerial video or still photo flight operations that L-3 CE proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications and operating documents ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE, andL-3 CE' proposed operating limitations, ensure that L-3 CE will safely operate the batterypowered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbatterypower to fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.



### M Extent OfReliefL-3 CESeeksAnd The Reason L-3 CESeeksRelief From Sections 91.405(a) Since Section 91.405(a) only applies to aircraft with an airworthiness certificate, L-3 CE requests relieffrom these Sections because 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do not require airworthiness certificates. As set forth more fully below, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, L-3 CE will use trainedtechnicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed in UAS operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE User Manuals). Furthermore, L-3 CE will document and maintain all maintenance records for the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs.



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N Extent OfReliefL-3 CE SeeksAnd The ReasonL-3 CE Seeks Relief From Sections 91.407(a)(l) Since Section 91.407(a 

### )(1) only applies to aircraftwith an airworthiness certificate, L-3 CE requests relieffrom these Sectionsbecause 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do notrequire airworthiness certificates. As set forth more fully below, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, L-3 CE will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed inUAS operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE User Manuals). Furthermore, L-3 CE will document and maintain all maintenance records for the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs.



### 0 Extent Of Relief L-3 CE SeeksAnd The ReasonL-3 CE SeeksRelief From Sections 91.409(a)(l) & (a)(2) Since Sections 91.409(a)(l) & (a)(2) only applyto aircraft with an airworthiness certificate, L-3 CErequests relief from these Sections because 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do not require airworthiness certificates. As set forth more fully below, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, L-3 CE will use trained technicians to perform maintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques, andpractices prescribed inUAS operating documents (i.e., MonthlyMaintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE User Manuals). Furthermore, L-3 CE will document and maintain all maintenance records for the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs.

P Extent OfReliefL-3 CE SeeksAnd The ReasonL-3 CE SeeksRelief From Sections 91.417(a) & (b). Since Sections 91.417(a) 

### & (b) only apply to aircraft with an airworthiness certificate, L-3 CE requests relieffrom this Sections because 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do not require airworthiness certificates. As set forth more fully below, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, L-3 CE will use trained technicians to perform maintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques, andpractices prescribed inUAS operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE User Manuals). Furthermore, L-3 CE will document and maintain all maintenance records for the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs.

4. The Reasons Why Granting L-3 CE Request Would Be In The Public Interest; That Is, How ItWould Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing L-3 CE to safely, efficiently, and economicallyperform aerial video andphotography oflandscape over certain areas ofthe United States. Additionally, use ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will decrease congestion ofthe NAS, reduce pollution, and provide significantbenefits to the economy. Notably, the benefits ofL-3 CE' proposed operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will be realized without implicating any privacyissues.


### Q The Public Will BenefitFrom Decreased Congestion Of The NAS. 3DRSOLO, INFINITY6, INFINITY and INSPIRE UASs are batterypowered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Byreducing the amount ofmanned aircraft needed to perform aerial video and photography, an exemption allowing the use ofa 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs would reduce the amount.ofmanned aircraft inthe NAS, reduce noise and airpollution, as well as increase the safety oflife and property in the air and onthe ground. Furthermore, byreducing the number ofmanned aircraft operating in the NAS, congestion around airports causedbyarriving and departing aircraft will be reduced. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do not require an airport to takeofforland. Likewise, a reduction ofmanned aircraft conducting aerial video andphotography missions would result in fewer aircraft that mustbe handled byair traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.

R Thepublic will benefit from the safety andefficiency of the 3DRSOLO, INFINITY6, INFINITY9 andINSPIRE UASs.



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Conducting aerial video and photography with the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs, instead ofmanned aircraft, will greatlybenefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Byusing batterypower and electric motors, 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraftthat are typicallyutilized for aerial video and photography, while burning approximately 20-30 gallons perhour ofleaded aviation fuel. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, while reducing the carbon footprint of aerial video andphotography, also eliminates noise pollution, as the UA is propelledbybatterypowered electric motors, rather than aninternal combustion engine. Byusing the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs to perform aerial video and photography, the substantial risk to life and propertyinthe air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated.



### S PerformingAerial Video andPhotography Operations With The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS Will Benefit The Economy. In addition to being safe and efficient, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofa 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will allow United States based companies, like L-3 CE, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adoptnew and alternative technology inorderto remain competitive. Operating the batterypowered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs is one such technology thatnot only allows companies greater operational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft.

T ThereAreNo PrivacyIssues. Similarto the manned aerial video and photographyflight operations that have been conducted for decades, L-3 CE' proposed operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will not implicate anyprivacy issues. Specifically, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will be operated onlyin compliance with operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE Instruction Manual) whichrequires property owner involvement as well as local law enforcement notification, and in accordance with theFederal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

### § 91.119. E.



### 5. The Reasons Why Granting The ExemptionWould Not Adversely Affect Safety, OrHow The Exemption Would Provide A Level OfSafety AtLeastEqual To That Provided By TheRule From Which L-3 CE Seeks Exemption.

U 

### Reasons Why 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs MeetThe Conditions OfThe FAAModernization and ReformAct of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft (UA) and its operation, L-3 CE' operation ofa 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs meets the conditions ofFMRA 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 ofthe NAS orthe public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, inpart: V In General--Notwithstanding any otherrequirement ofthis subtitle, and not later than 180 days after the date of
enactment ofthis Act, the Secretary ofTransportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rulemaking required by section 332 ofthis Actor the guidance required by section 334 ofthis Act. 

### W Assessment ofUnmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum--



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a) (l) which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazard
to users ofthe national airspace system orthe public orpose a threat to national security; and (2) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation ofunmanned aircraft systems identified underparagraph 

### (1).

X Requirements for Safe Operation.--Ifthe Secretary determines under this section that certainunmanned aircraft systems mayoperate safely inthe national airspace system, the Secretary shall establishrequirements for the safe operation ofsuch aircraft systems in the national airspace system. b) c) In seeking this exemption, L-3 CE submits that the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS; (b) the pilot certificationrequirement; and (c) the specific operating limitations.

Y The Specifications Ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS Demonstrate their Safe Characteristics. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do not create a hazard to users of the NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

a) Technical Specifications Ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs. The technical specifications ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs are set forth in the appendices and attachments.

3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs Autonomous Flight AndNavigation Modes Enable The UAS To Remain Within A Defined Operational Area. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs maybe operated in both manual and fully autonomous flight modes. Flight Operations Of3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs Are Limited To The Line OfSight OfA Certificated Pilotin Command With A Safety Observer. L-3 CE will only utilize certificatedpilots to act as a pilot in command (PIC) ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS. Additionally, a safety observer will assist all pilots during flight time. Z Flights 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, L-3 CE proposes to commercially operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations: 1. Operations authorized bythis grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a newpetition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 45 knots.



### 4. The UAS mustbe operated at an altitude ofno more than 500 feet above ground level (AGL), as indicated bythe procedures specified inthe operating documents unless a special request is made and approvedby ATC. All altitudes reported to ATC mustbe in feet AGL.



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5. The UAS mustbe operated withinvisual line ofsight (VLOS) ofthe 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 onthe PIC's FAA-issued airman medical certificate.

6. Theuse offirst person view (FPV) goggles bythe PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO maybe 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 notpermitted during flight operations. The PIC mustbe designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the SO canperform the functions prescribed in the operating documents.

8. The SO must notperform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is notpermittedto operate the camera or flight instruments, butmayrelay radio communications.

9. The operating documents and the grant ofexemption mustbe accessible during UAS operations and made available to the Administratorupon request. Ifa discrepancy exists betweenthe conditions and limitations contained inthe grant ofexemption and the procedures outlined inthe operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must followtheprocedures as outlined in its operating documents. The operatormayupdate or revise its operating documents. Itis the operator's responsibility to track suchrevisions and presentupdated and revised documents to the Administratoruponrequest. The operator must also presentupdated and revised documents ifitpetitions for extension or amendment to the grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant ofexemption. The FAA's UAS Integration Offi.ce (AFS-80) maybe contacted ifquestions arise regarding updates 'or revisions to the operating documents.

10. Priorto each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. The Ground Control Station mustbe included inthe preflightinspection. All maintenance and alterations must be properly documented inthe aircraft records.

11. AnyUAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa 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 ofthe operating documents.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements.

14. The operator must carry outits maintenance, inspections, andrecord keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts mustbe noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorizedpersonreturning 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 inthe aircraft record ofthe corrective action taken against discrepancies discovered between inspections.



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17. The PIC mustpossess at least a private pilot certificate and at least a currentthird- class medical certificate.

18. The operator may notpermit anyPIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS ina manner consistent with howthe UAS will be operatedunder the exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours mustbe logged in a

manner consistent with 14 C.F.R. § 61.51 (b). Flights for the purposes oftraining the operator's PICs are permittedunderthe terms ofthe exemption. However, training operations mayonlybe 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 C.F.R. § 91.119.

19. UAS operations may notbe conducted during night, as defined in 14 C.F.R. § 1.1. All operations mustbe conductedunder visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UAS maynot operate within5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chartunless a letter ofagreement withthat airport's management is obtained, and the operation is conducted inaccordance with a NOT AM as required bythe operator's COA. The letter ofagreement with the airport management mustbe made available to the Administrator uponrequest.

21. The UAS maynotbe operated less than 500 feet belowor less than 2,000 feet horizontally from a cloud or whenvisibility is less than 3 statute miles from the PIC.

22. Ifthe UAS loses communications or loses its GPS signal, itmust return t6 a pre- determined location within the planned operating area and land orberecovered in accordance with the operating documents.

23. The PIC must abort the flight inthe event ofunpredicted obstacles or emergencies in accordance withthe operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly atnormal cruising speed to the intended landing point and land the UAS with 25% batterypowerremaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) priorto conducting any operations underthe grant ofexemption. This COAwill also require the operatorto request a Notice to Airman (NOT AM) notmore than 72 hours in advance, butnot less than48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude andpotential transponder requirements.

26. All aircraft operated in accordance withthe exemption mustbe identifiedby serial number, registered in accordance with 14 C.F.R. part47, and have identification (N- Number) markings in accordance with C.F.R. part45, Subpart C. Markings mustbe as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS
must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agencyrequirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents mustbe made available to the Administrator or anylaw enforcement official upon request.



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29. The UAS mustremain clear and yield the right ofway to all manned aviation operations and activities at all times.

30. The UAS maynotbe operatedbythe PIC from any moving device orvehicle.

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 presentthat sufficiently protect nonparticipating persons from the UAS and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remainunder suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UAS, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has grantedpermission and the PIC has made a safety assessment of the risk ofoperating closer to those objects and determinedthat it does notpresent anundue hazard, and;

c. Operations nearer to the PIC, SO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a).

d. All operations shall be conducted overprivate or controlled-access property withpermission 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.

e. Any incident, accident, or flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined bythe applicable COAmustbe reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation SafetyBoard (NTSB) per instructions contained onthe NTSB Website: www.ntsb.gov.

AAReasons Why An Exemption From The Requirements OfSection 61.113(a) And (b) Would Not Adversely Affect Safety. L-3 CE submits that the equivalent level ofsafety establishedby Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS unless that PIC has demonstrated, bymeeting minimum flight-hour and currencyrequirements, that the PIC is able to safely operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering L-3 CE' proposed area ofoperations and the operating limitations set forth-above; the parallel nature of privatepilot aeronautical knowledge requirements to those ofcommercial pilotrequirements; and the airmanship skills necessaryto safely operate the UAS, L-3 CE submits that the additional manned airmanship experience ofa commercially certificatedpilot would not correlate to the airmanship skills necessary for L-3 CE's specific proposed flight operations.

The FAAhas previously granted relieffrom Section 61.113 (a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11741, 13382, 13999). L-3 CE will not allow any PIC to operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS unless that PIC has demonstrated, bymeeting minimum flight-hour requirements orthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS training and currencyrequirements, that the PIC is able to safely operate 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 oftotal time as a UAS rotorcraftpilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model ofUAS to beused 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).

E.3. Reasons WhyAn Exemption From The Requirements OfSection 91.7(a) Would NotAdversely Affect Safety.



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The equivalent level ofsafety establishedby Section 91.7(a) will be maintainedbecause priorto every flight, L-3 CE will ensure that the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs are in an airworthy condition basedupon the UAS's compliance withits operating documents and as stated in the conditions and limitations herein.



### EA. Reasons WhyAnExemptionFromThe Requirements OfSection 91.121 Would Not Adversely Affect Safety.

The equivalent level ofsafety establishedby Section 91.121 will be maintainedbecause the altitude information of 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will beprovided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with L-3 CE's operation of3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs within visual UAS line ofsight, at orbelow 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generatedby GPS equipment installed onboard the aircraft. Priorto eachflight, a zero altitude initiationpoint is automatically establishedbythe UAS at ground level.

E.5. Reasons Why AnExemptionFrom The Requirements OfSection 91.151(b) WouldNotAdversely Affect Safety.

A grant ofthis exemption would ensure anequivalent level ofsafety establishedby 14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications of3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs; (2) the limitations onthe proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, L-3 CE will ensure that itwill safely operate the batterypowered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UA during daylight hours inVFR conditions, with enoughbatterypowerto fly for a maximum duration of30 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

E.6. Reasons Why An Exemption FromThe Requirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) WouldNotAdversely Affect Safety.

In seeking this exemption, L-3 CE submits that the equivalent level ofsafety withregard to the regulatory maintenance and alteration requirements establishedby Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

### & (a)(2), and 91.417(a) 

### & (b) will be met because L-3 CE will use trained technicians to perform maintenance, alterations, or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE Instruction Manual). Furthermore, L-3 CE will document and maintain all maintenance records for the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS. Since the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will be inspected as prescribedbythe operating documents, L-3 CE will maintain the equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of3DRSOLO, INFINITY6, and INSPIRE User Manuals are attached. A summary is presented in the Appendices. Likewise, the exemption sought will not adversely affect safetybecause L-3 CE will use trained technicians to perform maintenance, alterations or preventive maintenance onthe UAS using the methods, techniques, andpractices prescribedby the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety establishedby Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe UAS will be performedbytrained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted bythe FAAconcerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Inconsideration ofL-3 CE' proposed operating limitations, the operating documents, and the technical aspects ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, L-3 CE submits that safety will notbe adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

E.7. The FAAMayPrescribe Any Other Conditions For Safe Operation.



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In accordance with Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, L-3 CE requests that the FAAprescribe special conditions for the intended operation of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, which contain such safety standards thatthe Administrator finds necessary to establish a level ofsafety equivalent to that establishedby 14 C.F.R. Part 21, SubpartH, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UAS for the limitedpurpose of conducting aerial video and photography over certain areas ofthe United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certificationin accordance with any requirements that must be established for the safe operation ofthe UAS intheNAS. Likewise, the Administrator mayprescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel orunusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propellerbecause ofa novel orunusual design feature ofthe aircraft, aircraft engine orpropeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance withPart 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine orpropeller as the FAAfinds necessary to establish a level ofsafety equivalentto 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 L-3 CE intended operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that establishedby 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

F. A SummaryThatCanBePublished InThe Federal Register, stating: The Rules From Which L-3 CE Seeks Exemption: The Rules From WhichL-3 CE Seeks Exemption: L-3 CEseeks exemptionfrom 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)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A BriefDescription OfThe Nature OfThe Exemption L-3 CE Seeks: This exemption willpermitL-3 CE to commercially operate an UnmannedAircraftSystem (UAS)for thepurpose of conducting aerial video andphotography overcertain areas of the UnitedStates. AnyAdditional Information, Views, Or Arguments Available To SupportL-3 CE's Request. This Petition is made pursuantto the FAAModernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain U AS may operate safely in the NAS. As such, L-3 CE' request for exemption maybe granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe 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, L-3 CE will operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS safely inthe NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threat to national security.

Conclusion

As set forth herein, L-3 CE seeks anexemptionpursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography overcertain areas ofthe United States. Bygranting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAAModernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing L-3 CE to safely, efficiently, and economically operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs commercially within the NAS. In accordance with the Federal Aviation Regulations and the FAAModernization and Reform Act of2012, Section 333, L-3 CE respectfully requests that the Administrator grantthis Petition for an exemption from the requirements of 14 C.F.R



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Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), andpermitL-3 CE to operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States.

L-3 CE trusts this information is adequate for the FAAto grant ourrequests. Ifyou have any questions orrequire any additional information, please contact Harish Hiriyannaiah, at 513-204-7256, Chris Fearing, at 513-573-6972, or the undersigned.

Respectfully submitted,

L-3 COMMUNICATIONS CINCINNATI ELECTRONICS

George L. Macomber DivisionDirector ofContracts 513-204-7168 George.Macomber@L-3Com.com

Appendices: A. 3DR Solo B. Turbo Ace Infinity 6 C. Turbo Ace Infinity-9Pro Octocopter D. DJl Inspire 1

Attachments: A. Solo UserManual B. CineWing-6 Manual C. Inspire 1 UserManual en v2.0 1218



### 14

### Appendix 

### A: 

### 3DRSolo communications

Cincinnati Electronics



### htt //3d b f 

### I t t/ 1 d /2015/11/ 8 11 20 15 df ps: ro o tcs.com wp-con en upJoa s v .pc Estimated flight time up to 25 minutes* Default maximum altitude 150ft. (46 m) above ground level** Range .5 mile*** (.8 km) 

### Payload capacity 1lb. (450 g) Cruise speed 18 mph (8 m/s) Maximum speed 33 mph (15 m/s)**** Wind speed limitation 25 mph (11 m/s) Operating temperature 32° F- 113° F (0° C to 45° C) Height 10" Wingspan 18" Total Weigh! 3.3lb

* Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style, and pilot skill. Listed flight time applies to elevations less than 2,000 ft above sea level. **To adjustmaximum altitude, see Section 8.7. ***Depending on environmental conditions ****This top speed corresponds to Solo when operating in Flymode. Maximum speeds for advanced modes may vary; see Section 8.1 for more information.

Appendix B: 

### Turbo Ace Infinity 6



### Estimated flight time up to 30 minutes* Estimated maximum altitude 1000 ft Range .5 

### mile Payload capacity 10 lb. Cruise speed 22 mph (10 m/s) Estimated Maximum speed 45mph Wind speed limitation 22 mph (10 m/s) Operating_temperature 32° F- 113° F (0° C to 45° C) 

### Height 19.2" Wingspan 51.75" Total weight Notto exceed 25 lb

15

### communications

Cincinnati Electronics



### Appendix C: Turbo Ace lnfinity-9Pro Octocopter



### Estimated flight time up to 15 minutes* Estimated maximum altitude 1000 ft Range 1.2 mile Maximum Total Wei_gh_t 46.5 Payload capacity 20 lb. Cruise speed 22 mph (10 m/s) Estimated Maximum speed 45mph Wind speed limitation 35mph Operating temperature 32° F- 113° F (0° C to 45° C) Height 24" Wingsgan 66.5" Total weight Notto exceed 46.5 lb

Appendix D: 

### DJ1 I 1 nsQ1re 

### Estimated flight time u_p to 15 minutes* Estimated maximum altitude 400ft Range 1.2 mile MaximumTotalWeight 7.5lb. Payload capacity 1lb. Cruise sp_eed 22 mph 

### _(10 m/s) Estimated Maximum**s~eed** 

### 45mph Wind speed limitation 35mph Operating temperature 32° F- 

### 113° F 

### (0° C to 45° C) Height 12" Wingsgan 17" Total weight Not to exceed 7.5lb

16