28 January 2016 

Federal Aviation Administration 

US Department of Transportation 

Docket Management System 

1200 New Jersey Ave. S.E. 

Washington, D.C. 20590 

communications 

Cincinnati Electronics 

7500 Innovation Way 

Mason, OH 45040 

513-573-6100 Fax: 513-573-6741 

www.L-3Com .cornice 

i' \ 

In Reply, Please Refer to Letter #GLMOVHD01282016 

Subject: L-3 Communications Cincinnati Electronics Exemption Request for Section 333 of FAA 

Modernization and Reform Act of2012 

Dear Sir or Madam, 

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 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit L-3 CE to operate a UAS for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Use and Interests of the 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 which provide best in class detection, identification and classification for US 

military. Based on more than 40 years experience in the design, development, and integration of IR devices in the 

defense/military and commercial sectors, L-3 CE's IR thermal imaging technology delivers superior performance 

and reliability. 

L-3 CE sensors and thermal imaging systems empower our national security on every level. Our technologies 

increase situational awareness, enhance surveillance capabilities, and aid in the detection and deterrence of potential 

threats. The proven performance and reliability of our systems improves the safety of our military forces and 

homeland security professionals. In conflict zones, our high performance systems empower the 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 takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet, smart 

phone systems or laptop computer. Each aircraft to be operated by L-3 CE will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft Registration, and marked in accordance 

with 14 C.F.R. Part 45, Identification and Registration Marking. 
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Basis For Petition 

Petitioner, L-3 CE, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to commercially operate the 3DRSOLO, INFINITY6, INFINITY9, and 

INSPIRE UAS in the NAS, and for an exemption from the requirements of 14 C.F.R. §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration of the speed, 

weight, size, and limited operating area associated with the unmanned aircraft and its operation, L-3 CE's operation 

of the 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 relief from 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 apply to aircraft with an airworthiness certificate. 

L-3 CE submits that the requested relief is proper since an equivalent level of safety will be ensured. L-3 CE will 

use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance 

Log, and 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. 

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

in command, is requested by L-3 CE to the extent necessary to allow a Pilot in Command (PIC) holding a private 

pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight- hour and currency requirements, that the PIC is able to safely operate the 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 not require 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, prior to 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 of Section 91.121, entitled Altimeter Settings, 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 be provided to 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 of the flight path. This altitude information, combined 

with L-3 CE's operation of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS within visual line of sight, 

at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, L-3 CE seeks an 

exemption from the requirements of Section 91.151 (b), entitled Fuel requirements for flight in VFR conditions. L-3 

CE submits that safety will not be affected by operation of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE 

UASs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with 

enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended 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 CE provides the following information in support of its petition for exemption: 

1. Name And Address Of The Petitioner. 

L-3 Cincinnati Electronics 

7500 Innovation Way 

Mason, Oh 45040 

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2. The Specific Sections Of 14 C.F.R. From Which L-3 CE Seeks Exemption. 

A L-3 CE Seeks Exemption From The Requirements Of Section 61.J13(a) and (b). Section 61.Jl3, entitled Private 

pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant 

part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business 

Or employment if--

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

B L-3 CE Seeks Exemption From The Requirements Of Section 91. 7(a). Section 91.7, entitled Civil aircraft 

airworthiness, subsection (a), states the following: 

No person may operate a civil aircraft unless 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) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case 

may be, by reference to an altimeter that is set, when operating--

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

(ii) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; 

(iii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported 

altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate 

altimeter setting available before departure. · 

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 may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

E L-3 CE Seeks Exemption From The Requirement OfSection 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft--

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, 

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

chapter[.] 

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 

alteration unless--

(i) It has been approved for return to service by a person authorized under§ 43.7 of this chapter. 

G L-3 CE Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

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

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had--

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(I) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a 

person authorized by§ 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

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 work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall 

keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 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 of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a 

specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the 

inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, 

the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently 

installed engines, rotors, propellers, and appliances. 

,(b) The owner or operator shall retain the following records for the. periods prescribed: 

(1) The records specified in paragraph (a)(l) of this section shall be retained until the work is repeated or superseded 

by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the 

time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until 

the defects are repaired and the aircraft is approved for return to service. 

3. The Extent Of Relief L-3 CE Seeks And The Reason L-3 CE Seeks The Relief. 

I Extent OfReliefL-3 CE Seeks And The Reason L-3 CE Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is 

requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current 

and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in 

Section 61.1 13(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. As set forth more fully below, L-3 CE submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the UAS unless that PIC has met certain flight hour 

and currency requirements, 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 in this 

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, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to L-3 CE business; and (2) will not carry passengers 

or property for compensation or hire. · 

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J Extent OfReliefL-3 CE Seeks And The Reason L-3 CE Seeks 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 condition prior to 

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 Instruction Manuals). L-3 CE seeks the requested 

relief because the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE 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 condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE 

Instruction Manuals) prior to 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 CE Seeks And The Reason L-3 CE Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 3DRSOLO, 

INFINITY6, INFINITY9 and INSPIRE UASs, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to 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 be reported 

to air traffic control (ATC) in feet above ground level (AGL), L-3 CE seeks the requested relief because 3DRSOLO, 

INFINITY6, INFINITY9 and INSPIRE UAS's altimeter may be set on the ground to zero feet AGL, rather than the 

local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed 

operations, relief from 14 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 of safety 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 prior to each 

flight, and provides the PIC with altitude information of the UAS on the heads-up display of the GCS. 

L ·Extent OfReliefL-3 CE Seeks And The Reason L-3 CE Seeks Reli~fFrom Section 91.151(b). 

Relief from Section 91.151 (b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent 

required to allow flights of the battery powered 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 of intended landing and, assuming normal cruising speed, to fly after that for at least 

4.5 minutes. L-3 CE seeks the requested relief because without an exemption from Section 91.151 (b), the flight 

time duration of the battery powered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will severely 

constrain the practicality of any 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 of the 

3DRSOLO, INFINITY6, INFINITY9 and INSPIRE, and L-3 CE' proposed operating limitations, ensure that L-3 CE 

will safely operate the battery powered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly 

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

M Extent OfReliefL-3 CE Seeks And The Reason L-3 CE Seeks Relief From Sections 91.405(a) 

Since Section 91.405(a) only applies to aircraft with an airworthiness certificate, L-3 CE requests 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, or preventive 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 Seeks And The Reason L-3 CE Seeks Relief From Sections 91.407(a)(l) 

Since Section 91.407 (a )(1) only applies to aircraft with an airworthiness certificate, L-3 CE requests 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, or preventive 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. 

0 Extent Of Relief L-3 CE Seeks And The Reason L-3 CE Seeks Relief From Sections 91.409(a)(l) & (a)(2) 

Since Sections 91.409(a)(l) & (a)(2) only apply to aircraft with an airworthiness certificate, L-3 CE requests 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, or preventive 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. 

P Extent OfReliefL-3 CE Seeks And The Reason L-3 CE Seeks Relief From Sections 91.417(a) & (b). 

Since Sections 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, L-3 CE requests relief from 

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, or preventive 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. 

4. The Reasons Why Granting L-3 CE Request Would Be In The Public Interest; That Is, How It Would 

Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing L-3 CE to safely, efficiently, and 

economically perform aerial video and photography of landscape over certain areas of the United States. 

Additionally, use of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofL-3 CE' proposed 

operation of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will be realized without implicating any 

privacy issues. 

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

3DRSOLO, INFINITY6, INFINITY and INSPIRE UASs are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount 

of manned aircraft needed to perform aerial video and photography, an exemption allowing the use of a 3DRSOLO, 

INFINITY6, INFINITY9 and INSPIRE UASs would reduce the amount.ofmanned aircraft in the NAS, reduce 

noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, 

by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and 

departing aircraft will be reduced. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations. 

R The public will benefit from the safety and efficiency of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE 

UASs. 

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Conducting aerial video and photography with the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs, 

instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using battery power and electric 

motors, 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 aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, while reducing the carbon footprint of 

aerial video and photography, also eliminates noise pollution, as the UA is propelled by battery powered electric 

motors, rather than an internal combustion engine. By using the 3DRSOLO, INFINITY 6, INFINITY9 and 

INSPIRE UASs to perform aerial video and photography, the substantial risk to life and property in the air and on 

the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. 

S Performing Aerial Video and Photography 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 of a 

3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will allow United States based companies, like L-3 CE, to 

remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned 

and operated companies must adopt new and alternative technology in order to remain competitive. Operating the 

battery powered 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

T There Are No Privacy Issues. 

Similar to the manned aerial video and photography flight operations that have been conducted for decades, L-3 CE' 

proposed operation of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs will not implicate any privacy 

issues. Specifically, the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will be operated only in 

compliance with operating documents (i.e., Monthly Maintenance Log, and 3DRSOLO, INFINITY6, INFINITY9 

and INSPIRE Instruction Manual) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements 

of 14 C.F.R. § 91.119. E. 

5. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption 

Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which L-3 CE 

Seeks Exemption. 

U Reasons Why 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs Meet The Conditions Of The 

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

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft (UA) 

and its operation, L-3 CE' operation of a 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 of the NAS or the public, or otherwise 

pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: 

V In General--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of 

enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan and rulemaking required by section 

332 of this Act or the guidance required by section 334 of this Act. 

W Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary 

shall determine, at a minimum--

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a) (l) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard 

to users of the national airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of 

title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph 

(1). 

X Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft 

systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

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 certification requirement; and (c) the 

specific operating limitations. 

Y The Specifications Of the 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 or the public, or otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability. 

a) Technical Specifications Of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs. The technical 

specifications of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs are set forth in the 

appendices and attachments. 

3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined Operational Area. The 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE 

UASs may be operated in both manual and fully autonomous flight modes. 

Flight Operations Of3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs Are Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer. 

L-3 CE will only utilize certificated pilots to act as a pilot in command (PIC) of the 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 of conducting aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption 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 new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial 

video and photography. 

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

4. The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated 

by the procedures specified in the operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL. 

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5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC 

to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's 

FAA-issued airman medical certificate. 

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally 

at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or flight 

instruments, but may relay radio communications. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. The operator may update or 

revise its operating documents. It is the operator's responsibility to track such revisions and present updated 

and revised documents to the Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA granted the exemption, 

then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration 

Offi.ce (AFS-80) may be contacted if questions arise regarding updates 'or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the U AS to ensure that it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft records. 

11. Any U AS that has undergone maintenance or alterations that affect the U AS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The 

PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or 

equipment, not already covered in the relevant sections of the operating documents. 

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

inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance 

with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAS to service. 

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

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

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17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria 

and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51 (b). Flights for the purposes of training the operator's PICs are 

permitted under the terms of the exemption. 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 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). If flight at night is required, a special request 

will be made at the FAA office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current 

FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, 

and the operation is conducted in accordance with a NOT AM as required by the operator's CO A. The letter 

of agreement with the airport management must be made available to the Administrator upon request. 

21. 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. 

22. If the UAS loses communications or loses its GPS signal, it must return t6 a pre- determined location 

within the planned operating area and land or be recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the 

operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 

25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA) prior to conducting any operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in 

accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 

C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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29. The UAS must remain clear and yield the right of way to all manned aviation operations and activities at all 

times. 

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than 

the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 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 where nonparticipating persons leave such 

protection and are within 500 feet of the UAS, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an undue 

hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue 

hazard to those persons per§ 91.119( a). 

d. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

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

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

AAReasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. L-3 CE submits that the equivalent level of safety established by Section 61.113(a) and 

(b) will be maintained because no PIC will be allowed to operate the 3DRSOLO, INFINITY6, INFINITY9 and 

INSPIRE UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, 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 of operations and the operating limitations set forth-above; the parallel nature of 

private pilot aeronautical knowledge requirements to those of commercial pilot requirements; and the airmanship 

skills necessary to safely operate the UAS, L-3 CE submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for L-3 CE's specific proposed 

flight operations. 

The FAA has previously granted relief from Section 61.113 (a) and (b) specific to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 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, 

by meeting minimum flight-hour requirements or the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS 

training and currency requirements, 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 of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a 

UAS pilot operating the same make and model ofUAS to be used for operations under the exemption). In addition 

to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

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

Affect Safety. 

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The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, L-3 

CE will ensure that the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs are in an airworthy condition 

based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations 

herein. 

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

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of 

3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the 

flight path and altitude. This altitude information, combined with L-3 CE's operation of 3DRSOLO, INFINITY6, 

INFINITY9 and INSPIRE UASs within visual UAS line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard 

the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground 

level. 

E.5. Reasons Why An Exemption From The Requirements Of Section 91.151 (b) Would Not Adversely Affect 

Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UASs; 

(2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, L-3 CE will ensure that it will safely operate the battery powered 3DRSOLO, INFINITY6, 

INFINITY9 and INSPIRE UA during daylight hours in VFR conditions, with enough battery power to fly for a 

maximum duration of 30 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

E.6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, L-3 CE submits that the equivalent level of safety with regard to the regulatory 

maintenance and alteration requirements established by 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 on the 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 prescribed by the operating documents, L-3 CE will maintain the equivalent level of safety 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 safety because L-3 CE will use trained technicians to perform maintenance, alterations or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating 

documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 

91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous 

exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(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 of the 

UAS are considered. In consideration ofL-3 CE' proposed operating limitations, the operating documents, and the 

technical aspects of the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, L-3 CE submits that safety will 

not be 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 FAA May Prescribe Any Other Conditions For Safe Operation. 

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In accordance with Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 

entitled Special Conditions, L-3 CE requests that the FAA prescribe special conditions for the intended operation of 

the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F .R. Part 21, 

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 of the UAS for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA 

Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to 

operate without airworthiness certification in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. § 21.16, for operation of the 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 or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If 

the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety 

standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, 

aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the 

FAA may prescribe special conditions for L-3 CE intended operation of the 3DRSOLO, INFINITY6, INFINITY9 

and INSPIRE UAS, which contain such safety standards that the Administrator finds necessary to establish a level 

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 

91. 7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which L-3 CE Seeks 

Exemption: 

The Rules From Which L-3 CE Seeks Exemption: 

L-3 CE seeks exemption from the requirements of 14 C.F.R Sections 61.113 ( a)&(b), 91. 7(a), 91.121, 91.151 (b), 

91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption L-3 CE Seeks: 

This exemption will permit L-3 CE to commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support L-3 CE's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which 

directs the Secretary of Transportation to determine if certain U AS may operate safely in the NAS. 

As such, L-3 CE' request for exemption may be 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 of the NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, L-3 

CE will operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS safely in the NAS, without creating a 

hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

Conclusion 

As set forth herein, L-3 CE seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the 3DRSOLO, INFINITY6, 

INFINITY9 and INSPIRE UASs commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of2012, 

while also advancing the interests of the 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 FAA Modernization and Reform Act of2012, Section 333, L-3 CE 

respectfully requests that the Administrator grant this 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), and permit L-3 CE to operate the 3DRSOLO, INFINITY6, INFINITY9 and INSPIRE UAS commercially for 

the purpose of conducting aerial video and photography over certain areas of the United States. 

L-3 CE trusts this information is adequate for the FAA to grant our requests. If you have any questions or require 

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 

Division Director of Contracts 

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 User Manual 

B. CineWing-6 Manual 

C. Inspire 1 User Manual en v2.0 1218 

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Appendix A: 

3DRSolo 

communications 

Cincinnati Electronics 

https: //3d ro b o f tcs.com I wp-con t en t/ upJ 1 d oa s v /2015/11/ 8 11 20 15 .pc df 

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 adjust maximum altitude, see Section 8.7. 

***Depending on environmental conditions 

****This top speed corresponds to Solo when operating in Fly mode. 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 3 0 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 Not to exceed 25 lb 

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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 Not to exceed 46.5 lb 

Appendix D: 

DJ1 I nsQ1re 1 

Estimated flight time u_p to 15 minutes* 

Estimated maximum altitude 400ft 

Range 1.2 mile 

Maximum Total Weight 7.5lb. 

Payload capacity 1lb. 

Cruise sp_eed 22 mph _(1 0 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 

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