Brandon McDonald

CEO

Royal	Vision	Productions	LLC

1315	14th St	Sw

Puyallup,	WA	98371

253-576-0185

royalvisionnw@gmail.com

Re: Request for exemption from multiple regulatory provisions to allow the use of 

small unmanned aerial systems on land controlled by clients of Royal Vision Productions 

LLC to assist in the safe inspections of infrastructure and Photography or Videography

for our clients. 

To Whom It May Concern,

Royal Vision Productions LLC (RVP) respectfully requests an exemption from 

multiple provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the 

use of small unmanned aerial systems (sUAS) to assist in the inspection of infrastructure 

and photography or videography for our clients. I am requesting the exemption from 

these Title 14 codes with the objective to maximize safety in the infrastructure inspection 

industry along with providing highly sought after, useful photography and videography

for the real estate industry. RVP is requesting FAA exemption for sUAS safe operation

photography and videography content.

The intended plan of use of RVP’s sUAS would be beneficial to the public for 

many ways. Exemption would not completely eliminate the need for in-person visual 

inspection of infrastructure, but it would make it a much safer operation. Utilizing the 

abilities of sUAS will help visualize the possibility of faulty infrastructure before going 

for the in-person inspection. RVP anticipates that the visualization you obtain from a 

sUAS would be a great asset regarding infrastructure safety assessments and preventative 

measures, along with initial post accident assessment of infrastructure, before sending inperson inspectors or first responders. The approval for exemption, in this case, would

accelerate the public interest and enhance the safety and efficiency of infrastructure 

operations. There are many reasons why infrastructure can fail or can cause infrastructure 

to be unusable for extended periods of time, extreme weather conditions such as heat and 

cold, heavy snow, earthquakes, landslides, torrential rain and other factors like excess 

weight, abandoned vehicles blocking and more, giving reason as to why inspections need 

to be done on a regular basis. Our potential clients’ employees routinely inspect 

infrastructure, such as bridges, support structures, tunnels, railroad tracks and more. The 

work is being done by personnel in motor vehicles, specialized equipment or on foot. 

While every safety precaution is being exercised, there is always a risk associated with an 

employee going out onto a structure. In order to do this, usually they have to climb onto 

or over structures, which can be slippery, sharp or rough because they are exposed to the 

elements. Using a sUAS will not eliminate all risks associated with this type of work, but 
it will greatly reduce the risks to employees by having a remote, live streaming aerial 

view that would be impossible to get otherwise. Fixed wing aircraft are not suitable for 

these types of jobs because of the altitude that they are required to fly safely at. The 

images and video would be to far away to notice any small anomalies in the assets, thus 

making the footage irrelevant. Helicopters would be a better option than fixed wing, but 

the fuel needed is highly flammable, there is more risk to human safety and it much more 

costly.

In the case of a natural disaster or collapse, first responders and infrastructure 

inspectors usually go into a situation with little prior knowledge of what they are up 

against because the urgency of the situation calls to bring people and property, if 

possible, to safety as fast and safe as they can. RVP thinks a sUAS would help first 

responders by providing them with a quick, live streaming assessment of the situation 

before they proceed. For inspectors, it would give them a firsthand hand view of what 

part of the infrastructure has failed without putting their life in danger. Helicopters and 

small planes have been used for purposes like these in the past, but you can’t have them 

dispatched to the incident as fast as you can put a sUAS in the air. The cost to fuel planes 

and helicopters along with hiring pilots is not cost efficient compared to a sUAS. There is 

no fossil fuels powering the sUAS, nor does it require a cockpit active pilot, there for 

making it safer to fly over natural disasters such as post-earthquake destruction, wildfires

or collapsed infrastructure. With the sUAS you can also get a more up-close, controlled 

view of collapsed infrastructure compared to a plane or helicopter. As you can see, a 

sUAS will not eliminate all risk from the operations but it will provide a greatly

beneficial added safety measure to every job. This will be a highly valued benefit in the 

public’s interest.

Using sUAS in the real estate industry is greatly beneficial to real estate agents, 

land surveyors, people in the market for purchasing real estate and people who greatly 

value their property or landscape. RVP anticipates the continual growth in the want for 

aerial views for high-end property and sizeable parcels of land. Using a sUAS on private 

land will not adversely affect safety. It will be used in a controlled environment, only

photographing the home or property that is to be listed or showcased. These types of 

operations don’t call for flights to ascend to altitudes greater than 200 feet, all done while

keeping the sUAS in direct line of sight. Using sUAS for real estate listing purposes is 

very beneficial to the selling agent and to potential buyers. For the listing agents, it show 

cases homes in a unique way that focuses on the exterior of the home and its property in a 

single picture instead of multiple. It also showcases unique landscape features better than 

ground photographs or video. For potential buyers this is a great way to view the property 

without being there in person. If you live out of the state that you intend to move to, 

sUAS are very beneficial because they show you a complete over view of the property, 

the house and how well the grounds have been maintained. The aerial operators that fly

fixed wing aircraft over properties can only get shots from one angle and need to fly at 

great altitudes for safe operations. The quality of the photos from these altitudes aren’t 

nearly as good as what can be achieved with up close, sUAS photos. RVP can also get 

multiple angles of the house, showing the front, back and sides of the house and property. 

A sUAS will also benefit land surveyors and people that are proud of their property or 
landscape alike. Surveyors normally use satellite imagery to view a property. The images 

you get from satellites don’t provide high details in their photos because of their altitude. 

RVP hopes that surveyors will utilize our services to provide them with photos that show 

more detail of the land they are surveying and the topography associated with that land. 

For people that are proud of their landscape or completed landscaping project, the best 

way for them to capture a good overview photo of their work is by standing on the roof of 

their home. This is a very dangerous way to get a photograph with the potential to fall 

off, so it would be in their best interest to have the photos done by a sUAS. It’s a safe, 

effective way to get the photographs and RVP can shoot it at multiple angles giving the 

client the best possible view of their hard work. 

Granting an exemption would not adversely affect safety.

The comparison to remote controlled model aircraft, manned civil aircraft and 

sUAS are greatly diverse. They have different methods of staying airborne, fuel or power 

source, ability to carry a payload of passengers or cargo and much more. The design and 

use profiles of model and civil aircraft are very different to sUAS, this is why I would 

like to focus on why the sUAS operations would not adversely affect safety.

A granted exemption to RVP will not adversely affect safety. RVP is up-to-date 

and knowledgeable on all FAA regulations on safe operating procedures for sUAS. RVP 

plans to only fly the sUAS over client owned or controlled land or property, at altitudes 

lower than 300 feet to ensure we pose no threat to other aircraft, only operate during day

light hours, out of congested areas when applicable, and at least 5 miles away from any

airport. Our potential clients in real estate and infrastructure operations have already

taken certain action to prevent unauthorized access. For example, rail road tracks are 

usually elevated, fenced or otherwise secured to prevent public access. And bridges are 

temporarily closed to traffic while inspections are taking place. In real estate, most 

properties are fenced or gated off to prevent public access. RVP intendeds to use the 

sUAS at low altitudes and low speeds during all of our operations. If the situation arises 

that we may need to fly near an airport, contact will be made with the air control tower 

and instructions from them will be followed, even if it means we are not allowed to fly.

If an exemption is granted that allows the commercial use of sUAS in these 

industries, it will enhance safety while reducing risk. If a helicopter was allowed to 

operate in close proximity to the ground, people and structures, the risks presented are 

much greater and can cause much more damage to property or human life than a sUAS 

could. These helicopters weigh thousands of pounds and carry over 100 gallons of highly 

flammable jet fuel and the sheer mass of these aircraft greatly dwarf the sUAS. We plan 

to use the DJI Inspire 1, it weighs just about 5 pounds fully loaded, is battery powered 

and virtually eliminates all risk because of the reduced mass and lack of combustible fuel. 

Helicopters and fixed wing aircraft need to fly to and from the inspection site, whereas 

the sUAS is carried to, launched and lands at the site. 

The strict operation conditions described above and below, with a sUAS weighing 

less than 55 pounds, will provide an equivalent level of safety to support the grant of the 
exemptions requested. Operating the sUAS at low speeds, low altitude and in controlled 

environments is a much safer operation than conventional helicopters operating in close 

proximity to people and the ground.

To ensure safety for people associated with the operation as well as the public, the 

sUAS flight area will be restricted to granted access by the company. A security

perimeter will be established before any flight takes place as part of pre-flight control and 

all personnel associated with the operation will be briefed and must consent to be in the 

area. All others will be excluded from the operating area. During flight, RVP sUAS Pilot 

in Command (PIC) will stay in visual line of sight with aircraft and will not fly a distance 

of more than .5 miles away from take off point or remote controller. All avenues to 

ensure PIC training is in full compliance and understanding of all FAA sUAS regulations, 

safe flight practices and sUAS specific operations are exercised. PIC must display their 

complete competence with new firmware updates, updated FAA regulations, aeronautical 

knowledge and UAS airmanship skills before any flights outside of training take place. 

Two operators will control the UAS at all times. The PIC will control and watch the 

aircraft at all times, operator two will control the camera and camera operations at all 

times. An additional observer will be employed if needed to ensure that all safety 

precautions are being addressed and to aid the PIC with avoiding objects.

There are no standards for either Private or Commercial sUAS pilot certificates. 

The safe operation and control of the UAS as described in this application does not 

depend on the type of FAA license held by the PIC. Given the restricted and controlled 

airspace within operations will take place, the key factors needed by the PIC are 

knowledge of the airspace within the operation will take place and how that airspace fits 

into the National Airspace System (NAS). That knowledge can be and is gained primarily

through ground school and not through flight training in fixed wing or rotor aircraft, nor 

does it depend on the acquisition of a commercial or private pilot’s certificate. Those 

certificates demonstrate knowledge of the factors and skills needed for the safe operation 

of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a 

commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or 

ability to safely operate a small unmanned aerial vehicle, within strictly controlled preapproved airspace. Besides knowledge of airspace regulations, dexterity in the control 

and operation of the sUAS acquired from actual operation of the aircraft is the most 

important factor in establishing an equivalent level of safety. 

RVP Safety Operations and Procedures Overview

sUAS Out Of Box Standard Technology

The DJI Inspire 1 Quadcopter we intend to use comes packed with standard 

technological safety features that have been tested and developed by highly reputable 

industry partners. Features include;

1- Auto take off, auto land and Return To Home (RTH) features. Before flight starts, 

a home point will always be Global Positioning System (GPS) locked. If for any
reason the connection between the UAV and the remote controller is lost, the 

UAV has the ability to automatically return to its home point and land. 

2- Continually computing battery algorithms to make sure it always has enough 

battery to make it safely back to the home point. Once it reaches that level it will 

automatically RTH. Even though it has this feature, RVP’s safe practice is to 

manually return to home when battery level reaches 30% power reserve. 

3- Automatically will land if battery level becomes unstable or voltage becomes 

abnormal. 

4- Live streaming video footage to screen attached to each operator’s remote 

controller. This user-friendly interface shows you everything you need to know 

about the current health of your sUAS. It shows exactly how much battery is 

remaining, UAV’s altitude, distance from remote controller, battery voltage, GPS 

maps location, flight path, how many satellites are locked on (averages 15 

satellites linked at one time), and much more. Having the live streaming video 

helps us see what the sUAS sees, along with being able to see its surroundings 

and have a better sense of spatial awareness.

5- Max altitude limit. This allows us to program the UAV to stop climbing in 

elevation once it reaches a certain altitude. It is RVP’s policy to always make sure 

that the altitude limiter is set to stop at 350 feet before every flight to ensure we 

don’t put our sUAS or any other aircraft at risk. 

Operations

1- sUAS will always be in line of sight of PIC. Operating with the UAV in direct 

line of sight at all times will eliminate the possibility of loosing connection from 

the remote controller. 

2- The sUAS of choice will weigh less than 55 pounds and fly at a speed no greater 

than 50 Knots.

3- Battery reserve will always exceed the amount needed for actual flight time.

4- Flights will always stay below 400 Feet Above Ground Level (AGL).

5- Spotter will be used if necessary for the operation to ensure maximum safety.

6- Radio frequency spectrum analysis will be conducted before every flight for 

optimal connection between UAV and remote controller.

7- A flight path will be planned out and the airspace that will be used will be 

thoroughly checked for telephone or electricity wires, trees, or other objects that 

could cause an interference with the sUAS. A briefing going over the day’s

activities will be mandatory for anyone involved in the operations within the 

safety perimeter for the project.

8- Operator will obtain consent from everyone involved in the sUAS operations 

being performed. Whomever does not consent will be asked to stay 100 feet back 

from the operation while sUAS is operational.

9- PIC, camera operator and extra spotter, if available, will always be able to 

communicate by voice.

10- Written, or verbal permission from property owner/s will be obtained before every 

flight.
11- If in range of any airport, verbal permission from Air Traffic Control Tower must 

be obtained before any flight. All altitude information needs to be reported in 

FEET AGL.

12- The operator’s manual and this petition of exemption must be maintained and 

made available to the Administrator upon request. If a discrepancy exists between 

the conditions and limitations in this exemption and the procedures outlined in the 

operator’s manual, the conditions and limitations herein take precedence and must 

be followed. Otherwise, the operator must follow the procedures as outlined in its 

operator’s manual. 

13- All maintenance of sUAS must be up to date as explained in the operator’s 

manual maintenance schedule. If maintenance is not complete, the sUAS will be 

grounded until completed. 

14- A thorough inspection by the PIC of the sUAS must be done prior to each flight to 

ensure its safe to fly. If the inspection reveals something that prohibits the UAV 

from having a safe, successful flight, it shall be grounded until the issue has been 

resolved and it is clear it is in a safe condition to fly. All maintenance and repairs 

will be documented in aircraft records.

15- The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

When unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements must be established and identified in the 

operator’s manual. At a minimum, requirements for the following must be 

included in the operator’s manual: 

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator 

16- Prior to operations conducted for the purpose of infrastructure inspections or real 

estate purposes, the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours 

of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot 

with a similar UAS type (single blade or multirotor). Prior documented flight 

experience that was obtained in compliance with applicable regulations may

satisfy this requirement. Training, proficiency, and experience-building flights 

can also be conducted under this petition of exemption to accomplish the required 

flight cycles and flight time. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered 
nonparticipants, and the PIC must operate the UAV with appropriate distance 

from nonparticipants in accordance with 14 CFR § 91.119. 

17- The UAV may not be operated directly over any person, except authorized and 

consenting personnel, below an altitude that is hazardous to persons or property

on the surface in the event of a UAS failure or emergency. 

18- All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C. Markings must be as large as practicable. 

19- The operator must develop procedures to document and maintain a record of the 

UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

These procedures must be added to the operator’s manual. 

20- At least three days before scheduled sUAS flight or operation, the operator of the 

UAS affected by this exemption must submit a written Plan of Activities to the 

local FSDO with jurisdiction over the area of proposed infrastructure inspection. 

The 3-day notification may be waived with the concurrence of the FSDO. The 

plan of activities must include at least the following: 

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS operations conducted 

under this petition of exemption;

c. Name and phone number of the person responsible for the on-scene operation 

of the UAS;

d. Make, model, and serial or N-number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the event;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the operation event; the list of those who gave 

permission must be made available to the inspector upon request;

g. Signature of exemption-holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which sUAS operation will be conducted and 

the altitudes essential to accomplish the operation. 

21- The documents required under 14 CFR §§ 91.9 must be available to the PIC at the 

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

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

official upon request. 

22- UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. 

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

Flights under special visual flight rules (SVFR) are not authorized. 
Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, RVP provides the 

following information: 

Contact Information:

Brandon McDonald

CEO

Royal Vision Productions LLC

1315 14th ST SW

Puyallup, WA 98371

253-576-0185

royalvisionnw@gmail.com

Regulatory Provisions From Which RVP Seeks Exemption

RVP believes it may need an exemption from the following provisions to conduct the 

proposed operations. In some instances, relief is needed because relief from another 

provision renders compliance with the regulation at hand infeasible. 

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c)

14 C.F.R. §91.121 

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)(1)&(2)

14 C.F.R. §91.417(a)&(b)

RVP believes an exemption is only needed from the above-listed regulatory provisions. 

To the extent that the FAA believes that additional relief is required for RVP to conduct 

the operations described here, we request an exemption from any such regulatory

provisions as well.
The Extent of Requested Relief and the Reasons Relief is Needed 

Section 333 Aircraft Exemption Status: 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from 

the requirement for an airworthiness certificate based on a consideration of the size, 

weight, speed, operational capability of the particular UAS, as well as its proximity to 

airports and populated areas. An analysis of these criteria demonstrates that the sUAS 

operated without an airworthiness certificate in the areas and under the conditions 

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

or rotorcraft) operating with an airworthiness certificate without the conditions proposed 

in this request. 

The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

and operates exclusively within a secured area. Unlike other civil aircraft, operations 

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

observer. Operations will be conducted in compliance with the FAA and with local public 

safety requirements to provide security for the area of operation as is now done with 

conventional equipment, infrastructure inspection and real estate photography. These 

safety enhancements provide an expanded degree of safety to the inspectors over 

conventional operations. Lastly, application of these same criteria demonstrates that there 

is no credible threat to national security posed by the sUAS, due to its size, speed of 

operation, location of operation, lack of explosive materials and inability to carry a 

substantial external load. 

Given the size and limited operating area associated with the aircraft to be utilized 

by the Applicant, this meets the requirements of an equivalent level of safety under Part 

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

and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS 

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

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

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

conditions proposed. 
14 C.F.R. §61.113(a) and (b) 

§61.113 Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 

a private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 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.

*****

RVP anticipates using specialized, highly trained sUAS staff to conduct the sUAS 

operations. While these individuals will not hold commercial pilots lisence. The sUAS 

operations will not carry persons or property for compensation or hire because of the size, 

since it will be used solely to assist in the inspections of infrastructure, bridges, rail road 

tracks, tunnels, out buildings and real estate. The employees’ operation of the sUAS will 

not be incidental to their employment with RVP, and they will be compensated for such 

work. Without an exemption, the pilot would be required to hold a commercial pilot 

certificate under §61.133. However, the risk associated with the proposed operations is 

less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below 

the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and 

within a geographical envelope under the sole control of RVP clients. Accordingly, the 

risk would be limited to RVP personnel, who will be appropriately outfitted in safety 

gear, and RVP’s client’s property on the ground. Requiring a commercial pilot certificate 

would provide no appreciable safety benefit and would needlessly impose additional cost 

on RVP. Because the contemplated operations would not comply with §61.113(b)(1) and 

none of the other exceptions to paragraph (a) apply, relief is needed from both paragraphs 

(a) and (b). 

14 C.F.R. 91.119(c) 

§91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

*** 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over 

any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft.
 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

*****

RVP submits that the only relief it requires from §91.119 is from the minimum 

altitudes listed in paragraphs (b) and (c). Relief is required from paragraph (b) for fixed 

wing operations because asset evaluation of bridges, railroads, and other structures may

be near a populated area. Asset evaluation from 1,000 feet above any obstacle within a 

horizontal radius of 2,000 feet would pose inefficient to the operation and asset 

evaluation. Operations at this altitude would pose a heightened risk of collision with 

another aircraft, safety can only be assured through an exemption. RVP’s sUAS 

operations near populated areas would be limited to 150 feet AGL and temporary

closures or restricted access to the area of operation while sUAS is in operation would be 

strictly enforced. Relief is required from paragraph (c) for fixed wing operations because 

asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful

to the operation. Since operations at this altitude also pose a heightened risk of collision 

with another aircraft, safety can only be assured through the grant of an exemption. The 

anticipated uses of the sUAS are described above in the Operations section. Additionally, 

relief should not be needed from paragraph (a) because an emergency landing of the 

aircraft due to a power failure will not create an undue hazard to persons or property on 

the surface. As noted in the explanation of why an exemption will not adversely affect 

safety, RVP clients has exclusive use of the land over which the sUAS will be operated, 

and public access is restricted. It also has exclusive use of significant portions of land 

adjacent to the infrastructure and structures that will be the objects of evaluation and 

analysis. RVP’s Clients tightly control access to land and have the ability to assure that 

no individuals unassociated with the planned operations are on the affected land. As such, 

the risk of injury is minimal. 

14 C.F.R. 91.121 

14 C.F.R. §91.121 Altimeter Settings 

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

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

appropriate altimeter setting available before departure.”

***** 

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read 

out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.
Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric 

data feed, which downlinks from the aircraft to a ground-based on-screen display. This 

altitude information will be generated by equipment installed on board the aircraft, using 

GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will be 

established and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed – (1) During the day, to fly after 

that for at least 30 minutes. 

(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. 

*****

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve 

fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could 

run out of fuel in the event it has to be flown to an alternate airport or circle the planned 

airport in the event of unanticipated conditions. RVP does not intend to use the sUAS for 

point-to-point flights and will not operate the sUAS beyond visual line of sight. Nor will 

the sUAS require an airport in order to land. Rather, RVP will operate the sUAS using 

pre-planned flight paths (taking into account weather conditions) designed to allow the 

sUAS to fly to the point of intended landing. As such, there is no need for a time-based 

excess fuel requirement. Rather it should be sufficient to require only as much additional 

excess flight capacity as necessary to safely land the sUAS. We believe that a 30% 

battery reserve is more than sufficient to meet this objective. 
14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) 

§91.405 Maintenance required. 

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; 

*****

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

(a) No person may operate any aircraft that has undergone maintenance, rebuilding, or 

alteration unless –

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

chapter;

*****

§91.409 Inspections.

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

unless, within the preceding 12 calendar months, it has had __

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by §43.7 of this chapter; or

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

21 of this chapter.

*****

§91.417 (a) & (b)

***** 

RVP believes that an exemption from these three maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow 

an operator to meet the part 91 maintenance requirements. In particular, there are no 

individuals authorized by the FAA to approve a sUAS for return to service under 

§91.407(a) or to conduct the initial airworthiness and annual return to service inspections 

required by §91.409(a). RVP will maintain the aircraft as instructed in the owner’s 

manual and will not operate the aircraft until it has reasonably determined that any 

needed repairs have been made. However, because of the technical impossibility of 

meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an 

exemption from these provisions is appropriate. 
Please feel free to contact me at anytime, via phone number or email provided if 

there are any questions or concerns. Thank you for your time and consideration.

Brandon McDonald CEO, Royal Vision Productions LLC

Summary for Federal Register Publication 

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

Federal Register should the FAA determine that publication is needed. 

Petitioner: Royal Vision Productions LLC

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(b)&(c) 

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

14 C.F.R. §91.417(a)&(b) 

Brief Description Of Relief Sought:

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 

C.F.R., 61.113(a)&(b)), 91.119(b)&(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), 

and 91.417(a)&(b) to conduct sUAS operations over RVP Client’s owned or controlled 

land, solely during daylight hours, to assist in the safe evaluation and analysis of 

infrastructure operations and real estate. In general, sUAS operations are intended to be 

conducted in areas remote from both congested areas and airports. Some operations may

be near populated or congested areas, in which case extra safety precautions for operation 

will be enforced. The nature of operations anticipated by RVP requires that the sUAS be 

flown at relatively low altitudes. RVP expects that in most cases, the sUAS will be flown 

less than 75 feet from the highest structure along the path of the sUAS and in no 

instances will be flown higher than 400 feet above the ground. Accordingly, the risk of 

interference with other aircraft is minimal. 
Proposed	Aircraft	(sUAS)	Make	and	Model	For	Proposed	Operations:

DJI	Inspire	1

Specifications	Information:

AIRCRAFT

Model T600

Weight	(Battery	Included) 2935	g

Hovering	Accuracy	(GPS	mode) Vertical:	0.5	m

Horizontal:	2.5	m

Max	Angular	Velocity Pitch:	300°/s

Yaw:	150°/s

Max	Tilt	Angle 35°

Max	Ascent	Speed 5	m/s

Max	Descent	Speed 4	m/s

Max	Speed 22	m/s	(ATTI	mode,	no	wind)

Max	Service	Ceiling	Above	Sea	Level 4500	m	(Default	altitude	limit:	120	m	above	takeoff	point)

Max	Wind	Speed	Resistance 10	m/s

Max	Flight	Time Approximately	18	minutes

Motor	Model DJI	3510H

Propeller	Model DJI	1345T

Indoor	Hovering Enabled	by	default

Operating	Temperature	Range -10°	to	40°	C

Diagonal	Distance 559	to	581	mm

Dimensions 438x451x301	mm

Power	Spectral	Density 9.06mW/MHz

CAMERA

Name X3

Model FC350

Total	Pixels 12.76M

Effective	Pixels 12.4M

Image	Max	Size 4000x3000

ISO	Range 100-3200	(video)
100-1600	(photo)

Electronic	Shutter	Speed 8s	- 1/8000s

FOV	(Field	of	View) 94°

CMOS Sony	EXMOR	1/2.3”

Lens 20mm	(35mm	format	equivalent)f/2.8	focus	at	∞

9	Elements	in	9	groups

Anti-distortion

Still	Photography	Modes Single	shoot

Burst	shooting:	3/5/7	frames

Auto	Exposure	Bracketing	(AEB):	3/5	bracketed	frames	at	0.7EV	

Bias

Time-lapse

Video	Recording	Modes UHD	(4K):	4096x2160p24/25,	3840x2160p24/25/30

FHD:	1920x1080p24/25/30/48/50/60

HD:	1280x720p24/25/30/48/50/60

Max	Bitrate	of	Video	Storage 60	Mbps

Supported	File	Formats FAT32/exFAT

Photo:	JPEG,	DNG

Video:	MP4/MOV	(MPEG-4	AVC/H.264)

Supported	SD	Card	Types Micro	SD

Max	capacity:	64	GB.	Class	10	or	UHS-1	rating	required.

Operating	Temperature	Range 0°	to	40°	C

CHARGER

Model A14-100P1A

Voltage 26.3	V

Rated	Power 100	W

BATTERY	(OPTIONAL)

Name Intelligent	Flight	Battery

Model TB48

Capacity 5700	mAh

Voltage 22.8	V

Battery	Type LiPo	6S

Energy 129.96	Wh

Net	Weight 670	g

Operating	Temperature	Range -10°	to	40°	C

Storage	Temperature	Range Less	than	3	months:	-20	to	45°	C

More	than	3	months:	22°	to	28°	C

Charging	Temperature	Range 0°	to	40°	C

Max	Charging	Power 180	W