United States Department of Transportation Sunday, November 1, 2015

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Petition to Amend Exemption No. 11825 as a Comment to Regulatory Docket No FAA-2015-0373 

Dear Sir Or Madam:

Redline Aerospace LLC currently maintains an approved 333 exemption for aerial data collection. 

REDLine Aerospace LLC (hereafter referred to as Redline or Redline Aero) requests an amendment to 

our 333 exemption to include FAA approval to conduct Commercial UAS Operations for the purpose of 

filming and film-production related activities (such as on set data collection or power transmission) on 

closed sets in both scripted and unscripted production in the motion picture, television, large format film, 

commercial advertisement, virtual reality, new media and digital industry. Included in this document are 

the items we seek relief from as well as the following attachments: 

 Redline Aerospace LLC - Operations - Motion Picture and Television Operations Manual 

 Redline Aerospace LLC - Operations - DJI Inspire 1 User Manual (LINK ONLY) 

REDLINE AEROSPACE

Redline PICs have extensive experience in both manned and UAS operations, averaging 3,100 hours per 

pilot with over 1,250 hours in UAS. More information is online at www.RedlineAerospace.com. 

Redline’s approved 333: EXEMPTION NO. 11825 REGULATORY DOCKET NO. FAA-2015-0373

RELIEF REQUESTED

This is a petition to amend to our existing 333 / COA to include Closed Set filming. Our Motion Picture 

and Television Operations Manual (attached) requests relief from the following, or amendments to 

approved relief as described below: 

1. 14CFR § 61.113(a) Safety Observer, considered part of the aircrew by Redline, may assist the PIC 

with visual search and line of sight responsibilities without the SO regulatory requirements of a PIC. 

2. 14CFR § 91.119(c) consistent with FAA Order 8900.1 V3, C8, S1, participating persons, vehicles, 

and structures directly involved in the performance of actual filming. 

2.1. Requesting flight operations conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production as specified in the MPTOM. 

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Non participating persons are not allowed within 500 feet of the operating area with a reduction 

to 200 feet if an acceptable level of safety can be achieved and the Administrator has approved it. 

2.2. Redline requests defined relief for a further reduction in UAS-to-non-participants (human and 

animal) who are safely inside an object such as an automobile, boat, ship, train or covered 

moving object on land or water (or under water) from 500/200 feet to 50 feet while operating a 

medium-weight UAS with a payload at or under 33.5 lbs. 

2.2.1. Specifically, Redline requests the waiver to operate at 50 feet from those who are 

near or a part of production but have not (such as cars passing by), can not (such as 

animals) or are unable to commit to participant status. The API will list the 50 foot 

exemption as an option and with the reasons why the 50 foot separation is desired. 

2.2.1.1. Examples of this 50 foot separation would be to film near a waterway 

such as those in Los Angeles where roads above are not blocked from cross 

traffic. The UAS could safely pass under the bridge. Other examples: 

Aerials of a train passing over a bridge in a gorge, sledding events through a 

narrow pass led by animals, or wildlife observation in natural settings. 

2.2.1.2. The primary reason to include reduced separation and overflight is that 

the human, animal or object has moderate protection from the structure (car, 

boat, etc) or they are not in the flight path vector in the unlikely event of 

catastrophic system failure. 

2.2.2. Additional safety measures for 50 foot operations would be the reduced payload 

size (33.5 lbs maximum) and landing zone nets shaped to preclude overshooting a 

50 foot mark. For example, a backstop in a baseball field. The 50 foot exclusion 

with a backstop or fenced zone (shaping where the 50’ exclusion applies) is ample 

distance to separate non-participants and participants from debris or systems 

experiencing a malfunction during the take-off or landing phase. 

2.2.2.1. Standard 500/200 feet of separation would be reduced to 50 feet due to 

closed set size, non-participants near an open set, weather, terrain or lighting 

advantages. 

3. 14CFR § 91.151(a) Fuel Requirements for Flight in VFR Conditions 

3.1. Similar exemptions have been granted including Nos. 2689, 5745 and 10650. Similar UAS relief 

has been granted in Exemption Nos. 8811, 10808 and 10673 for daytime, VFR conditions. 

3.2. Redline Aerospace LLC UAS VLOS operations in controlled, closed-set filming environment 

will be restricted to 30 knots as suggested by the UA manual, returning to land with 20% or more 

power based on current operating conditions or a pre-planned amount higher above 20% based 

on terrain, wind, vertical obstructions or other safety or environmental factors. 

4. 14CFR § 91.405(a) and (b) ///Already exempted by Exemption No 11825/// Maintenance Required: 

Re-iterating that Redline maintains and requests relief by adhering to manufacturer-suggested 

maintenance documents with visual inspection of high-stress parts after each flight and part 

replacement as suggested by manufacturer guidance. Redline operations listed in 

5. 14CFR § 91.407(a)(1) ///Already exempted by Exemption No 11825/// Operating documents will 

contain minimum inspection requirements and daily preflight inspection for the UAS.

6. 14CFR § 91.409(a)(1) & (2) ///Already exempted by Exemption No 11825/// Operating documents 

will contain minimum inspection requirements and daily preflight inspection for the UAS. 

7. 14CFR § 91.417(a) and (b) ///Already exempted by Exemption No 11825///

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8. 14CFR § 91.7(a) ///Already exempted by Exemption No 11825/// Clarifying that Redline will operate 

only UAS systems approved through our COA / 333 exemption including system upgrades the 

manufacturer offers. For example, the DJI Inspire 1 upgraded to the DJI Inspire 1R by adding a better 

camera, adding small body upgrades to support the new gimbal. Redline requests that for minor 

upgrades within a system, such as the case with the DJI Inspire 1R, an amended exemption would not 

be required. 

9. ADDITIONAL RELIEF - If there are additional exemptions found essential to closed set film 

operations or common requests other than those requested above or those previously exempted in 

docket FAA-2015-0373 (listed in 9.1) we would appreciate your professional insight. 

9.1....Pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me 

by the Administrator, REDLine Aerospace, LLC is granted an exemption from 14 CFR §§ 

61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

10. The purpose of request 2.2 to maneuver in to 50 feet from non-participating personnel / participating 

personnel w/ 33.5lb payload while non-participants are in a transitory or protected position is because 

we believe sound judgement reduces and mitigates risk of collision significantly. By writing the 

FSDO on each API to confirm the 50’ exemption, by exception and on a case by case basis, Redline 

believes safety will remain paramount while making the most of medium payload UAS. 

10.1. Examples for API 50’ exemption: when there is a backstop or net in between the UAS and 

non-participants or a UAS passing under an overpass while autos pass overhead. 

Questions or comments may be addressed to Christopher R. Vasquez, Redline Aerospace LLC 

Christopher R Vasquez 

CEO, Chief Pilot - Redline Aerospace LLC 

www.RedlineAerospace.com

chris@RLAero.com (831) 224-2778 

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