RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

December 9, 2014 

Via Electronic Filing 

Attn: Docket Operations 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue SE, Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001 

Re: Exemption Request of Replicopy, Inc. d/b/a! RDM Productions under Section 333 

of the FAA Reform Act; Part 11 of the Federal Aviation Regulations; 14 CFR 

45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 

91. 1 03 (b); 91.109: 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 

91.407(a)(1); 91.409(a)(2); 91.417(a) & (b). 

Dear Sir or Madame: 

This application is sought on behalf of Replicopy, Inc. d/b/a! RDM Productions 

("Replicopy" or "RDM") pursuant to the FAA Modernization and Reform Act of 2012 and 14 

C.F.R. 11. RDM is a broadcasting and media production company based out of the DallaslFort 

Worth area, Texas SOS File No. 0149067900. RDM seeks exemption from the Federal Aviation 

Regulations (FARs) contained herein so that RDM be permitted to operate its small unmanned 

aircrafts ("SUAs"), or unmanned aircraft systems ("UASs"), commercially in airspace regulated 

by the Federal Aviation Administration ("FAA") wherein such operations are conducted within 

and under the requirements set out and established by the FAA in Section 333 of the FAA 

Reform Act. 

RDM specializes in standard and aerial videography and film production for the purposes 

of documentation, experimentation, demonstration and education. RDM seeks the use of SUAs 

or UASs to assist in RDM's documentation, experimentation, demonstration and education. 

RDM's opportunities for growth in the media production market are limited because of the 

current FAA restrictions as it pertains to the operations of UASs. RDM submits this proposed 

Petition for Exemption to the FAA to demonstrate its commitment in complying with the Federal 

Aviation Regulations and the National Airspace System ("NAS") in their safe, responsible and 

limited commercial use ofUASs. 

Daniel L. Redd is the Owner and President of Replicopy, Inc., d/b/a RDM Productions. 

Robert L. Redd is the Vice President and Manager at Replicopy, Inc., Director at RDM 

Productions and Manager of Memories Films. As Daniel Redd is an experienced, licensed pilot, 

and Robert Redd holds a student pilot license and has flying experience, both Daniel and Robert 

·8150 N. Central Expressway· Suite 747 . Dallas, Texas· 75206 . Telephone (214) 522-4111 . 

. Facsimile (214) 522-3550 . rayjobe@gmail.com . 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

Redd are familiar with commercial aviation and are aware and familiar with the dangers that 

unregulated UASs operation presents to persons and property on the ground. RDM has aptly 

equipped each of their UASs for aerial photography and cinematography. RDM applies for an 

exemption from the F ARs to allow operation of its UASs on motion picture sets, within and 

under the conditions outlined herein, and under such other limitations as may be established by 

the FAA as required by Section 333 of the FAA Modernization and Reform Act of 2012, Pub. 

Law 112-95, 126 Stat. 11 (2012). 

Section 333 of the FAA Modernization and Reform Act of 2012 ("F AAMRA") grants the 

authority to the Secretary to establish a policy outlining guidelines until the Unmanned Aircraft 

Systems rule is finalized. As the FAAMRA found that because UASs do not pose a threat to 

national airspace users or national security, operations of UASs do not need an FAA-issued 

certificate of airworthiness. 

This Petition for Exemption would permit the operation of small, lightweight, unmanned 

UASs under controlled conditions in airspace, in the UASs pilot's line of sight, that is further in 

limited and predetermined and marked areas of operation. RDM would allow for controlled 

access and would further provide safety enhancements to the already safe operations in the film 

and television industry presently using conventional aircraft. RDM acknowledges how essential 

safety is when operating UASs. The specifications regarding operating procedures a.l1d safety 

controls listed in UASs manuals are attached hereto. The operating specifications and safety 

procedures of the UASs, which RDM commits to uphold, ensures that they do not pose a hazard 

or threat to other aircraft, national security or public safety. 

Granting RDM's Petition for Exemption coheres with the Secretary of Transportation's 

responsibility to integrate UASs into the NAS and to "establish requirements for the safe 

operation of such aircraft systems in the national airspace system" pursuant to the FAA Reform 

Act § 333(c). 

Considering the foregoing and RDM's commitment to safety and regulations of the FAA, 

the specific regulations from which exemptions under Title 14 of the Federal Code of 

Regulations are herein requested are as follows: 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 

61.113(a) & (b). 

Exemption Request Section 333 of the FAA Reform Act; Part 11 of the Federal Aviation 

Regulations; 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(l); 

91.409(a)(2); 91.417(a) & (b). 

RDM Productions submits this Petition in accordance with the FAA Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

RDM contemplated commercial photography and cinematography, research and other flight 

operations within the NAS. The Reform Act in Section 332 provides for such integration of civil 

UASs into our NAS as it is in the public's interest to do so. RDM's lightweight UASs meet the 

definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of 

2 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

RDM's lightweight UASs are expressly contemplated by the Reform Act. RDM would like to 

operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA 

to promulgate rules governing such craft. 

The size, weight, speed and operational capabilities of the UASs at issue, which RDM 

would use, with authorization from the FAA, show that they do not pose a threat to other aircraft, 

national security nor public safety. The term "small unmanned aircraft," as defined by the U.S. 

Congress in Section 331, 112 Pub. Law 95, 2014, means "an unmanned aircraft weighing less 

than 55 pounds." 

RDM's UASs are small, lightweight devices containing counter-rotating propellers for 

optimum balance, control and stability. They are capable of vertical and horizontal operations 

but operate only within the line of sight ofthe pilot (UAS operator). Each device weighs no more 

than 55 pounds, including any photography or cinematic equipment. The UASs operate at speeds 

at 50 knots (57 mph) speeds or less and are capable of hovering less than 400 feet altitude. In 

addition to the UAS pilot, RDM uses a spotter and a technician, such that, at minimum, three 

RDM personnel govern the safe flight of an RDM small unmanned aircraft at all times. 

RDM does not operate its UASs near airports and generally does not operate them near 

populated areas. The UAS operating software and GPS navigation systems do not allow any of 

the RDM UAS devices to operate near airports or restricted fly zones. The failsafe software will 

disable the UAS devices from taking off and also limit the UAS systems from operating within 

specific GPS preset no-fly zones. To date, RDM has only operated its UAS on cordoned off 

areas and areas under the complete control of RDM or RDM clients. RDM only operates its 

UASs in predetermined areas and only in compliance with well regarded safety protocols such as 

those contained within the well established and commonly known Motion Picture and Television 

Operations Manual. 

Applicant further and specifically seeks authorization to use UASs, which are equipped 

with cameras and sensors, in order to perform photography, audio and video filming by air for 

public and private uses, including: television, cinematography, advertising, promotions, or public 

events. 

RDM's operation of its UASs will not "create a hazard to users of the national airspace 

system or the public." 112 P.L. 95 § 333(b). Given the small size and weight of RDM's UASs, 

combined with their operation in cordoned off and well-controlled areas, RDMs fleet falls within 

Congress's contemplated safety zone when it promulgated the FAA Reform Act and the 

corresponding directive to integrate UASs into the NAS. RDM's UASs have a solid safety 

record and do not pose any threat to the general public or national security. 

Maintenance of the UASs will be performed by the operator, in accordance with the 

aircraft's flight and operating manual. The operator agrees to ensure the each UASs is inspected 

before each flight, to perform all required maintenance and to maintain a log of all maintenance 

and repairs performed on all umnanned aircraft systems. 

3 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

Granting RDM's exemption request furthers the public interest. First, Congress has 

already pronounced that it is in the public's interest to integrate commercially flown UASs into 

the NAS, hence passing the FAA Reform Act. Second, RDM has conducted research into safe 

UAS operation each time it flies one of their UASs. Flight data, visual inspections, recorded 

observations and flight analyses are compiled to further enhance current safety protocols in 

place. Allowing RDM to log more flight time directly relates to its research and its ability to 

further enhance current safety measures. Third, the public has an interest in reducing the danger 

and emission associated with current aerial cinematic capture methods, namely, full size 

helicopters. RDM's UASs are all battery powered and create no emissions. If an RDM UAS 

crashes there is no fuel to ignite and explode. The impact ofRDM's lightweight UASs is far less 

than a full size helicopter, notwithstanding the statistically noteworthy safety record of full size 

helicopters used in motion picture capture. The public's interest is furthered by minimizing 

ecological and crash impacts by permitting motion picture capture through RDM's lightweight 

UASs. 

Progression of the arts and sciences has been fundamental to our society since its 

inclusion in the u.S. Constitution. Indeed, Congress mandated the integration of UASs into our 

NAS, in part, to achieve progression in this noteworthy, and inevitable, field. Permitting RDM to 

immediately fly within the United States furthers these goals. Whether it is the amalgam of 

scientific discoveries applicable to feature film making (including those drawing upon 

architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable 

technologies or advancements in equipment available to law enforcement personnel and first 

responders that does not cost millions of dollars, granting RDM's exemption request 

substantially furthers the public's interest in ways known and currently unknown. 

To further explain why RDM's exemption will not adversely affect safety or how 

granting RDM' s exemption request will provide a level of safety at least equal to existing rule: 

RDM's exemption will not adversely affect safety. Permitting RDM to log more flight 

time in FAA controlled airspace will allow RDM to innovate and implement new and as of yet 

undiscovered safety protocols. Additionally, RDM proposes the following safety procedures and 

restrictions if granted an exemption: 

• RDM's UASs weight not more than 55 pounds, including any photography or cinematic 

equipment; 

• RDM only operating its UASs at an altitude of 400 feet or less; 

• RDM shall limit the UAS operation to thirty (30) minute flights, or ceasing operation at 

25% battery; 

• RDM's lands its UASs when they reach 25% battery; 

• The operator(s) ofthe unmanned aircraft system will hold private pilot certificates; 

4 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

• RDM's remote control pilots operate RDM UASs only within line of sight; 

• RDM's remote control pilots have video backup should they somehow lose sight of its 

UASs; 

• RDM staffs each flight with a remote control pilot, technician and a spotter with 

communication system enabling real-time communications between them; 

• RDM employs a GPS system within each UAS allowing the UAS to hover in place if 

communications between the device and the remote control pilot is lost and then slowly 

descend at twenty-five (25) percent battery; 

• RDM actively analyzes electronic flight data and other sources of information to 

constantly update and enhance safety protocols; 

• RDM only operates its UASs in secured areas that are strictly controlled, are away from 

airports and populated areas; 

• RDM shall not operative its UASs at night; 

• RDM shall conduct an inspection of its UASs before each flight; 

• RDM shall operate its UASs only on closed sets; 

• All RDM flights shall occur only in private or controlled access property, having the 

property owner's prior consent and knowledge; 

• RDM has procedures in place to abort flights in the event of a safety breach or a potential 

danger; and 

• RDM shall obtain all necessary consent and permissions prior to operation of those being 

filmed or an agreement to be in the designated filming area prior to filming taking place. 

A summary the FAA may publish in the Federal Register: 

A. 14 C.F .R. 21 and 14 C.F .R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F .R. § 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements 

for procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed operations area ofRDM's UASs permits 

exemption from Part 21 because RDM'S UASs meet an equivalent level of safety 

pursuant to Section 333 of the FAA Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. 

§44701 (f)) and Section 333 of the Reform Act. Both pieces oflegislation pennit the 

FAA to exempt UASs from the airworthiness certificate requirement in consideration 

5 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. RDM's UASs meet or exceed each ofthe elements. 

14 C.F.R. § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

F ARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are 

no pilots or passengers, and given the size of the UASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual 

at the flight operations center with the remote control pilot of the RDM UAS. The 

FAA has previously issued exemptions to this regulation in Exemptions Nos. 8607, 

8737,8738,9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as RDM's 

UASs utilize electronic global positioning systems (GPS) and internal gyroscopes to 

provide spatial coordination. 

14 C.F.R. §§ 91.203 (a) and (b) provides for the carrying of civil aircraft certifications 

and registrations. They are inapplicable for the same reasons described above, The 

equivalent level of safety will be achieved by maintaining such certifications and 

registrations at the RDM flight operations center. 

B. 14 C.F.R. § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to 

certain specifications. RDM's UASs are, by definition, unmanned. They therefore do 

not have a cabin, cockpit or pilot station on which to mark designated words or 

phrases. Further, two-inch lettering is difficult to place on such a small aircraft. 

Regardless, RDM will mark its UASs in the largest possible letting by placing the 

word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. § 45.29(f) so that 

the pilot, technician, spotter and others working with the UA V will see the markings. 

The FAA has previously issued exemptions to this regulation through Exemption 

Nos. 8738,10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: 

Pursuant to 14 C.F.R. §§ 61.113 (a) and (b), private pilots are limited to noncommercial operations. RDM can achieve an equivalent level of safety as achieved 

by current regulations because RDM's UASs do not carry any pilots or passengers. 

Further, while helpful, a pilot license will not ensure remote control piloting skills, 

though RDM pilot vetting and training programs will. Further, private pilot licensees 

will operate RDM's UASs with the same skill. The risks attendant to the operation of 

RDM's UASs is far less than the risk levels inherent in the commercial activities 

outlined in 14 C.F.R. § 61 et seq. Thus, allowing RDM to operate its UASs with a 

6 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

private pilot as the pilot in control will exceed current safety levels in relation to 14 

C.F.R. §§ 61.113 (a) and (b). 

D. 14 C.F.R. § 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. RDM's 

UASs will never operate at an altitude greater than 400 AGL. RDM will, however, 

operate its UASs in cordoned off areas with security perimeters, providing a level of 

safety at least equivalent to those in relation to minimum safe altitudes. Given the 

size, weight, maneuverability and speed of RDM's UASs, an equivalent level of 

safety will be achieved. 

E. 14 C.F.R. § 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) and (b): Maintenance 

Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to "have [the] 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 ofthjs chapter." 

These Regulations only apply to aircraft with an airworthiness certificate. They will 

not, therefore, apply to RDM should its requested exemption be granted. RDM 

conducts an extensive maintenance program that involves regular software updates 

and constant inspection for assessment of any damaged hardware. Therefore, an 

equivalent level of safety will be achieved. RDM has researched and developed its 

own designs. 

F. Summary 

RDM seeks an exemption from the following Regulations: 14 C.F .R. 21, subpart H; 

14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 

91.9(b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. 

§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203 (a) and (b); 14 C.F.R. § 

91.405(a); 14 C.F.R. § 91.407(a)(I); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. §§ 91.417 

(a) and (b) to commercially operate its fleet of small unmanned vehicles and 

lightweight unmanned aircraft vehicles in motion picture or television operations and 

to conducts its own research. 

Granting RDM's request for exemption will reduce current risk levels and thereby 

enhance safety. Currently, motion picture image capture relies primarily on the use of 

larger aircraft running on combustible fuel. RDM's UASs do not contain potentially 

explosive fuel, are smaller, lighter and more maneuverable than conventional motion 

picture aircraft. Further, RDM UASs operates at lower altitudes and in controlled 

airspace. RDM has been analyzing flight data and other information in compiling 

7 
RAYMOND V. JOBE 

ATTORNEY AND COUNSELOR AT LAW 

novel safety protocols and the implementation of a flight operations manual that 

exceeds currently accepted means and methods of safe flight. 

There are no people on board RDM UASs and therefore the likelihood of death or 

serious bodily injury is significantly limited. RDM's operation of its UASs, weighing 

less than 55 pounds and traveling at speeds no more than 50 knots in cordoned off 

areas will provide at least an equivalent level of safety as that achieved under current 

FARs. 

Therefore, RDM respectfully respects that the FAA grant its exemption request 

without delay. The FAA has the authority to issue the exemption sought by RDM 

pursuant to the Federal Aviation Act, 85 P.L. 726, as amended (the "Act"). 

Respectfully submitted, 

RAYMONf{ V. JOBE 

Counsel for Replicopy, Inc. d/b/a/ RDM Productions 

cc: Daniel L. Redd 

8