R&D Design LA, LLC- Section 333 Exemption Request 1

January 24, 2016

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam,

On behalf of R&D Design La LLC. (“Applicant”), and Pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 and 14 C.F.R. Part 11, I David K Holtman, Managing Director, am seeking an 

exemption from 14 CFR Part 21, 14 C.F.R. 45.23(b), 14 CFR 61.113 (a) & (b), 14 C.F.R. 91.7 (a), 14 CFR 

91.9 (b) (2), 14 C.F.R. 91.103, 14 C.F.R. 91.109, 14 C.F. R. 91.119, 14 C.F.R. 91.121, 14 CFR 91.151 (a), 14 

CFR 91.203 (a) & (b), 14 CFR 91.405 (a), 14 CFR 407 (a) (1), 14 CFR 409 (a) (2), 14 CFR 417 (a) & (b).

As described more fully below, the requested exemption would permit the operation of Small 

Unmanned Aircraft Systems (“sUASs”) under controlled conditions in airspace that is:

1. Limited

2. Predetermined

3. Controlled as to access 

4. Providing safety enhancements to the already safe operations in the infrastructure and business 

operations industry presently using conventional aircraft. 

Approval of this exemption would thus enhance safety and fulfill the Secretary of Transportation and the 

FAA Administrator’s responsibility to “....establish requirements for the safe operation of such aircraft 

systems in the national airspace systems.” Section 333(c) of the Reform Act. 

APPLICANT INFORMATION:

R&D Design La, LLC.

Name: David K Holtman and Ryan Becnel

Phone: 978-835-1348

Email: david@rddesignla.com

Business Address: 1615 Poydras St. Ste 907, New Orleans, La 70112

Operator 1 (PIC): David K Holtman; 946 Harding Dr., New Orleans, La 70119

Operator 2: Ryan Becnel; 4916 Lasalle St., New Orleans, La 70115

BACKGROUND INFORMATION:

R&D Design La is in the business of providing high quality photography and videography / 

cinematography to organizations engaging in construction, tourism, commercials, nature, disaster relief. 

The Applicant is requesting FAA Exemption for the UAS for safety, inspection and photography / 

videography capture usage. 

THE UNMANNED AIRCRAFT:

The UAS is lightweight (under 55lb. gross weight), battery operated multi- rotor copter that takes off 

and lands vertically and has the ability to self stabilize in one location while in flight. 
R&D Design LA, LLC- Section 333 Exemption Request 2

 DJI Inspire 1

o UAS Cert #: FA3Y4ELHKA

o Issued: 12/24/2015

o Exp: 12/24/2018

THE UAS INCLUDES: 

 An on-board flight computer with GPS navigation and location ability that receives signals for 

flight control from a ground-based transmitter/controller. 

 An on-board camera and sensor package used to document physical and/or environmental 

conditions of structures and the natural environment. 

 An on-board telemetry system that delivers flight data from the on-board flight computer to the 

radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of 

flight and direction back to its launch site. 

 A 2.4GHz on-board radio transmitter that transmits live video from the on-board camera plus all 

the flight data from the telemetry system described above. 

 The capability to return at a predetermined location if site or GPS communications are lost.

 FAA Certification number clearly displayed.

THE GROUND STATION PART OF THE SYSTEM: 

 A Pilot in Command (PIC) in operational control of a mission from beginning to end, and who 

controls the UAS while in the air. 

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while in flight. 

 Ground Station (tablet or smart phone based app: DJI GO) which receives and displays video and 

system telemetry real time from the UAS. 

 A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UAS 

while in flight.

QUALIFICATIONS OF PIC:

 Primary PIC- David Holtman has logged over 100 non-commercial, recreational flights with the 

UAS and averages 5 hours of flight time per week to ensure familiarity and increase skill and 

ability with the maneuvering of the UAS. David maintains an excellent level of health and always 

uses discretion while operating the UAS. Currently David follows all safety regulations set by the 

FAA while flying recreationally and continues education to keep up with any changes and 

expand knowledge of regulations and safety procedures. This experience also qualifies David as 

a VO when the UAS is not being operated by David.

 Secondary PIC- Ryan Becnel has logged over 80 non-commercial, recreational flights with the 

UAS and averages 5 hours of flight time per week to ensure familiarity and increase skill and 

ability with the maneuvering of the UAS. Ryan maintains an excellent level of health and always 

uses discretion while operating the UAS. Currently Ryan follows all safety regulations set by the 

FAA while flying recreationally and continues education to keep up with any changes and 

expand knowledge of regulations and safety procedures. This experience also qualifies Ryan as a 

VO when the UAS is not being operated by Ryan.

ADDITIONAL SAFETY MEASURES TAKEN

 A pre-flight safety inspection will occur as it pertains to all equipment. 

 Flights will be operated within line of sight of the PIC.
R&D Design LA, LLC- Section 333 Exemption Request 3

 Maximum flight time for each operational flight will be 30 minutes and will be ended when 

batter level reaches 25% of battery reserve. 

 Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet 

above an elevated platform which flight is planned.

 The UAS pilot will be and is a specially trained staff member of the Applicant knowledgeable of 

the airspace which the flight will take place within. 

 A briefing of the flight pattern will be reviewed prior to flight with specific attention to safety. 

 Operator will obtain consent of all persons involved in the flight and only consenting individuals 

will be allowed within 100 feet of the flight path. This radius may be reduced to 30 feet based on 

an equivalent level of safety determination. With advanced permission of the relevant FSDO, 

operations at closer range can be approved. 

 Pilot and observer will have been trained in operation of UAS generally and received up to date

information on the particular UAS to be operated.

 All required permissions and permits will be submitted for and received by state, county or city 

jurisdictions.

PRE FLIGHT SAFETY INSPECTION AND FLIGHT PROCEDURES:

The following steps are conducted for each and every flight.

1. Visually inspect the UAS/UAV prior to all flights

2. Inspect the blades and insure they are installed properly and free of any damage

3. Confirm that all the batteries are fully charged

4. Confirm a proper communication connection between the UAS/UAV and the controller prior to 

any flight

5. Visually inspect the flight area by walking the entire perimeter

6. Confirm and locate a safe takeoff and landing location

7. Discuss flight emergency options and potential hazards with the Flight Spotter and all project 

participants

8. Test the flight proficiency of UAS/UAV first by flying to a 4-foot height level, hover for 1 min, test 

the Yaw, Pitch and Roll. Once safely completed land the aircraft and prepare for the actual flight

9. Log the flight with the project name, purpose, location, time and date

10. Confirm the surrounding conditions are safe for flight. This includes people, traffic, telephone 

wires, wildlife, buildings and weather

11. No flight will ever take place nor will any control of any UAS/UAV ever be conducted while 

under any influential drug

12. Always maintain a safe distance from any buildings and always maintain a clear line of site while 

operating a UAS/UAV

13. Always within compliance of the FAA maintain appropriate distance from airports unless 

otherwise granted permission by the control tower of airport within radius. 

14. While in flight keep the UAS/UAV in front of you, never fly the aircraft behind you

15. Confirm that the FAA assigned UAS certificate number is in tact and properly placed on the 

aircraft

16. UAS/UAV aircraft is required to always remain in a direct visual line of site while in the air

17. Pay close attention to UAS/UAV distance, battery level and aircraft location throughout the 

entire flight

INTENDED USE / PUBLIC GOOD: 14 CFR §11.81(d)

The requested exemption would allow the Applicant to use the UAS for aerial image acquisition to 

support various mapping and surveying applications as well as video documentation for the public good. 
R&D Design LA, LLC- Section 333 Exemption Request 4

Typical applications would include, but are not limited to: 

 Aerial Photography 

 Aerial Mapping 

 Commercial Videography

 Motion Picture Videography

 Special Event Videography / Photography

 Infrastructure Inspections 

 Utility Inspections 

 Construction Site Monitoring 

 Volumetric Calculations 

 Search and Rescue 

 Education 

The ability of the UAS to capture imagery from a low altitude including photos and video from several 

angles is far more effective than ground-based imagery for displaying the characteristics of buildings, 

sites and properties. Further, UAS can access locations not accessible to conventional aircraft due to 

their own flight restrictions due to size. The applicant produces maps from aerial imagery that public 

and private entities use for infrastructure assessment, utility inspections, land development projects and 

construction site safety inspections. These images, videography, maps and other products produced 

from UAS are used to better the local economy and promote local business. 

PUBLIC SAFETY: 

UAS are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel; they operate at lower altitudes (under 400’) with no people on board 

thereby reducing current risk levels and enhancing public safety. With a small payload and maximum 

flight time of approximately 20 minutes. UAS offer little or no risk to national security due to their size, 

payload capacity and flight duration. 

DJI models have their own built in failsafe functionality which will cause the UAS to return to its take-off 

location and land before the battery becomes empty, or the system loses communication. In addition

DJI uses geo fencing technology to restrict flight operations where the FAA has mandated no fly zones 

such as: Airports, National Parks, and Stadiums.

PRIVACY:

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. Infrastructure and construction inspections and business operations will be performed 

for people who have also consented for work to be performed or otherwise have agreed to be in the 

area where UAS flight will take place.

SUMMARY EXEMPTION REQUEST: 

This request follows many others using similar systems and process that have been granted previously. I 
R&D Design LA, LLC- Section 333 Exemption Request 5

am requesting the FAA issue a summary grant of exemption as this request would not set a precedent. 

R&D Design La LLC respectfully requests that the FAA grant it’s exemption request. 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. Please contact me at any time if you require additional information or clarification. I am the 

primary point of contact for this request and look forward to working with your office.

David K Holtman

Cell: 978-835-1348

Email: david@rddesignla.com