Rincon Aerial Imaging, LLC

Miguel Bekkevold, CEO

1525 SW 47th Ter #1123 

Gainesville, FL 32698

mbekkevold@gmail.com

January 10, 2016 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA FMRA and Part 11 of the Federal Aviation 

Regulations. 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Miguel Bekkevold, owner and operator of Rincon Aerial Imaging LLC, 

(“the petitioner”), Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer 

on-demand commercial UAS operations for a host of industries and applications and to 

perform the purposes listed below, hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its sUAV’s/UAS, so long as 

such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. 

§44701(f). As described more fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in airspace that is 1) limited; 2) 

predetermined; and 3) would provide safety enhancements to citizens in which it will 

operate, which now depends upon conventional aircraft or humans climbing high on 

dangerous structures, walking in insect laden swamps, and working adjacent to treacherous 

infrastructure which are just a few examples. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “... establish requirements for the safe operation of such aircraft systems in 

the national airspace system.” Section 333(c) of the Reform Act.
Rincon Aerial Imaging LLC is a company who will use UAV’s in the following industries: 

AERIAL PHOTOGRAPHY AND VIDEOGRAPHY 

Aerial photography and videography, film production, cinematography, special events: 

including high schools. Colleges, professional sports, concerts, open air events and fairs, 

television, residential and commercial real estate, weddings, private use, aerial video and 

photography for public and private use including television, public events, cinematography, 

live feed and live news gathering, closed-set filming, architecture, real estate appraisal. 

SURVEYING, MAPPING AND INSPECTIONS 

3D modeling, mapping, planning, aerial surveying, construction, pipeline inspections, 

structural assessments, energy systems inspections, telecommunications inspections, gas 

emissions inspections, environmental, engineering, utilities, land surveying, flare stack 

inspection, utility-power generation system inspections and patrolling, cell towers, air 

pollution, disaster and catastrophe events, power generation system inspections and 

patrolling, transportation, and inspection of power lines, cell towers and towers, building 

inspections, aerial inspections of infrastructure, architecture. 

LAW ENFORCEMENT, FIRE AND PUBLIC OPERATIONS 

Search and rescue, fish and wildlife, fire inspections, wildlife and forestry monitoring, law 

enforcement operations, forensic documentation, aerial video and live video feed to assist 

with search and rescue operations under the authority and support of local authority officials, 

disaster and catastrophe events. 

LAND MANAGEMENT 

Agriculture, historical preservation, ranching, highways, dams, wind farms, aqueducts, pipes, 

mining, livestock/ranch and cattle operations, forestry, construction sites, cell towers, 

engineering, wildlife and forestry monitoring and mosquito and insect control, asset 

management, disaster and catastrophe events, planning in environmental, construction, 

engineering, mining, utilities, forestry, agriculture, ranching. 

The petitioner plans to begin commercial operations in 2016 if the requested exemptions are 

approved. 

REQUESTED EXEMPTIONS 

• 14 C.F.R. Part 21 

• 14 C.F.R. Part 36 Noise Standards 

• 14 C.F.R. 45.23(b) Markings and Registration Number 

• 14 C.F.R. 61.113(a) & (b) Private Pilot Privileges and Limitations 

• 14 C.F.R. 61.133(a) Commercial Pilot Privileges and Limitations 

• 14 C.F.R. 91.7(a) & (b) Civil Aircraft Worthiness 

• 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual Marking and Placard Requirements 

• 14 C.F.R. 91.119 Minimum Safe Altitudes 

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• 14 C.F.R. 91.121 Altimeter Settings 

• 14 C.F.R. 91.151(a) & (b) Fuel Requirements in VFR conditions 

• 14 C.F.R. 91.203(a) & (b) Airworthiness Certificate 

• 14 C.F.R. 91.207 Emergency locator transmitters 

• 14 C.F.R. 91.405(a) Maintenance Inspections 

• 14 C.F.R. 91.407(a)(1) Maintenance Inspections 

• 14 C.F.R. 91.409(a)(2) Maintenance Inspections 

• 14 C.F.R. 91.417(a) Maintenance Inspections

EXPLANATION OF EXEMPTIONS REQUESTED: 

• 14 C.F.R. Part 21 

The petitioner requests exemption from airworthiness certification because the size, weight, 

speed, and operational capability of the UAS pose significantly less risk than the risks posed 

by conventional aircraft. While manned aircraft pose risks to the life and safety of the crew; 

that is not a consideration with the UAS. Risks to third parties are also minimized given the 

minimal weight of the UAS, the slow speed at which the UAS would operate, and the limited 

flight area of the UAS. There are no risks of fuel spillage with the UAS since they are batterypowered; therefore the risk of fire in the event of an accident is much less for the proposed 

UAS than for traditional aircraft. Thus the petitioner requests that the FAA waive the 

requirement that the UAS designated in this request maintain an airworthiness certificate.

• 14 C.F.R. Part 36 

Noise Standards The petitioner requests exemption from noise standards because; given the 

small size and battery-powered engine, the UAS would have negligible noise impact. 

• 14 C.F.R. 45.23(b) Markings and Registration Number 

The petitioner requests exemption from the size requirement of aircraft identification 

markings. Due to the small size of the UAS, it cannot accommodate the type-size 

requirement. The petitioner will identify the UAS aircraft by serial number in the largest feasible 

type-size, registered in accordance with 14 CFR Part 45 & 47. 

• 14 C.F.R. 61.113(a) & (b) Private Pilot Privileges and Limitations / 14 C.F.R. 61.133(a) 

Commercial Pilot Privileges and Limitations

The petitioner, Miguel Bekkevold, is a private pilot with over 100 hours. The petitioner requests 

an exemption that would allow a pilot in command to be employed and duly compensated 

who meets the requirements of private pilot with current class 3 medical certificate or drivers 

license in the event that the petitioner himself is not the pilot in command. The petitioner will 

only operate the UAS over property where the owner or owner's representative have agreed 

that the operation should occur. 

• 14 C.F.R. 91.7(a) & (b) Civil Aircraft Worthiness 

As requested in 14 C.F.R. Part 21, the petitioner requests exemption from the requirement of 

an airworthiness certificate. However, the petitioner will ensure the safety and airworthiness of 

the UAS aircraft during all flights. 

• 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual Marking and Placard Requirements 

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The petitioner requests exemption from the requirement of placards and on-board flight 

manuals since these items would not be feasible due to the small size of the UAS aircraft. The 

petitioner will ensure that the appropriate operating manuals and safety procedure 

guidelines are located at the ground station during flights. 

• 14 C.F.R. 91.109 Flight Instruction 

The petitioner requests exemption from the requirement that flight instruction be conducted 

in aircraft that have dual controls. In the event that the petitioner hires another person to act 

as pilot in command, that person will be a private pilot, hold a current class 3 medical 

certificate/valid drivers license, and undergo ‘instruction’ on the UAS during dedicated 

training flights which will be operated at least 500 feet from non-participating persons. 

• 14 C.F.R. 91.119 Minimum Safe Altitudes 

The petitioner requests exemption from this requirement since the UAS can be safely flown at 

lower altitudes than traditional aircraft. The UAS will be flown at or below 400 feet AGL. The 

equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as 

the location where it is operated. No flight will be taken without the permission of the 

property owner, facility owner and local officials. Because of the advance notice to the 

property owner and participants all affected individuals will be aware of the planned flight 

operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55 lbs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL in the aerial photography industry. In 

addition, the low altitude operations of the UAS will ensure separation between these smallUAS operations and the operations of conventional aircraft that must comply with Section 

91.119.

• 14 C.F.R. §91.121 Altimeter Settings

Section 91.121 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 a UAS may not have a 

barometric altimeter, but instead a GPS altitude data, an exemption is needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the FOPM and Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. The petitioner requests exemption for the required altimeter settings since the 

UAS aircraft is not equipped with an on-board altimeter as outlined in the regulation.

• 14 C.F.R. 91.151(a) & (b) Fuel Requirements in VFR conditions 

The petitioner requests an exemption from the VFR-flight fuel carrying requirements because 

the UAS will operate on battery power. Operations with the UAS will maintain a 5-minute 

reserve battery time. 

• 14 C.F.R. 91.203(a) & (b) Airworthiness Certificate 

The petitioner requests exemption for the required airworthiness and registration certificates. 

• 14 C.F.R. 91.207 Emergency locator transmitters 

The petitioner requests exemption from the requirement that aircraft be equipped with an 

emergency locater transmitter, given the limited flight area of UAS flights. 

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• 14 C.F.R. 91.405(a) Maintenance Inspections 

• 14 C.F.R. 91.407(a)(1) Maintenance Inspections 

• 14 C.F.R. 91.409(a)(2) Maintenance Inspections 

• 14 C.F.R. 91.417(a) Maintenance Inspections 

“The Petitioner” requests exemption from the regulated inspection intervals and mechanic 

certifications required for manned aircraft. The petitioner will maintain records of 

maintenance, service and repair to the UAS and will follow guidelines outlined by the UAS 

manufacturer. 

Description of Type, Make and Models of UAV/UAS Requested:

DJI PHANTOM 3 

DJI PHANTOM 4 

DJI PHANTOM 5 

DJI INSPIRE 1 

DJI INSPIRE PRO 

DJI INSPIRE 2 

DJI INSPIRE 3 

DJI MATRICE 

DJI SPREADING WINGS S900 

DJI SPREADING WINGS S900+ 

DJI SPREADING WINGS S1000 

DJI SPREADING WINGS S1000+ 

DJI AGRAS MG-1 

DJI S1100 

DJI S1200 

3D ROBOTICS X8-M 

3D ROBOTICS SOLO 

3D ROBOTICS AERO-M - FIXED WING 

3D ROBOTICS IRIS+ 

3D ROBOTICS IRIS M PRO 

SENSEFLY EBEE 

HONEYCOMB AgDrone

AERIAL TECHNOLOGY INTERNATIONAL AG550 

LILY ROBOTICS - LILY DRONE 

SKYCATCH EVOLUTION 3 

SKYCATCH COMMANDER 

MICRODRONE MD4-200 

MICRODRONE MD4-1000 

MICRODRONE MD4-3000 

CINESTAR 8 

OCTO 

ALTAVIAN 

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NOVA 6500 

BLADE 350 QX3 

AG EAGLE 

Cinestar 8

YUNEEC Q500 TYPHON 

DRAGAN FLYER X4-ES 

TRIMBLE UX5 

FCC COMPLIANCE 

UAS aircraft operations will comply with Part 15 of the FCC rules. Operation is subject to the 

following two conditions: (1) This device may not cause harmful interference, and (2) this 

device must accept any interference received, including interference that may cause 

undesired operation. 

Radiation Exposure Statement: UAS systems have been tested to ensure compliance with 

FCC-mandated limits for general population radio frequency (RF) exposure for an 

uncontrolled environment. These limits ensure that no harmful effects will result from 

operating Solo according to the standard operating procedures described in this manual. 

All devices will comply with Part 15 of the FCC Rules. Operation is subject to the 

Condition that this device does not cause harmful interference.

Remote Controller and Aircraft Frequency 

5.725GHr5.850GHz (Remote Controller to Remote Controller) 

2.400GHr2.483GHz (Remote Controller to Aircraft)

AREA OF OPERATIONS

Rincon Aerial Imaging LLC is requesting approval for UAV/UAS operations in the continental 

United States. In addition we are also requesting Alaska, Puerto Rico and Hawaii.

PUBLIC INTEREST AND WOULD NOT ADVERSELY AFFECT PUBLIC SAFETY 

The UAS operates at lower altitudes with no people on board and will thereby reduce current 

risk levels associated with traditional aircraft, enhance safety and greatly diminish the 

likelihood of death or serious bodily injury. The environmental impact (including air and noise 

pollution) caused by the UAS is also less than traditional aircraft, based on its smaller size, 

more limited flight times and alternative power source. Batteries power the UAS described in 

this petition; and they are smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel. Also, with a small payload and typical flight time of only 20 

minutes, as well as the restricted secure environments in which the UAS would be operated, 

there is little or no risk to national security. 

Photography, surveying, commercial applications, land management, agricultural 

inspections and the like available from UAS could previously only be obtained using fully 

manned aircraft, which was cost-prohibitive for many applications. The lower cost and ease 

of accessibility from UAS’s will be a benefit to many small to medium businesses that would 

otherwise be unable to afford those services. Additionally, we plan to make our UAS 

available to first responders in our community who might require assistance, including fire 

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fighters, police, sheriff, et al., while remaining subject to all limitations cited in this application. 

Flight safety will be maintained at a level that is equivalent to traditional flight operations, by 

the Exemption Request Section 333, Rincon Aerial Imaging LLC, Miguel Bekkevold, CEO, an 

FAA licensed pilot in a manner consistent with safe operation, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures. 

VIEWS OR ARGUMENTS TO SUPPORT THIS REQUEST

Congress’s national policy favors early integration of UAS into the national airspace in 

controlled, safe working environments such as those proposed in this petition. Those goals are 

furthered when businesses such as “Aerial PIC LLC” are granted exemption, thereby helping 

to facilitate and promote the safe integration of UAS into the NAS, while providing education 

and awareness of UAS operations and capabilities. By providing lawfully operated UAS 

operations, Rincon Aerial Imaging LLC offers a safer alternative to the public at large, in 

comparison with those who are currently operating UAS illegally in national airspace.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

UASs operated by Rincon Aerial Imaging LLC weigh less than 55 pounds, including the 

payload (i.e., camera, lens, and gimbal). They operate at speeds of no more than 50 knots, 

can hover, and can simultaneously move vertically and horizontally. Rincon Aerial Imaging 

LLC will only operate its UASs in line of sight and will operate only within the sterile area. Such 

operations will insure that the UAS will “not create a hazard to users of the national airspace 

system or the public.” 

Given the small size of Rincon Aerial Imaging LLC’s UASs and the restricted sterile 

environment within which they will operate, Rincon Aerial Imaging LLC’s UAS operations 

adhere to the Reform Act’s safety requirements. Additionally, due to the size of the UASs and 

the limited areas in which they will operate, approval of this application presents no national 

security issues. Based on the substantial level of safety surrounding the proposed operations, 

and the significant public benefit (enhanced safety), reduction in environmental impacts 

(reduced emissions and noise), granting this exemption is in the public interest. 

The operating limitations proposed by Rincon Aerial Imaging LLC provide for at least an 

equivalent or higher level of safety because operations further enhance safety of movie and 

television filming using conventional aircraft. 

LIMITATION AND CONDITIONS INCLUDE

• The UAS will weigh less than 55 pounds. 

• Flights will be operated within line of sight of a pilot and/or observer. 

• Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated 

at 25% battery power reserve should that occur prior to the 30 minute limit. 

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

feet above an elevated platform from which filming is planned. 

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

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (if 

needed), and the Camera Operator. 

• A UAS pilot will be an FAA licensed airman with at least a private pilot’s certificate a third 

class medical or a valid drivers license. 

• A UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other then the UAS 

Pilot, who possesses the necessary PIC qualifications, is also present on set (i.e., the Aerial 

Coordinator), that person can also be designated as PIC. 

• The UAS will only operate within a confined “Sterile Area” as defined in the FOPM. The 

FOPM requires the establishment of a “Security Perimeter” for the flight operations area. 

• A briefing will be conducted for planned UAS operations prior to each day’s flight. All 

personnel performing duties within the boundaries of the safety perimeter are required to 

attend. 

• The operator will file an FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office (”FSDO”). 

• The operator will obtain consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 100 feet of the flight operation. This radius may be 

reduced to 30 feet based upon an equivalent level of safety determination, as required 

under the FOPM. With the advanced permission of the FSDO, operations at closer range 

can be approved. 

• The operator will submit a written Plan of Activities to the FSDO three days before the 

proposed shoot as required if required to do or flying within controlled airspace. The 

operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this petition of exemption. 

This COA will also require the operator to request a Notice to Airman (NOTAM) not more 

than 72 hours in advance, but not less than 48 hours prior to the operation. 

• The Pilot and observer must be trained in UAS operations and have received current 

information on the particular UAS to be operated as required. The operator will follow the 

UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components. 

• The Observer and pilot will at all times be able to communicate by voice and/or text. 

• Written and/or oral permission from the relevant property holders will be obtained. 

• All required permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

• The UA will not operate in Class B, C, or D airspace without written approval from the FAA. 

The UA will not operate within 5 nautical miles of the geographic center of a non towered 

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airport 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 NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management will be made available to the Administrator upon request. 

• If the UAS loses communications or loses its GPS signal, the UAS will have the capability to 

return to a pre-determined location within the Security Perimeter and land. 

• The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: 

• Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial 

operations. Because the UAS will not carry a pilot or passengers, the proposed operations 

can achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is remotely 

controlled by a ground-based operator. The operational area is controlled and restricted, 

and all flights are planned and coordinated in advance. The level of safety exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the use of a UAS are so diminished from the 

level of risk associated with commercial operations contemplated by Part 61 allowing UAS 

use by a private pilot as the PIC exceeds the present level of safety sought by 14 C.F.R. 

§61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 91.103 requires each pilot to 

preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraft 

flight manuals will not be used, an exemption is requested. However, an equivalent level of 

safety will be provided. The PIC will take all actions, including reviewing weather, flight 

battery requirements, landing and takeoff distances, and aircraft performance data 

before commencement of flight. 

• 14 C.F.R. §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for 

operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when 

necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: (c) Over other than congested areas. An altitude of 400 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.” 

COMMUNICATIONS

Prior to the start of any operation covered by this manual, the pilot in command will 

formulate a plan to provide communications capability to all participants during the actual 

operation and filming. Oral, visual or radio communications may be used as long as it is 

effective and is capable of keeping the participants continuously apprised of the current 

status of the operation.

CERTIFICATION/AIRWORTHINESS

All Rincon Aerial Imaging LLC aircraft used in operations requiring a waiver of FAR 91 .119 (b) 

and (c) for the purpose of filming must be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N-Number, Serial Number or how 

required) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large 

as practicable.

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ACCIDENTS

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. Further flight operations will not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided.

PERMISSION TO OPERATE

Before any flight operations is conducted near an airport, under the provisions of the 

certificate of waiver and this manual, the operator will obtain permission to conduct these 

operations from property owners and local officials as necessary or appropriate. 

Persons from whom permission may be required are listed below: 

(1) Property owners

(2) Law enforcement officials

(3) Fire department officials

(4) Local, State and Federal government

(5) Air traffic control

Rincon Aerial Imaging LLC personnel obtaining such permission will do so in writing whenever 

practical, however, verbal permission is acceptable otherwise. A standard permission form is 

provided and may be used when obtaining written permission. Rincon Aerial Imaging LLC 

personnel will assure a sufficient number of those forms are available at the job site. Written 

permission forms will be maintained at the job site until flight operations are completed, and 

then turned into the chief pilot to be kept on file for a minimum of six (6) months. These forms 

will be made available for inspection by the FAA or other official personnel upon request. 

At least three (3) days prior to any scheduled filming, Rincon Aerial Imaging LLC may submit 

a written plan of activities to the local FSDO having jurisdiction over that area if required. The 

plan of activities should include the following:

(1) Dates and times for all flights.

(2) Name and phone number of person responsible for the filming production event.

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial or N-number of aircraft to be used and type of airworthiness 

certificate, including category. 

(5) Name and certificate number of pilots involved in the filming production Event.

(6) A statement that the waiver holder has obtained permission from property owners and/or 

local officials to conduct the filming production event. The list of those who gave permission 

must be made available to the inspector upon request from the waiver holder.

(7) Signature of waiver holder or representative.

(8) A description of the flight activity including maps or diagrams of any area, city, town, 

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county, and/or State over which flight activity will be conducted and the minimum altitudes 

essential to accomplish the operations. 

The three (3) day notification equipment may be waived, however, the operator should 

contact the FSDO as soon as possible with this request and be prepared to explain in detail 

why the three (3) day notification is not practical. 

REGARDING THE PILOT IN COMMAND (PIC)

“The Petitioner,” Miguel Bekkevold, obtained his private pilot certificate in 2010, (will maintain 

a class 3 medical or hold a valid drivers license) and has over 100 hours of accumulated 

flight time, certified in aircraft with retractable landing gear and a high altitude 

endorsement. The petitioner has never been subject to an FAA enforcement action, nor has 

he ever been involved with an aircraft accident or incident. “The Petitioner” has flown 

unmanned remote controlled aircraft as a hobbyist since 2010. In the event that the 

petitioner utilizes an employee to act as pilot in command of the UAS aircraft, they will have 

a minimum private pilot certificate, a current class 3 medical or valid drivers license, and 

supervised training on the UAS aircraft to include emergency maneuvers and other safe flight 

requirements.

During flights, the petitioner will utilize a visual observer(s) who are able to communicate 

verbally or via two way radio(s) with the pilot in command at all times.

As part of the safety and flight planning procedure to be followed prior to each flight, the 

pilot in command will: visually survey the flight area to ensure there are no potentially 

dangerous situations; create a designated ground station and/or landing area with restricted 

access for involved personnel only; ensure the flight area is more than 5 nautical miles from 

an airport (unless prior permission is obtained or a COA is issued) and not subject to any TFRs; 

ensure the weather conditions are suitable for flight; ensure the flight area is a safe distance 

from uninvolved persons, dangerous obstacles, and the public at large; and complete a preflight inspection of the UAS aircraft and ground station components.

CHIEF PILOT/PIC DUTIES AND RESPONSIBILITIES

• Final word in the formulation of policy and procedures concerning this manual. 

• Act as liaison between Rincon Aerial Imaging LLC and the FAA on matter concerning this 

manual. 

• Assure that each approved pilot is issued a copy of this manual and obtain a signed 

statement from each that they have read and understand its contents.

• Maintain a current copy of this manual at the main base of operations for Rincon Aerial 

Imaging LLC.

• Responsible for assuring that all revisions to this manual are distributed and processed 

properly. 

• Must approve or disapprove each proposed job or operation performed by Rincon Aerial 

Imaging LLC under the provisions of this manual.

• Assume the responsibilities of pilot in command when acting as such.

• The chief pilot may delegate functions to other personnel but retains responsibility.

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PILOT IN COMMAND/SECOND OPERATOR/CO-PILOT DUTIES AND RESPONSIBILITIES 

• Assure that aircraft to be flown is in airworthy condition and all inspections and required 

maintenance have been performed as per appropriate FAR’s.

• Acquire permission from the chief pilot before any operation under the provisions of this 

manual.

• Be very knowledgeable of the contents of this manual and abide by the procedures, 

policies and conditions contained herein.

• Coordinate with movie and television personnel to formulate plans, routes, locations, etc., 

with safety of all persons involved in the primary concern.

• Maintain their copy of this manual in current condition and have it on site at any job or 

operation requiring the waiver. 

• The pilot in command may delegate functions to other personnel, but retains responsibility. 

BRIEFING OF PILOT/PIC/PERSONNEL

Prior to the start of any operation under the provisions of this manual, the pilot in command 

will conduct a briefing of all procedures to participating personnel of the risks involved, 

emergency procedures, and safeguards to be followed during the filming production event. 

Personnel will also be briefed on additional provisions that may be issued by the FSDO that 

has geographic responsibility for the operational area, including the location of boundaries 

or time limits. The briefing shall cover: 

• Authorization for motion picture and television certificate of waiver and the attached 

special provisions

• Operations manual

• Plan of activities 

• Radio Communications

• Takeoff procedures

• Aviation activities to be conducted during the filming production event 

• Approach and landing procedureS 

• Recall procedures

• Emergency procedures

• Risks to participating personnel

• How to control nonparticipating persons. 

PRIVAVCY 

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

consent and knowledge. Inspections will be of inanimate objects in areas where the owners 

and/or operator will have consented to observation/filming or otherwise have agreed to be 

in the area where inspection will take place. 

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CONCLUSION / SUMMARY FOR PUBLICATION

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

Register, should it be determined that publication is needed: 

Rincon Aerial Imaging LLC seeks an exemption from the following rules: 

• 14 C.F.R. Part 21 

• 14 C.F.R. Part 36 Noise Standards 

• 14 C.F.R. 45.23(b) Markings and Registration Number 

• 14 C.F.R. 61.113(a) & (b) Private Pilot Privileges and Limitations 

• 14 C.F.R. 61.133(a) Commercial Pilot Privileges and Limitations 

• 14 C.F.R. 91.7(a) & (b) Civil Aircraft Worthiness 

• 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual Marking and Placard Requirements 

• 14 C.F.R. 91.119 Minimum Safe Altitudes 

• 14 C.F.R. 91.121 Altimeter Settings 

• 14 C.F.R. 91.151(a) & (b) Fuel Requirements in VFR conditions 

• 14 C.F.R. 91.203(a) & (b) Airworthiness Certificate 

• 14 C.F.R. 91.207 Emergency locator transmitters 

• 14 C.F.R. 91.405(a) Maintenance Inspections 

• 14 C.F.R. 91.407(a)(1) Maintenance Inspections 

• 14 C.F.R. 91.409(a)(2) Maintenance Inspections 

• 14 C.F.R. 91.417(a) Maintenance Inspections

As established by the UAS exemptions already granted by the FAA, allowing commercial 

operations of UAS’s in the film industry will enhance safety by reducing risk. Conventional 

operations, using turbine aircraft, operate at low altitudes and present the risks associated 

with aircraft that weigh around 4,000 pounds, and which carry large amounts of Jet A fuel. 

Such aircraft must also fly to and from the location. In contrast, a UAS weighing fewer than 55 

pounds and powered by batteries eliminates virtually all of that risk given the small size and 

lack of combustible fuel. The UAS is carried, and not flown, to a flight location. In this regard, 

the UAS carries no passengers or crew and, therefore, will not expose them to the risks 

associated with manned flights. 

The operation of UASs conducted in the strict conditions outlined in the FOPM will provide an 

equivalent level of safety supporting the grant of the exemption requested herein. The UASs 

operate at slow speeds, close to the ground, and in a sterile environment. As a result, they 

are far safer than conventional operations conducted with turbine helicopters carrying fuel 

and flying near the ground and people. 

The petitioner respectfully requests consideration of this request for exemption from the 

aforementioned Federal Aviation Regulations for the purpose of commercial flight operations 

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of UAS aircraft. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. 

If you have any questions or need any additional information, please contact the 

undersigned at 805-455-4875 or at mbekkevold@gmail.com 

Sincerely yours, 

Miguel Bekkevold 

CEO/President 

Rincon Aerial Imaging, LLC 

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