1034 Front Street 

Unit 129 

Lahaina, Hi 96761

T (888) 309-7873 

sales@rvrd.com

www.rvrd.com

Dec 21, 2014 

To whom it may concern, I “Jason Toth” owner of Revered Cinema (RVRD LLC) is supplying 

addition information requested by the FAA on Nov 24th 2014 for Docket FAA-2014-0938 for Exception 333 (UAV Operations). 

• The specific section or sections of 14 CF from which you seek relief, the extent of relief 

you seek, and the reason you seeks relief.

Requesting exemption from Part 21, Subpart H of the Title 14 CFR: 

We operate UAV’s commercial in Canada and require the Section 333 Exemption for the U.S. in 

the following industries: 

- Motion Picture Film Operations 

- Whale Research in the Hawaiian Islands w/ permission from NOAA, University of Hawaii, University of Maui, Whale Trust, Hawaiian Marine Sanctuary

- Data collection on private properties / industries (Energy, Agriculture, Civil Engineering)

45.23(b) - I request an exemption from 14 CFR § 45.23 as these are small UAV’s under 50lbs 

and max speed of 10m/sec which there are no airworthiness certification. The UAV carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area as set out in the Motion Picture & Television Operations Manual. In addition, the UAV has integrated safety features designed, as described in our Operations Manual, to ensure the safety of persons and property within and surrounding the limited 

operating area. In the event the UAS loses communications or its GPS signal, the UAV will have 

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

stated in our Operations Manual.

45.23(b) - We are using a Unmanned Aerial Vehicle (UAV) w/ no entrance to the cabin, cockpit, 

or pilot station (no personal aboard). This UAV designation will use the terminology of “Experimental” in a restricted environment and under the conditions and limitations proposed by the the 

chief operator, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate.

45.23(b) - Given the size of the UAV, it in not possible to have two-inch lettering or call signs visible on the UAV. 

45.23(b) - I assure that an equivalent level of safety will be provided by having the UAV marked 

with the word “experimental” on the fuselage in compliance with 14 CFR § 45.29(f), in a location 

where the pilot, observer, and others working with the UAV will see the identification easily.
45.23(b) - The petitioner states that the unmanned aircraft (UA) to be operated under this request is less than 55 lbs. fully loaded, flies at a speed of no more than 50 knots, no higher altitude than 400ft AGL (but 90% of operations will be under 100ft AGL), max distance VLOS (Visual Line of Sight) carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the MPTOM. In 

addition, the petitioner has integrated safety features into the design of the UAS, as described in 

the petitioner’s FOPM, to ensure the safety of persons and property within and surrounding the 

limited operating area. The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will have the capability to return to a pre-determined location 

within the Security Perimeter and land. It will also 

61.113(a)(b) - UAV operation is different than traditional aircraft piloting. I have done ground 

school to learn about the airspaces that we will be operating in. Please see my Ground School 

certificate previously attached to my original application Docket (re-attached to this request as 

well on page 04 of the “RVRD FAA Exemption Application - Dec 2014.pdf”) 

91.7(a) - Our UAVs are airworthy but not able to be certified since there is no governing body for 

UAV certification as of yet.

91.9(b)(2) - We use our own flight manual for UAV operations since we operate at low level, we 

have markings and lighting on our UAV’s for easy visibility during operations. 

91.103 - Please see page 08 of the “RVRD FAA Exemption Application - Dec 2014.pdf”). 

This section does not apply to small UAV operations BUT we do operate under these required 

guidelines. We are well versed in airspace regulations and proceeders due to our Transport 

Canada SFOC guidelines which require the same.

91.105 - Please see page 07 of the “RVRD FAA Exemption Application - Dec 2014.pdf”)

91.109 - We do have dual controls (Pilot/Trainer) but is not required for UAV operations. We 

have training programs set up that do not require the UAV pilot to has assistance from a Trainer 

or Co-pilot since they are experienced at small UAV operations.

91.119 - We will only be operating on a closed film production set or over water for NOAA research where there is no danger to General Public Safty or Properties. All nonparticipating personnel will be required to be at least 500 feet from flight operations, with possible relief to allow 

reductions to 200 feet (terrain features, obstructions, buildings and barriers may protect nonparticipating persons from debris in the event of an accident. Please see our attached SFOC applications for all Canadian Provinces on which we have operated per the Permit Guidelines commercial for the past 3 years in Canada and will be following the same rules that we would apply 

to U.S. operations ( _RVRD_TransportCanada_UAV_Permits.pdf ) 

91.121 - We operate at no higher altitude than 400ft AGL (but 90% of operations will be under 

100ft AGL), max distance VLOS (Visual Line of Sight). All our UAVs are equipped with telemetry 

that is live streamed to various ground station monitors. Also our UAVs have predetermined 

boundary areas set in the flight controllers so the UAV if rouge could not pass these thresholds. 

91.151(a) - Please see page 08 (imposed restrictions) of the “RVRD FAA Exemption Application 

- Dec 2014.pdf”). Also please see page 2-6 of the attached ( _RVRD_TransportCanada_UAV_Permits.pdf ) where it specifies our operating requirements used for our UAV operations. 

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91.203(a)(b) - please see 91.9 

91.405(a) & 91.407(a)(1)

 - We keep a record of each UAV operation, duration and have a maintenance schedule for 

100hrs & 200hrs of flight. Each flight t(pre/Post) check as necessary: props, wires, bolts, 

screws, systems check, preflight checklist & test flight before each operation. At 100hrs of Operations we change out the motors bearing which could be the failure point of UAV operations. 

At 200hrs we do a full rebuild of the UAV or retire it. ( Please see page 08 of the “RVRD FAA 

Exemption Application - Dec 2014.pdf”)

91.409 - UAVs operations are requesting relief of Airworthiness Certificates BUT we do do our 

own inspection since we are manufactures and builders of our own Model UAVs. We have a 

great understanding on whats involved with UAV operation, maintenance, manufacturing, building, etc. 

91.417(a)(b) - We are required to do this for Transport Canada so its standard for any UAV operations we do 

• The reason why granting the request would be in the public interest; this is, how it 

would benefit the public as a whole

The enhanced safety achieved using a UAV with the specifications described in our Exemption 

Request PDF and carrying no passengers or crew, rather than a manned aircraft of significantly 

greater proportions, carrying crew in addition to flammable fuel, is in the best public interest - 

since its impact on the public would be lesser than a maned aircraft (safety, noise, collision, privacy, ect). 

UAVs are one of the best tools for the filmmaking and research industry, adding a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft. We 

have been operating legally in Canada for 3 years and our client list is very extensive proving 

that UAV operations is safe and requested by production companies and accepted by local 

communities. We are excited the the FAA is granting exemptions so we can operate UAV legally 

in the USA. Productions we have operated for: http://www.rvrd.com/#clients

Miramax Films, Nestle, Lincon, Food Network, Sega, NBC, Google, Subway, Socy, Walk Disney, CBC, Paramount, Exxon Mobile, ABC, Lexus, Dodge, Cigna, Michelob, Mazda, 21st Centry 

Fox, Lifetime, A&E, etc 

We have also been requested by various Whale Research institutions in the Hawaiian Islands 

(NOAA, University of Hawaii, University of Maui, Whale Trust, Hawaiian Marine Sanctuary). To 

observe Humpback Whales using UAVs since its non-threatening to the marine mammal, they 

are wanting to use for resist to see if the Humpback population could be taking off the endangered list. 

• The reason why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which 

Part 03 - Page 02 of 03
you seek an exemption

The exemption would not only equal but enhance the safety of the rules in which we seek an 

exemption. We have been operating in Canada w/ Permission from Transport Canada for 3 

years and understand more about commercial UAV operations than anyone in North America. 

We operate on the highest level of safety, professionalism and have so daily for 3 years giving 

us more real world experience than any other commercial UAV company in North America. We 

follow the aviations guidelines with in or SFOCs and have to report to Transport Canada pre/

post every operation so we are all versed in how to perform under government jurisdiction, safety, and responsibility. Please see our SFOC requirements, manual, Emergency Response Plan, 

Risk Assessment Charts, etc which are attached.

• Any addition information, views, or arguments available to support your request. 

Please see attached PDF some of which where attached on our initial request for Section 333 

Exemption. 

RVRD_TransportCanada_UAV_Permits.pdf

RVRD FAA Exemption Application - Dec 2014.pdf

Sincerely, Jason Toth

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