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RedFly Pictures, LLC

128 East 2nd Street

Covington, KY 41011

christian@redflypictures.com

October 5, 2015

FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

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

Regulations 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)

Dear Exemption Manager,

Our team, RedFly Pictures, is submitting this Petition for Exemption for Unmanned Aircraft Systems 

operations. The RedFly team consists of myself with an extensive commercial real estate 

photography background, as well as a small team of commercial real estate developers and 

brokers.

As the RedFly team manager, I will be working with and overseeing individuals with a Sport Pilot 

License (“SPL”) and with more than 40 hours of Small Unmanned Aircraft Systems (“sUASs”) 

experience. The sUASs are better described as “drones” in common vernacular and in the media.

The closest FAA approved ground school course is located in Dayton, OH. I will complete this 

training in sync with approval of this request. We take sUAS operating skills, safety and education 

quite seriously. We have a thorough understanding of the current FAA regulations regarding sUASs 

and continue to monitor the updates regarding comprehensive sUAS operator regulations.

We submit this proposal for a waiver of the sections identified above in an effort to operate sUASs 

in use of commercial applications for real estate and marketing purposes, agricultural inspections, 

electrical engineering inspections, live sporting events and television production.

Operations

RedFly Pictures, LLC hereby agrees to be bound by the following sUAS drone safety operations and 

best practices:

1. The sUAS drones will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a sUASs Drone Pilot and/or Visual 

Observer.

3. Maximum total 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.
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4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet 

above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Drone Pilot and the Visual Observer.

6. The sUAS Drone Pilot will be Pilot in Command (PIC). If the PIC deems another operator to be 

qualified with the necessary skills to be PIC, that person can also be designated as PIC provided 

they have a minimum of 40 hours of flight time with the sUAS drone.

7. Flights will be operated at a lateral distance of at least 50 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have not signed a 

waiver in advance of the operation.

8. A briefing will be conducted in regard to the planned sUAS drone operations prior to each day’s 

production activities. It will be mandatory that all personnel involved with the operational duties of 

the flight within the boundaries of the safety perimeter be present for this briefing.

9. The sUAS Drone Pilot will obtain the consent of all persons involved in the filming and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation, and this radius 

may be reduced to 30 feet based upon an equivalent level of safety determination. With the 

advanced permission of the relevant Flight Standards District Office (“FSDO”), operations at closer 

range can be approved.

10. The sUAS Drone Pilot will file an FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the FSDO.

11. The sUAS Drone Pilot and Visual Observer will have been trained in operation of sUAS drones 

and receive up-to-date information on the particular sUAS drone to be operated.

12. The Visual Observer designated for any operation will have at least a class 2 medical 

certificate.

13. The Visual Observer and sUAS Drone Pilot will at all times be able to communicate by voice, 

radio or telephone.

14. Written and/or oral permission from the relevant property holders or property representatives 

will be obtained.

15. 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.

16. If the sUAS drone loses communications or loses its GPS signal, the sUAS drone is equipped 

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

autonomously.

17. The sUAS drone will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies.

18. A pre-flight and post-flight checklist sUAS drone examination will take place to detect any 

abnormalities.
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Craft and Safety

We currently own two (2) sUAS rotorcraft, weighing 55 or fewer lbs., including payload. We are 

utilizing two (2) of the most well-known sUAS drones – the DJI Inspire 1 and the DJI Phantom 3 

Pro.

Our safely calculated operations will insure that the sUAS drones will “not create a hazard to users 

of the national airspace system or the public.” The safety measures we have designed are 

implemented to insure that the sUAS will “not create a hazard to users of the national airspace 

system or the public” as per the Reform Act Section 333 (b).

The sUAS drones operate under normal conditions at speeds no higher than 50 knots. They are 

able to hover, move on the vertical and horizontal plane simultaneously, and will always operate 

within line of sight.

The sUASs operate electrically, carry no flammable fuel, have integrated GPS pilot systems, 

provide and store location-based information along with height AGL, speed and battery life. The 

sUASs have programmed no-fly zones for controlled airports, and provide direction of travel and 

distance from the pilot.

Education and Public Impact

As anyone who has been actively involved in the sUAS drone community knows, there is much to 

be done to inform the public about the unbelievable benefits of safe, responsible usage of sUAS 

drones. In the Cincinnati area, there is currently no FAA approved ground school course. I will have 

to travel to Dayton, OH to complete my training.

Upon receipt of our exemption, we will work with other local and regional sUAS pilots to create a 

Cincinnati Area focused training program that provides users a resource to gain safe operating 

skills, knowledge of safety procedures, and recommended best practices when operating their 

sUAS.

Our business is well-suited to safely perform integrated sUAS drone oprations. We are highly 

professional, have a great network and have already laid the foundation to move forward with this 

process. We want to paint the sUAS drone industry in a positive light and are certainly capable of 

doing so through safe, responsible and intelligent flight plans.

Sincerely,

Christian Vetter