510 W_ Lake Mary Blvd, Suite 100, Sanford, FL 32773 Office: (407_732_7710) 

March 26, 2015 

Department of Transportation 

Docket Management System 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave_ SE 

Washington, DC 20590-001 

Re: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir/Madam 

-~~J~ '"·1 l ~ ." j : ;-'; - I p ,.-._ 0 I :.:> : 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act''), and 14 

CF_R_ Part 11-Federal Aviation Regulations, RKC Media Solutions, LLC ("RKC"), an aerial video company 

operating a small Unmanned Aircraft System/Vehicle (hereinafter referred to as "UAS" or "UAV") 

equipped to conduct aerial photography and survey for various industries, hereby applies for an 

exemption from the Federal Aviation Regulations {FARs) listed below to allow for the commercial 

operation of RKC's UAS in airspace regulated by the Federal Aviation Administration (FAA) so long as such 

operations are conducted with and under the conditions outlined herein or as may be provided by the FAA 

as required by Section 333_ 

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The requested exemption would permit RKC to provide services to its consumers interested in aerial data 

capture using a small advanced UAV in the following areas: 

• Communication Cellular Tower Inspections and Monitoring 

• Real Estate Photography 

• Surveying 

• Marine Photo & Video 

• Agriculture 

• Special Events 

• Other 

RKC provides that all UAS flights that will occur over private or controlled access property will be done 

with the property owner's prior consent and knowledge and that only people who have consented or 

otherwise have agreed to be in the area where filming will take place will be filmed. 

Additionally, RKC's UAS will be flown by persons holding a FAA Private Pilot License with Class Ill Medical 

Certificate. 

Regulations From Which the Exemption Is Requested: 

14 C.F.R. 61.113(a) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.119 (c) 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a)(1} 

14 C.F.R. (91.401- 91.417) 

Unmanned Aircraft System 

UAVs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and 

personnel cost, reduced noise and, as such, a much smaller environmental impact which promotes public 

safety. 

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RKC is petitioning for exemption from the regulations set forth above to enable RKC to operate a DJI-5900 

UAV ("DJI-5900"). This UAV has a built- in capability to limit the height it flies above the ground, to limit 

the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace 

including a no fly zone feature. The DJI-5900 also has the failsafe function of the autopilot system which 

means when the communication between the Main Controller and the transmitter is disconnected or any 

other error is detected by the on-board flight controller system, the outputs of all command sticks from 

the controller will go to the center position and, using the on-board GPS system, the vehicle is designed to 

return to its pre-flight calibrated starting point and will land safely. 

The above specifications meet with the Model Aircraft Operating Standards as set below: 

• The petitioner will only operate its UAS in line of sight of a pilot and/or observer 

and will operate at sites that are a 'sufficient distance' from populated areas within 

the sterile area described in the FOPM. Such operations will insure that the UAS 

will "not create a hazard to users of the national airspace system or the public." 

• When flying a U A V within 5 miles of an airport, airport operators will be notified 

and the operator will give the right of way to avoid flying in the proximity of fullscale aircraft. 

• Maximum flight time for each operational flight will be 20 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to 

the 20 minute limit. 

• The UA V will be programmed so that it will not be operated at an altitude of any 

higher than 400 feet AGL, and not more than 200 feet above an elevated platform 

from which filming is planned. 

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

Observer, and the Camera Operator. 

• The UAS PIC's (Pilot in Command) will be an FAA licensed airman holding a FAA 

Private Pilot License and Third Class FAA Medical Certificate. 

• The UAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e., camera, lens, and gimbal). 

• The UAV will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size ofthe UAS and the restricted sterile environment within which 

they will operate RKC's UAS operations adhere to the Reform Act's safety 

requirements. 

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In further support of RKC's request for the exemptions set forth herein, please find attached the Pilot 

Operating Handbook for the DJI-5900 ("Handbook"). The Handbook includes the specifications of the DJI5900 UAS, as well as a pre-flight checklist and post-flight checklist. 

Under the requested exemption, RKC will ensure that all operators have completed a UAS education and 

training program including all applicable regulations and guidance documents; including aeronautical 

background information such as charts, NOTAMS and Aircraft Circulars; Radio Communications 

Procedures; Basic Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe 

Operating Procedures. 

RKC respectfully requests exemption under Section 333 to enable RKC to operate efficient, limited, lowrisk commercial UAVoperations for the activities above-stated respecting at all times the space and 

privacy of citizens and property whilst keeping our skies safe. 

Sincerely 

Randy C. Zachary, President 

RKC Media Solutions, LLC 

520 W. Lake Mary Boulevard 

Suite 100 

Sanford, FL 32773 

(407) 732-7710 

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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

RKC Media Solutions, LLC requests an exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of the UAV System: 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and 

limitations. 

The regulation provides that no person that holds a Private Pilot certificate may act as Pilot in Command of an aircraft 

for compensation or hire. RKC's proposed operations require that the PIC must hold at least a Private Pilot Certificate 

issued by the FAA and, since the aircraft cannot carry passengers or property, RKC feels it meets the intent of 61.113. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 

91.119(c) Minimum safe altitudes over other than congested areas: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since 

the typical mission of the UAS would be photography or survey of persons, vessels, vehicles or structures it would be 

necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons 

where permission has been obtained and careful pre-planning has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the 

surface. Therefore RKC maintains that, due to the small size of the UAS, the hazard to persons, vehicles and structures is 

minimal compared to manned aircraft, which should be considered in granting the exemption. 

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The UAV 

will always fly below 400 feet Above Ground level ("AGL") and will not need to maintain cruising altitudes in order to 

prevent conflict with other aircraft. An AGL altimeter measurement above the takeoff point is transmitted via radio 

from the UAV on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough 

fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. RKC feels the intention of 

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this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAV is battery operated and 

the maximum duration of flight from a single battery charge is 20 minutes with a 25% reserve. Since the aircraft will 

never fly more than 3,500 feet from the point of intended landing, a full battery charge at launch will ensure that the 

reserve energy requirement of this paragraph will be met. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations. 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, 

including compliance with parts 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 43. 7" after 

maintenance and inspection. It is RKC's intention that the PIC perform maintenance and inspection of the aircraft and 

"be authorized to approve the aircraft for return to service . "The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance 

performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and 

updating software and firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. RKC 

feels that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

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