510 W_ Lake Mary Blvd, Suite 100, Sanford, FL 32773 Office: (407_732_7710)
March 26, 2015

Department ofTransportation Docket Management System West Building Ground Floor, Room W12-140 1200 NewJersey Ave_ SE Washington, DC 20590-001 Re: Exemption Request Section 333 ofthe FAA ReformAct Dear Sir/Madam**-~~J~** '"·1 l**~** ." j : ;-'; - I 

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Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (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 forvarious industries, hereby applies for an exemption from the Federal Aviation Regulations {FARs) listed belowto allowforthe commercial operation of RKC's UAS in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein oras may be provided by the FAA as required by Section 333_

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# 12 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 TowerInspections and Monitoring • Real EstatePhotography • Surveying • Marine Photo & 

### Video • Agriculture • Special Events • Other RKC provides that all UAS flights thatwill occur over private orcontrolled 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: 14C.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 superiorto helicopters due tothe smaller devices cheaper equipment and personnel cost, reduced noise and, as such, a much smaller environmental impactwhich promotes public safety.

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# 13 RKC is petitioningfor exemption from the regulations set forth above to enable RKC to operate a DJI-5900 UAV ("DJI-5900"). This UAV has a built- in capabilityto limitthe height itflies above the ground, to limit the radius ofthe distance itflies from the operator and to exclude itfrom Class B, Cand Dairspace including a nofly zone feature. The DJI-5900 also has thefailsafe function ofthe 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 ofall command sticks from the controller will go to the center position and, using the on-board GPS system, thevehicle is designed to return to its pre-flight calibrated starting pointand will land safely. The above specifications meetwith the Model Aircraft Operating Standards as set below:



### • The petitioner will only operate its UAS in line ofsight ofa 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 ofthe national airspace system orthe public." • When flying a UAV within 5 miles ofan airport, airport operators will be notified and the operatorwill givethe right ofway to avoid flying in the proximity offullscale aircraft. • Maximum flight time for each operational flight will be 20 minutes. • Flights will be terminated at 25%battery power reserve should that occur priorto the 20 minute limit. • The UAV will be programmed so that it will not be operated at an altitude ofany 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 ofthe 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 PrivatePilot License and Third Class FAAMedical Certificate. • The UAS operatedbythe petitioner weighs less than 55 pounds, including the payload (i.e., camera, lens, and gimbal). • The UAV will operate at speeds ofno morethan 50 knots, can hover, and can simultaneously move vertically and horizontally. • Given the small size oftheUAS and the restricted sterile environment within which they will operateRKC's UAS operations adhere totheReform Act's safety requirements. Error! Unknown document property name.

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# 14

In furthersupport of RKC's requestfor the exemptions setforth herein, please find attached the Pilot Operating Handbookforthe DJI-5900 ("Handbook"). The Handbook includes the specifications ofthe DJI5900 UAS, as well as a pre-flight checklist and post-flight checklist. Underthe 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 forthe activities above-stated respecting atall times the space and privacy ofcitizens and propertywhilst keeping ourskies 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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# 15 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 maytechnically apply tothe operation ofthe 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 Pilotcertificate may actas Pilot in Command ofan aircraft for compensation or hire. RKC's proposed operations require thatthe 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 of61.113. 14 CFR 91.7 Prohibitsthe Operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated bythe FARs, this Regulation is inapplicable. 91.119(c) Minimum safe altitudes overotherthan 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 ofthe UAS would be photography orsurvey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500feet 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 aircraftwill be operated ata low altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or property on the surface. Therefore RKC maintains that, due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered ingranting 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 ofthe aircraft.The UAV will always fly below 400 feetAbove Ground level ("AGL") and will not need to maintain cruising altitudes in orderto prevent conflict with otheraircraft. An AGL altimeter measurement above thetakeoffpoint is transmitted via radio from the UAV on-board computer to the display screen held by the PIC, providing aconstantly updated AGL readout. 14 CFR 91.151 Fuel requirementsforflight in VFR conditions. The regulation provides that no person may begin aflight in an airplane under day-VFR conditions unless there is enough fuel to flytothefirst point ofintended landing and to fly afterthatfor at least30 minutes. RKC feels the intention of Error! Unknown document propertyname.

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# 16 this paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The UAV is battery operated and the maximum duration offlightfrom a single battery charge is 20 minutes with a 25% reserve. Since the aircraftwill neverfly more than 3,500 feetfrom the pointof intended landing, afull battery charge at launch will ensure thatthe reserve energy requirement ofthis paragraph will be met.

14 CFR Subpart E(91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations. The regulation provides thatthe operator is primarily responsible for maintainingthe 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 intentionthat the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service ."The PIC will ensure thatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed bythe PIC is limitedto 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 bythe manufacturer ortheir designated repair facility. The PIC will documentwork performed in accordance with 91.417. RKC feels that dueto the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.

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