August 5th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Radio Control Aerial Vehicles (RCAV) for an Exemption Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012

To Whom it May Concern:

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

C.F.R. Part 11, RCAV LLC ("RCAV ") hereby applies for an exemption from the Federal Aviation 

Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles 

(i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting controlled flights for aerial 

photography and videography visual video inspection of real-time conditions of residential, commercial, 

industrial, military, public and private buildings, facilities and structures. 

 

This petition for exemption is created based on information outlined in this Petition for Exemption, 

as well as but not limited to these accompanying RCAV documents; 

1. Flight Operations Manual;

2. Operations Manuals

(Collectively referred to as “Operations Manuals")

3. User Guide and;

4. User Manual 

(Collectively referred to as "Manufacturer's Manual").

1

The RCAV submits these as well as other RCAV supporting materials as confidential documents 

pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary

information that the RCAV has not and will not share with others. Additionally, these documents contain 

operating conditions and procedures that are not generally available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. §552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
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This Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Aerial Photography for Commercial Purposes

B. Aerial Photogrammetry, Property and Building Mapping, Sensing and Surveys

III. Relevant Statutory Authority

IV. RCAV’S Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and

Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

 L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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I. DESCRIPTION OF PETITIONER

Radio Controlled Aerial Vehicle Services, (RCAV), uses rotary and fixed winged vehicles to provide 

airborne sensing, mapping, photography, videography services, and secondary services with rotary/fixed wing 

unmanned aerial vehicle (UAV). RCAV also conducts accessories sales of UASs and related equipment. 

RCAV’Ss business focus is in photography and videography providing services to government, private and 

commercial business for their needs. The approval of exemptions for RCAV will allow commercial 

operations of UAVs for airborne photography, videography, mapping, and contracted mapping services. 

Principal Robert T. Jenkins owner/operator holds an ATP /Flight Engineer certificate with over 6,000 hours 

of flight time operation in the (NAS). Jenkins also has more than 14 years working with a major aerospace 

company providing flight planning services, working in software development and providing Flight 

Management Systems. 

The contact information for Petitioner is as follows: 

Robert. T. Jenkins

RCAV Unlimited 

328 White River Dr.

Pacific, WA 98047

Phone: (253) 335.6677

Email: theedge26@comcast.net

II. DESCRIPTION OF PROPOSED OPERATION

RCAV seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Inspire 1, 

Phantom 1, QR X350 Pro Quadcopter, and the Anaconda, Skywalker X (The UASs). All UAS 

operations will occur under tightly controlled conditions on private property where RCAV has received 

permission to operate from the landowner, controller or authorized representatives. The proposed UAS 

operations will be conducted in accordance with the conditions and limitations of this Petition for 

Exemption and RCAV’S Operations Manuals. As detailed in RCAV’S Operations Manuals, all UAS

operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the

operator, in uncontrolled airspace, and will occur at least 5 nm away from an airport. Moreover,

RCAV’S Operations Manuals incorporate redundant safeguards to assure that the aircraft does not travel 

outside the controlled area of UAS operations, including GPS "geo-fencing" technologies.

A. Aerial Photography 

RCAV seeks to use small UASs for the purpose of conducting aerial videography and 

photography to record images and gather industrial, military, and commercial information. RCAV has 

tailored its operations to meet the requirements established by the FAA in prior grants of exemptions

authorizing commercial use of UAS in photo and video production including:
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 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Astraeus Aerial (Exemption No. 11062) 

 Alan D. Purwin (Exemption No. 11161) 

 Flying-Cam, LLC (Exemption No. 11080)

 Picture Factory, Inc. (Exemption No. 11178)

 Dronair Solutions (Exemption No. 11671)

All UAS photo and video production including operations will be conducted on private property in a

controlled area, away from spectators and persons not involved in the photography and videography 

sessions. All UAS photo and video shoots will be conducted during daylight hours, VFR conditions, at 

altitudes below 400' AGL. As set forth below, RCAV’S operations provide a superior level of safety and 

quality compared to performing the same filming work using conventional fixed-wing aircraft or

helicopters.

B. Aerial Photogrammetry, Property and Building Mapping and Surveys 

RCAV seeks to use small UASs for the purpose of conducting controlled flights for aerial 

photography and videography visual video inspection of real-time conditions of residential, commercial, 

industrial, military, public and private buildings, facilities and structures. Traditional methods of building 

and property video capture and surveying including accessing areas with power lines, steep and uneven 

rooftops, tight spaces, heating and air-conditioning equipment, and chimneys which expose survey and 

photogrammetry professionals to uncalled risk, physical harm, serious injury or death. Photographers and 

professional surveyors in most situations are required to climb towers and perform elevated work that 

exposes them to the risk of dangerous falls, electrocution or other work-related harm, injury or death. In 

addition, photographers and professional surveyors are exposed to uneven and unstable geography and

proximity to equipment which involves a risk of exposure to radiation or mechanical hazards associated 

with industrial sites and construction facilities. The use of small UAS mitigates these hazards for and is 

ultimately a much safer method of performing these and most other types of inspections for insurance risk 

assessment.

Small UAS inspection is also safer and is basically impossible to perform low altitude inspections 

with traditional manned aircraft. Conventional operations using rotorcraft and fixed-wing aircraft in low 

level operations present risks associated with vehicles weighing thousands of pounds and carrying large

amounts of fuel. It is important to note that the use of small UAS in this area will not only be safer and 

more cost effective, but the quality of collected data and information is far superior. Small UAS

inspection is more reliable, and allows for the collection, dissemination, and storage of visual and other

sensory data with greater precision and duration. Small UASs are also capable of accessing and

inspecting areas that would otherwise be inaccessible to humans or cannot be completed with 

conventional aircraft.
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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant 

to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to 

operate in the National Air Space ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in

the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. §

44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). A party

requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a 

whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal 

to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. RCAV’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION

333 OF THE REFORM ACT 

The small UAS operations proposed by RCAV in this Petition for Exemption qualify for expedited

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors

are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the UASs due to its size weight, speed,

and operational capability.
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 The UASs has been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

 The UASs weighs less than 55 pounds, including payload.

 The UASs will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. This 

information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall safety and 

predictability of the system. If connection to the remote control or ground control station is lost, failsafe

systems will permit the UAS to return to a predetermined location and safely land without injury or 

damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency requirements. 

The operating frequency for The UASs are 2.4 GHz & 5.8 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely

exceed 6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The

difference in weight between The UASs and a helicopter significantly reduces the potential harm to the

participating and non- participating individuals or property in the event of an accident or incident. In

addition, the risk to the onboard pilot and camera operator is eliminated.

_______________________

2

See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, 

Corp. (Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); 

Grant of Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156).
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B. Approval is Warranted Based on the Operational Restrictions Set Forth in RCAV’S Operations

Manuals

RCAV’S Operations Manuals and the Manufacturer's Manual for the selected UASs will contain 

the procedures and limitations necessary to safely and successfully perform the operations specified in 

this Petition for Exemption. To assist the FAA in making a safety assessment of RCAV proposed 

operations, below is a summary of operational limitations and conditions that RCAV will adhere to, and 

which will ensure an equivalent or higher level of safety to operations conducted under current regulatory

guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight operation.

3. All UASs operated under the Grant of Exemption will be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 

14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct 

the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. The

PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which

the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the RCAV’S

Operations Manuals. 
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The Operations Manuals will be maintained and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in the Grant of Exemption and RCAV’S

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and 

must be followed. Otherwise, RCAV shall follow the procedures outlined in their Operations Manuals.

10. RCAV may update or revise its Operations Manuals. Revisions will be tracked and a revised copy

of the Manual will be provided to the Administrator upon request. RCAV will also present an updated and

revised Operations Manuals if it petitions for extension or amendment to its Grant of Exemption. If an

update or revision would affect the basis upon which the FAA grants the exemption, RCAV will seek an 

amendment to its Grant of Exemption. RCAV will contact the FAA’s UAS Integration Office (AFS-80) if

questions arise regarding updates or revisions to the operating documents.

11. RCAV’S Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather 

conditions) there is enough power to fly to the first intended point of landing, and assuming normal 

cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using The UASs will be limited to 40 

minutes or the amount of time the UAS can be flown and still maintain a reserve battery power of no less 

than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable 

controlled airspace without prior written authorization and approval from the FAA. In the event the

structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above

the highest point on the structure, and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons 

leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or;
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b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such

vessels, vehicles or structures has granted permission and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

16. The UA 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 PIC.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current FAApublished 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 RCAV COA. The letter of

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

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. 

The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or

equipment, not already covered in the relevant sections of the operating documents. The PIC shall not 

operate the UAS if the inspection reveals a condition that affects the safe operation of the UAS until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The

ground control station shall be included in the preflight inspection. All maintenance and alterations must 

be properly documented in the UAS records as required by RCAV’S Operations Manuals.

19. RCAV will carry out its maintenance, inspections, and record keeping requirements in accordance

with the Operations Manuals. Maintenance, inspection, and alterations will be noted in the UAS records, 

including total time in service, description of work accomplished, and the signature of the authorized 

person returning the UAS to service.

20. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight

characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight in

accordance with RCAV Operations Manuals. The PIC who conductsthe functional test flight must make an

entry in the UAS aircraft records of the flight. The requirements and proceduresfor a functional test flight

and UAS record entry shall be included in the RCAV’S Operations Manuals.
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21. The UAS will be operated and maintained according to the Manufacturer's Manuals and any

required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on 

RCAV’S Operations Manuals.

23. RCAV will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level 

and potential transponder requirements.

24. 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.

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or

emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner

consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a UAS 

rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner

consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 logged hours as 

UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and 

thirty take-offs and thirty landing in the preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, 

hang gliders, etc.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAs will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control of the

UA will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act,

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

3

RCAV seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using

a UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety

better than or equal to the rules from which exemption is sought.

4

 ________________________________

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716). 

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would

provide a level of safety at that provided by the rule from which you seek exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, 

however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the 

requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

RCAV’S use of The UASs is safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV (A), The UASs

weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of 50 

knots. UAS is also equipped with safety features that will allow Petitioner to operate the UAS safely after 

experience certain in-flight contingencies or failures.

6 7

 __________________________________

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The UASs have the capability to operate safely after experiencing certain in-flight contingencies or

failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also able to

respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, predictable,

automated flight maneuver, and manual flight control functionality as a backup. These safety features

provide an equivalent level of safety compared to a manned aircraft performing a similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

The UASs’s can be operated entirely by a touch-screen, map-based interface. This means the operator only 

needs to command the system where to go, and the system does all the flying for the operator. The UASs

can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a 

map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones or 

maximum flight ranges and altitudes so the system cannot enter areas

{footnote continued}
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Additionally, The UASs carry neither pilots nor passengers, carry no explosive materials or flammable 

liquid fuels, and operate exclusively within the parameters stated in RCAV’S Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety requirements, to provide security for the area

of operation. RCAV will also provide the FAA with advance notice of all operations via NOTAMs as

required by the applicable COA. In all cases, operation of The UASs under the proposed conditions will be

at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, The UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In addition, no 

sense-and-avoid technology is necessary for The UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.

9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that Company’s small UASs would otherwise require certification 

under Part 27, Petitioner seeks an exemption from Part 27's airworthiness same reasons standards for the 

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

__________________________

{continued from previous page} 

deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent

fault handling which allows The UASs to detect a system fault while in the air and automatically fly back to

its takeoff location and land. Faults that can be detected include: loss of communication; exceeding pre-set

wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate.

At any point if the operator is not explicitly commanding the system to move, the system automatically 

holds its GPS position. The flight control system employs not only GPS positioning but a variety of sensors

including sonar, barometric pressure, temperature, wind speed and othersto ensure stability so long as wind

thresholds are not exceeded. Also a flight termination link – to prevent a 'fly away' or other potentially

dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id. airworthiness standards for the same reasons identified in the request for exemption from 14

C.F.R. Part 21, Subpart H, supra.
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

RCAV seeks an exemption from the aircraft marking and identification requirements contained in 

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance

with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not

less than two inches nor more than six inches high, the words "limited," "restricted," "light-sport,

"Experimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin,

fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by RCAV will bear N-number markings that are as large as practicable in accordance

with 14 C.F.R. Part 45, Subpart C.

11

____________________________

10 FAA Docket No. FAA-2014-0352.

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
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D. C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

RCAV seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft 

with an airworthiness certificate, which the UAS to be operated under this grant of exemption will not

have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service

Bulletins. Further, as required by RCAV’S Operations Manuals, the PIC will conduct a pre-flight 

inspection of the UAS and all associated equipment to account for all discrepancies and/or inoperable

components. Maintenance will be performed and verified to address any conditions potentially affecting

safe operation of the UAS and no flights will occur unless, and until, all flight critical components of the

UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be 

conducted following the replacement of any flight-critical components. As required by RCAV’S

Operations Manuals, the PIC who conducts the functional test flight will make an entry in the UAS aircraft 

records of the flight.

RCAV’S Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control 

surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including

batteries), ground control station, hazard accessories, and spare parts. Further, RCAV’S Operations 

Manuals also includes procedures to document and maintain a record of the UAS maintenance, 

preventative maintenance, alterations, status of replacement /overhaul component parts, and the total time 

in service of The UASs used under this Grant of Exemption. As a whole, the maintenance and inspection 

procedures required in RCAV’S Operations Manuals ensure that an equivalent or higher level of safety will

be achieved.
U.S. Department of Transportation

August 5th, 2015

Page 16

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

RCAV seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from 

flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo 

for hire. In this case, while The UASs will be operated as part of a commercial operation, it carries neither

passengers nor cargo for hire. In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the

unique characteristics of UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical 

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions RCAV has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial. RCAV will operate on private property away from persons and property not

involved in the operation. RCAV will also obtain an ATO issued COA prior to conducting any operations 

under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 

A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, RCAV will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will

have experience not only in UAS operations generally but have logged flight time in the specific make and

model used for the operations before they are permitted to participate in commercial flights on behalf of

RCAV. The pilot qualification, training, and currency requirements in the Operations Manuals ensure that 

RCAV’S pilots are competent and proficient in the UAS they are operating. RCAV’S training and 

qualification requirements are consistent with those contained in prior FAA Section 333 Grants of 

Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety.

_______________________

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

August 5th, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for The UASs, RCAV seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at

the cabin or cockpit entrance so that it is legible to passengers or crew.

Given the small size and configuration of The UASs, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and the UAS has 

no cabin or cockpit.

__________________

13

See id. at 13-14, 22 
U.S. Department of Transportation

August 5th, 2015

Page 18

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be

achieved by ensuring that the pilot has access to the documents at the ground control station from which he

or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

RCAV seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the RCAV’S Operations Manuals and 

the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the RCAV’S Operations Manuals, including checklists covering

Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather,

flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency

landing areas—before initiation of flight. RCAV’S Operations Manuals and the Manufacturer's Manual

will be kept at the ground control station and will be accessible to the PIC at all times while operating the 

UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

_______________________________________

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
U.S. Department of Transportation

August 5th, 2015

Page 19

RCAV seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their

design, do not have functional dual controls. Instead, flight control is accomplished through the use of a

device that communicates with the aircraft via radio communications. Accordingly, an exemption will be 

required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of The UASs that RCAV intends to use, an equivalent level of safe

training can still be performed without dual controls because no pilot or passengers are aboard the UAS, 

and as required by the RCAV’S Operations Manuals, all persons will be a safe distance away in the event 

that the UAS experiences any difficulties during flight instruction. Moreover, as required by the RCAV’S

Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a

whole, the safety procedures provided for in RCAV’S Operations Manuals ensure that the proposed UAS

operations provide an equivalent or higher level of safety than that provided by the flight instruction 

regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

RCAVrequests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less 

than those minimum altitudes when it can be operated "without hazard to persons or property on the

surface," provided that "each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to occur below 

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 

feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and 

within 50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the

Pilot and/or Observers(s) may need to be less than 500 feet away from the UAS.

_________________________

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a

tree Aerial (FAA-2014-0534 at 15)
U.S. Department of Transportation

August 5th, 2015

Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with The UASs, any risk associated with these

operations is far less than those that presently exist with conventional aircraft. An equivalent level of 

safety will be achieved given the size, weight, and speed of The UASs, as well the controlled location 

where the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be 

restricted to 400 feet AGL or below, or when inspecting a structure whose height exceeds 400 feet AGL, 

within 100 feet above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, The UASs will be operated in a restricted area, and all

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless 

that person is in a position where he or she is shielded from the UAS and any possible debris resulting from 

UAS failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person

within 500 feet of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet 

away from vehicles or structures unless the property owner/controller has granted permission and the PIC 

has made a safety assessment of the risk of operating closer to those objects and, operations near the PIC or

Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in RCAV’S

Operations Manuals will ensure operations can be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

RCAV seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure An exemption is required to the extent that The UASs do not 

have a barometric altimeter, but rather a GPS altitude read out.

__________________________

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such

protection. The operator must also ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA,

flight operations must cease immediately. When considering how to immediately cease operations, the

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that

operations may be conducted closer than 500 feet to vessels, vehicles and structures when the 

owner/controller of any such vessels, vehicles orstructures grants permission for the operation and the PIC

makes a safety assessment of the risk of operating closer to those objects and determines that it does not 

present an undue hazard.”
U.S. Department of Transportation

August 5th, 2015

Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121

 can be achieved in circumstances where: (1) The UASs will be operated below 400 feet AGL or 

below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the 

operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation 

point is established for the PIC to confirm accuracy of the onboard GPS.

18

The UASs that RCAV intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by RCAV’S Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, The UASs RCAV intends to use, and the safety mitigation procedures contained in the

Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of 

Exemption to the requirements of §191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

RCAV requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and,

assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

 ________________________

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more

than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation

August 5th, 2015

Page 22

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning the UASs flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered 

that the UAS batteries for The UASs provided provide approximately 20 minutes of powered flight (with 

payload) and provided battery level and battery time remaining in minutes and seconds to the PIC.19 The 

FAA also considered the fact that the UASs operating manual states: “start every flight with a fully 

charged battery in the aerial vehicle”, and that in the event that the UAS should run low on power, the 

PIC will be alerted and can land The UASs as soon as possible. Like the VDOS Grant of Exemption, 

RCAV use of the DJI S1000, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA 

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions could 

be achieved by prohibiting the PIC from beginning a flight with The UASs unless (considering wind and 

forecast weather conditions), there was enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining. RCAV will adhere to this limitation 

for The UASs flights. 

The UASs includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS to a groundbased-on-screen display.20 As required by RCAV’S Operations Manuals, the PIC will promptly fly the 

UAS back to the home launch location or pre-determined abort location where the UAS may safely land, 

while still maintaining a minimum of 25% reserve battery power. RCAV submits that the procedures 

requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the 

requirement that flights only be conducted within a secure, isolated area, using a UAS weighting less than 

25 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide 

an equivalent or higher level of safety to that provided by the regulations from which exemption is 

sought. 

 _________________________

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The UASs ground control station displays, The UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading 

and orientation relative to the UAS. 
U.S. Department of Transportation

August 5th, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

RCAV will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting RCAV’S Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe 

working environments such as those proposed in this Petition. Granting this Petition for Exemption helps 

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk harm or serious injury to inspecting engineers. Traditional methods of building and property 

video capture and surveying including accessing areas with power lines, steep and uneven rooftops, tight 

spaces, heating and air-conditioning equipment, and chimneys which expose survey and photogrammetry 

professionals to uncalled risk, physical harm, serious injury or death. Photographers and professional 

surveyors in most situations are required to climb towers and perform elevated work that exposes them to 

the risk of dangerous falls, electrocution or other work-related harm, injury or death. In addition,

photographers and professional surveyors are exposed to uneven and unstable geography and proximity to

equipment which involves a risk of exposure to radiation or mechanical hazards associated with industrial 

sites and construction facilities. The use of small UAS mitigates these hazards for and is ultimately a

much safer method of performing these and most other types of inspections for insurance risk assessment.

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft weighing 

thousands of pounds, carrying crew in addition to flammable fuel, The UASs carry no passengers or 

crew. Further, in the unlikely event of an accident, RCAV small battery powered UASs presents 

significantly less danger to persons on the ground when compared to operations by conventional manned 

aircraft.21 As Petitioner's UASs are battery powered, the public will also benefit from a reduction in 

harmful emissions associated with conventional aircraft performing in the same functions proposed 

herein. 

_____________________________

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh 

less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the 

aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard 

pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming 

operation." 
U.S. Department of Transportation

August 5th, 2015

Page 24

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to video producers, UASs 

provide an additional tool for the aerial photo, video and inspection industry, adding a greater degree of 

flexibility, which supplements the current capabilities offered by manned aircraft.22

VIII. PRIVACY 

All RCAV UAS operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

IX. FEDERAL REGISTER SUMMARY 

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:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) 

& (b).

The exemption will enhance safety by reducing risk to the videography, photography and 

inspection-survey crew, the property owners, residents, and the general public of potential substantial 

hazards from those associated with performing equivalent aerial production work performed by with 

conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

RCAV Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 

2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation 

within VLOS and national security. The proposed UAS operations will benefit the public as a whole by 

improving safety and reducing risk by alleviating human exposure to dangers of injury or death. In 

consideration of the foregoing, this Petition for Exemption provides the FAA with more than adequate 

justification for granting the requested exemptions allowing RCAV to use small UASs for the purpose of 

conducting controlled flights for aerial photography and videography visual video inspection of real-time 

conditions of residential, commercial, industrial, military, public and private buildings, facilities and 

structures. 

_______________________

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

August 5th, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted,

Robert T. Jenkins

Radio Control Aerial Vehicles (RCAV) 

328 White River Dr.

Pacific, WA 98047

Should you have any questions, or if you need any additional information to support the requested 

exemptions, please contact the undersigned at:

 RCAV Unlimited

Phone: (253) 335.6677

Office: (253) 394.4316

Email: theedge26@comcast.net

(The following attached items contain and commercial information exempt from disclosure under the 

Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 

C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols 

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals