September 14, 2015

Exemption No. 12842

Regulatory Docket No. FAA−2015−2091

Mr. Robin Stoz 

RRS Aerial Media, LLC

14134 Coquina Bay Avenue

Corpus Christi, TX 78418

Dear Mr. Stoz:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on June 4, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of RRS Aerial Media, LLC (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct flight training, news services, real estate photography and videography, 

construction, waterway, land planning, agriculture, and education photography, oil and gas 

industry infrastructure inspection and demonstration flights.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are a DJI 550 Flame Wheel, DJI S1000+, 3DRobotics 

Iris+, 3DRobotics X8+, 3DRobotics, X8-M, 3DRobotics Aero-M, and PrecisionHawk.
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In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, RRS Aerial Media, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, RRS Aerial Media, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI 550 Flame 

Wheel, DJI S1000+, 3DRobotics Iris+, 3DRobotics X8+, 3DRobotics, X8-M, 

3DRobotics Aero-M, and PrecisionHawk when weighing less than 55 pounds 

including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
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limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must 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 must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, 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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Petition ofRRS Aerial Media, LLC for Exemption Pursuant to Section 333 of the FAA 

Modernization and Refonn Act of2012. 

To Whom It May Concern: 

Pursuant to Section333 of the FAA Modernization and Reforn1 Act of2012 and 14 CFR Part 11, 

RRS Aerial Media, LLC, hereby applies for an exemption from Federal Aviation Regulations 

(F ARs) identified below, to allow commercial operations of small umnanned aerial system (i.e., 

sUAS). 

This exemption is in accordance with protocols outlined in this petition for exemption, the 

enclosed the UAS manufacturer's operations and/or instructions manual, UAS User's Manuals, 

UAS Quick Start Guides, and any other requirements established by the FAA pursuant to Section 

333 of the Refonn Act. 

This exemption would pennit commercial operation by RRS Aerial Media, LLC, which uses all 

versions ofDJI 550 Flame Wheel, DJI S1000+, 3DRobotics Iris+, 3DRobotics X8+, 3DRobotics 

X8-M, 3DRobotics Aero-M, and PrecisionHawk to conduct sUAS flight training, support to 

news services, real estate photography and videography, construction, waterway and land 

planning and use photography, agriculture, education, oil and gas industry infrastructure 

inspection and demonstration flights. 

RRS Aerial Media, LLC's operation under the exemption will be subject to strict operating 

requirements and conditions to ensure an equivalent level of safety to currently authorized 

operations using manned aircraft and under conditions as may be modified by the FAA as 

required by Section 333.2 

RRS Aerial Media, LLC will be operated under controlled VFR conditions at low altitude in 

airspace that is pennitted in accordance with RRS Aerial Media, LLC's approved Certificate of 

Authorization (COA). They will operate the sUAS's with pilots who are current and qualified 

with a FAA Pilot Certificate and only after completing RRS Aerial Media, LLC's training 

program. Finally, when operating within controlled airspace, the controlling FAA ATC will 

approve the airspace in which the sUAS will operate in advance. 

RRS Aerial Media, LLC respectfully submits this request for an exemption because it operates 

sUAS's. The operations ofRRS Aerial Media, LLC will be conducting will be in lieu of 

comparatively hazardous operations now conducted with fixed wing and rotary conventional 

aircraft. The FAA can have confidence that the operations will be conducted at an equivalent 

level or greater level of safety. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities under Section 
333(c) of the Refonn Act to "establish requirements for the safe operation of such aircraft 

systems in the national airspace system." 

For your convenience, RRS Aerial Media, LLC has organized this Exemption request as follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations 

V. Regulations From Which Exemption is Requested 

VI. Public Interest 

VII. Privacy 

VIII. Federal Registry Summary 

IX. Conclusion 

I. Petitioner's Description 

RRS Aerial Media, LLC., headquartered in Corpus Christi, Texas, is a company that provides 

sUAS flight training, support to news services, real estate photography and videography, 

construction, waterway and land planning and use photography, agriculture, education, oil and 

gas industry infrastructure inspection and demonstration flights in a compliant and safe 

environment. RRS Aerial Media, LLC plans on providing a wide range of services as the sUAS 

market expands. 

The management at RRS Aerial Media, LLC has over 50 years of experience in aviation and 

over 7 years combined experience operating sUAS/UAS's. All RRS Aerial Media, LLC pilots 

hold CPL or ATP certificates in fixed-wing or rotary-wing. 

The contact infonnation for Petitioner is as follows: 

RRS Aerial Media, LLC. 

14134 Coquina Bay Ave 

Corpus Christi, TX 78418 

II. Relevant Statutory Authority 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) ofthe 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 Refonn Act, the FAA Administrator is to consider whether certain unmanned 

aircraft systems may operate safely in the National Airspace ("NAS") before completion of the 

fom1al UAS rulemaking, 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 ofthe UAS within the visual line of sight ofthe operator. 

If the Secretary detennines that such vehicles "may operate safely in the National Airspace 

System, the Secretary shall establish requirements for the safe operation of such aircraft in the 

National Airspace System". 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

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

the public interest. 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). 

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

statutory authority, by its tem1s, includes exempting civil aircraft, as the term is defined under 

40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service: 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections. 

III. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Refonn Act. Each of the statutory criteria and other relevant factors are 

satisfied. 

The proposed operations would pennit RRS Aerial Media, LLC the use of smallUAS under 

controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that 

(3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft 

are used to accomplish the same purpose. 

RRS Aerial Media, LLC uses UASs that are multirotor and fixed wing airplanes, weighing less 

than 55 pounds including payload. They operate, under normal conditions, at speeds not to 

exceed 50 mph. The multirotor has the capability to hover and move in the vertical and 

horizontal plane. RRS Aerial Media, LLC's UASs will operate in line of sight, during daylight 

hours, and will only operate within a sterile area. RRS Aerial Media, LLC will operate at or 
below 400 feet AGL and will file a NOT AM for each flight operated in controlled airspace that 

is required. All required permissions and pennits would be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies prior to operating a sUAS. 

Given the small size of the sUAS's involved and the restricted sterile enviromnent within which 

they will operate, this RRS Aerial Media, LLC's exemption falls within the zone of safety and 

demonstrate an equivalent level of safety, in which Congress desired the FAA to pennit 

commercial UAS operations by exemption pending completion of formal rulemaking. Also, due 

to the size ofthe sUAS's and the confined area in which these UAS's will operate, approval of 

the application presents no hazard in the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in the 

public interest. 

IV. Description of Proposed Operations 

To assist the FAA in its safety assessment ofRRS Aerial Media, LLC's proposed sUAS 

operations, below is a summary of operational limitations and conditions that will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory guidelines: 

1. The sUAS will weigh less than 55 pounds. 

2. Flights will be operated within line of sight of the PIC and/or visual observer. 

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the sUAS can be flown and still maintain a reserve battery power or fuel quantity of 

no less than 25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or who 

have not signed a waiver in advance of the operation. 

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a 

Visual Observer when operating with the use of FPV equipment. Additional 

crewmembers may consist of a Pilot and a Camera Operator. 

7. The sUAS Pilot in C01mnand will be an FAA licensed airman with at least a private 

pilot's certificate, second class medical, and a current check required by14 CPR Part 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

8. RRS Aerial Media, LLC will designate a Pilot in Command ("PIC") for each mission. 
9. The sUAS will operate only within a confined sterile area. 

10. Prior to the operations at a particular location, a site inspection will have been 

conducted. On the day of the mission the management person with operational control 

and the PIC will concur on dispatching of the mission. 

11. A briefing will be conducted in regard to the planned sUAS operations prior to each 

day's missions. It will be mandatory that all personnel who will be perfmming duties 

within the boundaries of the sterile area be present for this briefing. 

12. RRS Aerial Media, LLC crew will use the checklist and callouts. 

13. All sUAS's will be maintained in compliance with the manufacturer's and Company 

guidelines. 

14. In the event of an accident involving an RRS Aerial Media, LLC sUAS, the PIC will 

cease operations and report the accident to the NTSB and AFS-80. 

15. Pilot in Command and Visual Observer will at all times be able to communicate by 

vmce. 

16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational 

Personnel will have been trained and tested in accordance toRRS Aerial Media, LLC's 

UAS Aircraft Training Manual. 

17. All required permissions and pennits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate govermnental 

agencies. 

18. In compliance with the approved Waiver, RRS Aerial Media, LLC management will 

submit a written "Plan of Activities" to the local Flight Standards District Office (FSDO) 

having jurisdiction over the area of proposed filming three days in advanced of 

operations during film or movie productions. 

19. If the sUAS loses communications signal, the sUAS will have the capability to return 

to a pre-determined location within the Sterile Area and land. 

20. Contingency plans will be in place to safely tenninate flight if there is a loss of 

communication between the pilot and the observer. 

21. The sUAS has the capability to abort a flight in case ofunpredicted obstacles or 

emergencies. 

22. RRS Aerial Media, LLC, will assure no individuals' privacy is violated. 
23. A TC will be contacted prior to operating in airspace other than G. 

V. Regulations From Which Exemption is Requested 

A. 14 CFR § 91.103: Preflight Action 

B. 14 CFR § 91.113: Right-of-Way Rules 

C. 14 CFR § 91.119 (c): Minimum Safe Altitudes 

D. 14 CFR § 91.121: Altimeter Settings 

E. 14 CFR § 91.151 (b): Fuel Requirements for Flight in VFR Conditions 

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

Inspections 

A. 14 CFR § 91.103: Preflight Action 

RRS Aerial Media, LLC requests an exemption from the preflight actions requirements of 14 

CFR 91.113 that prescribes the preflight actions under which aircraft may operate: 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. 

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been advised 

byATC; 

(b) For any flight, nmway lengths at airports of intended use, and the following takeoff 

and landing distance infonnation: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b )(1) ofthis section, 

other reliable infonnation appropriate to the aircraft, relating to aircraft 

perfonnance under expected values of airport elevation and nmway slope, aircraft 

gross weight, and wind and temperature. 

RRS Aerial Media, LLC will not operate sUAS's under IFR conditions or when the ceilings are 

below 1000 feet and the visibility is below 3 statute miles. Neither DJI, PrecisionHawk nor 3DR 
sUAS 'shave published approved Airplane or Rotorcraft Flight Manual containing takeoff and 

landing distance data. 

Equivalent Level of Safety 

RRS Aerial Media, LLC will to ensure that the weather will be adequate to complete the mission 

in VFR condition. Since RRS Aerial Media, LLC operates in traditionally density altitude area, 

never usually above 2000 feet MSL, UAS perfonnance is not affected. When RRS Aerial Media, 

LLC operates at a high altitude location, the UAS will be test flown at gross weight to test 

perfonnance limitations prior to conducting commercial operations. 

B. 14 CFR 91.113: Right-of-Way Rules 

RRS Aerial Media, LLC request an exemption from 14 CFR 91.113 Right-of-way rules, 

requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. 

When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that 

aircraft and may not pass over, under, or ahead of it unless well clear. 

RRS Aerial Media, LLC operates small pilotless UAS's and crumot comply with these rules as 

they have been written. 

Equivalent Level of Safety 

RRS Aerial Media, LLC operates sUAS's at or below an altitude of 400 feet AGL, well below 

the normal operating altitude of other aircraft. An RRS Aerial Media, LLC PIC with extensive 

aeronautical experience will oversee each mission and has knowledge of the avoid rules. A 

Visual Observer will assist the PIC in looking for aircraft entering the operations area. It's the 

responsibility of the PIC to cease operations and land the UAS immediately whenever and 

aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until 

the threat is clear. 

C. 14 CFR. § 91.119: Minimum Safe Altitudes 

RRS Aerial Media, LLC requests an exemption from the minimum safe altitude requirements of 

14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may operate: 

• Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of2,000 feet of the aircraft. 

• Over other than congested areas at an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 
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." 

To provide the intended operations, the sUAS is nonnally operated below 400 feet AGL. 

Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral 

distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from 

people not associated with the operation. 

Equivalent Level of Safety 

Compared to flight normal aircraft, RRS Aerial Media, LLC's multi-rotor aircraft weigh a 

maximum of 25 pounds, and given the lack of flammable fuel, 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 ofthe UAS, as well as the 

location where it is operated. The sUAS will be operated in a sterile area, where buildings and 

people will not be exposed to operations without their pre-obtained consent. Because of the 

advance notice to the property owners and participants, all affected individuals will be well 

aware of the planned flight operations. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that 

are subject to the minimum safe altitude regulations. Finally, the successful safety record of the 

DJI and 3DR sUAS's demonstrates that the sUAS can be safely used at these lower altitudes and 

closer operating environments. 

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

RRS Aerial Media, LLC seeks an exemption from 14 CFR 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 

because some of the sUAS aircraft do not have a barometric altimeter, but rather a GPS altitude 

read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved in that RRS Aerial Media, LLC will confinn the 

altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC 

will use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring 

operation at safe altitudes. 

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

RRS Aerial Media, LLC requests an exemption from 14 CFR § 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 VPR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and assuming normal cmising speed -

(1) During the day, to fly after that for at least 25 minutes; or 

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

The batteries powering RRS Aerial Media, LLC's UAS's provide approximately 10-18 minutes 

of powered flight. To meet the 30 minutes reserve requirement in 14 CPR 91.151, sUAS flights 

could not be conducted. Given the limitations on the sUAS's proposed flight area and the 

location of its proposed operations within a predetennined area, a safety margin based on a 

reserve amount of battery life is needed. 

RRS Aerial Media, LLC will not be conducting any sUAS flights at night. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the sUAS. All flights will be planned to tenninate with no less 

than 25% reserve battery power still available. This restriction would be more than adequate to 

return the sUAS safely to its planned landing zone from anywhere in its confined area of 

operation even in the event of an unexpected occutTence. Operation of the sUAS with less than 

30 minutes ofreserve fuel does not include the type ofrisks that Section 91.151(a) was intended 

to alleviate given the size and speed of the small UAS, and the proximity of the flight operation 

to the landing zone. Moreover, operation will be limited to controlled areas where only people 

and property owners, or official representatives who have signed waivers will be allowed. 

F. 14 CFR § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections 

RRS Aerial Media, LLC also seeks an exemption from the maintenance inspection requirements 

contained in 14 CPR 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 CPR Part 43. 14 CPR 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 to these regulations is needed because Part 

43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS 

will not have. 

Equivalent Level of Safety 

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

perfonned in accordance with DJI, PrecisionHawk and 3DR User's Manuals. The operator will 

ensure that the sUAS is in working order prior to initiating flight, perfom1 required maintenance, 

and keep a log of any maintenance perfonned. The operator is the person most familiar with the 
aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time during daylight 

hours, creates less risk than that associated with conventional rotorcraft performing the same 

operation. 

VI. PUBLIC INTEREST 

Granting RRS Aerial Media, LLC. an exemption furthers the public interest. National policy set 

by Congress favors early integration ofUAS into the national airspace in controlled, safe 

working environments such as those propose in this petition. The one vision of RRS Aerial 

Media, LLC is to help facilitate safe integration ofsUAS's into mainstream USA in the 

following areas: 

• Training 

To ensure that UAS Operators are properly trained and certified to safely operate they're 

particular type of sUAS aircraft. Also, training will be conducted in the type of operations 

they will be using their aircraft. 

• Real Estate 

The sUAS can be used in all areas of real estate, including commercial, residential and 

industrial properties. Using a sUAS, real estate professionals can create promotional 

videos, photos and unique shots that nonnal camera aspects cannot capture. RRS Aerial 

Media, LLC's easy-to-use video and photo platfonn enables properties to stand out, 

providing dazzling views that are typically shown via expensive computer animation or 

costly helicopter rentals. Imagine shooting a view from a high-rise condo in stunning 

high definition that shows your potential customer the actual view from the residence. 

The remote platform is great for new plam1ing, zoning and large developments. Simple 

and easy-to-use video and photos allow for multiple height pictures and elevation views. 

• Cinematography 

Whether the shot requires unique views and expansive pmming or extreme altitude with 

radical views, the UAS is designed to hold up under demanding conditions. Because of 

the autopilot feature with pre-designed mission management and RIC control interrupt, 

the pilot and camera operator can easily create the ultimate shot with HD video or HD 

still photos. 

• News Gathering 

Similar to movies and videography, each news assignment may require a completely 

different shot or view of a scene. With budgets for traditional helicopter use being greatly 
reduced, the UAS is the perfect solution to allow for easy news gathering for a fraction of 

the cost. The sUAS can and will be operated in a sterile area away from the public, while 

the traditional helicopter must hover over persons and property increasing the danger to 

individuals. 

• Agriculture and Conservation 

RRS Aerial Media, LLC would introduce and demonstrate to fanners of all types that the 

sUAS can aid cmmnercial agriculture, land management and conservation efforts by 

assessing crops, mapping flood zones, measuring snow pack and more. The sUAS can fly 

pre-saved missions via the fully automated ground station, which allows for time-lapse 

photos of fields, crops and known land tracts. It also can accurately recreate the same 

pattern during all seasons, providing invaluable data for land and soil management. 

Using HD video, HD photos, and IR cameras allows for detailed analysis and recording. 

With photo rendering software, 3D maps and topography can be used in conjunction with 

time-lapse photos to create highly detailed maps for erosion, flood mapping and other 

critical aspects of land management. 

• Oil and Gas Industry Infrastructure Inspection 

RRS Aerial Media, LLC will use HD video, HD photos, and IR cameras to inspect 

critical oil and gas infrastructures allowing detailed analysis prior to scheduled 

maintenance. This analysis will enable repair crews to minimize down-time which in turn 

greatly improve production efficiency. 

VII. Privacy 

RRS Aerial Media, LLC is committed to protecting the public privacy. RRS Aerial Media, LLC 

knows that many individual have concerns about privacy from the operations of sUAS 's. RRS 

Aerial Media, LLC will inform residents, commercial property owners, churches, schools, and 

governmental organizations of our intent to conduct commercial drone operations in proximity to 

their property. 

VIII. Federal Registry Summary 

Pursuant to 14 CPR Part 11, the following summary is provided for publication in the Federal 

Register, should it be detennined that publication is needed: 

RRS Aerial Media, LLC. seeks an exemption from the following rules: 

14 CPR 91.103; 14 CPR 91.113; 14 CPR 91.119; 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 

91.405(a); 14 CPR 91.407(a)(1); 14 CPR; 91.409(a)(2); 14 CPR 91.417 (a) & (b). 

Approval of this exemption request allows RRS Aerial Media, LLC to conduct commercial 

operations with small and lightweight unmanned aerial systems. RRS Aerial Media, LLC is 
committed safety, education, and solutions, which enhance safety of sUAS operations in the 

NAS while reducing risk to the general public and property owners. 

RRS Aerial Media, LLC uses sUAS, weighing less than 55 pounds and powered by batteries and 

small amounts of fuel. This eliminates virtually all of that risk given the reduced mass and lack 

oflarge amounts of combustible fuel carried on board as compared manned aircraft. The sUAS is 

transported to the designated mission area and set up there. The sUAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. 

The operation of this small UAS will provide an equivalent level of safety, supporting the grant 

of the exemptions requested herein, including exempting the applicant from the requirements of 

several regulations and allowing commercial operations. These lightweight sUAS's operate at 

slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than 

conventional aerial survey and inspection operations conducted with fixed wing aircraft or 

helicopters. 

If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned at: 

Very Respectfully, 

.--&/#{ 

-f=stotz 

President 

RRS Aerial Media, LLC 

Cell Phone: 361.215.6213 

Robin. Stotz@RRSAerialMedia.com