Ralph C. Stutes

RCSRC Aerial Productions

7401 Fox Run Court

Granbury, TX 76049
July 8, 2015

U.S. Department of Transportation, Docket Operations

1200 New Jersey Avenue, SE

West Building Ground Floor, Room w12-140

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 

91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Ralph Stutes, am writing pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, to request that I, Ralph Stutes, dba

RCSRC Aerial Productions, hereafter referred to as “RCSRC”, an owner and operator of 

small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) 

listed below so that RCSRC, may operate small unmanned aircraft system (“sUAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”). 

As described herein RCSRC, is a photographer and videographer; experienced in flying 

hobby aircraft for recreational purposes since 1969. In addition, the owner, Ralph 

Stutes currently holds a FAA Airline Transport Pilot certificate, number 2155503. This 

exemption is for the anticipated use of the following sUAS vehicles: DJI Aspire 1, DJI 

Phantom 3, and Yunnec Typhoon Q500+, each equipped with a self-contained camera 

with intent for aerial photography and videography; following exemption and approval by 

the FAA.

RCSRC’s exemption request would permit operation of light weight, unmanned (piloted 

by remote control) and comparatively inexpensive sUAS(s) in tightly controlled and 

limited airspace, in predetermined in areas away from large public gatherings, airports 

and heliports for community videos, photos and video of new and remodeled 

commercial buildings/projects, individual homeowner aerial photography/videography, 

photography and video of land developments for builders, and nature photos and videos 

in completely unpopulated areas and other community related events upon request.

Currently, similar lightweight, remote controlled sUASs are legally operated by 

unmonitored amateur hobbyists with no safety plan or controls in place to prevent 

catastrophe. RCSRC has personally instilled safety protocols and controls to avoid and 

prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to 
further safety protocols exclusive to lightweight sUAS's specific to photography & 

videography usage as RCSRC records flight data and other information gained through 

permitted flight operations to share with the FAA through any required FAA reports to 

assist with future protocol and safety regulation.

Granting RCSRC’s request comports with the Secretary of Transportation’s (FAA

Administrator’s) responsibilities and authority to not only integrate sUASs into the 

national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems [sUASs] in the national airspace system” under Section 333(c) of the 

Reform Act specific to the use of sUASs for photography & videography purposes. 

Further RCSRC, will conduct all operations in compliance with the protocols described 

herein or as otherwise established by the FAA.

For the reasons stated below RCSRC, respectfully requests the grant of an exemption 

allowing operations of light weight, remote controlled sUASs for the purposes of 

acquiring aerial photos & videos, both of which will promote local economic growth 

through increased employment and increased tax base. Both purposes will also keep

public safety in mind by reducing heavier, manned aircraft operations which contain 

combustible fuel that pose potential public hazards.

Supplemental Files:

Appendix A

 DJI Inspire 1 User Manual (latest version 1.2) 

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

 DJI Phantom 3 Vision User Manual (latest version1.2)

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Man

ual_v1.2_en.pdf

 Yunnec Typhoon Q500+ User Manual (latest version 1.0)

http://yuneec.com/download/TyphoonQ500PUserManualV1.pdf

Appendix B - Personal Protocols and Controls

Contact Information:

Ralph Stutes, 7401 Fox Run Ct. 

Granbury, TX 76049

Home: (817) 579-0884

Mobile: (817) 894-1391. 

Email: ralphstutes@aceweb.com.
The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

RCSRC Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 

407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

The Extent of relief RCSRC seeks and the Reason He Seeks Such Relief

I, Ralph Stutes, submit this application in accordance with the Reform Act, 112 P.L. 95 

§§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, 

Ralph Stutes, contemplated commercial cinematic, academic and other flight operations 

within the national airspace system. The Reform Act in Section 332 provides for such 

integration of civil unmanned aircraft systems into our national airspace system as it is 

in the public’s interest to do so.

Each sUAS meets the definition of “small unmanned aircraft” as defined in Section 331 

and therefore the integration of my sUAS is expressly contemplated by the Reform Act. 

I would like to operate my sUAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft; thereby, providing direct 

experience and valuable information for formal regulation that can be administered 

uniformly to all related sUAS aerial photography & videography.

The Reform Act guides the Secretary in determining the types of sUASs that may 

operate safely in our national airspace system. Considerations include: The weight, 

size, speed and overall capabilities of the sUASs; whether the sUAS will be operated 

near airports or heavily populated areas; and, whether the sUAS will be operated by line 

of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for 

RCSRC. Each sUAS utilizes four (4) counter-rotating propellers for balance, control 

and stability, and is equipped with GPS and auto return safety technology. Each weighs

less than five (25) pounds (far below the maximum 55 pound limit); including camera 

with gimbal.

I, Ralph Stutes, consider safety as upmost importance with every flight. My small 

unmanned aircraft is designed to hover in place via GPS. Built in safety systems 

include a GPS mode that allows the sUAS to hover in place when radio controls are 

released. With three separate flight modes to choose from, I utilize the GPS Mode for 

aerial photography and videography. This is the safest, most reliable and stable mode 

to prevent accidents and hazards. When pilot communication is lost, the sUAS is 

designed to return to a pre-designated home point and slowly descend to landing.
RCSRC will not operate any sUAS near airports, Hospitals nor Police heliports, and will

not operate near areas where general public is within thirty to one hundred (30-100) 

yards depending on location, conditions and weather. I am constantly on alert for any 

manned aircraft (Police/Medical helicopters, etc.) and prepared to abort/land

immediately to the nearest and safest ground point should a manned aircraft approach 

my location or I suspect manned aircraft may approach near my location. My sUAS is 

capable of vertical and horizontal operations, and are flown only within my line of sight 

of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, 

flights generally last between fifteen (15) to twenty (20) minutes, with an altitude under 

four hundred (400) feet. I will utilize a fresh, fully charged battery with each flight as a 

safety precaution; full flight time limit for each battery is twenty-five (25) to thirty (30) 

minutes as tested.

RCSRC will not operate any sUAS at or below the manufacturer recommend minimum 

charge levels for operation; remaining well within a safe operating range to insure 

adequate communication between radio control and sUAS to eliminate potential for 

crash, loss of control or hazards. Reserve batteries are at hand with each exercise to 

insure replacement for sufficient safe level of operation. I do not believe in taking any 

risk that may cause a crash, which could create hazards to the public / property / 

manned aircraft, and have no desire to lose an investment. I have done scores of 

practice flights in remote areas as a hobbyist simulating flights for future commercial 

use to gain familiarization with the characteristics of this specific sUAS’s performance 

under different temperature and weather conditions. All for the sake of safety.

RCSRC, is extremely cautious when operating of any sUAS unmanned aircraft and will 

not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 

§ 333 (b). Given the small size and weight of each sUAS, it falls well within Congress’s 

contemplated safety zone when it promulgated the Reform Act and the corresponding 

directive to integrate sUASs into the national airspace system. RCSRC’s sUAS, used in 

hobby flight, has a demonstrable safety record and does not pose any threat to the 

general public or national security.

How Ralph Stutes’ Request Will Benefit the Public As A Whole: 

Aerial photography has been around for a long time through the use of manned fixed 

wing aircraft and helicopters. For small budget productions the expense of such aerial 

photography and videography is cost prohibitive. Only larger companies can afford to 

absorb such expense. Manned aircraft pose a threat to the public through the potential 

of a catastrophic crash. My sUAS poses no such threat since size and lack of 

combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate 

commercially flown sUASs into the national airspace system, hence the passing of the 

Reform Act. Granting RCSRC’s exemption request furthers the public interest through 

academic/visual awareness of the photography and videography fields. All sUASs are
battery powered and create no emissions that can harm the environment. The 

consequence of any sUAS crashing is far less than a full size helicopter or fixed wing 

aircraft; which are heavy, contain combustible fuel and can cause catastrophic 

devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting 

aerial photography and videography captured through battery operated sUASs. 

Permitting me, Ralph Stutes, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially furthers the economic 

impact for companies looking to use aerial photography and videography, both of which 

serve as a stimulus to the community.

Reasons Why RCSRC’s Exemption Will Not Adversely Affect Safety, Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

RCSRC’s, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated will permit RCSRC to log more flight time in FAA controlled airspace, 

with communication with the FAA, and will allow contributions to the innovation and 

implementation of new and novel, as of yet undiscovered safety protocols for 

photographers and videographers for development in cooperation with the FAA.

In addition, RCSRC submits the following representations of enhancements to current 

aerial photography/videography. All sUAS models anticipated for use weigh less than 

25 pounds complete with a small, ultra-lightweight high quality camera; all sUAS models 

will be operated below 400 feet (within the 400 foot permissible ceiling set by the FAA 

Modernization and Reform Act of 2012); each sUAS only operates for fifteen (15) to 

twenty (20) minutes per flight; each sUAS will be landed prior to manufacturer 

recommended minimum level of battery power; each sUAS will be piloted through 

remote control only by visual line of sight; each sUAS has GPS, a flight safety feature 

whereby it hovers, returns to a designated home position and then slowly lands if 

communication with the remote control pilot is lost. I actively analyze flight data and 

other sources of information to constantly update and enhance safety protocols; I only 

operate in reasonably safe environment away from airports and areas with large groups 

of people; I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance; I always obtain all necessary permissions prior to operation; 

and, I have procedures in place to abort flights in the event of safety breaches or 

potential danger.

RCSRC’s safety protocols provide a level of safety equal to or exceeding existing rules. 

It is important to note that absent the integration of commercial sUAS into our national 

airspace system, helicopters are the primary means of aerial photography and 

videography. While the safety record of such helicopters is remarkably astounding, 
there has been incidents involving loss of life as well as extensive property damage; it is 

far safer to operate a battery powered sUAS.

First, the potential loss of life is diminished because sUASs carry no people on board 

and I only operate my sUAS in specific areas away from mass populations. Second, 

there is no fuel on board any sUAS and thus the potential for fire or explosions is greatly 

diminished. Third, the small size and extreme maneuverability of each sUAS allow me 

to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small 

size and weight, even when close enough to capture amazing images, my sUAS need 

not be so close to the objects they are focused on through the technology and the use 

of post editing software allowing panning, tilting and zooming.

Accordingly, each sUAS has been experimentally operated for familiarization and 

competency and will continue to operate at and above current safety levels.

A Summary: The FAA May Publish in the Federal Register:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 

C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). 

The size, weight and enclosed operational area of all RCSRC’s sUAS permits 

exemption from Part 21 because all sUAS meets (and exceeds) an equivalent level of 

safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA 

to exempt sUASs from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. My current and projected sUASs meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight 

manual in the aircraft. As there are no on board pilots or passengers, and given the 

size of the sUASs, this Regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining a safety/flight manual delineating areas where safety can be 

defined. The FAA has previously issued exemptions to this regulation in Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 

32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as all anticipated

sUASs utilizes electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The 
equivalent level of safety will be achieved by maintaining any such required 

certifications and registrations by RCSRC. 

14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. All sUASs are, by 

definition, unmanned. They, therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place 

on such small aircraft with dimensions smaller that minimal lettering requirement. 

Regardless, I will mark the sUASs in the largest possible lettering by placing the word

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, 

or anyone assisting me as a spotter with the UAV will see the markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700. 

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. 

§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. RCSRC, 

can achieve an equivalent level of safety as achieved by current Regulations because 

all sUASs does not carry any pilots or passengers. Further, while helpful, a pilot license 

will not ensure remote control piloting skills. The risks attended to the operation of my 

sUAS is far less than the risk levels inherent in the commercial activities outlined in 14 

C.F.R. § 61, et seq. Thus, allowing RCSRC to operate all sUASs referenced will meet 

and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes 

for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in 

certain conditions. All sUASs will never operate at an altitude greater than 400 AGL. 

RCSRC will operate all sUASs in safe areas away from public and traffic, providing a 

level of safety at least equivalent to or below those in relation to minimum safe altitudes. 

Given the size, weight, maneuverability and speed of all sUASs, an equivalent or higher 

level of safety will be achieved. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] aircraft inspected as prescribed in subpart E of this part and

shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my sUASs. However, as a safety precaution I thoroughly inspect my 

sUAS before and after each flight.
The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). 

The size, weight and enclosed operational area of my sUAS permits exemption from 

Part 21 because RCSRC’s sUASs meet an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt

sUASs from the airworthiness certificate requirement in consideration of the weight, 

size, speed, maneuverability and proximity to areas such as airports and dense 

populations. All sUASs meet or exceed each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight 

manual in the aircraft. As there are no pilots or passengers, and given the size of the 

sUASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a manual. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance 

program that involves regular software updates and curative measures for any 

damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, RCSRC seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §

91.7 (a); 14 C.F.R. § 91.9 (b) (2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. 

§ 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 

14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); and, 14 

C.F.R. §§ 91.417 (a) & (b) to commercially operate my small unmanned 

vehicle/lightweight unmanned aircraft vehicle in community awareness and aerial 

photography and videography operations. Currently, area awareness and aerial 

photography and videography relies primarily on the use of larger aircraft running on 

combustible fuel, posing potential risk to the public. Granting my request for exemption 

will reduce current risk levels and thereby enhance safety. My sUAS craft do not 

contain potentially explosive fuel, are smaller, lighter and more maneuverable than

conventional aircraft, and will not require flight transit time to/from operation locations. 

Further, I operate at lower altitudes and in controlled airspace eliminating potential 

public risk flying to and from established air fields. I, Ralph Stutes, have been informally 

analyzing flight information and will compile safety protocols and the implementation of 

a flight operations manual that exceeds currently accepted means and methods for safe 

flight. Formal collection of information shared with the FAA will enhance the FAA's 

internal efforts to establish protocols for complying with the FAA Modernization and 
Reform Act of 2012. There are no personnel on-board any sUAS and therefore the 

likelihood of death or serious bodily injury is significantly diminished. 

RCSRC’s operation of all sUASs, weighing less than 55 pounds and travelling at lower 

speeds within limited areas will provide an equivalent level of safety as that achieved 

under current FARs. Accordingly I, Ralph Stutes, respectfully request that the FAA 

grant my exemption request and am willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Ralph Stutes, Photographer / Videographer 

7401 Fox Run Ct. 

Granbury, TX 76049