May 30, 2015

Remote Control Video Productions, LLC

Dave Bradlaw

Director of Videography

PO Box 93592

Southlake, TX 76092

214-945-3776

Cell 817-681-3996

Email: nadar1@charter.net

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

Exemption Numbers:

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)

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642)

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of 

the FAA Modernization and Reform Act of 2012, Remote Control Video Productions, LLC, referred to

hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal 

Regulations §§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a) (1); 91.409 (a) 

(1); 91.409(a) (2); 91.417(a) & (b); in order to operate small unmanned aircraft systems (UAS) 

commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of 

aerial photography, cinematography, videography, and other flight operations that could be performed 

safely and more cost effectively with the use of small UAS at low altitude within the U.S. national 

airspace system as compared to a manned aircraft. Operations will be performed only at the request of

and with the authorization and permission of clients or their authorized agents in order to facilitate 

commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such 

operations are conducted within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn 

from references listed above.

The FARs
The petitioner seeks exemption from the above mentioned FARs for the following reasons;

61.113(a) & (b)

The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with 

the addition of a trained observer. All pre-flight inspection, maintenance and flight logs will be saved 

and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of 

safely integrating civil UAS operation in the National Airspace System.

91.119(c)

As discussed in Exemption Nos. 11062, 11109, 11112, and 11213, operations conducted closer than 500 

feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or 

objects that would not be possible without additional relief. The petitioner requests modification,

waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. 

The petitioner requests waiver for this condition to allow reasonable and responsible operations in 

areas of subdivisions and neighborhoods if required. The petitioner will operate the UAS between 

ground level and 400 feet. The UAS will be operated over designated properties with the owner’s 

consent and while maintaining a safe distance from persons. The petitioner will compile flight data from 

the logs. This data may assist the FAA in development of regulations for commercial operations in lowrisk, controlled environments.

91.121

As discussed in Exemption Nos. 11062, 11109, 11112, and 11213, 91.121 is not applicable since the UAS 

does not have an altimeter and instead utilizes electronic GPS with a sensor for altitude information.

91.151(a)

As discussed in Exemption Nos. 11062, 11109, 11112, and 11213 prior relief has been granted for 

manned aircraft to operate at less than the prescribed minimums, In addition, similar UAS specific relief 

has been granted for daytime, VFR conditions. The UAS provides battery power remaining in percent to 

the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in 

the operating documents discusses procedures regarding remaining battery power management. Those 

documents contain a condition in which the PIC will initiate a landing procedure when battery remaining 

reaches a specified level. Given the limitations on proposed operations and the location of those 

proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR

conditions was reasonable.

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

As discussed in Exemption Nos. 11062, 11109, 11112, and 11213, the petitioner proposes to inspect and 

ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The 

FAA found that adherence to the petitioner’s operating documents and the conditions and limitations 

specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient 

to ensure that safety would not be adversely affected.

The UAS
The DJI Inspire 1 and DJI S1000+ are highly successful professional grade small rotorcraft. The DJI Inspire 

1 is a quadcopter design and the DJI 1000+ is an octocopter design. Both models have a weight of less 

than 55 pounds including payload and are designed primarily to carry aloft a high definition camera. 

Both models have an advertised maximum speed of less than 87 knots (100 mph). Both models are 

equipped with the DJI A2 flight controller and utilize an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial 

orientation and position. Each UAS is controlled through an FCC certified radio control (RC) unit. Real 

time video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle. Both models have failsafe modes of operation for either loss 

of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can

be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard 

flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery 

state. An automatic termination of flight and landing will be initiated when the battery reaches a 

predetermined low state. More information is available in attachment 1 and 2.

Risk mitigation

The petitioner has reviewed the Conditions and Limitations section of the FAA exemptions referenced 

above and believes that the procedures specified therein are reasonable and will be utilized in order to 

manage and mitigate risk and ensure public safety. 

A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified 

before launch. Airworthiness will be maintained by performance of routine inspections before each 

flight, maintaining flight and maintenance logs to record time on failure prone components. These

documents will be made available to the FAA to assist in future implementation of safety standards and 

regulations. The petitioner will only operate the UAS over designated properties with the owner’s 

consent. Flight plans will be predetermined to limit the UAS flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight obstacles prior to operating 

the UAS. UAS operation will always be within VLOS of the PIC and the observer.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact 

as compared to similar operations conducted with manned aircraft of greater proportions, carrying a 

crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their desired 

photographic subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and enhance personal 

photography. Aerial surveying and inspections can increase work site efficiency, improve volumetric 

estimations and reduce risks. The petitioner will provide clients with photographic data for these 

purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. 

Flight data including UA flight time, Control Unit operation time, incident, accident, and details 

concerning any deviations from normal operations will be available to FAA and SoT for use in collecting 

data regarding the use of UAS as part of this application. This data may be submitted to FAA via

traditional means or other means as required.
Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, 

videography, inspections, and other flight operations”. The reason for such a general and broad based 

request is that the petitioner wishes to utilize a business strategy to maximize economies of scope in 

order to capitalize on opportunities as they may arise in the future without the turnaround time 

associated with additional exemptions. The petitioner's business model is based on the idea of offering 

ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, 

effective, and legal option to enhance their business or hobby. The petitioner has refrained from 

engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the

capability to offer those services while remaining in compliance. The petitioner’s Director of 

Videography is a member of the Academy of Model Aeronautics (AMA) and has experience in the radio 

control model aircraft hobby.

Respectfully submitted,

Remote Control Video Productions, LLC

Dave Bradlaw

Director of Videography