Revolutionary Unmanned Systems, LLC. - SECTION 333 EXEMPTION REQUEST Page 1 of 3

October 26, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS) 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

On Behalf of Revolutionary Unmanned Systems, LLC., and Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I John Santry, President am seeking an 

exemption from Part 21 Subpart H; and Sections 91.203 (a) (1), 45.23 (b), 91.7 (a), 91.9, 61.113, 61.133, 

91.109, 91.119, 91.121, 91.151, and (91.401 - 91.417) Subpart E, of Title 14, Code of Federal Regulations 

(14 CFR). This proposed exemption would allow for the operation of our unmanned aircraft (UA): The DJI 

Phantom 3, DJI Inspire 1, DJI S900, DJI S1000, 3DR Solo, 3DR Iris+, Freefly Alta, and the Intuitive Aerial 

Aerigon

THE UNMANNED AIRCRAFT (UA):

 The UA’s are lightweight (under 55lb. gross weight), battery operated multi Rotor copters that 

take off and land vertically and have the ability to hover in one location during flight. 

THE UA INCLUDES:

 An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a ground-based transmitter/controller;

 An on-board camera capable of capturing imagery in the form of full color, high definition still 

photos and video

 An on-board telemetry system that delivers flight data from the on-board flight computer to the 

on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site

 On-board radio transmitter that transmits live video from the on-board camera plus all the flight 

data from the telemetry system described above

THE GROUND STATION PART OF THE SYSTEM:

 A Pilot in Command (PIC) In operational control of a mission from beginning to end, and who 

controls the UA while in the air

 A radio transmitter/controller operated by the PIC to control the UA while in flight 

 Ground Station (computer, tablet for smart phone based app) which receives and displays video 

and system telemetry real time from the UA

 A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA 

while in flight.
Revolutionary Unmanned Systems, LLC. - SECTION 333 EXEMPTION REQUEST Page 2 of 3

PILOT IN COMMAND (PIC) AND VISUAL OBSERVER:

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training.

I submit that the combination of the UA’s light weight, flight performance and ability, fully qualified 

flight crew and strict operation under the guidelines established in 8900.227, and under all of the 

Restrictions listed above, the FAA can have full confidence that the operation will have an equivalent or 

greater level of safety than manned aircraft performing the same mission.

INTENDED USE:

The requested exemption would allow us to use the UA for aerial image acquisition to support various 

mapping and surveying applications as well as video documentation for the public good. Typical 

applications would include, but are not limited to: 

 Inspection Services

 Aerial Photography

 Real Estate Photography

 Videography

 Aerial Mapping

 Volumetric Surveys

 Agricultural Inspection

 Closed Set film making*

INTENDED USE / PUBLIC GOOD: 14 CFR § 11.81(d)

The inherent ability of the UA to capture imagery from a low altitude including oblique photos and video 

from several angles is far more effective than ground-based imagery for displaying the characteristics of 

buildings, sites and properties or areas where consistent monitoring is needed. In addition the ability to 

provide these services at a much lower cost than chartering a fixed wing aircraft or helicopters make this 

service much more affordable to my client base. The reduced cost and higher quality data from the UA 

is beneficial to the public in many applications including: real estate photography, accident or crime 

scene investigation, search and rescue, terrain mapping to delineate flood prone areas, and the 

preservation of historic buildings or archeological sites where access is limited due to the sensitive 

nature of the site. In Addition the applicant is often asked to capture imagery and video to produce 

maps for public entities such as Municipalities, City County Government, Chambers of commerce and 

local businesses to support projects for the public good.

PUBLIC SAFETY:

UA’s, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel; they operate at lower altitudes (under 400’) with no people on board 

thereby reducing current risk levels and enhancing public safety. With a small payload and maximum 

flight time of approximately 30 minutes, UA’s offer little or no risk to national security. 
Revolutionary Unmanned Systems, LLC. - SECTION 333 EXEMPTION REQUEST Page 3 of 3

SUMMARY GRANT REQUEST:

This request follows many others using similar systems and process that have been granted previously. I 

am requesting the FAA issue a summary grant of exemption, as this request would not set a precedent.

 The requested relief is identical to exemptions recently granted by the FAA; Exemption Nos. 

11624, 12026, 12366 and 12369

 The requested relief (specific to Closed Set film making) is identical to exemptions granted 

previously, specifically, Exemption(s) Nos. 11062 (Astraeus Aerial), 11066 (Aerial MOB), 11065 

(Helivideo), and others.

 A grant of exemption would be in the public interest.

THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED 

Beside each regulation number is the page of the attached Addendum upon which each may be found 

together with a proposed equivalent level of safety for each regulation:

- 14 CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a) (1) Addendum Page 1

- 14 CFR 45.23 (b) Addendum Page 1

- 14 CFR 91.7 (a) Addendum Page 2

- 14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 Addendum Page 3

- 14 CFR 91.151 Addendum Page 3

- 14 CFR Subpart E (91.401 - 91.417) Addendum Page 4

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. Please contact us at any time if you require additional information or clarification. I am the 

primary point of contact for this request and look forward to working with your office.

Sincerely,

John Santry, President 

Revolutionary Unmanned Systems, LLC

4909 Ruffner St

San Diego, CA 92111

Phone: 804.852.7355

Email: john@revolutionaryus.com

Addendum Containing Exemption Requests and Equivalent Level of Safety

Appendix A – Flight Operations/Procedures

Appendix B – User’s Manuals

Appendix C- MPTOM
Revolutionary Unmanned Systems, LLC. - EXEMPTION REQUEST AND LEVEL OF SAFETY Page 1 of 4

ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I, John Santry, President of Revolutionary Unmanned Systems, LLC, request an exemption from the

following regulations as well as any additional regulations that may technically apply to the 

operations of the following UA’s: The DJI Phantom 3, DJI Inspire 1, DJI S900, DJI S1000, 3DR Solo, 3DR 

Iris+, Freefly Alta, and the Intuitive Aerial Aerigon.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR 91.203( a) (1). 

Given the size and limited operating area associated with the UA to be utilized by the Petitioner, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 

11 and Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the 

FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular UA. In all cases, an analysis of these criteria demonstrates that the UA 

operated without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions proposed. The UA to 

be operated hereunder is less than 55 lbs. fully loaded, is by definition unmanned and carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a limited flight area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the Operator and will also remain within the requirements of, and in 

compliance with, local public safety requirements. These safety enhancements, which already apply to 

civil aircraft provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UA due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. 45.23 (b). Marking of the Aircraft

The regulation requires; 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 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

Even though the UA will have no airworthiness certificate, an exemption may be needed as the UA will 

have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. 

Given the size of the UA, two-inch lettering will be impossible. The word "Experimental" will be placed 

on the fuselage in compliance with 45.29 (f). The equivalent level of safety will be provided by having 
Revolutionary Unmanned Systems, LLC. - EXEMPTION REQUEST AND LEVEL OF SAFETY Page 2 of 4

the UA marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working 

with the UA will see the identification of the UA as "Experimental." 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167 A.

14 C.F.R. 91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained herein for the use of safety check lists prior to each flight, an equivalent level of 

safety will be provided.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation; the documentation would 

not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

approved UA Flight Operations/Procedures (Appendix A) must be available to the crew at the ground

station anytime the aircraft is in, or preparing for, flight. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot

privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot

in command of an aircraft in connection with any business or employment if: (1) The flight is only

incidental to that business or employment; and (2) The aircraft does not carry passengers or property

for compensation or hire. 

Our proposed operations require that the PIC must either

1. Hold a Private or Sport Pilot Certificate issued by the FAA, and have logged 10 hours of flight 

experience in this type of UA, or

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in 

which the PIC is required to complete "FAA private pilot ground instruction" and pass "the

FAA Private Pilot written examination." Since there are currently no means available for the 

pilot of a UA to gain the experience in an equivalent category and class in order to apply for a 

private pilot's license, we propose to generate an equivalent level of safety by requiring our 
Revolutionary Unmanned Systems, LLC. - EXEMPTION REQUEST AND LEVEL OF SAFETY Page 3 of 4

pilots to complete, at a minimum, FAA private pilot ground instruction and pass the FAA

Private Pilot written examination in addition to completing the private pilot requirements. 

Since the aircraft cannot carry passengers or property, we feel that we meet the intent of 

61.113 Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls."

The UA’s ground-based control station consists of a small hand-held radio transmitter and while it does 

not offer a second set of "controls", both the student and instructor can, and will, operate the single set

of controls simultaneously. With both student and instructor having "hands-on" the controls during

flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum 

of 400 feet AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety The UA’s will not be operated over congested areas or

over any open air assembly of persons without prior approval. Any property owner affected will be 

briefed on the expected route of flight and the associated risks to persons and property on the ground.

The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing

without undue hazard to persons or property on the surface. Therefore we maintain that due to the 

small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned

aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter Settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to 

prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff 

point is transmitted via radio from the UA’S on-board computer to the display screen held by the PIC,

providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 

30 minutes.

The intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. 

Each UA is battery operated and the maximum duration of flight from a single battery charge is 18
Revolutionary Unmanned Systems, LLC. - EXEMPTION REQUEST AND LEVEL OF SAFETY Page 4 of 4

minutes with a 20% reserve. Since the aircraft will never fly more than 3/4NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent

interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under

43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to 

approve the aircraft for return to service." As provided in the Pre-Flight Checklist in Appendix A, the PIC 

will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct 

detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to 

repairing small cracks, replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. All other maintenance will be performed by the manufacturer or

their designated repair facility. The PIC will document work performed in accordance with 91.417. We

feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent 

level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. And Paragraph 16(e)(1) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate 

issued under part 67 in order to perform as a pilot or observer.

The UA’s maximum gross weight are each less than 8lbs., are constructed primarily of, plastic and 

carbon fiber. The PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the

unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, 

the UA will return autonomously to the site of launching and land without crew intervention. Therefore, 

requiring the PIC and VO to meet the same medical requirements as commercial pilot carrying 

passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to

20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC

and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger 

vehicle. 
Revolutionary Unmanned Systems, LLC. – APPENDIX A – FLIGHT OPERATIONS AND PROCEDURES

APPENDIX A – FLIGHT OPERATIONS/PROCEDURES

The UA’s will be operated under the following flight restrictions.

OPERATIONAL FLIGHT RESTRICTIONS

The UA will be operated in the field with both a PIC and a VO in accordance with and with the following 

Restrictions:

 All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of 

no more than 25 knots and no further than 3/4 NM from the PIC;

 All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate 

by voice at all times during a flight operation;

 The PIC must have accumulated and logged, in a manner consistent with 14 CFR §

 61.51 (b), 10 hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot 

with a similar UA type;

 The UA will not be operated over densely populated areas; without prior approval

 The UA will not be operated over any open-air assembly of people; without prior approval

 The UA will not be operated within 5 NM of an airport or heliport; without prior approval

 Operations will be restricted to day only and weather conditions equivalent to VFR

 The PIC will brief the VO and property owner about the operation and risk before operation

 No flight will be made without a Pre-Flight Inspection by the PIC before each operation to 

ascertain that the UA is in a condition safe for flight

PRE-FLIGHT CHECKLIST

Prior to operation preflight checklists provided by the manufacturer of the UA’s will be followed. Below 

is such an example. 

1. Remote Controller, battery, Range Extender and Viewing device are fully charged.

2. Propellers are mounted correctly.

3. Damping absorbers are in good condition, not broken or worn.

4. Camera lens cap has been removed.

5. Micro-SD card has been inserted if necessary.

6. Gimbal is functioning as normal.

7. Motors can start and are functioning as normal.

8. Sensor connection is established.
Revolutionary Unmanned Systems, LLC. – APPENDIX A – FLIGHT OPERATIONS AND PROCEDURES

TAKE OFF/LANDING PROCEDURES 

Manufacturer recommended Takeoff and Landing procedures will be followed.

Place the UA on ground with the battery level indicator facing you.

1. Power on the remote controller.

2. Power on the range extender.

3. Power on or connect sensor.

4. Power on the aircraft by turning on the battery

5. Connect the mobile device (Ground Station) to the UA.

6. Wait until the LED flight indicator lights indicate good GPS connectivity and Ready to Fly.

7. Push the throttle stick up slowly to lift the aircraft off the ground. 

8. When landing, hovering over a level surface, pull down on the throttle stick gently to 

descend and land.

9. After landing the aircraft on the ground, keep the throttle stick down while the motors 

come to a complete stop.

FAILSAFE FUNCTION

The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight 

control system will automatically control the aircraft to return to home and land to reduce injuries or 

damage. The following situations would make the aircraft fail to receive a signal from the remote 

controller and enter Failsafe mode:

1. The remote controller is powered off.

2. The aircraft has flown out of the effective communication range of the remote controller.

3. There is an obstacle obstructing the signal between the remote controller and the aircraft, 

essentially reducing the distance the signal can travel.

4. There is interference causing a signal problem with the remote controller.

OPERATIONS RELATED TO MOTION PICTURE AND CLOSED SET FILM MAKING

The following additional procedures will apply when operating for Motion Picture or Closed Set Film 

Making. 

The team will carry and have on hand a motion picture and television operations manual (MPTOM) At 

least 3 days before aerial filming, the operator of the UAS will submit a written Plan of Activities to the 

local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. 

The plan of activities will include the following: 

 Dates and times for all flights

 Name and phone number of the operator (PIC) 

 Name and phone number of the person responsible for the on-scene operation of the UAS

 Make, model, and serial or N−Number of UAS to be used

 Name and certificate number of UAS PICs involved in the aerial filming; 
Revolutionary Unmanned Systems, LLC. – APPENDIX A – FLIGHT OPERATIONS AND PROCEDURES

 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

 Signature of exemption holder or representative 

 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.
Revolutionary Unmanned Systems, LLC. – APPENDIX B – User’s Manuals

APPENDIX B – USER’S MANUALS

Users Manuals for each of these systems can be downloaded here. 

Revolutionary Unmanned Systems, LLC, will keep a copy with each UA. 

DJI Phantom 3 User Manual

DJI Inspire 1 User Manual

DJI S900 User’s Manual

DJI S1000 User’s Manual

3DR Solo User’s Manual

3DR Iris+ User’s Manual

Freefly Alta User Manual

Intuitive Aerial Aerigon

Upon request these will be provided
Revolutionary Unmanned Systems, LLC. – APPENDIX C -MPTOM

APPENDIX C MPTOM

Revolutionary Unmanned Systems, LLC

Motion Picture and Television Flight Operation Manual (MPTOM)
Date: 10.19.2015 Revision: Original

Page 1 of 15

Motion Picture and Television 

Flight Operation Manual

Revolutionary Unmanned Systems, LLC

4909 Ruffner St

San Diego, CA 92111

Revolutionary Unmanned Systems LLC is a Service Disabled Veteran Owned Small Business
Date: 10.19.2015 Revision: Original

Page 2 of 15

Table of Contents

1. Introduction

A. Purpose 4

B. Pilot/Operator Organization 4

C. Persons Authorized 4

D. Area of Operations 4

E. Plan of Activities 5

F. Permission to Operate 5

G. Security 6

H. Briefing of Pilot/Production Personnel 6

I. Certification/Airworthiness 7

J. Pilot Personnel/Minimum Requirements 7

K. Communications 8

L. Accident Notification 8

M. Recall/Stop Procedures 8

N. Aerobatic Competency 8

O. Aerobatic Competency 9

2. CompanyOrganization

A. Chief Pilot 9

B. Pilot in Command 10

Appendix A

1 List of Approved Pilots 11

2 List of Approved Aircraft 12

3 Permission Acquisition Form (sample) 13

4 Revision Letter (sample) 14
Date: 10.19.2015 Revision: Original

Page 3 of 15

Revision Control Page

Revision# Date Initials
Date: 10.19.2015 Revision: Original

Page 4 of 15

1. Introduction

A. Purpose

This manual has been developed by "Revolutionary Unmanned Systems, LLC",

hereafter referred to as "RevUS", in conjunction with an application for a

Certificate of Waiver of Authorization of the provisions of FAR 91.119 (b) and (c) 

for the purposes of filming. RevUS pilots and other company personnel when

applicable will comply with the policies, procedures and conditions of this manual,

whenever motion picture or television flight operations are performed that require

a Waiver of Authorization as mentioned above.

B. Pilot/OperatorOrganization

Scott Painter – Lead Pilot

Revolutionary Unmanned Systems, LLC

4909 Ruffner St

San Diego, CA

office • 844-370-1813

cell • 804-852-7355

C. Persons Authorized

FAR 91.119 (c) is waived only with respect to those persons, vehicles and 

structures directly involved in the performance of the actual filming. The certificate 

holder shall ensure that no persons are allowed within 500 feet of the area except

those consenting to be involved and necessary for the filming production. This 

provision may be reduced to no less than 200 feet if an equivalent level of safety 

can be achieved and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an ASI’s evaluation of the filming

production area to note terrain features, obstructions, buildings, etc. Such barriers 

may protect nonparticipating persons (observers, the public, news media, etc.) 

from debris in the event of an accident.

D. Area of Operations

RevUS's approved area of operations will be the continental United States,

Alaska, and Hawaii. 
Date: 10.19.2015 Revision: Original

Page 5 of 15

E. Plan of Activities

At least three (3) days prior to any scheduled filming, RevUS will submit a written

plan of activities to the local FSDO having jurisdiction over that area. The plan of

activities should include the following:

(1) Dates and times for all flights.

(2) Name and phone number of person responsible for the filming production

event.

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial or N-number of aircraft to be used and type of

airworthiness certificate, including category.

(5) Name and certificate number of pilots involved in the filming production

event, including any notation of external load endorsements or aerobatic 

competency, if required.

(6) A statement that the waiver holder 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 from the waiver holder.

(7) Signature of waiver holder or representative.

(8) 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 

minimum altitudes essential to accomplish the operations.

The three (3) day notification equipment may be waived, however, the operator 

should contact the FSDO as soon as possible with this request and be prepared to 

explain in detail why the three (3) day notification is not practical.

F. Permission to Operate

Before any flight operations is conducted at less than 500 feet under the

provisions of the certificate of waiver and this manual, the operator will obtain 

permission to conduct these operations from property owners and local officials as 

necessary or appropriate. Persons from whom permission may be required are

listed below:
Date: 10.19.2015 Revision: Original

Page 6 of 15

(1) Property owners

(2) Law enforcement officials

(3) Fire department officials

(4) Local, State and Federal government

(5) Air traffic control

The RevUS personnel obtaining such permission will do so in writing whenever 

practical, however, verbal permission is acceptable otherwise. A standard 

permission form is provided in Appendix A and may be used when obtaining 

written permission. RevUS personnel will assure a sufficient number of those

forms are available at the job site. Written permission forms will be maintained at

the job site until flight operations are completed, and then turned into the chief

pilot to be kept on file for a minimum of six (6) months. These forms will be made

available for inspection by the FAA or other official personnel upon request.

G. Security

Prior to any flight operation the operator will coordinate with appropriate 

production personnel to devise a plan of securing the area(s) of operation from all 

unauthorized persons and vehicles. Provisions will be made to immediately

discontinue operations should the area(s) become unsecured or for any other 

reason in the interest of safety.

H. Briefing of Pilot/Production Personnel

Prior to the start of any operation under the provisions of this manual, the pilot in

command will conduct a briefing of all procedures to participating personnel of the 

risks involved, emergency procedures, and safeguards to be followed during the 

filming production event. Personnel will also be briefed on additional provisions

that may be issued by the FSDO that has geographic responsibility for the

operational area, including the location of boundaries or time limits. The briefing 

shall cover:

• Authorization for motion picture and television certificate of waiver and the

attached special provisions

• Operations manual

• Plan of activities

• Aircraft parking and starting

• Taxi procedures

• Radio Communications

• Takeoff procedures
Date: 10.19.2015 Revision: Original

Page 7 of 15

• Aviation activities to be conducted during the filming production event

• Approach and landing procedures

• Recall procedures

• Emergency procedures

• Risks to participating personnel

• How to control nonparticipating persons

I. Certification/Airworthiness

All RevUS aircraft used in operations requiring a waiver of FAR 91 .119 (b) and

(c) for the purpose of filming will be properly certified and hold airworthiness

certificates. However, restricted category aircraft cannot be used as the filming

"vehicle" in motion picture and television filming. Also, aircraft in the experimental

category must have an airworthiness certificate issued for the purpose of

exhibition in order to be used in motion picture and television filming. The aircraft

will be 100hr/annual inspection program. Other required tests and inspections 

(transponder, E.L.T., etc.) will be performed as per Part 91 when necessary. Each 

aircraft will have a flight log containing upcoming scheduled maintenance and 

inspections and the dates or times they must be performed. A section for 

discrepancies is also found in the flight log. The pilot in command will assure the 

aircraft to be flown is in airworthy condition and all required inspections and 

maintenance has been completed before each flight.

J. Pilot Personnel/Minimum Requirements

The pilot/operator shall establish and specify the minimum pilot requirements.

Minimum requirements shall meet or exceed the following:

(1) A current U.S. sport pilot certificate with ratings appropriate to the 

category, class and type (if applicable) of aircraft to be used under the 

terms of the waiver.

(2) At least 500 hours logged as PIC and at least 20 hours logged as the PIC 

in the aircraft type.

(3) A minimum of 100 hours in the category and class of aircraft to be used.

(4) A minimum of 5 hours in the make and model aircraft to be used under

the waiver.

(5) In the event that the 1,500-foot minimum standard contained in the 14

CFR 91.303(e) is to be waived, the pilot performing aerobatic maneuvers 

must hold FAA Form 8710-7, Statement of Acrobatic Competency, to

perform the operations.
Date: 10.19.2015 Revision: Original

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(6) In the event the operation to be conducted contains elements of an

external-load operation, whether fixed or rotary wing operations, pilots

used in the operation shall be qualified. This qualification may be

obtained through a knowledge test (which may be oral and/written) and/or

skill. The inspector or another company pilot approved by the 

geographically responsible FSDO who is qualified to carry loads 

externally will give the test(s) which are similar to part 133 requirements 

and cover the following subjects:

(a) Steps to be taken before starting operations, including a survey of the 

Flight area.

(b) Proper method of loading, rigging, or attaching the external load.

(c) Aircraft performance capabilities under motion picture operating 

procedures and the aircraft flight manual.

(d) Proper instructions for flight and ground crew personnel.

(e) Aircraft flight manual, pilot operations handbook, or a rotorcraft-load

combination flight manual and limitations, if appropriate.

K. Communications

Prior to the start of any operation covered by this manual, the pilot in command 

will formulate a plan to provide communications capability to all participants 

during the actual operation and filming. Oral, visual or radio communications may 

be used as long as it is effective and is capable of keeping the participants 

continuously appraised of the current status of the operation.

L. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the 

notification requirements of FAR Part 830 would comply.

M. Recall/StopProcedures

Radio communication, oral, visual or a combination will be utilized to keep the 

participants continuously apprised of the current status of operation.

N. Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710-7, Statement of

Aerobatic Competency, refer to Volume 5, Chapter 9, Issue/Renew/Rescind a 

Statement of Aerobatic Competency.
Date: 10.19.2015 Revision: Original

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O. Special Provisions

The controls, procedures, and conditions set forth in the RevUS motion picture

and television operations manual is the primary assurance that persons on the 

surface will not be jeopardized.

The aircraft and pilots used under this authorization and/or waiver will only be 

those specified in the RevUS motion picture and television operations manual

(“Appendix A” page 11) or associated plan of activities. Each pilot’s name and

certificate number shall appear on each daily plan of activity. All civil aircraft and 

pilot(s) participating in the activity shall be available for FAA inspection before the 

scheduled event.

Each pilot-in-command conducting operations authorized under this certificate

understands the conditions of issuance, and that it constitutes a waiver of FAR

91.119 (b) and (c) . (see attached document under “Appendix B” page 15)

Rotorcraft takeoff and landing areas will be protected in a manner that will

prevent unauthorized persons from entering the takeoff and landing area.

RevUS will ensure that the participating persons involved in the operations are 

thoroughly briefed on special procedures, communication, emergency 

procedures, and on the provisions of the authorization and/or waiver before 

beginning the activities. No person may participate in any event unless that

person has received a briefing on the provisions of the waiver.

2. Company Organization

A. Chief Pilot

Duties and Responsibilities:

• Final word in the formulation of policy and procedures concerning this 

manual.

• Act as liaison between RevUS and the FAA on matter concerning this manual.

• Assure that each approved pilot is issued a copy of this manual and obtain a 

signed statement from each that they have read and understand its contents.
Date: 11.21.2011 Revision: Original

Page 10 of 15

• Maintain a current copy of this manual at the main base of operations for

RevUS.

• Responsible for assuring that all revisions to this manual are distributed and 

processed properly.

• Must approve or disapprove each proposed job or operation performed by 

RevUS under the provisions of this manual.

• Assume the responsibilities of pilot in command when acting as such.

• The chief pilot may delegate functions to other personnel but retains 

responsibility.

B. Pilot in Command

Duties and Responsibilities:

• Assure that aircraft to be flown is in airworthy condition and all inspections and 

required maintenance have been performed as per appropriate FAR's.

• Acquire permission from the chief pilot before any operation under the 

provisions of this manual.

• Be very knowledgeable of the contents of this manual and abide by the 

procedures, policies and conditions contained herein.

• Coordinate with movie and television personnel to formulate plans, routes,

locations, etc. with safety of all persons involved in the primary concern.

• Maintain their copy of this manual in current condition and have it on site at any 

job or operation requiring the waiver.

• The pilot in command may delegate functions to other personnel, but retains

responsibility.
Date: 09.10.2015 Revision: Original

Page 11 of 15

Appendix A .1

List of Approved Pilots

Chief Pilot

Name : Scott Painter

Certificate Number : 550062391

Grade : Private Pilot

Medical Class/Date : Third 11-2014

Contact Number : (805) 890-1991

Pilots

Name : Will maintain on file

Certificate Number : at main RevUS office 

Grade : located at:

Medical Class/Date : 4909 Ruffner St

Contact Number : San Diego, CA 92111

Name :

Certificate Number :

Grade :

Medical Class/Date :

Contact Number :
Date: 09.10.2015 Revision: Original

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Appendix A .2

List of Approved Aircraft

Make and Model Registration Number

1. Freefly ALTA N532RU

2. Intuitive Aerial Aerigon SN: IA47 (RN Pending)

3. DJI S1000 SN: 02Q0024530 (RN Pending)

4. DJI Inspire 1 N869SP

5. Tarot T-15 N848SP

6. DJI Inspire 1 N533RU

7. DJI Phantom 3 SN: P76DCD23010363 (RN 

Pending)

8. 3DR Solo SN: S111A5705331 (RN Pending)

*Serial numbers will be replaced by registration numbers once registration is 

complete. No aircraft will be operated without an approved N-Number.
Date: 09.10.2015 Revision: Original

Page 13 of 15

Appendix A .3

RevUS Productions, Inc.

Permission Acquisition Form

In signing this form, I am giving the pilots of RevUS Productions, Inc. Permission to

operate their aircraft at less than 500 feet from property, or in some jurisdiction in which I

am responsible for or affiliated with, for the purpose of film or television production.

Name: 

Title:

Basis of Authority to Grant Permission:

Location:

Date of Operation:

Signature 

Date

RevUS Representative Receiving Permission
Date: 09.10.2015 Revision: Original

Page 14 of 15

Appendix A .4

Revision Letter

Rev# Section Page Action Remarks Initials

R  Remove and Replace D  Delete and Destroy N  Insert New Page

Manual Serial# Issued To 

Revised By 

Date

This form must be returned to the Chief Pilot no later than ____________________________
Date: 09.10.2015 Revision: Original

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