Revolutionary Unmanned Systems, LLC.

- SECTION 333 EXEMPTION REQUEST Page 1 of 

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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, 91.1 21, 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, 3 DR Iris+, Freefly Alta, and the Intuitive Aerial

Aerigon

THE UNMANNED AIRCRAFT (UA):

 The UA’s are lightweight (under 55l b. gross weight), battery operated multi Rotor copter s 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 camer a 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 a nd 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 O F THE SYSTEM:

 A Pilot in Command (PIC) I n operati onal 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, table t 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.

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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 per form 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, t he FAA can have full confidence that the operation wil l 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:

 Inspect ion 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 t he sensitive

nature of the site. I n Addition t he 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 enhanc ing 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.

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SUMMARY GRANT REQUEST :

This request follows many others using similar systems and process tha t have been grant ed 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.

TH E REGULATIONS FROM W HICH THE EXEMPTION S 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 C F R 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 C F R 91.109, 91.119, 91.12 1 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 p r e p a r e d to m odi f y o r a mend a n y p a rt of t his r e qu e st t o satis f y t h e n ee d for a n e quival e nt lev e l of

s a f e t y

. P le a se c onta c t us a t a n y t i me if y ou r e quire a ddi t ional info r mation or c la r ifi c a t i on. I am the

primary point of contact for this request and look fo r w a rd to w o r ki n g with y o ur o f f ic e

.

S inc e r e l y

,

John Santry , President

Revolutionary Unmanned Systems, LLC

4909 Ruffner St

San Diego, CA 92111

Phone: 8 04.852.7355

Email: john@revolutionaryus.com

Add e ndum C ont a in i n g Ex e mp t ion R e qu e sts a nd Equiv a lent L e v e l of S a f e t y

App e ndix A

– F l i g ht Operations/Procedures

App e ndix B

– User ’ s Man ua l s

Appendix C

- MPTOMRevolutionary Unmanned Systems, LLC.

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EXE M P TION RE Q UE S TS A N D EQUI V AL E NT L EVEL OF S A F ETY

I

, John Santry , President of Revolutionary Unmanned Systems, LLC, r e qu e st a n e x e mp t ion f r om t he

f ol l owing re g u l a t i ons a s w e ll a s a n y a ddi t ional r e g ulations that m a y t e c hnic a l l y a pp l y t o the

op e r a t i on s 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: Airwo rthiness Certificates 14 C.F.R. 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedura l requirements for the issuance

of airworthiness certific ates 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 Subpar t 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 airworthi ness 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 airworthin ess 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 ar ea. 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 c riteria 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 on ly the Roman capital letter "N" and the registration

number is displayed on limited, res tricted or light

- sport category aircraft or experimental or

provisionally certificated a ircraft, the operator must also display on that aircraft near each entrance to

the cabin, cockpit, or pilot stat ion, in letters not less than 2 inches nor more than 6 in ches high, the

words "limited," "restricted," "light

- sport, " "experimental," o r "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 havingRevolutionary Unmanned Systems, LLC.

- EXEMPTION REQUEST AND LEVEL OF SAFETY Page 2 of 

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the UA marked on its fuselage as required by 4 5.29 (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 e xemptions 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 reg ulatory 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 C F R 91.9 Civil air c r a f t f l ig h t m a nu al, m a r k i n g, a n d p laca r d re qu ir e m e n ts.

This r e g u l a t i on p r ovides that no p e rson m a y op e ra te a n a ir c r a ft unless a c u r r e nt, app r o v e d fli g h t

manu a l i s in t he a ir c r a ft. We a ssu m e that the intent of this r e quir e ment is to ensu r e that fl i g ht manu a l

i n f o r mation i s a v a i l a ble to the a ir c r e w while op e r a t i n g the a i r c r a ft. We re qu e st an e x e mp t ion t o th i s

r e quir e ment sin c e the a i r c r a ft is not on l y too small t o ca r r y do c u m e ntation; t he do c ument a t i on would

not be a v a i l a ble to the c rew during f l i g ht ope r a t i on s

.

To obtain a n e quival e nt l e v e l of s a f e t y a nd m e e t t he in t e nt of 91.9, we pr o pose that a c u r r e nt,

a ppro ve d U

A F l i g ht Operations/Procedures ( App e ndix A) must be a v a i l a ble to the c rew a t the g rou n d

station a n y t i me the a ir c r a ft is i n, or p re p a ring fo r

, f l i g ht.

T he 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 C F R 61.113 P r iva t e p i l ot p r iv i leg e s a n d l i m ita t io n s: P i l ot in C o m m a n d a n d 61.133 C o m m e rc ial p i l ot

p r iv i l e g e s a n d l i m ita t io n s.

The r e g ulation provid e s t h a t no pe r son th a t ho l ds a p riv a te pilot ce rtif i ca te m a y ac t as pilot i n

c om m a nd of a n a i r c r a ft f or c ompens a t i on or h i r e

. S ubp a ra g r a ph (b) a l l ows a priv a te pilot to a c t a s pilot

in command of a n a ir c r a ft in c onn e c t i on with a n y busin e ss or e m p l o y ment if: (1) T h e fli g ht i s on l y

inci d e ntal to t h a t bus i n e ss or e mp l o y ment; and ( 2) The a ir c r a f t does not c a r r y p a sse n g e rs o r p r op e r t y

f o r c ompens a t i on or hi r e

.

Our pro p osed o p e r a t i ons r e quire that the P I C must e i t h e r

1. Hold a Private or Sport Pilot C e rtifi ca te is s u e d b y the F AA, a nd h a ve l o g g e d 10 hou r s of f l i g ht

e x p e ri e n c e in t his t y

p e of U A , or

2. M ee t t he re qui r e ments of 8900.227 p a ra 16 ( c ) ( 2 ) ( c ) " Op e r a t i ons without a pi l ot c e rtifi ca t e " in

which the P I C is r e qu i r e d to complete " F AA p r ivate pi l ot g round ins t ruct i on" a nd p a ss " the

F AA P riv a te P i lot w ritten e x a m i n a t i on." S ince the r e a r e c u r r e nt l y no me a ns a va i l a ble for the

pilot of a U

A to g a in t he e

x p e ri e n c e in a n e quival e nt c a t e g o r y a nd c lass in ord e r to a pp l y f o r a

private p i l ot '

s l i ce nse, we pro p ose to g e n e r a te a n e quiva l e n t l e v e l of s a f e t y b y r e quiri n g ourRevolutionary Unmanned Systems, LLC.

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p i l ots t o c omp l e te, a t a min i mu m

, F AA private pi l ot ground ins t ru c t i on a nd p a ss t he F AA

Private P i l ot w r i t ten e x a m i n a t i on in add i t i on to c omp l e t i ng the p r i v a te p i lot re quir e ments.

S ince t he a ir c r a

ft c a nnot c a r r y p a sse n g e rs o r p r op e r t y , we f e e l that we me e t t he in t e nt of

61.113 S ubp a ra g r a ph ( b ) e v e n tho u gh the intent of th i s ap p l i ca t i on is to c ondu c t a business.

14 C F R 91.109 F l i g h t I n st r u c tion; S i m u lat e d i n st r u me n t f l i g h t and c e r tain f l i g h t te sts

The r e g ulation stat e s that " No p e rson m a y op e r a te a c iv i l air c r a ft th a t i s be i ng used for f l i g ht

instru c t i on unless that a ir c r a ft h a s ful l y fun c t i oning du a l c ontrols."

The UA’s g roun d

- b a s e d c ontrol station c o nsi s ts of a small h a nd

- h e l d r a dio t r a nsm i t t e r a nd while it does

not of f e r a se c ond s e t of " c ontro l s " , both t he student a nd i nstru c tor ca n, a nd wil l , op e r a te the si n g le s e t

of c ontrols si m ul t a n e ous l y

. W i t h both student a nd instru c tor h a ving " h a nds

- o n " the c ontrols d u r ing

f l i g ht, we f

e e l t h a t t his t ec hnique m ee ts t he i ntent 91.109 a nd p r ovides a n e quiva l e nt le v e l of s a f e t y

.

14 C F R 91.119 M i n i m u m sa f e altitu d e s: G e ner al.

The re g ulation stat e s that ov e r sp a r s e l y popu l a ted a r e a s t h e a ir c r a ft ca nnot be op e r a t e d c loser than

500 fee t t o a n y p e r s on, v e ssel, v e hicl e , or st r u c tur e

. S ince the a ir c r a ft will be op e r a t i n g a t a ma x i m um

of 4 00 fee t A G L

, we c a nnot comp l y w i t h th i s r e quir e m e nt.

I n o rd e r to pr o vi d e a n e q uival e nt l e v e l of s a f e t y The UA ’s will not be op e r a ted ov e r c ong e sted a r e a s o r

ov e r a n y o p e n a ir a ssemb l y o f p e rsons with out prior approval. Any property owner affected w i l l be

b r i e f e d on the e x

p ec ted r oute of flight a nd the a ssoci a ted risks to p e rsons a n d p r op e r t y on the g roun d

. The a ir c r a ft will be o p e rated a t a low a l t i t ude a l l o win g , if a pow e r unit f

a i l s, an e me r g e n c y land i ng

without undue h a z a rd to pe r sons or p r op e r t y on the su r f a c e . Th e r e

f o re we maintain t h a t due to the

sm a ll si z e of the UA, the h a z a rd to p e rsons, v e hicl e s and stru c tur e s is m i ni m a l comp a r e d to mann e d

a ir c ra ft, whi c h should be c ons i d e r e d in g r a nt i ng the e x e mp t ion.

14 C F R 91.121 A lt i m e ter S e t ting s

.

The r e g ulation r e quir e s t h a t air c r a ft sh a ll mainta i n c ruising a l t i t ud e s b y r e f e r e n c e to an a l t i m e ter

s e t t ing a v a i l a b l e with i n 100 NM of the a i r c raft.

The UA will a lw a y

s f l y b e low 4 00 fee t A G L a nd will n o t ne e d to m a in t a in c r uis i ng a l t i t ud e s in o r d e r to

p re v e nt c onfli c t with other a ir c r a ft. An A bove G r ound L e v e l a l t i m e ter me a s u r e ment a bove the t a k e o f f

point is t r a nsm i t t e d via ra dio f r o m t he UA’S on

- bo a rd c o m puter to t he disp la y s c r e e n h e ld b y the P I C,

p rovi d ing a c onst a n t l y up d a ted A G L r ea dout.

14 C F R 91.151 F u e l r e q u ir eme n ts f or f l i g h t in VFR c o nd itio n s.

The r e g ulation provid e s t h a t no pe r son m a y b e g in a f l i g ht i n a n a irpl a ne u n d e r d a y

- V F R c ondi t ions

unless the r e is enou g h fu e l t o f l y to t he fi r st po i nt of in t e nd e d la n ding a nd to f l y a ft e r that f or a t l ea st

30 m i nutes.

The in t e nt i on of th i

s pa r a g r a ph is to provi d e a n e n e r g y r e s e r v e a s a s a f e t y buf f e r f o r d e l a y s to l a ndi n g

. Each U A is batt e r y op e r a ted a nd the m a x i m um dur a t i on o

f f l i g ht f rom a sin g l e b a t t e r y c h ar g e is 18Revolutionary Unmanned Systems, LLC.

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m i nutes with a 20% re s e rv e

. S ince the a i r c raft will n e v e r f l y mo r e than 3/4NM f

r om t he point of

intend e d landi n g

, a f ull b a t t e r y c h ar g e a t l a un c h will e nsure that w e me e t the re s e r v e e n e r g y

r e qui r e ment of th i

s pa r a g ra ph. W

e re qu e st a n e x e mp t ion t o the w o r d "fu e l " a nd a sk for a n e quival e nt

in t e rp re tation wi t h the w o r d "en e r g y ".

14 C F R S ubp a r t E ( 9 1.401

- 91.417)

- M ai n t e n a n ce , P re v e n tive M ai nt e n a n ce , Alt e r a t io n s

The r e g ulation provid e s t h a t t he op e r a t o r is p r i m a r i l y re spons i ble f o r maintaining the a ir c r a ft in a n

a irwo r t h y c ondi t ion, i n c lud i ng c omp l ia n c e wi t h p a rt 39 a nd 43. P a ra g r a phs 91.407 a nd

91.409 re quire that the a i r c raft be " a ppro v e d for return to se r vice b y a p e rs o n a uthori z e d und e r

43.7" a ft e r m a in t e n a n c e a nd insp ec t i on.

I t i s our intention t h a t t he P I C p e r fo r m m a in t e n a n c e a nd inspe c t i on of the a i r c raft a nd " be a uthori z e d to

app r ove the a i r c r a

ft f or r e turn to se r v ic e ." As p r ovided in the P r e

- F l i g ht C h ec kl i st in App e ndix A, the P I C

will e nsure that the a i r c raft is i n a n a irwo r t h y c on d i t ion prior to e v e r y fli g ht and in addit i on c o n du c t

det a i l e d insp ec t i ons a

ft e r e v e r y two ho u rs of f l i g ht. Mainten a n c e p e r

f o r med b y t h e P I C is l i m i t e d to

r e p a iring small c r a c ks, r e pl a c ing a p r o p e l l e r, c h ec ki n g e le c tri c a l conn e c t i ons a nd upd a t i ng soft w a re a nd

f irmw a re f

o r the on

- b o a rd c ompu t e r. All o t h e r mainten a n c e will be p e r f o r med b y t h e m a nu

f ac tu r e r or

their d e si g n a ted r e p a ir f

a c i l i t y . The P I C will do c ument wo r k p e r f o r med in acc o rd a n c e wi t h 91.417. We

fee l t h a t d ue to t he si

z e

, c onstru c t i on, a nd simp l ici t y of the a i r c r a ft, the P IC ca n e nsure a n e quiva l e nt

l e v e l of sa fe t y

.

8900.227 P a r ag r a p h 16( c ) ( 4) P I C Me d ical. And P a r a g r a p h 16( e ) ( 1 ) Ob s er v e r Me d ical.

This po l i c y pro v ides that both t he P I C a nd VO m u st have a v a l i d F AA s e c o n d

- c lass medi ca l ce rtifi c a te

issued und e r p a rt 67 in ord e r to pe r f o r m a s a pilot or o b s e rver.

The UA’s ma x i m um g ross w e i g ht are each less than 8l bs., are constru c ted primarily of, plastic and

carbon fiber. T

he P I C is not on boa r d. B oth t he P I C a nd the V O a re r e quir e d to be in V LO S . Giv e n t h e

unl i k e l y e v e nt t h a t bo t h the P I C a nd VO b ec ome m e dic a l l y in c a p ac i t a ted while the a ir c r a ft is i n fli g ht,

t he UA will re turn a utono m o us l y to t he si t e of laun c h i ng a nd l a nd without c r e w in t e rv e nt i on. Th e r e f o r e

,

r e quiri n g the P I C a nd VO to me e t t he s a me m e d i ca l r e quir e m e nts a s commercial pilot carrying

passengers in a l a r g e a i r c r a ft is a n u nn ece ss a r y burd e n.

W e pro p ose th a t t he m i ni m um m e dic a l r e quir e m e nts for the P I C a nd VO b e vis i on c o r re c ted to

20/20 and a v a l i d, st a te i s sued d r ive r '

s l i ce n s e . The 20/20 v i

sion r e quir e me n t wi l l ensu r e that the P I C

and VO ca n 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 AN D PROCEDURES AP P E N DIX A

– F LIG H T OPERATIONS/PROCEDURES

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

OPERATIONAL F L I G HT RE S TRI C T I ONS

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 voi ce 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 wi ll not be operated over densely populate d 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 h eliport; without prior approval

 Ope rations will be restricted to day only and weathe r 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 operati on to

ascertain that the UA is in a condition safe for flight

P RE

- F L I G HT CHECKLI S T

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 AN D PROCEDURES

TAKE OFF/LANDING PROCEDURES

Manufacturer recommended Takeoff and Landi ng 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 unti l 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, p ull 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 wil l 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 of f.

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

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

essentially reducing the distance the signal can travel.

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

OPERATIONS RELATED TO MOTION PICTURE AND CLOSED SET FILM MAKING

T he 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 t he 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, mode l, 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 AN D 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 AP P E N DIX B

– USER’S MANUAL S

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 providedRevolutionary 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 BusinessDate: 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. P l a n o f Ac ti v iti e s 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. Company Organization

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) 14Date: 10

. 19 .2015 Revision: Original

Page 3 of 15 

## Revision Control Page

Revision# Date InitialsDate: 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 " R ev US ", 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. Rev US 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/Operator Organization

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 le vel 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

Rev US '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, Rev US 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 Rev US 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. Rev US personnel will assure a sufficient number of those

forms are available at the job site. Written permiss ion 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 proceduresDate: 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 Rev US 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 certi ficate 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

Page 8 of 15 

### (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 starti ng 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/Stop Procedures

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

Page 9 of 15 

## O. Special Provisions

The controls, procedures, and conditions set forth in the Rev US 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 Rev US 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.

Rev US 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 Rev US 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

Rev US

.

• 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

Rev US 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

Page 1 2 of 15 

## 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

Rev US Productions, Inc.

Permission Acquisition Form

In signing this form, I am giving the pilots of Rev US 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

Rev US Representative Receiving PermissionDate: 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

Page 15 of 15