R&M Aerial Imagery Page 1 

March 16, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or Madam: 

Attached please find R&M Aerial Imagery, LLC' s request for an exemption from the 

listed Federal Aviation Regulations to allow commercial operations of its Small 

Unmanned aircraft Systems ("sUASs") for aerial imagery and survey of; real estate, 

ground structure exteriors, research, development, test and evaluation of sUAS flight 

operations aerial support within the designated FAA low altitude restrictions for local, 

state, and federal government agencies. 

R&M Aerial Imagery, LLC is a veteran owned Virginia corporation. The company has 

over 30 years aviation flight experience in private and US Navy operations: mission 

planning, airspace de-confliction and management, airways navigation, airport takeoff 

and landing procedures (VFR and IFR), aviation safety, research, development, test 

and evaluation (RDT&E), airframe functional check flights, aviation accident 

investigations, scheduling, maintenance, aviation simulation, and standardized training 

and flight procedures. The two principals of R&M Aerial Imagery have 60 years 

combined experience in mechanics, electronics, electro-mechanical repair, and ground 

safety. The attached company Operations Manual outlines our safe and standardized 

operating guidelines for sUAS operations, training, maintenance, and documentations 

from flight brief to debrief. 

Thank you for your time and consideration, and please contact us with any questions. 

Ronald Stites and Michael Kitchen 

R&M Aerial Imagery, LLC 

March, 9 2015 

4412 Monmouth Castle Road 

Virginia Beach, VA 23455 

Stitesrp@gmail.com 

MichaelBKitchen@gmail.com 

757-408-3648 

757-292-0553 

 
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I. RELEVANT STATUTORY AUTHORITY 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act), R&M Aerial Imagery, LLC, (the operator); Ronald Paul Stites and Michael Brent 

Kitchen (the applicants), planned operators of Small Unmanned Aircraft Systems 

(sUASs) equipped to conduct aerial photography and survey for various industries 

hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow 

commercial operation of their sUASs, 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. 

As described more fully below, the requested exemption would permit the operation of 

sUAS by the applicants for commercial use that would provide the following benefits: 

1. Operations would be performed in an area of operation limited in size suitable to the 

specific use, briefed in advance of flight. 

2. The flight would be planned in advance to minimize hazards to persons and property 

in the air and on the ground. 

3. The operator would reasonably limit or control access to provide safety to those not 

involved in the operation. 

4. Operation of a sUAS would provide significant safety, environmental and other 

enhancements not possible by larger sized aircraft.

5. An FAA licensed airman will operate the sUAS. 

6. Provide a beneficial and currently unavailable service to government organizations 

and the general public that would serve the public interest. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrators) responsibilities to "establish requirements for 

the safe operation of such aircraft systems in the national airspace system." Section 

333(c) of the Reform Act. 

It is possible to operate sUASs so to not create a hazard to users of the National 

Airspace System (NAS), the public or pose a threat to national security if done so safely 

and responsibly. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicants propose that the exemption requested herein apply to civil aircraft that 

have the characteristics of sUAS and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or higher level of safety to operations 

under the current regulatory structure as the proposed operations represent a safety 
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enhancement to the already safe aerial commercial photography and survey operations 

conducted with conventional aircraft. 

The sUAS's to be operated are multi-rotorcraft (MR), each weighing 55 or fewer pounds 

including payload. They would operate, under normal conditions, at a speed of no more 

than 50 knots. The principal construction material of these sUAS craft lightweight 

composites and/or plastic. Operations will be performed by a qualified sUAS operator 

(the Pilot in Command, PIC), as outlined below, to insure that the sUAS will "not create 

a hazard to users of the national airspace system or the public." Given the small size of 

the sUASs involved and the pre-planned environment within which they will operate, the 

applicant believes that these operations fall squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of sUASs to commence immediately. Our 

standard sUAS operations (see attached Operations Manual) will prevent any possible 

national security issues. The operation of sUASs by knowledgeable professionals with 

experience in the NAS will serve to enhance safety, add to the public benefit and reduce 

environmental impacts related to current methods of aerial photography and survey. 

II. R&M AERIAL IMAGERY LLC PROPOSED OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF THE REFORM ACT 

R&M Aerial Imagery LLC shall abide by FAA regulations when conducting commercial 

sUAS flight operations. 

1. Safety is the first and foremost consideration for all sUAS commercial and flight 

training operations. 

2. The sUAS operator will be an FAA licensed airman (preferably Armed Forces 

veterans). 

3. sUAS Observers will assists the sUAS PIC with help in spotting and avoiding 

other air traffic, objects aloft, or ground hazards. 

3. All flights will be conducted within line of sight of the operator. 

4. The sUAS will weigh less than 55 pounds total. 

5. Flights will be operated in FAA designated sUAS airspace envelopes. 

6. The relevant airspace controlling agency will be notified as far in advance as 

practicable. For flights within 5 miles of an airport, the operator will provide the airport 

operator or the airport air traffic control tower (if the ATC is co-located at the airport) 

with prior notice of the operation. 

7. All flights will be operated under visual flight rules (VFR). 

8. The sUAS will give way to any aircraft carrying people. 

9. Minimum crew for each operation will consist of the sUAS PIC and observer. 

The Observer will monitor safety of flight and will be in voice communication with the 

PIC. 

10. Prior to a sUAS flight, the flight brief and FAA airspace requirements will 

establish the mission flight envelope. All collision hazards will be noted and safety 

procedures for ground personnel, property and flight emergencies will be defined. 

11. Flight planning will include flight completion with at least 25 percent (25%) battery 

power remaining as measured by the sUAS software. 
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12. All sUAS aircraft will utilize GPS navigation, failsafe, return-to-home (RTH) 

and/or flight abort safety features. 

13. All required permissions and permits will be obtained from applicable private, 

local, state, and federal governmental agencies. 

14. Written electronic and/or oral permission from relevant property owners will be 

obtained prior to an operation. 

15. The sUAS pilot will be a FAA licensed airman trained in advance for the safe 

operation of the sUAS to be operated. R&M Aerial Imagery’s training syllabus is outlined 

in our Operations Manual (attached). This will include operation of the sUAS both in 

normal and emergency modes of operation, and will include complete familiarization 

with the sUAS manufacturer operation manual. 

16. R&M Aerial Imagery representatives will establish a working relationship with the 

local FSDO to annually review safety procedures and other operations to further 

enhance safety. 

17. R&M Aerial Imagery will conduct research, development, test and evaluation of 

sUAS operations with government agencies and provide lessons learned to all 

interested parties. 

III. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

14 CFR Part21, Subpart H: Airworthiness Certificates 

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates and 14 C.F.R. §91.203(a)(I) 

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the sUAS selected provides an equivalent level of safety 

when compared to aircraft normally used for the same application. These criteria are 

met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, 

Docket No. F AA-2014-0352 at 13-14,22. If, however, the FAA determines that there are 

some characteristics of the chosen sUAS that fail to meet the requirements of the 

Reform Act, an exemption is requested. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew." A sUAS is too small to 

carry documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and meet the intent of 

91.203, we propose that documents deemed appropriate for this aircraft by the FAA will 

be co-located with the crew at the ground control station and available for inspection 

upon request. ln order to identify the aircraft, we propose the use of the sUAS' unique 

manufacturers serial number, and a contact telephone number be mounted on the 

sUAS on a placard of reasonable size in relation to the sUAS. ln the event that a unique 

manufacturers serial number is not available, the previously mentioned placard will be 

affixed to the sUAS consisting of the model name and number of the sUAS, as well as a 

contact telephone number. 
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A. Equivalent Level of Safety 

The sUASs identified in the Operations Manual are safe when taking into account their 

size, weight, speed, and operational capability. All of the sUASs weigh less than 55 

pounds and will be flown at less than 30 miles per hour. The sUASs carry neither pilots 

nor passengers, carry no explosive materials and or flammable liquid fuels, and operate 

exclusively within the parameters stated in the Operations Manual. 

For commercial hire, R&M Aerial Imagery will fly the DJI Inspire 1 with the following 

model specifications: 

Weight (Battery Included) 2935 g 

Hovering Accuracy (GPS mode) Vertical: 0.5 m Horizontal: 2.5 m 

Max Angular Velocity Pitch: 300°/s Yaw: 150°/s 

Max Tilt Angle 35° 

Max Ascent Speed 5 m/s 

Max Descent Speed 4 m/s 

Max Speed 22 m/s (no wind) 

Max Flight Altitude 4500 m 

Max Wind Speed Resistance 10 m/s 

Max Flight Time Approximately 18 minutes 

Diagonal Distance 559 to 581 mm 

Dimensions 438x451x301 mm 

DJI Remote Controller 

Operating Frequency 5.725~5.825 GHz 2.400~2.483 GHz 

Transmitting Distance (outdoor and unobstructed) 2 km 

If, in the future, R&M Aerial Imagery procures different models of sUAS (Other than DJI 

Inspire 1) for use in commercial operations, we shall provide the FAA with: model name, 

specifications, controlling frequencies, safety information, and maintenance plans and 

documentation. , 

2 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements 

of regulations prescribed pursuant to Sections 44701 (a) and (b) and Sections 

44702 - 44716). 

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek exemption. 

Operations under this exemption will be closely controlled and monitored by the 

operator and will be conducted in compliance with local public safety requirements, to 

provide security for the area of operation. R&M Aerial Imagery will provide the FAA with 

advance notice of all operations via coordination with the local FSDO. In all cases, the 
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sUASs operated under the proposed conditions, will be at least as safe as, or safer than 

conventional rotorcraft operating with an airworthiness certificate without the restrictions 

and conditions of the proposed sUAS operations. 

The aircraft themselves do not need a means to communicate with other aircraft or 

ATC. See Grant of Exemption, Docket FAA-2014-0352 at 13. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification 

of normal category rotorcraft. To the extent the Petitioner's sUASs would otherwise 

require certification under Part 27, Petitioner seeks an exemption from Part 27's 

airworthiness standards for the same reasons identified in the request for exemption 

from 14 C.F.R. Part 21, Subpart H, supra. 

C. 14 C.F.R. §§ 91.9(c), 4S.23(b) and 4S.27(a): Aircraft Marking and 

Identification Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

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. 

• 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces 

of the cabin, fuselage, boom, or tail the marks required by § 45.23. In a previous Grant 

of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are as large as practicable." 

Re FAA Docket No. FAA-2014-0352. 

Equivalent Level of Safety 

R&M Aerial Imagery will mark all aircraft with their N-Number in a prominent spot on the 

fuselage with markings that are as large as practicable. 

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 
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Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft- 

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

 (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate.(b) No person may operate a 

civil aircraft unless the airworthiness certificate required by paragraph (a) of this section 

or a special flight authorization issued under § 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

R&M Aerial Imagery does not request an exemption from this section but instead 

notifies the FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated 

August 8, 2014, the sUAS flight manual, registration certificate and other documentation 

will be kept at the control station with the PIC during flight. The Chief Counsel's Office 

has held that for all sUAS operations, this alternate method constitutes full compliance 

with the regulations. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption 

is required to the extent that the requirements of Part 21 are waived or found 

inapplicable. Accordingly, Petitioner requests that the requirements for Section 91.7 be 

treated in accordance with Section III (A), supra. 

F. 14 C.F.R. § 91.103: Preflight Action 

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information 

contained in the FAA-approved Flight Manual on board the aircraft. While the PIC will 

be familiar with all information necessary to safely conduct the flight, an exemption is 

requested to the extent that an FAA-approved Flight manual is required. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the company Operations 

Manual and flight manual provided by the manufacturer. The PIC will take all required 

preflight actions - including performing all required checklists and reviewing weather, 

flight requirements, battery charge, landing and takeoff distance, aircraft performance 

data, and contingency landing areas - before initiation of flight. The Operations Manual 

and manufacturer's flight manual will be kept at the ground station with the operator at 

all times. 

 
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G. 14 C.F.R. § 91.109(a): Flight Instruction 

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." sUASs and 

remotely piloted aircraft, by their design, do not have functional dual controls. Instead, 

flight control is accomplished through the use of a device that communicates with the 

aircraft via radio frequency. 

Equivalent Level of Safety 

Given the size and speed of the sUASs employed by R&M Aerial Imagery, an 

equivalent level of safe training can still be performed without dual controls because no 

pilot or passengers are aboard the sUASs, and all persons will be a safe distance away 

in the event that the sUASs experience any difficulties during flights. Training flights will 

be conducted with the provisions in the Operations Manual and in compliance with FAA 

approved sUAS airspace envelopes. Accordingly, R&M Aerial Imagery's proposed 

method of operation provides equivalent levels of safety. 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any 

person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). 

Section 91.119(d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes 

or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, and speed of the 

sUASs, as well as the location where it is operated. In order to avoid any risk to aircraft, 

flight operations will be restricted to 400' AGL or below. 

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

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

altimeter setting available within 100 nautical miles of the aircraft. This petition seeks 

an exemption from 14 C.F.R. § 91.12 I, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. The sUAS will normally will be 

flying close to the ground, and in line of sight of the PIC. This line of sight operation will 

provide separation from other aircraft, obstructions, terrain, and would override the use 

of an altimeter for such a purpose. 

 
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Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety can be achieved if the sUASs will 

be operated at 400' AGL or below and within visual line-of-sight in addition to GPS 

based altitude information relayed in real time to the operator. See Grant of Exemption 

to Astraeus Aerial, Docket No. FAA-2014-0352. As the attached aircraft Owner’s 

Manual indicates, the chosen sUASs meets these requirements, and a zero altitude 

initiation point will be obtained prior to flight. 

J. 14 C.F.R. § 91.1S1(a): Fuel Requirements for Flight in VFR Conditions 

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless 

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

point of intended landing and, assuming normal cruising speed – 

(1) During the day, to fly after that for at least 30 minutes; or 

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

Here, the technological limitations on sUAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30 minute reserve. R&M 

Aerial Imagery proposes that all flights comply with this requirement by mandating that 

the aircraft be safely landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety is provided if the UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of 

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352. 

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

Petitioner seeks an exemption from the maintenance inspection requirements contained 

in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 C.F.R. 

Part 43. See, e.g., 14 C.F.R. §91.405(a) (stating that each owner or operator of an 

aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ... have discrepancies repaired as prescribed in part 

43 of this chapter"). An exemption from these regulations is needed because Part 43 

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

sUAS will not have. 

 
R&M Aerial Imagery Page 10 

Equivalent Level of Safety 

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

be performed in accordance with the sUAS aircraft owner’s manuals and inspection 

recommendations. R&M Aerial Imagery has elected to use its own process to maintain 

its sUAS and ensure that only airworthy and safe sUAS will be allowed to operate in the 

NAS. Maintenance will be “on condition” for all aircraft. 

The Operations Manual also sets requirements for maintenance log books and record 

keeping as well as routine and post-flight maintenance. The Manual sets requirements 

for both annual maintenance and preventative maintenance based on hours of flight. 

L. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations 

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot 

certificate holders from flying aircraft for compensation or hire, and would also require a 

second class medical certificate. The purpose of Part 61 is to ensure that the skill and 

competency of any PIC matches the airspace in which the PIC will be operating, as well 

as requiring certifications if the private pilot is carrying passengers or cargo for hire. In 

this case, while the sUASs will be operated as part of a commercial operation, it carries 

neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-

0352, the FAA determined that the unique characteristics of sUAS operation outside of 

controlled airspace did not warrant the addition cost and restrictions attendant with 

requiring a PIC to have a commercial pilot certificate and class II medical certificate. 

Equivalent Level of Safety 

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot’s license rather than a commercial pilot’s license to operate a 

small sUAS. Unlike a conventional manned aircraft, a sUAS is remotely controlled by a 

ground-based operator. The operational area is controlled and restricted, and all flights 

are planned and coordinated in advance. The risks associated with the use of a sUAS 

are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 allowing sUAS use by a private pilot as the PIC exceeds the 

present level of safety sought by 14 C.F.R.§61.113 (a) and (b). 

IV. DRUG AND ALCOHOL PROGRAM 

R&M Aerial Imagery has policies in place to ensure that no person may act as a PIC, 

observer, or sensor operator if they are under the influence of alcohol or any drug. 

V. PUBLIC INTEREST 

Granting R&M Aerial Imagery exemption request furthers the public interest. National 

policy set by Congress favors early integration of UAS into the NAS in controlled, safe 

working environments such as those proposed in this petition. In addition, the public 

also has an interest in reducing the hazards and emissions associated with alternate 
R&M Aerial Imagery Page 11 

use of helicopters to conduct similar inspection operations. The sUASs in question are 

very light and do not carry any flammable fuel, further reducing the risk from any 

potential accident. 

R&M Aerial Imagery intended uses for the sUASs have real-world benefits for civilian 

markets, local, state and federal government entities and the public at large. This will 

allow R&M Aerial Imagery to inspect difficult to reach structures (smokestacks, 

chimneys, building roofs, etc.). R&M Aerial Imagery sUASs enable elevated viewpoints 

that are less expensive than traditional crane and boom operations with a smaller 

ecological footprint. The sUAS work will aid in R&M Aerial Imagery member companies' 

risk assessment, risk management, loss control, and surety performance programs. 

These programs prevent accidents and injuries, and there is a strong public interest in 

making these programs more effective through the use of sUASs. 

Coordination and teaming with federal, state and local governments in preparation for 

emergencies will provide valuable training and onsite information to first responders and 

government entities. 

VI. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding 

privacy. 

VII. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

R&M Aerial Imagery seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR § 61.113; 14 

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 

14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 

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

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent work with 

conventional aircraft and rotorcraft. 

VIII. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, 

weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within visual line of sight, and national security-provides more than adequate 

justification for the grant of the requested exemptions to permit R&M Aerial Imagery to 

operate the selected sUASs and provide opportunities for RDT&E in coordination with 

local, state and federal agencies. 
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Granting the requested exemption will benefit the public interest as a whole in, many 

ways, including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing operating 

costs compared with conventional flight operations.

If you have any questions or require any additional information, please do not hesitate 

to call or email. 

Ronald Paul Stites, 757-408-3648, stitesrp@gmail.com 

Michael B. Kitchen, 757-292-0553; michaelbkitchen@gmail.com 

Attachments: 

1) R&M Aerial Imagery Operations Manual, 

2) Inspire_1_User_Manual_v1.0 

3) Inspire_1_Maintenance_ManualV1.0