May 15, 2015

Exemption No. 11594 Regulatory Docket No. FAA–2015–0480

Mr. Patrick Morehead RDX Aerial Media, LLC 1224 S. Corning Street, Unit 7 Los Angeles, CA 90035

Dear Mr. Morehead:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

By letter dated January 31, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of RDX Aerial Media, LLC (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to ope rate an unmanned aircraft system (UAS) to conduct aerial videogra phy and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Spreading Wings.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, a nd limited operating area associated with the2

aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pres ented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, RDX Aeri al Media, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a )(1), 91.409(a)(1) an d (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to ope rate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, RDX Aerial Media, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.3

1. Operations authorized by this grant of exemption are limited to the DJI Spreading Wings when weighing less than 55 pounds in cluding payload. Pr oposed operations of any other aircraft will requi re a new petition or a petiti on to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of th e PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or
U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC a nd VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability.
The VO and PIC must be able to communicat e verbally at all times; electronic messaging or texting is not permitted duri ng flight operations. The PIC must be designated before the flight and cannot tran sfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the du ties required of the
VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,
the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted this exemption, then4

the operator must petition for an amendmen t to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining a nd inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the
UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a
current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal
Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However,5

training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the
PIC at the Ground Control Station of the UAS any time the aircraft is operating.6

These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions
contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)
as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day7

notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;
d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;
f. A statement that the operator has obtain ed permission from property owners
and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and
h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/
John S. Duncan Director, Flight St andards Service

EnclosuresRDX Aerial Media, LLC.

, Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC.

, Los Angeles, CA - Sectio n 333 Exemption Petition Page 1 of 9 J an. 31 , 201 5

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14
C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

We

, RDX Aerial

, arewriting pursuant to the FAA Modernization and Reform Act of
2012 and the procedures contained within 14 C.F.R. 11, to request that RDX Aerial Media,
LLC. , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that We

, RDX Aerial , may operate our

small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein RDX Aerial Media Members

, are Certified Commercial Pilots in the
United States ; experienced in flying hobby helicopters for recreational purposes. Our Inventory includes a DJI Spreading Wings Octocopter with a Canon Mark III camera with
the intent for aerial videography/cinematography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical layout of the Southern California area, and augment real estate listing videos; following exemption and approval by the FAA. Thereby enhancing their academic research experience for the Southern California area.

Having flown small RC e lectric helicopters for over ten ( 10 ) years without incident. Committed to safety with each flight. RDX Aerial Media, LLC. , exemption request would permit operation of ultra light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. 3 Predetermined in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing videos/photos. Currently, similar lightweight, remote controlled UAS's are legally operated by unm onitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. We, RDX Aerial , h as developed and inacted Standard

1 Appendix A - DJI Spreading Wings Manual

2 Appendix B - A2 Manual

3 Appendix C - Futaba Controller ManualRDX Aerial Media LLC.

, Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC.

, Los Angeles, CA - Section 333 Exemption Petition

Page 2 of 9 Operating Procedures 4 to avoid and prevent public hazard, as well as manned aircraft hazards/cat astrophe. This will act to further safety protocols exclusive to lightweight
UAS's specific to real estate video and photography usage as We

, RDX Aerial

, record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting our, RDX Aerial Media's, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate
UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's ] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes. Further

We

, RDX Aerial, will conduct our operations in compliance with the protocols described he rein or as otherwise established by the FAA.

For the reasons stated bel ow, We, RDX Aerial , respectfully request the grant of an exemption allowing us to operate ultra light weight, remote controlled UAS’s for academic community aware ness to benefit/stimulate attraction to the Los Angeles
area and to enhance rea l estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard.

I. Contact Information:

RDX Aerial Media, LLC.
Patrick Morehead 1224 S. Corning St. Unit. 7 Los Angeles, CA 90035 Office: (651) 319-7933 Email: Patrick@rdxaerial.com

II

. The Specific Sections of Title 14 of the Code of Federal Regulations From
Which RDX Aerial Media, LLC. Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

4 Appendix D - SOP (Standard Operating Procedures)RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC.

, Los Angeles, CA - Sec tion 333 Exemption Petition

Page 3 of 9 III. T he Extent of relief RDX Aerial Media seeks and the Reason He Seeks Such Relief:

We, RDX Aerial, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent we, RDX Aerial Media, LLC. contemplated comm ercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. Our, RDX Aerial Media's, ultra light weight UAS
meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integra tion of our ultra light weight UAS is expressly contemplated by the Reform Act. We would like to operate our light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's ; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for us, RDX Aerial. Our UAS utilizes eight (8) counter-rotating propellers for balance, control and stability. Our UAS is equipped with GPS and auto return safety technology. Weighing less than fifteen (15) pounds (far below the max. 55 pound limit); including camera wi th gimbal.

RDX Aerial , considers safety as foremost with each flight. Our small unmanned aircraft is designed to hover in place via GPS and operate in less than a 13 knot (15 mph) wind. For safety, sta bility and fear of financial loss we will not fly in winds exceeding
13 k not (1 5 mph). Built in safety systems include a GPS mode that allows our UAS to hover in place w hen radio controls are released. With three modes to choose from, We
utilize the S afe Mode 5 for aerial videography/photography. This is the safest, most
reliable and st able mode to prevent accident and hazard. When pilot communication is lost UAS is designed to slowly descend to point of take off. No UAS operations near airports, Hospitals no r Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions
and weather. We are constantly on alert for any manned aircraft (Police/Medical helicopters, etc .) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach our location or we suspect manned aircraft may ap proach near our location. Our UAS is capable of vertical and horizontal operations, and are flown only within our line of sight of us , as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between t en ( 10 ) to fifteen ( 15 ) minutes, with an altitude under three hundred ( 30 0) feet. W e

, RDX

5 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. See Appendix A - Operator Manual.RDX Aerial Media, LLC.

, Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC.

, Los Angeles, CA - Section 333 Exemption Petition Page 4 of 9 Aerial

, utilize a fresh fully charged battery with each flight as a safety precaution; full flight tim e limit for each battery is ten ( 10 ) to fifteen (1 5 ) minutes as tested. We do not operate our UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of
control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. We do not believe in taking risk that

may cause a crash, that could create hazard to the public/property/manned aircraft,
and have no desire to lose an investment. We have clocked numerous practice flights in
remote area s as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. We have also developed a traing course manual
and outline for new members as well as current . All for the sake of safety.

We

, RDX Aerial Media' s, are e xtremely cautious when operating o ur UAS/ultra light weight unm anned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of our UAS it falls w ell within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. RDX Aerial Media ’s UAS, used in hobby flight, has a demonstrable safety
record and do es not pose any threat to the general public or national security.

IV. How RDX Aerial Media ’s Request Will Benefit the Public As A Whole:

Aerial videog raphy for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that the Los Angeles community has experienced i n the past with military aircraft and medical helicopter crashes within the
SoCal area

. Each resulting in loss of life. Each with combustible fuel that exploded
and burned o n impact. Police helicopters have made emergency hard landings within city limits. Our, RDX Aerial Media's , UAS pose no such threat since size and lack of
combustible f uel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the
Reform Act. Granti ng Our, RDX Aerial Media's , exemption request furthers the public
interest throu gh academic/visual awareness of the geographical benefits in and around
the Los Angeles area. Our ultra light weight UAS is battery powered and creates no
emissions that can harm the environment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.RDX Aerial Media, LLC.

, Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition Page 5 of 9 The publi c’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through our battery operated ultra light weight UAS's. Permitting us

, RDX Aerial Media , to immediately fly within national air space furthers economic growth. G ranting our exemption request substantially furthers the economic impact for the Los Angeles community for companies looking to relocate or build in the
SoCal area as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community.

V. Reasons Why RDX Aerial Media's Exemption Will Not Adversely Affect Safety Or How The Exemp tion Will Provide a Level of Safety At Least Equal To Existing
Rule:

Our, RDX Aerial Media , exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting us

, RDX Aerial , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow us to contribute to the
innovation and i mplementation of new and novel, as of yet undiscovered safety protocols for Realtors that can be embraced by the NAR 6

, CAR 7 , and BHLA 8 for development i n cooperation with the FAA. In addition We

, RDX Aerial , submit the following represent ations of enhancements to current aerial videography and photography for real estate:

Our UAS weighs less than 1 5 pounds complete with gimbal and high resolution
Canon Mark III Camera ; We only operate our UAS below 3 00 feet (well within the 400 foot permissible ceiling set by th e FAA Modernization and Reform Act of 2012);
Our UAS only operate for 10

- 15 minutes per flight;
We land our UAS prior to manufacturer recommended minimum level of battery

power; We pilot our

UAS through remote control only by line of sight;
Our UAS has GPS a flight safety feature whereby it hovers and then slowly lands
if communication with the remote control pilot is lost;
We actively analyze flight data and other sources of information to constantly update and enh ance safety protocols;
We only operate in reasonably safe environment that are strictly controlled, are away from power l ines, elevated lights, airports and actively populated areas;
We conduct extensive pre-flight inspections and protocol, during which safety carries primary imp ortance;
We always obtain all necessary permissions prior to operation; and,
We have procedures in place to abort flights in the event of safety breaches or potential dang er.

6 National Association of Realtors, http://www.realtor.org/

7 California Association of Realtors, http://www. car

. org /

8 Beverly Hills/ Greater LA Association of Realtors, http://www. bhglaar .com/RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

Page 6 of 9 Our,RDX Aerial Media's , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra light weight UAS. First, the potential loss of life is diminished because UAS's carry no people on
board and we only operate our UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of our UAS allow s us to remotely pi lot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, our

UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and

zoom. Accordingly, our UAS has been experimentally operated for familiarization/competency
and will cont inue to operate at and above current safety levels.

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

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

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of our

, RDX Aerial
Media ’s, UAS permits exemption from Part 21 because our UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Our

, RDX Aerial Media ’s, current and projected UAS's meet or exceed each of the
elements.

1 4 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining aRDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exempti on Petition

RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

Page 7 of 9 s afety/flight manual delineating areas of where safety can be defined. 10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes electronic glob al positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by us

, RDX Aerial Media

.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. Our UAS are, by definition, unmanned. They therefore do not have a cabin, co ckpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, We will mark our UAS in the largest possible lettering by pl acin g the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that we the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions No s. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.1 3 3: Commercial Pilot Privileges and Limitations: PIC.

Pursuant to14 C.F.R. § 61.1 3 3 (a - i, ii)

, Commercial pilots are not limited to commercial operations. We

, RDX Aerial , can achieve an equivalent level of safety as achieved by current Regulations because our UAS does not carry any pilots or passengers. Further, while helpfu l, our operaters are required to hold this certification to pilot UAVs . The risks attended to the operation of our UAS is far less than the risk levels inherent in the
commercial act ivities outlined in 14 C.F.R. § 61, et seq. Thus, allowing us

, RDX Aerial
Media , to operate our UAS and meet or exceed current safety levels in relation to 14 C.F.R. §61.1 13 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Our UAS will never operate at an altitude greater than 3 00 AGL; safely below the standard of 400 AGL. We, RDX Aerial , will however operate our UAS in safe areas away from public and traffic, providi ng a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS, an equivalent o r h igher level of safety will be achieved.

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

10 Appendix F - Safety ProceduresRDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

Page 8 of 9 The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”

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

, RDX Aerial Media 's,UAS. However, as a safety precaution we inspect our UAS before and after each flight as well as maintaining a maintanance log

.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of our UAS permits exemption from Part 21 because our

, RDX Aerial Media ’s, UAS meets an equivalent level of safety pursuant to Section 333 of
the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Our
UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation
of an aircraft w ithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, RDX Aerial Media seeks an exemption from the following Regulation s:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate our

, RDX
Aerial 's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community

awareness an d real estate operations, and to develop economic platforms for real estate to enhance the experience of those seeking to relocate to the Los Angeles area. Current ly, area awareness and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting our

, RDX Aerial Media ’s, request for exemption will reduce current
risk levels and thereby enhance safety. Our UAS craft do not contain potentiallyRDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition

RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition Page 9 of 9 expl osive fuel, is smaller, lighter and more maneuverable than conventional real estate
video and photographic aircraft wi th less flight time. Further, We operate at lower
altitudes a nd in controlled airspace eliminating potential public risk flying to and from
established air fields. We

, RDX Aerial Media have been informally analyzing flight
information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board our

, RDX
Aerial ’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. our

, RDX Aerial Media ’s, operation of our UAS, weighing less
than 1 5 pound s and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly We

, RDX
Aerial , respectfully request that the FAA grant our exemption request and arewilling to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

RDX Aerial Media, LLC.
Patrick Morehead 1224 S. Corning St. Unit 7 Los Angeles, CA 90035