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 granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the 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 operate an unmanned aircraft system (UAS) to 

conduct aerial videography 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, and limited operating area associated with the 
2 

aircraft and its operation, the Secretary of Transportation has determined 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 material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

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

 They are similar in all material respects to relief previously requested 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 situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant 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 Aerial 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) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate 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 and 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 including payload. Proposed operations of 

any other aircraft will require a new petition or a petition 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 restriction. 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 the 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 and 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 communicate verbally at all times; electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the VO can perform the duties 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 discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised 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 which the FAA granted this exemption, then 
4 

the operator must petition for an amendment 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 affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations 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 functional 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 and 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. The 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 manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot 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 PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles 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 experience-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 during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants 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 meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility 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 private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight 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 Authorization (COA). All 

operations shall be conducted in accordance 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 under the terms of the attached COA. 

22. All aircraft operated in accordance 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 the 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 way 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 protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such 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 structures 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 essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller 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 Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

If this exemption permits operations for the 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 over the area of proposed filming. The 3-day 
7 

notification may be waived with 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 responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. 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; 

g. Signature of exemption holder or representative; and 

h. 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. 

31. Flight operations may be conducted closer than 500 feet from participating 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 all 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 Standards Service 

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

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

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Jan. 31, 2015

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, are writing 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 electric 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 unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophe. We, RDX Aerial, has developed and inacted Standard

1

 Appendix A - DJI Spreading Wings Manual

2

 Appendix B - A2 Manual

3

 Appendix C - Futaba Controller Manual
RDX Aerial Media LLC., Los Angeles, CA - Section 333 Exemption Petition 

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Operating Procedures4 to avoid and prevent public hazard, as well as manned aircraft 

hazards/catastrophe. 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 herein or as otherwise established by the FAA. 

For the reasons stated below, We, RDX Aerial, respectfully request the grant of an

exemption allowing us to operate ultra light weight, remote controlled UAS’s for 

academic community awareness to benefit/stimulate attraction to the Los Angeles

area and to enhance real 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)
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III. The 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 commercial 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 integration 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 with 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, stability and fear of financial loss we will not fly in winds exceeding 

13 knot (15 mph). Built in safety systems include a GPS mode that allows our UAS to 

hover in place when radio controls are released. With three modes to choose from, We

utilize the Safe Mode5 for aerial videography/photography. This is the safest, most 

reliable and stable 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 nor 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 approach 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 ten

(10) to fifteen (15) minutes, with an altitude under three hundred (300) feet. We, 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. 
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Aerial, utilize a fresh fully charged battery with each flight as a safety precaution; full

flight time limit for each battery is ten (10) to fifteen(15) 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 areas 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 our UAS/ultra light 

weight unmanned 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 well 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 does 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 videography 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 in 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 on 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 fuel 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. Granting Our, RDX Aerial Media's, exemption request furthers the public 

interest through 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 

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The public’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. Granting 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 Exemption 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 implementation of new and novel, as of yet undiscovered safety 

protocols for Realtors that can be embraced by the NAR6, CAR7, and BHLA8 for 

development in cooperation with the FAA. In addition We, RDX Aerial, submit the 

following representations of enhancements to current aerial videography and 

photography for real estate: 

 Our UAS weighs less than 15 pounds complete with gimbal and high resolution

Canon Mark III Camera; 

 We only operate our UAS below 300 feet (well within the 400 foot permissible 

ceiling set by the 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 enhance safety protocols; 

 We only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas; 

 We conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance; 

 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 danger. 

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 

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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 allows us to

remotely pilot 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 continue 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. 

14 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 a 
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safety/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 global 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, cockpit 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 placing 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 Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.F.R. § 61.133: Commercial Pilot Privileges and Limitations: PIC. 

Pursuant to14 C.F.R. § 61.133 (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 helpful, our operaters are required to hold this certification to pilot UAVs. The risks

attended to the operation ofour UAS is far less than the risk levels inherent in the

commercial activities 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. §61.113 (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 300 AGL; safely below the standard of 400 AGL. 

We, RDX Aerial, will however operate our UAS in safe areas away from public and

traffic, providing 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 or higher 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 Procedures
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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 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

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 

Regulations: 

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 and 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. Currently, 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 potentially 
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explosive fuel, is smaller, lighter and more maneuverable than conventional real estate

video and photographic aircraft with less flight time. Further, We operate at lower 

altitudes and 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 15 pounds 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 are willing 

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