RF Guys 

1802 Jan a Ln Morris Illinois 60450 Page 1 of 13 

March 13, 2016 

Docket Management Facility 

U.S. Department ofTransportation 

1200 NewJerseyAve.,SE 

Washington, DC 20590 

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

Aviation 

Regulations 

DearSiror Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. 

Part 11, RF Guys an operator of Small Unmanned Aircraft Systems ("sUAS") equipped 

to offer on-demand commercial sUAS operations for a number of varied industries and applications. 

These include: 

• Aerial search and rescue operational support • Infrastructure inspection 

• Agricultural monitoring and support • Industrial refinery and manufacturer plant inspection 

• Promotional Activities • Accident/Incident survey and investigative support 

• Utility-powertransmission system inspections and patrolling 

• Private security monitoring 

• Filmmaking, cinematography, andvideography • Pipeline inspection and patrolling 

• Aerial surveying and mapping • Wildlife and forestry monitoring 

• Construction site inspection and monitoring • Public Entity Support Operations 

• Maritime aerial operations • sUAS Consulting 

• Real Estate videography and imagery Cell tower inspection 

TABLE 1 

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure 

at least an equivalent level of safety to currently authorized operations using manned aircraft and under 

conditions as may be modified by the FAA as required by Section 333. 

Approval ofthis exemption would therebyenhance safety and fulfill the Secretary ofTransportation's 

(the 

FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements 

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

The name and address of the applicant are: 
RF Guys 

1802 Jan a Ln Morris Illinois 60450 Page 2 of 13 

RF Guys 

Attn: Brandon Kindelspire 

1802 Jana Ln 

Morris Illinois 60450 

Phone: 435.210.8249 

Email: bkspire@gmail.com 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. § 61.113(a) & (b); 

14 C.F.R. § 61.133(a); 

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.151(a); 

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. § 91.417{a} & (b) 

Appendix A describes each rule listed above and explains the factors exemptions pursuant to the 

proposal 

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

RF Guys submits that grant of this exemption application for use of sUAS to accomplish services 

described 

in Table 1 that will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate 

the 

introduction of UASs into the national airspace system ("NAS") if it can be accomplished safely. This law 

directs the Secretary ofTransportation to consider whether certain UASs may operate safely in the NAS 

before completion of the rule making required under Section 332 oft he Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users 

of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation oft he UAS within visual line of sight of the operator. 

Reform Act§ 333(a)(1). lfthe Secretary determines that such vehicles "may operate safely in the 

national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system." I d.§ 333( c} (emphasis added). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pi lots to operate aircraft in commercial service: 
RF Guys 

1802 Jana Ln Morris lllinois60450 

The Administrator may grant an exemption from a requirement of a regulation pre scribed under 

subsection (a) or (b) of this section or any of sections 4470244716 of this title if the Administratorfinds 

the exemption is in the public interest. 

49 U.S.C. §44701(f). See also49 U.S.C. § 44711(a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(1). 

The grant oft he requested exemption is in the public interest based on the clear direction in Section 333 

of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent 

level of safety surrounding the proposed operations; and the significant public benefit, including 

enhanced safety and cost savings associated with transitioningto UASs for aerial surveying and 

photography. Accordingly, the applicant respectfully requests thatthe FAA grant the requested 

exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

RF Guys will operate the following aircraft: 

1. DJI Phantom 3 Professional 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with t he limitations listed herein . These limitations provide for at least 

an equivalent or even higher level of safety to operations underthe current regulatory structure 

because 

the proposed operations represent a safety enhancement to operat ions that would be conducted w ith 

conventional aircraft. These conditions are drawn from Exemptions 11062 through 11067, 11080, 

11109, 

and 11110. 

These limitations and conditions to which Tailwind (or "operator") agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. Ope rations of the sUAS will weighs less than fifty-five (55) pounds (the "UA'' or "UAS"). Proposed 

operations of any other aircraft will require a new petition or a petition to amend this gran t .G 

2. The UA may not be flown at an indicated airspeed exceeding 50 knots. 

3. The UA may be operated at an altitude of no more than 400 feet above ground level ("AGL"), as 

indicated by the procedures specified in the attached manuals. All altitudes reported to Air Traffic 

Control ("ATC") must be in feetAGL. 

4. The UA must be operated within visual line of sight ("VLOS") of the pilot-in-command ("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. 

5. All operations must utilize a visual observer("VO"). 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. The PIC must be designated before the flight and cannot transfer 

his or her designation for the duration oft he flight. The PIC must ensure that the VO can perform the 

functions prescribed in the operator's manual. 
RF Guys 

1802 Jan a Ln Morris Illinois 60450 Page4 of 13 

6. The manuals must be amended to include all conditions and limitations required by the FAA. The 

manuals must be maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in the exemption and the procedures outlined in the 

manuals, the conditions and I imitations in the exemption take precedence and must be followed. 

Otherwise, the operator mustfollowthe procedures as outlined in the manuals. The operator may 

update or revise the manuals. It is the operator's responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. The operator must also present 

updated and revised documents if it petitions for an extension or amendment of this exemption. If 

the operator determines that any update or revision would affectthe basis upon which the FAA 

granted this exemption, then the operator must petition for amendment to its exemption. 

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating unti I the necessary maintenance has been performed, and the UAS is found to be in a 

condition for safe flight. The ground control station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records. 

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 

in accordance with the operator's manual. The PIC who conducts the functional test flight must make 

an entry in the UAS aircraft records of the flight. The manuals include this requirement. 

9. The preflight inspection section in the manuals includes the following requirement: the preflight 

inspection must account for all discrepancies, i.e., inoperable components, items, or equipment, not 

cove red in the relevant preflight inspection sections of the operator's manual. 

10. The ope rat or must foil ow RF Guys UA aircraft/ component, maintenance, overhau I, rep I acement, 

inspection, and I ife I i mit requirements, with particular attention to flight critical components that may 

not be addressed in the manufacturer's manuals. 

11. Operator must carry out its maintenance, inspections, and record keeping requirements in 

accordance with the manuals. Maintenance, inspection, and alterations must be noted in the aircraft 

logbook, i ncl udingtotal flight hours, description of work accomplished, and the signature of the 

authorized technician returni ngthe UAS to service. 

12. The authorized technicians must receive and documenttraining referenced in the manuals. 

13. Each UAS operated under the exemption must comply with all manufacturers system and safety 

bulletins. 

14. Operator's maintenance personnel must make a record entry in the UAS logbook or equivalent 

document of the corrective action taken against discrepancies discovered between inspections. 

15. The PIC must possess at least a private pilot certificate and a third-class airman medical certificate. 

The PIC must also meetthe flight review requirements specified in 14C.F.R. 61.56 as to the UAS. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 5 of 13 

16. The operator may not permit any PIC to operate unless that PIC has demonstrated through RF Guys 

training and currency requirements that the PIC is able to safely operate the UA in a manner 

consistent with how the UASwill be operated underthis exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures. 

17. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined 

location within the private or controlled-access property and land or be recovered in accordance with 

the manuals. 

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

with 

the manuals. 

19. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather 

conditions) there is enough powertoflyto the first point of intended landing and, assuming normal 

cruising speed, toflyafterthatforat least10 minutes. 

20. The operator will file a request fora Notice to Airmen (NOT AM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. 

21. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered 

in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in accordance with 

14 C.F.R. part 45, Subpart C. Markings must be as large as practicable . 

22. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission ("FCC") or other appropriate 

government oversight agency requirements . 

23. The documents required under 14C.F.R. 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. These documents must be made available 

to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and yield the right ofwayto all other manned operations and activities at 

all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, 

hang gliders, etc.). 

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

26. UAS operations may not be conducted during night, as defined in 14 C.F.R. 1.1. 

27. All operations shall be conducted in Class G airspace. 

28. All operations must be conducted under visual meteorological conditions ("VMC"). 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 3statute miles from the PIC. 

29. During operations in Class G airspace, the UAS may not operate within 5 nautical miles of the 

geographic center of an airport as denoted on a current FAA-publ ished aeronautical chart unless a 

letter of agreement with that airport's management is obtained, and the operation is conducted in 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 6 of 13 

accordance with a NOT AM as required by the operator's COA. The letter of agreement with the 

airport management must be made available to the Administrator upon request. 

30. The UAS may not be operated overcongeste d or densely populated areas unless the conditions set 

forth in #31 are satisfied. These populated areas include, but are not limited to, the yellow areas 

depicted on World Aeronautical Charts ("WAC"), Sectional Aeronautical Charts ("Sectionals"), or 

Terminal Area Charts ("TAC"). However, aeronautical charts may not reflect pertinent local 

information. Ultimately, it is the PIC's responsibility to maintain the mini mum safe altitudes required 

by§ 91.119. 

31. Operations must be conducted at least 500 feet from all nonparticipating persons (persons other 

than 

the PIC or VO), vessels, vehicles, and structures unless: 

a. barriers or structures are present that sufficiently protect nonparticipating persons from 

debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection.lf a situation arises in which nonparticipating persons leave 

such protection and are within 500 feet of the UAS, flight operations must cease immediately; 

and/or 

b. the aircraft is operated near vessels, vehicles, or structures where the land owner/controller 

has granted permission and the PIC has made a safety assessment of the risk of operating 

closer to those objects; and 

c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, per§ 

91.119(a). 

32. All ope rations shall be conducted over private or controlled-access property with permission from 

the 

land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

33. In the event CO As are required, 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. 

Privacy. All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge.lnspection will be in areas where the owners will have consented to the 

inspections or otherwise have agreed to allow the UAS and the operator to be in the area where 

inspection 

will take place. 

Summary 

In summary, RF Guys seeks an exemption from the FARs set forth in AppendixA to operate 

commercially a small unmanned vehicle (551bs. or less) in aerial survey and photographic operations. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 7 of 13 

Approval of this exemption for commercia I aeri a I survey and photographic operations wi II enha ncesafety by 

reducing risk. Conventional operations, us i ngjet or piston powered aircraft, operate at extremely low altitudes just 

feet from the subject being inspected and in extreme proximity to people and structures. Such manned operations 

present the risks associated with vehicles that weigh in excess of 6000 I bs ., carrying I a rge a mounts of combustible 

fuel. Such aircraft must fly to and from the project location. In contrast, as UAS weighing fewer than fifty five (55) 

I bs., and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible 

fuel carried on boa rd. The sUAS is carried to the area of flight and not flown. The sUAS wi II carry no passengers of 

crew and, therefore, wi II not expose them to the risks associated with manned a i rcraftfl ights . 

The operation of small UASs, weighing less than fifty five (55) lbs ., conducted in the strict conditions outlined 

above, wi II provide an equivalent I eve I of safety supporti ngthe grant of exemptions requested herein. These 

I ightweight aircraft operate at slow speeds, close to the ground, and in areas that are under the control of the 

customer. As a result, they are far safer than convention a I operations conducted with manned aircraft operating in 

close proximity to the ground and people. 

Satisfaction ofthe criteria provided in Section 333 of the Reform Act of 20 12--.size, weight, speed, operating 

cap a bi I ities, proxi mityto airports and populated areas, and operation within visual! ine of sight and national 

security-provide more than adequate justification for the grant of the requested exemptions a II owing commercial 

operation of applicants UAS for the purposes out! i ned here in and are consistent with exemptions already granted, 

including Exemptions 11062 through 11067,11080,11109, through 11112, and 11114. 

Sincerely, 

:B~~ Brandon Kindelspire 

RF Guys 

Sole Proprietorship 

1802 Jana Ln 

Morris Illinois 60450 
RF Guys 

1802 Jan a Ln Morris Illinois 60450 Page 8 of 13 

APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES 

SUBJECT 

TO EXEMPTION 

RF Guys requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAS: 

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

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

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. 

In all cases, an analysis of these criteria demonstrates thatthe UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than fifty-five (55) lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and underthe requirements and in compliance with 

local 

public safety requirements . The FAA wi II have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the pub I ic and property owners than conventional 

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

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

posed 

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

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

14 C.F.R. §45.23 (b): Display of Marks, General 

When marks include only the Roman capital letter 11N" and the registration number is displayed on 

limited, 

restricted or I ight-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 11limited," 11 restricted," 11lightsport," 

uexperimental," or ~~provisional," as applicable. 

An exemption is being sought given the size and design of the sUAS. The sUAS has no entrance near the 

cabin, cockpit or pilot station where the word 11Experimental"letters of not less than 2 inches nor more 

than 6 inches high can be displayed. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 9 of 13 

The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by 

§45.29 (f) where the sUAS air vehicle (AV) vehicleoperator(VO), AV visual observer, and others working 

with the sUAS will see the identification of the sUAS as marked appropriately with registered aircraft 

markings. 

Each RF Guys sUAS air vehicle shall be registered with the FAA and the FAA aircraft registration number 

shall be placed on the airvehicle in the largest practicable manner. The FAA has issued the following 

exemptions to this regulation to Exemptions Nos.10700, 8738, 10167 and 10167A. 

14 C.F.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot 

certificate may act as pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection 

with 

any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Unlike a conventional aircraft that carries a pilot, passengers, and cargo, no persons or property are 

being carried by the sUAS. 

The risks associated with the operation of the sUAS (given its size, speed, operational capabilities, and 

lack of combustible fuel) are greatly diminished from the level of risk associated with commercial 

operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft). 

Given these safety features,RF Guys proposes that operators of the sUas should not be required to hold 

a commercial pilot certification. Instead, operators should be required to hold only a private pilot 

certification . 

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

(a) No person may operate a civil aircraft unless it is in an airworthy condition . 

(b) The pi lot in command of a civil aircraft is responsible for determining whetherthat aircraft is in 

condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, 

electrical, or structural conditions occur. 

No airworthiness certificates are issued for the sUAS, should this exemption be granted, no FAA 

regulatory 

standard will exist for determining airworthiness. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 10 of 13 

Given the size of the aircraft and the requirements setforth in the sUAS manuals, an equivalent level of 

safety will be achieved by ensuring com pi iance priorto each flight. The FAA has granted exemptions to 

conduct similar operations in Exemptions 11062 through 11067, 11080, 11109, and 11110. 

14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard requirements 

(2) For which an Airplane or Rotorcraft Flight Manual is not 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. 

Given its size and configuration, the sUAS has no ability or place to carry such a flight manual on the 

aircraft, there is no pilot on board, and no room or capacity to carry such an item on the sUAS. The 

equivalent level of safety will be maintained by keeping the flight manual at the GCS within the reach of 

the sUAS vehicle operatorforimmediate access. The FAA has issued the following exemptions to this 

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, 

and 10700. 

14 C.F .R. §91.1 03: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of 

flight. As FAA approved rotorcraftflight manuals will not be provided for the aircraft an exemption will 

be 

needed. An equivalent level of safety will be provided as set forth hereinabove. The PIC will take all 

actions 

including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft I 

performance data before initiation of flight using appropriate checklists. 

14 C.F.R. §91.109: Flight instruction; Simulated instrument flight and certain flight tests 

Section 91.103 provides that no 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. 

sUAV's and remotely piloted aircraft, bytheirdesign do not have fully functional dual controls. Flight 

control is accomplished through the use of a radiotransmitterthat communicates with the aircraft via a 

receiver in the sUAVS. The FAA has approved exemptions forflighttrainingwithoutfullyfunctional dual 

controls fora number of aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers 

will be carried in the aircraft and by the size and speed of the aircraft. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 11 of 13 

14 C.F.R. §91.119: Minimum safe altitudes: General 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119( d) allows 

helicopters to be operated at less than the minimums prescribed, provided the pe rson operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is 

for a SUAVS and the exemption requests authority to operate at altitudes up to 400 AGL underneath 

navigable airspace and in class E and G airspace maintaining safe separation from actual aircraft, an 

exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the 

location where it is operated. No flight' will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming 

activity, attempts will be made to contact all affected individuals regarding the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum fifty five (55) lbs. proposed herein, and the lack offlammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft. In addition, the 

low-altitude operations of the SUAVS wi II ensure separation between these sUAVS operations and the 

operations of conventional aircraftthat must comply with Section 91.119. 

14 C.F.R. §91 .121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an 

altimeter that is set" ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the SUAVS rnay not have a barometric altimeter, but instead a GPS 

altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confi rming the altitude of the launch site shown on the 

GPS 

altitude indicator before flight. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 12 of 13 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

(a} No person may begin a flight in an airplane underVFR conditions unless (considering wind and 

forecast 

weather conditions) t here is enough fuel to fly to the first point of intended landing and, assuming 

normal 

cruisingspeed-

(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. 

(b) No person may begin a flight in a rotorcraft underVFR conditions unless (considering wind and 

forecast 

weather conditions) there is enough fuel to fly to the first point of intended Iandin g and, assuming 

normal 

cruising speed, to fly after that for at least 20 minutes. 

Section 91.151 (a} prohibits an individual from beginning "a flight in an airplane underVFR conditions 

unless (consideringwind 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 afterthat for at least45 minutes." 

The battery powering the sUAS has a 20-20 minute duration for powered flight. As a result, an 

exemption 

from 30 minute fuel reserve. 

RF Guys believe that an equivalent level of safety can be achieved by limitingfl ights to landing with no 

less than 25% of battery power remaining. This restriction would be more than adequate to return the 

sUAV to its planned Iandi ng zone from anywhere within its I i mited operating area. Similar exemptions 

have been granted to numerous otheroperations. 

14 C.F.R. §91.203 (a} and (b): Civil Aircraft: Certifications required 

(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 ce rtifi cat e ..... . 

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, 

the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration 

certification issued under the laws of a foreign country. 

(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. 

The sUAS fully loaded weighs no more than 55 lbs and typically less than 20 lbs. And is operated without 

an on board pilot. As such, there is no ability or place to carry certification and registration documents or 

to display them on the sUAS. 
RF Guys 

1802 Ja na Ln Morris Illinois 60450 Page 13 of 13 

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUA$ will have immediate access to them, to the extent they are applicable to 

the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

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

These regulations require that an aircraft operator or owner "shall have that 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 asp rescribed in part43 of this chapter ... ," 

and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, and the 

requirements of pre -flight inspection required herein, these sections will not apply to the applicant. 

Routine and pre-flight maintenance will be accomplished by the operator. An equivalent level of safety 

will be achieved because these sUAVS are very limited in size and will carry avery small payload and 

operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAV can land 

immediately and given its small size poses very little risk to persona or property. 

The operatorwill ensure that the sUA Vis in workingorderpriorto initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most 

familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.