1

 

 Applicant contact Information:

 Richard L Ronco

Owner

2800 Hickey Creek RD.

Alva, FL 33920

roncogroupllc@gmail.com

 

Jan, 20 2015

RE: Exemption Request under section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R. Part 11

To whom it concerns:

Ronco Group-Inspection Solutions Simplified, LLC located at 2800 Hickey Creek RD. Alva Fl 33920 and 

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

C.F.R. Part 11, respectfully requests exemptions from several provisions of the Federal Aviation 

Regulations ("FAR"), specifically Section 333 which authorizes the FAA to determine:

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight do not 

create a hazard to users of the national airspace system or the public or pose a threat to national 

security; and

2. Whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

I am writing to request Ronco Group-Inspection Solutions Simplified, LLC, owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations listed below so that Ronco 

Group-Inspection Solutions Simplified, LLC, may operate it’s multiple small unmanned aircraft systems 

(UAS) commercially in airspace currently regulated by the Federal Aviation Administration or (FAA); 

Ronco Group-Inspection Solutions Simplified, LLC would conduct all flight practices within and under the 

conditions outlined within FAA requirements established by Section 333. 

Ronco Group-Inspection Solutions Simplified, LLC owner/operator will be actively involved in providing a 

service of Real Estate videography and photography, Roof Inspection’s both residential and commercial 

applications, rural GEO mapping, construction time lapse imaging, tower surveying, FLIR aerial imaging

and potentially providing outsourcing for local fire department/first responder units to aid in patient 

recovery during situations such as natural or manmade disasters prevalent to SWFL region. 
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This request is similar to several previously granted exemptions and borrows many factual elements 

from Regulatory Doc No FAA-2014-0803 in that Ronco Group-Inspection Solutions Simplified, LLC would

be using small unmanned remote controlled aircraft within direct line of sight that will be within very 

strict as well as geographically small areas. Each aircraft used is outfitted with the mechanics needed to 

address each specific task at hand. Payload would never exceed that of the recommended maximum 

requirement per FAA UAV guidelines.

For example during a commercial application of inspection for an ASTM (American Society for Testing 

and Materials) structured water infiltration test on the exterior of a multistory structure, the UAS 

airframe would be outfitted with a FLIR (Forward Looking Infrared) video imaging device along with a 

high definition video camera. This allows for the utilization of a direct line of sight application of stories 

above the ground floor and below 400 feet maximum height. 

This provides a few benefits beyond previous applications:

1.) As it stands in order to perform such tasks, multiple inspectors and or water infiltration 

technicians are needed on the roof of the inspected structure. They would then need to repel 

every drop or set of windows. The set up procedure is a time restraint due to the high risk factor 

of hanging from a rope on the side of a structure and the need for inspection of repelling 

equipment. By using a UAV equipped with the previous stated equipment and utilizing the builtin Intelligent Navigation Modes to create autonomous flight paths and maneuvers, the need for 

repelling is no longer there. 

2.) This in turn significantly reduces man power, which reduces overhead costs and lowers the risks 

of liability providing for a safer alternative. Although Ronco Group-Inspection Solutions 

Simplified, LLC cannot provide statistical data as to how much the safety aspect increases, 

simply due to a lack of statistical studies performed with UAV, Ronco Group-Inspection Solutions 

Simplified, LLC can attest first hand from real world application. The UAV, once given specific 

flight parameters, can relay the FLIR video image to the ground station which allows for the 

recording of such procedures. 

3.) As a result it gives pin point locations as to where the water infiltration is taking place at the 

exterior envelope of the structure, by then viewing the recorded temperature differences with 

in the building materials. This reduces not only incurred overhead costs to Ronco GroupInspection Solutions Simplified, LLC but also to building owner and or developers by reducing 

hours of inspection to trace the origin of water entry. 

Such procedures would be performed within direct line of sight of remote operated UAV from a ground 

station, cordoned off prior to UAV flight and would remain until flight has been completed. Flight area 

would be specifically marked and predetermined to provide a high level of safety. 

The substance of this request is essentially the same as that granted to Low Country RC, Corporation or 

LoCoRC Regulatory Docket No. FAA-2014-0803. 

Ronco Group-Inspection Solutions Simplified, LLC requests exemption for the reasons that follow:

Ronco Group-Inspection Solutions Simplified, LLC submits this application in accordance with the Reform 

Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FAR's operating to prevent 
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Ronco Group-Inspection Solutions Simplified, LLC contemplated commercial inspections, research 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. Ronco Group-Inspection Solutions Simplified, LLC lightweight UAS's meet the 

definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of Ronco 

Group-Inspection Solutions Simplified, LLC lightweight UAS's are expressly contemplated by the Reform 

Act. Ronco Group-Inspection Solutions Simplified, LLC would like to operate its lightweight UAS's prior to 

the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. 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; Whether the UAS will be operated near airports or populated areas; and, Whether the UAS will be 

operated by line of sight. 

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for Ronco Group-Inspection 

Solutions Simplified, LLC. UAS's Ronco Group-Inspection Solutions Simplified, LLC uses multi counterrotating propellers for extreme balance, control and stability. They each typically weigh less than 55 

pounds, including camera or other equipment. Each of Ronco Group-Inspection Solutions Simplified, LLC 

small unmanned aircraft is designed to primarily hover in place and operate at less than a 50 knot 

maximum speed. They are capable of vertical and horizontal operations but operate only within the line 

of sight of the remote control pilot. In addition to the remote control pilot, Ronco Group-Inspection 

Solutions Simplified, LLC uses a camera operator, such that, at minimum, two Ronco Group-Inspection 

Solutions Simplified, LLC personnel govern the safe flight of an Ronco Group-Inspection Solutions 

Simplified, LLC aircraft at all times.

Utilizing battery power and not combustible fuels, flights generally last between five and twenty 

minutes. Ronco Group-Inspection Solutions Simplified, LLC does not operate its UAS's with less than 

twenty five percent battery capacity. Safety systems in place include a GPS mode that allows Ronco 

Group-Inspection Solutions Simplified, LLC UAS's to hover in place if communication with the radio 

control pilot is lost and then slowly descend the UAS at twenty five percent battery capacity. Further, 

Ronco Group-Inspection Solutions Simplified, LLC. Fleet is programmed, in some instances, to slowly 

follow a predetermined set of waypoints to return to a safety point if communications are lost.

Ronco Group-Inspection Solutions Simplified, LLC does not operate its UAS's near airports and generally 

does not operate them near populated areas. 

Ronco Group-Inspection Solutions Simplified, LLC operation of its fleet of small unmanned aircraft will 

not "create a hazard to users of the national airspace system or the public." 112 P. L. 95 § 3 3 3 (b). 

Given the small size and weight of Ronco Group-Inspection Solutions Simplified, LLC UAS's, combined 

with their operation in cordoned off and well-controlled areas, Ronco Group-Inspection Solutions 

Simplified, LLC fleet falls 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. Indeed, Ronco 

Group-Inspection Solutions Simplified, LLC UAS's have a demonstrable safety record and do not pose 

any threat to the general public or national security. The FAA has the authority to issue the exemption 

to Ronco Group-Inspection Solutions Simplified, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 

(1958), as amended (the "Act"). 
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Commercial and Public Benefits Granting Ronco Group-Inspection Solutions Simplified, LLC exemption 

request furthers the public interest. First, Congress has already pronounced 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. Second, Ronco Group-Inspection Solutions Simplified, LLC conducts research into safe 

UAS operations every time it flies one of its UAS's. Flight data, visual inspections, recorded observations 

and flight analyses are compiled to further enhance current safety protocols. Allowing Ronco GroupInspection Solutions Simplified, LLC to log more flight time directly relates to its research and its ability 

to further enhance current safety measures. Third, the public has an interest in reducing the danger 

associated with current aerial inspection methods, namely, resorting to physically climbing high or 

compromised structures to inspect.

Granting Ronco Group-Inspection Solutions Simplified, LLC exemption request substantially furthers the 

public's interest in ways known and currently unknown. Permitting Ronco Group-Inspection Solutions

Simplified, LLC to immediately fly within the United States furthers advancements in publicly usable 

technologies or advancements in equipment available to law enforcement personnel and first 

responders with state of the art equipment that does not cost millions of dollars. Reasons Why Ronco 

Group-Inspection Solutions Simplified, LLC Exemption Will Not Adversely Affect Safety or How the

Exemption Will Provide a Level of Safety At Least Equal to Existing Rule: Ronco Group-Inspection 

Solutions Simplified, LLC exemption will not adversely affect safety. Quite the contrary, for the various 

reasons stated, permitting Ronco Group-Inspection Solutions Simplified, LLC to log more flight time will 

allow.

Ronco Group-Inspection Solutions Simplified, LLC to innovate and implement new and as of yet 

undiscovered safety protocols.

Ronco Group-Inspection Solutions Simplified, LLC UAS's weigh less than 55 pounds complete with 

equipment payload.

Ronco Group-Inspection Solutions Simplified, LLC only operates its UAS's below 400 feet;

Ronco Group-Inspection Solutions Simplified, LLC UAS's only operate for 5-45 minutes per flight;

Ronco Group-Inspection Solutions Simplified, LLC lands its UAS's when they reach 25% battery power;

Ronco Group-Inspection Solutions Simplified, LLC remote control pilots operate Ronco Group-Inspection 

Solutions Simplified, LLC UAS's by Visual Line of Sight (VLOS).

Ronco Group-Inspection Solutions Simplified, LLC remote control pilots have video backup should they 

somehow lose sight of the UAS;

Ronco Group-Inspection Solutions Simplified, LLC staffs each flight with a remote control UAS pilot and 

camera operator;

Ronco Group-Inspection Solutions Simplified, LLC UAS's have GPS flight modes whereby they hover and 

then slowly land if communication with the remote control pilot is lost or battery power is below 25%;

Ronco Group-Inspection Solutions Simplified, LLC will actively analyze electronic flight data and use

sources of information to constantly update and enhance safety protocols;
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Ronco Group-Inspection Solutions Simplified, LLC will only operate in secured areas that are strictly 

controlled and are away from airports as well as populated areas;

Ronco Group-Inspection Solutions Simplified, LLC will conduct extensive briefings prior to flight, during 

which safety carries primary importance;

Ronco Group-Inspection Solutions Simplified, LLC will always obtain all necessary permissions and 

permits prior to operation;

Ronco Group-Inspection Solutions Simplified, LLC will provide a level of safety at least equal to existing 

rules, and in nearly every instance, greater than existing rules. It is important to note that in the absence 

of integration of commercial UAS's into our national airspace system, helicopters are the primary means 

of aerial photography. While the safety record of such helicopters is remarkably astounding, it is far 

safer to operate a battery powered lightweight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board and Ronco GroupInspection Solutions Simplified, LLC only operates 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 Ronco Group-Inspection Solutions Simplified, LLC UAS's 

allow our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when 

close enough to capture required images, Ronco Group-Inspection Solutions Simplified, LLC UAS's need 

not be so close to the objects they are focused on. Accordingly, Ronco Group-Inspection Solutions 

Simplified, LLC UAS's have operated and will continue to operate at and above current safety levels.

Summary the FAA may publish in the Federal Register:

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)(l). The size, weight and enclosed 

operational area of Ronco Group-Inspection Solutions Simplified, LLC UAS's permits exemption from Part 

21 because Ronco Group-Inspection Solutions Simplified, LLC UAS's meet an equivalent level of safety 

pursuant to Section 3 3 3 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

A. 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. Ronco Group-Inspection Solutions Simplified, 

LLC 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 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 at the flight operations center. The FAA has previously issued 
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exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 

10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar 

as Ronco Group-Inspection Solutions Simplified, LLC UAS's utilize electronic global positioning systems 

and internal gyroscopes to provide spatial coordination.

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 such certifications and registrations at the Ronco Group-Inspection Solutions 

Simplified, LLC flight operations center.

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. Ronco Group-Inspection Solutions Simplified, LLC UAS's 

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. The 

FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A 

and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. PIC Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), 

private pilots are limited to non-commercial operations. Ronco Group-Inspection Solutions Simplified, 

LLC can achieve an equivalent level of safety as achieved by current Regulations because Ronco GroupInspection Solutions Simplified, LLC UAS's do not carry any pilots or passengers. Further, while helpful, a 

pilot license will not ensure remote control piloting skills, though Ronco Group-Inspection Solutions 

Simplified, LLC pilot vetting and training programs (based upon completion of an FAA Approved Ground 

School and a self-administered UAS flight training program and internal procedures) will. All Further, the 

risks attendant to the operation of Ronco Group-Inspection Solutions Simplified, LLC UAS's is far less 

than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

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. Ronco Group-Inspection Solutions Simplified, LLC 

UAS's will never operate at an altitude greater than 400 AGL. Ronco Group-Inspection Solutions 

Simplified, LLC will, however, operate its UAS's in sectioned off areas with security perimeters, providing 

a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, 

weight, maneuverability and speed of Ronco Group-Inspection Solutions Simplified, LLC UAS's, and an

equivalent 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. 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 Ronco Group-Inspection Solutions Simplified, LLC should its requested exemption be 

granted. Ronco Group-Inspection Solutions Simplified, LLC conducts an extensive maintenance program 

that involves regular software updates and constant inspection for assessment of any damaged 

hardware. Therefore, an equivalent level of safety will be achieved. Ronco Group-Inspection Solutions 

Simplified, LLC has researched and developed its own designs. 
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F. Summary

Ronco Group-Inspection Solutions Simplified, LLC seeks an exemption from the following Regulations: 14 

C.F.R. 21, subpart H; 14 C.P.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.P.R.§ 

91.409 (a)(2); 14 C.P.R.§ 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to commercially operate its fleet 

of small unmanned vehicles and lightweight unmanned aircraft vehicles and to conduct its own research 

and to develop economic platforms for aerial survey, fire departments and first responders, search and 

rescue. Granting Ronco Group-Inspection Solutions Simplified, LLC request for exemption will reduce 

current risk levels and thereby enhance safety.

Further, Ronco Group-Inspection Solutions Simplified, LLC operates at lower altitudes and in controlled 

airspace. Ronco Group-Inspection Solutions Simplified, LLC expressly plans to analyzing flight data and 

other information in compiling novel safety protocols and the implementation of a flight operations 

manual that exceeds currently accepted means and methods of safe flight. There are no people on 

board Ronco Group-Inspection Solutions Simplified, LLC UAS's and therefore the likelihood of death or 

serious bodily injury is significantly limited. Ronco Group-Inspection Solutions Simplified, LLC operation 

of its UAS's, weighting less than 55 pounds and traveling at speeds lower than 50 knots in cordoned off 

areas will provide at least an equivalent level of safety as that achieved under current FARs.

Ronco Group-Inspection Solutions Simplified, LLC owner operator emphasizes the highest level of safety 

in all regards. Being an active professional Firefighter and Emergency Services Technician employed by 

The City of Fort Myers Florida for the past 15 years, Safety is my number one priority. The second

priority is to provide clients with the highest level of satisfaction I can obtain without sacrificing time and 

labor at their expense. The technology today affords us the ability to provide this service using the UAS’s 

for safer means of operation.

Ronco Group-Inspection Solutions Simplified, LLC respectfully requests that the FAA grant its exemption 

request without delay. The FAA has the authority to issue the exemption sought by Ronco GroupInspection Solutions Simplified, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended 

(the "Act").

By _____________________________________ For: Ronco Group-Inspection

 Solutions Simplified, LLC 

 Richard L. Ronco 2800 Hickey Creek Rd.

 Owner 239-872-0751

 roncogroupllc@gmail.com

References:
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Marino, Anthony J. (September 29, 2014). Low Country RC, Corporation - Request Review and approval 

of Petition. Retrieved from http://dronecenter.bard.edu/the-drone-exemptions/