October 261

h, 2015 

James Pimley 

RPM Logistics. Inc [RPML] 

33470 Chinook Plaza 

Scappoose, Or 97056 

To whom it may concern, 

. ) 

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

C F.R. Part 11, James Pimley operator at RPM Logistics seek an exemption from Federal Aviation 

Regulations detailed herein for the operation of lightweight aerial imaging equipment, also referred to 

throughout as Unmanned Aerial Systems (UAS), as well as their ground based operation equipment 

described-within. RPM Logistics, INC will be referred to as RPML. 

For photography and videography for advertising and real estate, wildlife monitoring, and wildland 

fire suppression and documentation efforts, in c;ompliance with all FAA and Forest Service air space 

rules and regulations. 

Our operation will include: 

• Real Estate Photography and Videography 

• Commercial Advertising Video and Photography 

• Wildlife Monitoring 

• Wildland Fire Suppression and Videography 

• FREE services offered to our community, fire fighters, educators and law enforcement. 

• RPML is a federally designated Critical Resource (Agreement AG-0248-B-14-7086 from OF-294) 

participating in disaster response and is on the National ROSS (Resource Ordering and Status 

System) list. 

When public and private property, watersheds and forest resources are at risk, it is in the 

public interest for RPML to have UAS available for managing, monitoring and controlling 

incidents on a case by case basis. 

• RPML flies with a hand held aircraft radio set on local frequencies to keep track of 

aircraft such as crop dusters and experimental planes.below 400 AGL. 

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RPML UAS include the following: 

Solo by 3DR Robotics 

(RPM 111) 

The Solo system includes Solo, the Controller, and the Solo App. As the operator, you interact 

with the controller and app on the ground and the controller communicates with Solo during 

flight. 

Estimated flight time 

Default maximum altitude 

Range 

Payload capacity 

Cruise speed 

Maximum speed 

Wind speed limitation 

Operating temperature 

up to 25 minutes* 

150ft. {46 m) above 

ground level** 

.5 miles*** {.8 km) 

lib. (450 g) 

18 mph {8 m/s) 

33 mph {15 m/s)**** 

25 mph (11 m/s) 

3r F- 113° F (0° c to 45° 

C) 

The altitude and distance are set in a geo-fence which is part of the Solo programming. 
Iris Plus by 3DR Robotics 

{RPM 333) 

IRIS is a personal aerial imaging platform powered by open-source hardware, software, and 

firmware. 

Weight with battery: 1282 g 

Payload capacity: 400 g (.8 lbs) 

Radio range: up to 1 km (.6 miles) 

Flight time: 16-22 minutes* 

A safety fence restricts IRIS·to within 300 meters (980 feet) of the launch point and under 100 

meters (320 feet) in altitude. If IRIS reaches the edge of the geo-fence it will stop until operator 

returns it to the starting point. 
Phantom Vision by DJI 

(RPML222) 

The Phantom Vision is a small quad copter that uses GPS to maintain its location 

and flight direction. This quad copter has built is safety settings that keep it out of 

flight paths and to close to airports: 

Ready to Fly mode 

Zone Restriction DJI VISION App Notification 

Rear LED Flight 

Indicator 

No-fly Zone Motors will not start. 

Warning: You are in a No-fly zone. 

Take off prohibited. 

If the Phantom enters the restricted area in Ready to Fly (non-GPS) mode but Ready to 

Fly mode activates, the Phantom will automatically descend to land then stop its motors after landing. 

Warning: You are in a No-fly zone, automatic landing has begun. (If you are within 1.5 mite radius) 

Restricted-altitude flight zone. 

If the Phantom enters a restricted area in Ready to Fly (non-GPS) mode and Ready to Fly mode 

activates, it will descend to a safe attitude and hover 15 feet below the safe altitude. 

Warning: You are in a restricted zone. Descending to safe altitude. (If you are between the range of 1.5 

mile and 5 mile radius) 

Maximum payload 1350g 

Operating Frequency 5.728 GHz-5.85 GHz 

Communication Distance (open area) CE Compliance: 300m; FCC Compliance: 500m 

Transmitting Power (EIRP) CE Compliance: 2SmW; FCC Compliance: 125mW 

Range Extender 

Operating Frequency 2412MHz- 2462MHz 

Communication Distance (ope~ area) 300m 

Transmitting Power 17dBm · 
I. FLIGHT 10 I NO.: 

FLIGHT LOCATION:--------- w~ ---------------------

UNMANNED AIRCRAFT SYSTEM: 

MANUFACTURER:·. 

MODEL NUMBER: 

PREFLIGHT CHECKLIST: 

U Batteries Charged & SecurA 

0 Aircraft Hardvllare OK 

0 Equipment & Gear OK 

0 Transmitter Controls OK · 

CREW: 

PILOT: 

SPOrreR: ----------

0 Props OK & llght 

0 Software I FirmWQt'!l Update 

d Transmitter Control Povller ON 

0 Ain:rafl: Power ON 

0 llompass Calibration 

0 Cemlllp/FPVON 

0 Satellite Connection 

D Applications I Other Systems ON 

OPERATIONAL CONDffiONS & PREFLIGHT NOTES: "' 

I .. REMAAKS SESSION FLIGHT FLIGHT TIMES 

INTERVALS ... ---.....,.~ 

- .. ------------· ···------··-- START srOP TOTAL PROCEDURES & MANEUVFRS 

1. 

2. 

3. ... 

4. 

5. 

fl. 

7. 

8. 

9. 

10. 

TOTAL HOURS 

FOR SESSION 

TOTAL FORWARD ! 

TOTAL TO DATE 

110 
II. FLIGHT MAP Month __ _ 

' . 

POSTFLIGHT NOTES I JOURNAL ENTRIES: 

I CERTIFY THAT THE FOREGOING ENTRIES ARE TRUE AND CORRECT: 

Day _ _.___ 

4 

" 

Year 

~lO~------------------------------- SPOTTER:-------------------'-------

109 
The current regulations that we seek exemption from are: 

A. 14 CFR Part 21 (h) Airworthiness Certification 

Under this part we seek exemption to apply for and maintain airworthiness certification for our 

UAS. Model and serial number of our UAS will be provided within. 

B. 14 CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness 

We seek exemption from this part, as we will keep our UAS in a safe, reliable, and airworthy 

condition, it may not meet all standards as set for by this part of the FAR's. Operator will assume 

all responsibility for determining that the UAS is in a condition safe for flight, as well as a 

condition that will not harm other people or property. This will be accomplished using specific 

guidelines from the manufacture 3DR robotics, DJI, as well as following any guidance set for 

routine maintenance. 

C. 14 CFR Part 91 Subpart C: 91.203: Certifications Required 

• We seek exemption from this part as an airworthiness certificate does not apply to our specific 

UAS 

Under this part, (a) no person may operate an aircraft unless it has within it the following; an 

appropriate and current airworthiness certificate. This part also includes regulations regarding 

the use of fuel tanks, which do not apply because it operates on battery power only. 

D. 14 CFR Part 91 Subpart B; 91.119 Minimum Safe Altitude 

• We seek exemption from this part due to the nature of the operation, as well as the safety 

procedures set forth will have little to no risk of damaging any person or structure. 

Under this part, (a) no person may operate an aircraft below an altitude allowing, if power fails, 

an emergency landing without undue hazard. (c) Over other than congested areas an altitude 

below 400ft AGL. 

E. 14 CFR Part 91 Subpart 8; 91.121 (a)(1) Altimeter Setting 

• This section pertains to setting an altimeter setting below 18000ft to a reported altimeter 

reporting station setting. 

• We seek expedition from this part as our UAS has no way of setting an alternate altimeter 

setting. Operating less than 400ft AGL, we feel our UAS will have little to no impact on other 

. participating aircraft. Also our UAS will not need to recalibrate its altimeter while in flight. 

F. 14 CFR Part 91 Subpart B; 91.151 Fuel Required for VFR flight 

• This section contains requirements for fuel in VFR flight for combustion engines. 

• We seek exemption from this part as our UAS operates off of battery power only. We feel our 

operations will not compromise safety to either the operator or property as we have set forth a 

procedure to land our UAS when the battery level reaches 25%, or approximately 5 minutes 

flight time remaining. 

G. 14 CFR Part 91 Subpart E; 91.405 Maintenance Required 
• This section contains requirements for the operator to maintain and have inspected the 

aircraft in accordance with Part 43 of the CFR. Under this section it is required to keep 

maintenance logbooks with the aircraft. It also requires the aircraft to contain placards of the 

. inoperative equipment. 

• We seek exemption from this part as our UAS will not be operating with inoperative 

equipment and is too small to carry logbooks. We also seek exemption due to no certified 

maintenance technicians will work on the UAS. Under this exemption RPM Logistics will be 

completing pre-flight and post-flight inspections, and any required maintenance or repairs will 

be completed by the manufacturer or one of its certified technicians. 

H. 14 CFR Part 91 Subpart E; 91.407 Operation After Maintenance 

• This part requires an aircraft that has undergone repair, rebuilding, alterations, or general 

maintenance to be approved by an authorized person required by CFR 43.9 and CFR 43.11. 

• We seek exemption from this part as these inspections do not pertain to our operation of the 

UAS. The operator will be responsible for determining the airworthiness of the UAS prior to each 

flight. After maintenance provided by the manufacturer, the operator will complete test flights 

before any operation in the vicinity of persons or property to assure all systems are functioning 

normally. 

I. 14 CFR Part 91 Subpart E; 91.409 Inspections 

• This section provides details of the required inspection on an aircraft. No person will operate 

an aircraft unless in the preceding 12 months has had (1) an annual inspection (2) an issuance of 

an airworthiness certificate. 

• We seek exemption from this part as the inspection and airworthiness certificate to not apply 

to our UAS. Our operator will be responsible for the inspection and airworthiness determination 

prior to each flight and will have the UAS repaired by the manufacturer or one of its certified 

technicians, if the UAS is fo~nd to be in a state other than intended by the manufacturer. 

J. 14 CFR Part 91 Subpart E; 91.417 Maintenance Records 

• This section requires the owner/operator to complete and retain a list of all records pertaining 

to the work performed, the date of completion, the signature of the inspector, and all work 

performed on the aircraft. 

• We seek exemption from this part as the inspections and technician work will not apply. Our 

operator will be responsible for determining the airworthiness of the UAS prior to each flight 

and will not operate the UAS in any condition other t~an intended by the manufacturer. The 

operator will keep records of all work completed by the maintenance facility. 

K. 14 CFR Part 91 Subpart B; 91.103 Preflight Action 

• This section requires each pilot prior to flight will become familiar will all available 

information pertaining to that flight including runway lengths, flight information, weather, etc. 

For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information include; all applicable information relating to aircraft performance, airpo,rt 

elevation, runway slope, airc·raft gross weight, wind and temperature. 

• We seek exemption from this part as our operator, while utilizing all available information for 

the safe operation of the UAS, will not have the above information available for most flights. The 
operator will use good judgment and all resources available to ascertain the information 

necessary for the safe operation of the UAS. A preflight inspection will be accomplished 

according to the manufactures instructions prior to each flight. 

L. 14 CFR Part 91 Subpart B; 91.105 Flight Crew members Stations 

• This section pertains to the required crew members being at their stations during all phases of 

flight, and requires the use of seat belts and shoulder harnesses. 

• We seek exemption from this section as it pertains to aircraft with flight crew member 

stations. Our UAS does not have such stations. M. 14 CFR Part 91 Subpart B; 91.9 Placement of 

Manual 

• This part states no aircraft may operate without a manual onboard the aircraft. 

o Our UAS is not large enough to carry such operating manual. We will however carry a current 

manufacturer manual in the UAS carrying case along with the operator on all flights. 

M. 14 CFR Part 45.23 

• Under this part, it is required that each operator must display on that aircraft markings. 

• Our UAS is too small to attach large markings. We seek exemption from this part as we will be 

attaching all registration or serial number as required on the UAS itself. 

Thank you for considering these exemptions. If there is any additional information required 

please contact us. 

RPM Logistics 

33470 Chinook Plaza 

Scappoose, Or 97056 

503-799-8774