Ronald A McGee

RAM Visions Photography

900 Las Vegas Blvd S #706

Las Vegas, NV 89101

U.S Department of Transportation

Docket Management System

1200 New Jersey Ave, S.E.

Washington, DC 20590

To whom it may concern,

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

Part 11, Ronald A McGee, owner of RAM Visions, hereby apply for an exemption from 

the listed Federal Aviation Regulations to allow commercial operation of sUAS, so long 

as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

I am seeking relief to use sUAVs in the film industry, TV productions, real estate 

photography and video, surveying for development and ergonomic purposes, aerial 

mapping, and natural disaster assistance. Specifically, 

1. Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related professional 

activities.

2. Aerial video and/or photography for public and/or private use including 

television, public events, business promotions, calendars and cinematography.

3. Aerial inspection/photography/video of residential/commercial structures under 

contract with the owners or local government authority.

4. Aerial video/photography providing live video feed to assist with search and 

rescue operations in cases of emergency or natural disaster only when the local 

authorities or government has requested it by contract or donation.

I seek exemption from the following sections of 14 CFR:

• 14 CFR Part 21 subpart H - Airworthiness and Certificate

• 14 CFR 45.23 (b) - Identification and Registration Marking

• 14 CFR 91.7 (a) - Airworthiness

• 14 CFR 91.9 (b) (2) - Flight Manual

• 14 CFR 91.103 - Preflight Action

• 14 CFR 91.109 (a) - Flight Instruction

• 14 CFR 91.119 (c) - Minimum Safe Altitudes

• 14 CFR 91.121 - Altimeter Setting

• 14 CFR 91.151 (a) - Fuel Requirements in VFR Conditions

• 14 CFR 91.203 (a) and (b) - Certificates and Registration

• 14 CFR 91.405 - 14 CFR 91.407 (a) (1) - 14 CFR 91.409 (a) (2) - 14 CFR 

91.417 (a) and (b) - Maintenance Inspections
Aircraft and Equivalent Level of Safety

This exemption would not adversely affect safety, in fact it would create a safe 

environment and example of a professional operation adhering to the FAA standards that 

are currently set in place. 

Pilot experience:

I, Ronald A McGee, as the PIC, started flying remote controlled aircraft at an early age. 

Aviation has always been my passion. I received my pilots license while attending the 

University of Kansas, majoring in Aerospace Engineering. I continued my passion for 

flight by joining the USAF where I flew the T-41, T-37, T-38, F-4 C/D/E. OV-10 and 

A-10 aircraft. Post military I flew commercially for Braniff, Continental and United 

Airlines flying the B-727, DC-10, B-777 and B-787. I instructed and was an APD for the 

B-777 for 10 years, as well as a Line Check Airman on the B-787. I currently work for 

CCL/Boeing instructing the B-787 Dreamliner world wide. I retired from the airlines 

with just over 31,000 hours total combined time. I continued flying sUAV during and 

post commercial aviation career. I currently have over 150 hours of sUAV time logged.

I have been a long time member of AMA and abide by their rules and regulations as well 

as all FAA restrictions. Through AMA I have a Comprehensive General Liability 

Insurance Coverage with $2,000,000 aggregate coverage. 

I comply to the following for all my sUAV flights:

1. Flights will be operated within line of sight of the pilot at all times.

2. Flights will be conducted with an observer.

3. Maximum flight time for each flight will not exceed 30 minutes.

4. Flights will be terminated with a minimum of 20% battery power reserve.

5. Flights will be preceded with use of checklist to determine safety of the sUAV as 

derived by AMA, DJI, and personal recommendations and procedures.

6. Flights will not be operated at an altitude over 400 AGL and comply with any 

other altitude restrictions set forth by the exemption or future FAA restrictions.

7. A pre and post flight briefing will be conducted regarding the planned flight. 

8. The PIC will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 

100 feet of the flight operation, and the radius may be reduced to 30 feet for 

persons directly involved with the proposed flight following all equivalent level 

of safety.

9. The PIC and observer will be able to communicate by voice/radio at all times.

10. Written and/or verbal permission and permits will be obtained from territorial, 

state, county or city jurisdictions, including law enforcement, fire or other 

appropriate governmental agencies when needed. 

11. If the sUAV loses communications or loses GPS signal, the sUAV will have the 

capability to return to a pre-determined location within a designated location and 

land autonomously.
12. The sUAV will have the capability to abort a flight in case of unpredicted 

obstacles, weather, safety requirement or emergencies.

How will granting the exemption be in the public interest

Granting the exemption will greatly benefit the public for a number of reasons:

1. Create a positive environment for sUASs as a whole. Creating breathtaking aerial 

imagery the public is drawn to our content while adhering to safe sUAV 

operations. Helping to dispel the myth that UAVs are dangerous, operated in an 

unsafe manner, or invasive. 

2. Provide professional education to the public about sUAV operations.

3. Use of sUAVs verses full scale helicopters provide a safer environment for 

filming.

4. Provide aerial search and rescue efforts, when asked, without risking human life.

5. Provide economic growth for the public by allowing the public to hire RAM 

Visions Photography for their business growth through advertisement.

6. Provide aerial mapping of golf properties to help them see and control ergonomic 

issues associated with their property - benefiting the public environment in 

general.

Proposed Operations

I use sUAVs in the film industry, TV productions, real estate photography and video, 

surveying for development and ergonomic purposes, aerial mapping, and natural disaster 

assistance. Specifically, 

• Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related professional 

activities. 

• Aerial video and/or photography for public and/or private use including 

television, public events, business promotions, calendars and cinematography.

• Aerial inspection/photography/video of residential/commercial structures under 

contract with the owners or local government authority.

• Aerial video/photography providing live video feed to assist with search and 

rescue operations in cases of emergency or natural disaster only when the local 

authorities or government has requested it by contract or donation.

Make and Model of the aircraft for proposed operation

The sUAV I currently fly include:

• DJI Phantom 3 Pro

• DJI Phantom 4 Pro

• DJI Inspire 1

• DJI Inspire 1 Pro (X5 and X5R)
• DJI S1000

• Octocopter Cinestar 8

All the above sUAVs weight less than 35 pounds maximum weight.

Similar granted petitions include: 

2/3/2015 Alan D. Purwin; 1/23/2015 Burnz Eye View; 1/6/2015 Douglas Trudeau; 

2/18/2015 Picture Facture, Inc; 2/13/2015 Capital Aerial Video; 2/27/2015 Ross A 

Costanza, Ross Costanza Photography.

If granted, I as PIC, will continue to abide by the FAA regulations and policies set in 

place. As a long time Commercial Pilot, safe flight operations has been and will continue 

to be my utmost consideration, to include all sUAV operations. 

Sincerely, 

Ronald A McGee

RAM Visions 

900 Las Vegas Blvd S #706

Las Vegas, NV 89101

ramvisions@yahoo.com

480-203-6711