U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Petition ofRRS Aerial Media, LLC for Exemption Pursuant to Section 333 ofthe FAA Modernization and Refonn Act of2012. To Whom ItMay Concern: Pursuant to Section333 ofthe FAAModernization and Reforn1 Act of2012 and 14 CFRPart 11, RRS Aerial Media, LLC, hereby applies for an exemption from Federal Aviation Regulations (FARs) identifiedbelow, to allow commercial operations ofsmall umnanned aerial system (i.e., sUAS). This exemption is in accordance withprotocols outlined inthis petition for exemption, the enclosed the UAS manufacturer's operations and/or instructions manual, UAS User's Manuals, UAS Quick Start Guides, and any otherrequirements establishedbythe FAApursuant to Section 333 ofthe Refonn Act. This exemption would pennit commercial operationbyRRS Aerial Media, LLC, which uses all versions ofDJI 550 FlameWheel, DJI S1000+, 3DRobotics Iris+, 3DRobotics X8+, 3DRobotics X8-M, 3DRobotics Aero-M, and PrecisionHawk to conduct sUAS flight training, support to news services, real estate photography and videography, construction, waterway and land planning and usephotography, agriculture, education, oil and gas industry infrastructure inspection and demonstration flights. RRS Aerial Media, LLC's operationunder the exemption will be subject to strict operating requirements and conditions to ensure an equivalent level ofsafetyto currently authorized operations usingmanned aircraft and under conditions as maybemodified bythe FAA as required by Section 333.2 RRS Aerial Media, LLC will be operated under controlled VFR conditions at low altitude in airspace that is pennitted in accordance with RRS Aerial Media, LLC's approved Certificate of Authorization (COA). Theywill operate the sUAS's withpilots who are current and qualified with a FAA Pilot Certificate and only after completing RRS Aerial Media, LLC's training program. Finally, when operating within controlled airspace, the controlling FAA ATC will approve the airspace in whichthe sUAS will operate in advance. RRS Aerial Media, LLC respectfully submits this request for an exemptionbecause it operates sUAS's. The operations ofRRS Aerial Media, LLC will be conducting will bein lieu of comparativelyhazardous operations now conducted with fixed wing and rotary conventional aircraft. The FAA can have confidence that the operations will be conducted at an equivalent level or greater level ofsafety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities under Section333(c) ofthe Refonn Act to "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." For your convenience, RRS Aerial Media, LLC has organized this Exemptionrequest as follows: 

### I. Petitioner's Description II. Relevant StatutoryAuthority III. Qualifications for ApprovalUnder Section 333 ofthe Reform Act IV. Description ofProposed Operations V. Regulations FromWhich Exemption is Requested VI. Public Interest VII. Privacy VIII. FederalRegistry Summary IX. Conclusion I. Petitioner's Description RRS Aerial Media, LLC., headquartered in Corpus Christi, Texas, is a company that provides sUAS flight training, support to news services, real estate photography and videography, construction, waterway and landplanning and use photography, agriculture, education, oil and gas industryinfrastructure inspection and demonstration flights in a compliant and safe environment. RRS Aerial Media, LLC plans onproviding a wide range ofservices as the sUAS market expands. Themanagement at RRS Aerial Media, LLC has over 50 years ofexperience in aviation and over 7 years combined experience operating sUAS/UAS's. All RRS Aerial Media, LLC pilots hold CPL or ATP certificates in fixed-wing or rotary-wing. The contact infonnation for Petitioner is as follows: RRS Aerial Media, LLC. 14134 CoquinaBayAve Corpus Christi, TX 78418 

### II. Relevant Statutory Authority This petition for exemption is submitted to fulfill Congress' goal inpassing Section 333(a) through (c) oftheReform Act. Congress has directed the FAA "to safely accelerate theintegration ofcivil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 ofthe Refonn Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion ofthe fom1al UAS rulemaking, based on the following considerations:

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

• Operation ofthe UAS in close proximityto airports and populated areas; and

• Operation ofthe UAS within the visual line ofsight ofthe operator. Ifthe Secretarydetennines that such vehicles "may operate safely inthe National Airspace System, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the National Airspace System". Additionally, the FAA Administratorhas general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the publicinterest. A partyrequesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level ofsafety at least equal to the existingrules). The Federal Aviation Act expressly grants the FAAthe authorityto issue exemptions. This statutory authority, byits tem1s, includes exempting civil aircraft, as the term is defined under 40101 ofthe Act, from the requirement that all civil aircraft musthave a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any ofsections. III. Qualifications for Approval Under Section 333 ofthe ReformAct Theproposed operations inthis petition for exemption qualify for expedited approval under Section 333 ofthe Refonn Act. Each ofthe statutory criteria and other relevant factors are satisfied. Theproposed operations would pennitRRS Aerial Media, LLC the use ofsmallUAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level ofsafetybeyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. RRS Aerial Media, LLC uses UASs that are multirotor and fixed wing airplanes, weighing less than 55 pounds includingpayload. They operate, under normal conditions, at speeds not to exceed 50 mph. The multirotor has the capabilityto hover and move inthe vertical and horizontal plane. RRS Aerial Media, LLC's UASs will operate in line ofsight, during daylight hours, and will only operate within a sterile area. RRS Aerial Media, LLC will operate at orbelow 400 feet AGL and will file a NOT AM for each flight operated in controlled airspace that is required. All required permissions and pennits would be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies prior to operating a sUAS. Given the small size ofthe sUAS's involved and the restricted sterile enviromnent within which theywill operate, this RRS Aerial Media, LLC's exemption falls within the zone ofsafety and demonstrate an equivalent level ofsafety, in which Congress desired the FAA to pennit commercial UAS operationsby exemptionpending completion offormal rulemaking. Also, due to the size ofthe sUAS's and the confined area inwhich these UAS's will operate, approval of the applicationpresents no hazard inthe NAS. Consideringthe clear direction in Section 333 ofthe ReformAct, the authority contained inthe Federal Aviation Act, as amended, the equivalent level ofsafety surrounding the proposed operations, and the significantpublicbenefit, the grant ofthe requested exemptions is also inthe public interest. 

### IV. Description ofProposed Operations To assist the FAA inits safety assessment ofRRS Aerial Media, LLC's proposed sUAS operations, below is a summary ofoperational limitations and conditions that will ensure an equivalent orhigher level ofsafety to operations conducted under currentregulatory guidelines: 1. The sUAS will weigh less than 55 pounds. 2. Flights will be operated within line ofsight ofthe PIC and/orvisual observer. 3. Maximum total flight time for each operational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve batterypower orfuel quantity of no less than 25%. 4. Flights will be operated at an altitude ofno more than 400 feet AGL. 5. Flights will be operated at a lateral distance ofleast 100 feet from anyinhabited structures, buildings, vehicles, vessels, people not associated withthe operation or who have not signed a waiver in advance ofthe operation. 6. Minimum crew for each operation will consist ofthe sUAS Pilot in Command and a Visual Observer when operating with the use ofFPV equipment. Additional crewmembers may consist ofa Pilot and a Camera Operator. 7. The sUAS Pilot in C01mnand will be an FAA licensed airman with at least a private pilot's certificate, second class medical, and a current check required by14 CPR Part 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate. 8. RRS Aerial Media, LLC will designate a Pilotin Command ("PIC") for each mission.9. The sUAS will operate only within a confined sterile area. 10. Priorto the operations at a particularlocation, a site inspection will havebeen conducted. On the day ofthe mission the managementperson with operational control and the PIC will concur on dispatching ofthe mission. 11. A briefing will be conducted inregard to the planned sUAS operations priorto each day's missions. Itwill be mandatory that all personnel who will beperfmming duties within the boundaries ofthe sterile areabepresent for this briefing. 12. RRS Aerial Media, LLC crew will use the checklist and callouts. 13. All sUAS's will bemaintained in compliance with the manufacturer's and Company guidelines. 14. In the event ofan accident involving an RRS Aerial Media, LLC sUAS, the PIC will cease operations and report the accident to the NTSB and AFS-80. 15. Pilotin Command and Visual Observer will at all times be able to communicateby vmce. 16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel will havebeen trained and tested in accordance toRRS Aerial Media, LLC's UAS Aircraft Training Manual. 17. All required permissions and pennits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate govermnental agencies. 18. In compliance with the approved Waiver, RRS Aerial Media, LLC management will submit a written "Plan ofActivities" to the local Flight Standards District Office (FSDO) havingjurisdiction over the area ofproposed filming three days in advanced of operations during film or movie productions. 19. Ifthe sUAS loses communications signal, the sUAS will have the capabilityto return to a pre-determined location within the Sterile Area and land. 20. Contingencyplans will be inplace to safely tenninate flight ifthere is a loss of communicationbetween the pilot and the observer. 21. The sUAS has the capabilityto abort a flight in case ofunpredicted obstacles or emergencies. 22. RRS Aerial Media, LLC, will assure no individuals' privacyis violated.23. ATC will be contacted priorto operatingin airspace other than G. V. Regulations From Which Exemption is Requested A. 14 CFR § 91.103: PreflightAction B. 14 CFR § 91.113: Right-of-WayRules C. 14 CFR § 91.119 (c): Minimum Safe Altitudes D. 14 CFR § 91.121: Altimeter Settings E. 14 CFR § 91.151(b): Fuel Requirements for Flight inVFR Conditions F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

A. 14 CFR § 91.103: Preflight Action RRS Aerial Media, LLC requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions under which aircraft may operate: Eachpilot in command shall, beforebeginning a flight, become familiar with all available information concerning that flight. (a) Flightunder IFR or a flight not inthe vicinity ofan airport, weatherreports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and anyknown traffic delays ofwhich the pilot in command has been advised byATC; (b) For anyflight, nmwaylengths at airports ofintendeduse, and the following takeoff and landing distance infonnation: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containingtakeoffand landing distance data is required, the takeoffand landing distance data contained therein; and (2) For civil aircraft other than those specified inparagraph (b)(1) ofthis section, other reliable infonnation appropriate to the aircraft, relating to aircraft perfonnanceunder expected values ofairport elevation and nmway slope, aircraft gross weight, and wind and temperature. RRS Aerial Media, LLC will not operate sUAS's under IFR conditions or when the ceilings are below 1000 feet and the visibilityis below 3 statute miles. Neither DJI, PrecisionHawk nor 3DRsUAS'shavepublished approved Airplane or Rotorcraft Flight Manual containing takeoffand landing distance data. 

### Equivalent Level ofSafety RRS Aerial Media, LLC will to ensure that the weather will be adequate to complete the mission inVFR condition. Since RRS Aerial Media, LLC operates in traditionally density altitude area, neverusually above 2000 feet MSL, UAS perfonnance is not affected. When RRS Aerial Media, LLC operates at a high altitude location, the UAS will betest flown at gross weight to test perfonnance limitations prior to conducting commercial operations. 

### B. 14 CFR 91.113: Right-of-Way Rules RRS Aerial Media, LLC request an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance byeachperson operating an aircraft so as to see and avoid other aircraft. When a rule ofthis section gives another aircraft the right-of-way, the pilot shall give wayto that aircraft and maynotpass over, under, or ahead ofit unless well clear. RRS Aerial Media, LLC operates small pilotless UAS's and crumot comply withthese rules as theyhavebeenwritten. 

### Equivalent Level ofSafety RRS Aerial Media, LLC operates sUAS's at orbelow an altitude of400 feet AGL, well below the normal operating altitude ofother aircraft. An RRS Aerial Media, LLC PIC with extensive aeronautical experience will oversee each mission and has knowledge ofthe avoid rules. A Visual Observerwill assist the PIC in looking for aircraft entering the operations area. It's the responsibility ofthe PIC to cease operations and land the UAS immediately whenever and aircraft comes into the vicinity creating a potential threat. Operations cannotrecommence until the threat is clear. 

### C. 14 CFR. § 

### 91.119: Minimum Safe Altitudes RRS Aerial Media, LLC requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft mayoperate:

• Over any congested area ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft.

• Over otherthan congested areas at an altitude of500 feet above the surface, except over open water or sparselypopulated areas. In those cases, the aircraft may notbe operated closer than 500 feet to anyperson, vessel, vehicle, or structure.Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it canbe operated "without hazard to persons orproperty on the surface," providedthat "each person operatingthehelicopter complies with anyroutes or altitudes specificallyprescribed for helicopters bythe FAA." To provide the intended operations, the sUAS is nonnally operatedbelow 400 feet AGL. Additionally, due to the nature ofthe proposed operations, the sUAS will maintain a lateral distance ofat least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from peoplenot associated with the operation. Equivalent Level ofSafety Compared to flight normal aircraft, RRS Aerial Media, LLC's multi-rotor aircraft weigh a maximum of25 pounds, and given the lack offlammable fuel, anyrisk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed oftheUAS, as well as the location whereit is operated. The sUAS will be operated in a sterile area, wherebuildings and peoplewill notbe exposed to operations without their pre-obtained consent. Because ofthe advance notice to the property owners and participants, all affected individuals will be well aware ofthe planned flight operations. Furthermore, byoperating at such lower altitudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Finally, the successful safety record ofthe DJI and 3DR sUAS's demonstrates that the sUAS canbe safelyused at these lower altitudes and closer operating environments. D. 14 C.F.R. § 91.121: Altimeter Settings RRS Aerial Media, LLC seeks an exemption from 14 CFR 91.121, whichrequires a person operating an aircraft to maintain cruising altitude or flight level byreference to an altimeter that is setto the elevation ofthe departure airport orbarometricpressure. An exemptionis required because some ofthe sUAS aircraft do nothave a barometric altimeter, butrather a GPS altitude read out. Equivalent Level ofSafety An equivalent level ofsafety will be achieved inthat RRS Aerial Media, LLC will confinnthe altitude ofthe launch site shown on the GPS altitude indicatorbefore flight. Moreover, the PIC will use the GPS altitude indicator to constantlymonitor the sUAS's height, thus ensuring operation at safe altitudes. E. 14 CFR91.151(a): Fuel Requirements for Flight in VFR Conditions RRS Aerial Media, LLC requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states:(a) No person maybegin a flight in an airplane under VPR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and assuming normal cmising speed

- (1) During the day, to fly after that for at least 25 minutes; or (2) At night, to fly after that for at least 45 minutes. The batteries poweringRRS Aerial Media, LLC's UAS's provide approximately 10-18 minutes ofpowered flight. To meet the 30 minutes reserve requirement in 14 CPR 91.151, sUAS flights could notbe conducted. Given the limitations on the sUAS's proposed flight area and the location ofits proposed operations within a predetennined area, a safetymarginbased on a reserve amount ofbatterylife is needed. RRS Aerial Media, LLC will notbe conducting any sUAS flights at night. 

### EquivalentLevel ofSafety An equivalent level ofsafety will be achieved because the operations will be conducted on-site without significant transit time bythe sUAS. All flights will beplanned to tenninate with no less than 25%reserve batterypower still available. This restriction wouldbemore than adequate to return the sUAS safelyto its planned landing zone from anywhere inits confined area of operation even in the event ofanunexpected occutTence. Operation ofthe sUAS with less than 30 minutes ofreserve fuel does not include the type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS, and the proximity ofthe flight operation to the landing zone. Moreover, operation will belimited to controlled areas where onlypeople and property owners, or official representatives who have signed waivers will be allowed. 

### F. 14 CFR 

### § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections RRS Aerial Media, LLC also seeks an exemption from the maintenance inspection requirements contained in 14 CPR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 CPRPart43. 14 CPR 91.405(a) (stating that each owner or operator ofan aircraft "shall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). An exemption to these regulations is neededbecause Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will nothave. 

### EquivalentLevel ofSafety An equivalent level ofsafety will be achieved becausemaintenance and inspections will be perfonnedin accordance with DJI, PrecisionHawk and 3DRUser's Manuals. The operatorwill ensure that the sUAS is inworking orderpriorto initiating flight, perfom1 required maintenance, and keep a log ofanymaintenanceperfonned. The operator is the person most familiar withtheaircraft andbest suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. Ifmechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will onlytake place in restricted areas for limited periods oftime during daylight hours, creates less risk than that associated with conventional rotorcraftperforming the same operation. VI. PUBLIC INTEREST Granting RRS Aerial Media, LLC. an exemption furthers the public interest. National policy set by Congress favors early integration ofUAS into the national airspace in controlled, safe working environments such as those propose inthis petition. The one vision ofRRS Aerial Media, LLC is to help facilitate safe integration ofsUAS's into mainstream USA in the following areas:

• Training To ensure that UAS Operators are properlytrained and certified to safelyoperate they're particular type ofsUAS aircraft. Also, training will be conducted inthe type ofoperations theywill beusing their aircraft.

• Real Estate The sUAS canbeused in all areas ofreal estate, including commercial, residential and industrial properties. Using a sUAS, real estate professionals can create promotional videos, photos and unique shots that nonnal camera aspects cannot capture. RRS Aerial Media, LLC's easy-to-use video and photo platfonn enables properties to stand out, providing dazzling views that are typically shown via expensive computer animation or costly helicopterrentals. Imagine shooting a view from a high-rise condo in stunning high definition that shows yourpotential customer the actual view from the residence. The remote platform is great for new plam1ing, zoning and large developments. Simple and easy-to-use video and photos allow for multiple height pictures and elevation views.

• Cinematography Whether the shotrequires unique views and expansive pmming or extreme altitude with radical views, the UAS is designed to hold up under demanding conditions. Because of the autopilot feature with pre-designed missionmanagement and RIC control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD still photos.

• News Gathering Similarto movies and videography, each news assignment mayrequire a completely different shot or view ofa scene. Withbudgets for traditional helicopteruse being greatlyreduced, the UAS is the perfect solutionto allow for easy news gathering for a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, while the traditional helicopter musthover overpersons and propertyincreasing the danger to individuals.

• Agriculture and Conservation RRS Aerial Media, LLC would introduce and demonstrate to fanners ofall types that the sUAS can aid cmmnercial agriculture, land management and conservation efforts by assessing crops, mapping flood zones, measuring snowpack and more. The sUAS can fly pre-saved missions viathe fully automated ground station, which allows for time-lapse photos offields, crops and known land tracts. It also can accuratelyrecreate the same patternduring all seasons, providing invaluable data for land and soil management. Using HD video, HD photos, and IR cameras allows for detailed analysis and recording. Withphoto rendering software, 3D maps and topography canbeused in conjunction with time-lapse photos to create highly detailed maps for erosion, flood mapping and other critical aspects ofland management.

• Oil and Gas Industry Infrastructure Inspection RRS Aerial Media, LLC will use HD video, HD photos, and IR cameras to inspect critical oil and gas infrastructures allowing detailed analysis priorto scheduled maintenance. This analysis will enable repair crews to minimize down-time which in turn greatlyimprove production efficiency. 

### VII. Privacy RRS Aerial Media, LLC is committed to protecting the publicprivacy. RRS Aerial Media, LLC knows that manyindividual have concerns about privacyfrom the operations ofsUAS's. RRS Aerial Media, LLC will inform residents, commercial property owners, churches, schools, and governmental organizations ofour intent to conduct commercial drone operations inproximityto their property. 

### VIII. FederalRegistry Summary Pursuant to 14 CPR Part 11, the following summary is provided for publication in the Federal Register, should itbe detennined that publication is needed: RRS Aerial Media, LLC. seeks an exemption from the following rules: 14 CPR 91.103; 14 CPR 91.113; 14 CPR 91.119; 14 CPR 91.121; 14 CPR 91.151(a); 14 CPR 91.405(a); 14 CPR 91.407(a)(1); 14 CPR; 91.409(a)(2); 14 CPR 91.417 (a) & (b). Approval ofthis exemptionrequest allows RRS Aerial Media, LLC to conduct commercial operations with small and lightweight unmanned aerial systems. RRS Aerial Media, LLC iscommitted safety, education, and solutions, which enhance safety ofsUAS operations in the NAS while reducing risk to the general public and property owners. RRS Aerial Media, LLC uses sUAS, weighing less than 55 pounds and poweredbybatteries and small amounts offuel. This eliminates virtually all ofthat risk given the reduced mass and lack oflarge amounts ofcombustible fuel carried onboard as compared manned aircraft. The sUAS is transported to the designated mission area and set up there. The sUAS will carryno passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofthis small UAS will provide an equivalent level ofsafety, supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS's operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters. Ifadditional information is required, or ifyouhave any questions regarding this Petition for Exemption, please contact the undersigned at: VeryRespectfully, 

# .--&/#{ -f=stotz President RRS Aerial Media, LLC Cell Phone: 361.215.6213 Robin.Stotz@RRSAerialMedia.com