Dear Sir or Madam;

Re: Amendment to Exemption 11594 issued pursuant to Section 333 of the FAA 

Reform Act and Part II of the Federal Aviation Regulations in Regulatory Docket No. 

FAA-2014-0. 

RDX Aerial Media LLC was issued an Exemption numbered 11594 (hereinafter the 

Exemption) for the purpose of data collection. RDX Aerial Media LLC herby requests an 

amendment to the Exemption for the purpose of conducting scripted, closed-set filming 

for the motion picture and television industry that will fully comply with all other 

conditions of the Exemption previously granted. 

 As this is an amendment to an existing exemption asking for the addition of closed-set 

and scripted filming for the motion picture and television industry, RDX Aerial Medial 

LLC. Respectfully submits that good cause exists so that notice does not need to be 

published in the Federal Register for the requested amendment. 

Below information states our good cause for this amendment as well as the procedure and 

regulations that we are requesting. RDX Aerial Media LLC operates all equipment with 

private pilot or higher certificates thus increasing the level of safety to meet or exceed the 

current conditions in the movie and television industry. 

As was described in more detail in our initial exemption, the requested amendment would 

permit the operation of small, unmanned and relatively inexpensive sUAS under 

controlled conditions in airspace that is 

U.S Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

July 10, 2015

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

and 14 C.F.R. Part 11, RDX Aerial Media LLC, developer and operator of Small Unmanned 

Aircraft Systems (“sUASs”) equipped to conduct aerial photography for the motion picture 

and television industry for scripted closed set filming, hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

sUASs, so long as such operations are conducted within and under the conditions outlined 

herein, in our MPTF manual, or as may be established by the FAA as required by Section 

333.
1) limited 2) predetermined 3) controlled as to access and 4) would provide safety

enhancements to the already safe operations in the film and television industry presently

using conventional aircraft.

Approval of this amendment would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements 

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

Section 333(c) of the Reform Act.

The name and address of the applicant is:

RDX Aerial Media LLC Attn: Patrick Morehead 

Phone: 424-258-4014 

Email: Patrick@rdxaerial.com

Address: 10920 Palms Blvd. Unit 207, Los Angeles, CA 90034

The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 

3, Chapter 8-Issue a Certificate of Waiver for Motion Picture and Television Filming.

Regulations from which the exemption is requested:

14 CFR Part 21, 14 C.F.R. 45.23(b), 14 CFR 61.113 (a) & (b), 14 C.F.R. 91.7 (a), 14 

CFR 91.9 (b) (2), 14 C.F.R. 91.103 14 C.F.R. 91.109, 14 C.F. R. 91.119, 14 C.F.R. 

91.121, 14 CFR 91.151 (a), 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a), 14 CFR 407 (a) 

(1), 14 CFR 409 (a) (2), 14 CFR 417 (a) & (b)

RDX Aerial Media LLC’s sUAS’s are rotorcraft, weighting 55 or fewer lbs. including 

payload. They operate, under normal conditions at a speed of no more than 50 knots and 

have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate only in line of sight and will operate only within the 

sterile area described in the Confidential Motion Picture and Television Operations 

Manual, attached as Exhibit 1 (hereinafter “the Manual”). Such operations will insure that 

the sUAS will “not create a hazard to users of the national airspace system or the public.”

Given the small size of the sUAS’s involved and the restricted sterile environment within 

which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UAS’s to commence immediately. Also due 

to the size of the UAS’s and the restricted areas in which the relevant sUASs will operate, 

approval of the application presents no national security issue. Given the clear direction 

in Section 333 of the Reform Act, the authority contained 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, reduction in environmental 

impacts, including reduced emissions associated with allowing UAS’s for movie and 
television operations, the grant of the requested amendment is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

amendment without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the amendment requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the already safe movie and television filming operations conducted with 

conventional aircraft. 

These limitations and conditions to which RDX Aerial Media agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

This manual has been found acceptable for sUAS filming operations for the television 

and movie industry. Applicant submits this manual as a Confidential document under 14 

CFR 11.35 (b) as the entire manual contains proprietary information that the applicant 

has not and will not share with others. The manual contains operating conditions and 

procedures that are not available to the public and are protected from release under the 

Freedom of Information Act 5 USC 552 et.seq. Reform Act Section 333 (b). 

Sincerely, 

Patrick Morehead Jordan LaMotte

RDX Aerial Media LLC. RDX Aerial Media LLC

Owner of RDX Aerial Media LLC. Owner of RDX Aerial Media LLC.
Date: 07.15.2015 Revision: Original

Page 1 of 15

Motion Picture and Television 

Flight Operation Manual 

RDX Aerial Media, LLC.

10920 Palms Blvd. #207 • Los Angeles, CA 90034

(424) 258-4014
Date: 07.15.2015 Revision: Original

Page 2 of 15

Table of Contents

1. Introduction

A. Purpose 4 

B. Pilot/Operator Organization 4 

C. Persons Authorized 4 

D. Area of Operations 4 

E. Plan of Activities 5 

F. Permission to Operate 5 

G. Security 6 

H. Briefing of Pilot/Production Personnel 6 

I. Certification/Airworthiness 7 

J. Pilot Personnel/Minimum Requirements 7 

K. Communications 8 

L. Accident Notification 8 

M. Recall/Stop Procedures 8 

N. Aerobatic Competency 8 

O. Aerobatic Competency 9 

2. Company Organization

A. Chief Pilot 9 

B. Pilot in Command 10

 Appendix A 

 1 List of Approved Pilots 11

 2 List of Approved Aircraft 12

 3 Permission Acquisition Form (sample) 13

 4 Revision Letter (sample) 14 

 Appendix B

 1 Section 333 exemption (certification of authorization) 15
Date: 07.15.2015 Revision: Original

Page 3 of 15

Revision Control Page

Revision# Date Initials

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______________________________________________________________________

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Date: 07.15.2015 Revision: Original

Page 4 of 15

1. Introduction

A. Purpose

This manual has been developed by "RDX Aerial Media, LLC.", hereafter referred

to as "RDX", in conjunction with an application for a Certificate of Waiver of

Authorization of the provisions of FAR 91.119 (b) and (c) for the purposes of

filming. RDX pilots and other company personnel when applicable will comply with

the policies, procedures and conditions of this manual, whenever motion picture or

television flight operations are performed that require a Waiver of Authorization as

mentioned above.

B. Pilot/Operator Organization

Patrick Morehead - Pilot

Jordan LaMotte - Pilot

RDX Aerial Media, LLC.

10920 Palms Blvd. Unit 207

Los Angeles, CA 90034

Patrick Morehead - Manager (424) 258-4014 office • (651) 319-7933 cell

C. Persons Authorized

FAR 91.119 (c) is waived only with respect to those persons, vehicles and

structures directly involved in the performance of the actual filming. The certificate

holder shall ensure that no persons are allowed within 500 feet of the area except

those consenting to be involved and necessary for the filming production. This

provision may be reduced to no less than 50 feet if an equivalent level of safety

can be achieved and the Administrator has approved it. For example, an equivalent

level of safety may be determined by an ASI’s evaluation of the filming production

area to note terrain features, obstructions, buildings, etc. Such barriers may

protect nonparticipating persons (observers, the public, news media, etc.) from

debris in the event of an accident.

D. Area of Operations

RDX's approved area of operations will be the continental United States.
Date: 07.15.2015 Revision: Original

Page 5 of 15

E. Plan of Activities

At least three (3) days prior to any scheduled filming, RDX will submit a written

plan of activities to the local FSDO having jurisdiction over that area. The plan of

activities should include the following:

(1) Dates and times for all flights.

(2) Name and phone number of person responsible for the filming production

event.

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial or N-number of aircraft to be used and type of

airworthiness certificate, including category.

(5) Name and certificate number of pilots involved in the filming production

event, including any notation of external load endorsements or aerobatic

competency, if required.

(6) A statement that the waiver holder has obtained permission from property

owners and/or local officials to conduct the filming production event. The list

of those who gave permission must be made available to the inspector upon

request from the waiver holder.

(7) Signature of waiver holder or representative.

(8) A description of the flight activity including maps or diagrams of any area,

city, town, county, and/or State over which filming will be conducted and the

minimum altitudes essential to accomplish the operations.

The three (3) day notification equipments may be waived, however, the operator 

should contact the FSDO as soon as possible with this request and be prepared to 

explain in detail why the three (3) day notification is not practical. 

F. Permission to Operate

Before any flight operations is conducted at less than 500 feet under the

provisions of the certificate of waiver and this manual, the operator will obtain

permission to conduct these operations from property owners and local officials as

necessary or appropriate. Persons from whom permission may be required are

listed below:
Date: 07.15.2015 Revision: Original

Page 6 of 15

(1) Property owners

(2) Law enforcement officials

(3) Fire department officials

(4) Local, State and Federal government

(5) Air traffic control

The RDX personnel obtaining such permission will do so in writing whenever 

practical, however, verbal permission is acceptable otherwise. A standard 

permission form is provided in Appendix A and may be used when obtaining 

written permission. RDX personnel will assure a sufficient number of those forms 

are available at the job site. Written permission forms will be maintained at the job 

site until flight operations are completed, and then turned into the chief pilot to be 

kept on file for a minimum of six (6) months. These forms will be made available 

for inspection by the FAA or other official personnel upon request. 

G. Security

Prior to any flight operation the operator will coordinate with appropriate

production personnel to devise a plan of securing the area(s) of operation from all

unauthorized persons and vehicles. Provisions will be made to immediately

discontinue operations should the area(s) become unsecured or for any other

reason in the interest of safety.

H. Briefing of Pilot/Production Personnel

Prior to the start of any operation under the provisions of this manual, the pilot in

command will conduct a briefing of all procedures to participating personnel of the

risks involved, emergency procedures, and safeguards to be followed during the

filming production event. Personnel will also be briefed on additional provisions

that may be issued by the FSDO that has geographic responsibility for the

operational area, including the location of boundaries or time limits. The briefing

shall cover:

• Authorization for motion picture and television certificate of waiver and the

attached special provisions

• Operations manual

• Plan of activities

• Aircraft parking and starting

• Taxi procedures

• Radio Communications

• Takeoff procedures
Date: 07.15.2015 Revision: Original

Page 7 of 15

• Aviation activities to be conducted during the filming production event

• Approach and landing procedures

• Recall procedures

• Emergency procedures

• Risks to participating personnel

• How to control nonparticipating persons

I. Certification/Airworthiness

All RDX aircraft used in operations requiring a waiver of FAR 91 .119 (b) and (c)

for the purpose of filming will be properly certified and will follow the requirements 

in our Sect. 333 for airworthiness. The aircraft will be under our 50hr and annual 

inspection program. Other required tests and inspections (controller, battery, etc.) 

will be performed as per Part 91 when necessary. Each aircraft will have a flight 

log containing upcoming scheduled maintenance and inspections and the dates or 

times they must be performed. A section for discrepancies is also found in the 

flight log. The pilot in command will assure the aircraft to be flown is in airworthy 

condition and all required inspections and maintenance has been completed 

before each flight.

J. Pilot Personnel/Minimum Requirements

The pilot/operator shall establish and specify the minimum pilot requirements.

Minimum requirements shall meet or exceed the following:

(1) A current U.S. Private pilot certificate with ratings appropriate to the

category, class and type (if applicable) of aircraft to be used under the

terms of the waiver.

(2) At least 50 hours logged as PIC and at least 10 hours logged as the PIC

in the aircraft type.

(3) A minimum of 10 hours in the category and class of aircraft to be used.

(4) A minimum of 1 hours in the make and model aircraft to be used under

the waiver. 
Date: 07.15.2015 Revision: Original

Page 8 of 15

(6) In the event the operation to be conducted contains elements of an

external-load operation, whether fixed or rotary wing operations, pilots

used in the operation shall be qualified. This qualification may be

obtained through a knowledge test (which may be oral and/written) and/or

skill. The inspector or another company pilot approved by the

geographically responsible FSDO who is qualified to carry loads

externally will give the test(s) which are similar to part 133 requirements

and cover the following subjects:

(a) Steps to be taken before starting operations, including a survey of the

Flight area.

(b) Proper method of loading, rigging, or attaching the external load.

(c) Aircraft performance capabilities under motion picture operating

procedures and the aircraft flight manual.

(d) Proper instructions for flight and ground crew personnel.

(e) Aircraft flight manual, pilot operations handbook, or a rotorcraft-load

combination flight manual and limitations, if appropriate.

K. Communications

Prior to the start of any operation covered by this manual, the pilot in command

will formulate a plan to provide communications capability to all participants

during the actual operation and filming. Oral, visual or radio communications may

be used as long as it is effective and is capable of keeping the participants

continuously appraised of the current status of the operation.

L. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the

notification requirements of FAR Part 830 would comply.

M. Recall/Stop Procedures

Radio communication, oral, visual or a combination will be utilized to keep the

participants continuously apprised of the current status of operation.

N. Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710-7, Statement of

Aerobatic Competency, refer to Volume 5, Chapter 9, Issue/Renew/Rescind a

Statement of Aerobatic Competency.
Date: 07.15.2015 Revision: Original

Page 9 of 15

O. Special Provisions

The controls, procedures, and conditions set forth in the RDX motion picture and

television operations manual is the primary assurance that persons on the

surface will not be jeopardized.

The aircraft and pilots used under this authorization and/or waiver will only be

those specified in the RDX motion picture and television operations manual

(“Appendix A” page 11) or associated plan of activities. Each pilot’s name and

certificate number shall appear on each daily plan of activity. All civil aircraft and

pilot(s) participating in the activity shall be available for FAA inspection before the

scheduled event.

Each pilot-in-command conducting operations authorized under this certificate

understands the conditions of issuance, and that it constitutes a waiver of FAR

91.119 (b) and (c) . (see attached document under “Appendix B” page 15)

Rotorcraft takeoff and landing areas will be protected in a manner that will

prevent unauthorized persons from entering the takeoff and landing area.

RDX will ensure that the participating persons involved in the operations are

thoroughly briefed on special procedures, communication, emergency

procedures, and on the provisions of the authorization and/or waiver before

beginning the activities. No person may participate in any event unless that

person has received a briefing on the provisions of the waiver.

2. Company Organization

A. Chief Pilot

Duties and Responsibilities:

• Final word in the formulation of policy and procedures concerning this

manual.

• Act as liaison between RDX and the FAA on matter concerning this manual.

• Assure that each approved pilot is issued a copy of this manual and obtain a

signed statement from each that they have read and understand its contents.
Date: 07.15.2015 Revision: Original

Page 10 of 15

• Maintain a current copy of this manual at the main base of operations for

RDX.

• Responsible for assuring that all revisions to this manual are distributed and

processed properly.

• Must approve or disapprove each proposed job or operation performed by

RDX under the provisions of this manual.

• Assume the responsibilities of pilot in command when acting as such.

• The chief pilot may delegate functions to other personnel but retains

responsibility.

B. Pilot in Command

Duties and Responsibilities:

• Assure that aircraft to be flown is in airworthy condition and all inspections and

required maintenance have been performed as per appropriate FAR's.

• Acquire permission from the chief pilot before any operation under the

provisions of this manual.

• Be very knowledgeable of the contents of this manual and abide by the

procedures, policies and conditions contained herein.

• Coordinate with movie and television personnel to formulate plans, routes,

locations, etc. with safety of all persons involved in the primary concern.

• Maintain their copy of this manual in current condition and have it on site at any

job or operation requiring the waiver.

• The pilot in command may delegate functions to other personnel, but retains

responsibility.
Date: 07.15.2015 Revision: Original

Page 11 of 15

Appendix A .1

List of Approved Pilots

Chief Pilot 

Name : 

Certificate Number :

Grade : 

Medical Class/Date :

Contact Number : 

Pilots 

Name : 

Certificate Number :

Grade : 

Medical Class/Date :

Contact Number : 

Name : 

Certificate Number :

 Grade : 

Medical Class/Date :

Contact Number : 

Patrick Morehead

2743403

Commercial/CFII 

Third 07-2015 

(651) 319-7933

Jordan LaMotte

3501918

ATP/CFII

First 07-2011 

(###) ###-####

TBD 

########

Commercial 

TBD 

(###) ###-####
Date: 07.15.2015 Revision: Original

Page 12 of 15

Appendix A .2

List of Approved Aircraft

Make and Model Registration Number

1. DJI Spreading Wings S1000+ N901DX

2.

3.

4.

5.

6.

7.

DJI Inspire 1 N902DX
Date: 07.15.2015 Revision: Original

Page 13 of 15

Appendix A .3 

RDX Aerial Media, LLC. 

Permission Acquisition Form 

In signing this form, I am giving the pilots of RDX Aerial Media, LLC. Permission to 

operate their aircraft at less than 500 feet from property, or in some jurisdiction in 

which I am responsible for or affiliated with, for the purpose of film or television 

production. 

Name: 

Title: 

Basis of Authority to Grant Permission: 

Location: 

Date of Operation: 

Signature __________________________________________________ 

Date __________________________

RDX Representative Receiving Permission 

_______________________________________________________________
Page 14 of 15

Appendix A .4

Revision Letter

Rev# Section Page Action Remarks Initials 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

R • Remove and Replace D • Delete and Destroy N • Insert New Page

Manual Serial# ___________________ Issued To ___________________________

Revised By _________________________________ 

Date _______________________

This form must be returned to the Chief Pilot no later than _____________________________ 

Date: 07.15.2015 Revision: Original 
Date: 07.15.2015 Revision: Original

Page 15 of 15

Appendix B .1

(see attached form Section 333 Exemption and COA) 
May 15, 2015 

Exemption No. 11594

Regulatory Docket No. FAA–2015–0480 

Mr. Patrick Morehead 

RDX Aerial Media, LLC 

1224 S. Corning Street, Unit 7 

Los Angeles, CA 90035 

Dear Mr. Morehead: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter dated January 31, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of RDX Aerial Media, LLC (hereinafter petitioner or operator) for an exemption. 

The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct aerial videography and cinematography. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner is a DJI Spreading Wings. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
2 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, RDX Aerial Media, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, RDX Aerial Media, LLC is hereafter referred to as the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 
3 

1. Operations authorized by this grant of exemption are limited to the DJI Spreading

Wings when weighing less than 55 pounds including payload. Proposed operations of

any other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are

not permitted.

3.The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4.The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5.The UA must be operated within visual line of sight (VLOS) of the 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 or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the

visual line of sight (VLOS) of the PIC and VO at all times. 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; electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the VO can perform the duties required of the 

VO. 

7.This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in this grant of

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 
4 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9.The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the

UAS is in a condition for safe flight. The pre-flight inspection must account for all

potential discrepancies, e.g., inoperable components, items, or equipment. If the

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

prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

Government. The PIC must also meet the flight review requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

(training, proficiency, and experience-building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However,
5 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport symbol as denoted on the current

FAA-published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

17. 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 3 statute miles from the PIC.

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

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least 5 minutes or with the reserve

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be conducted in accordance with an ATO-issued COA. The

exemption holder may apply for a new or amended COA if it intends to conduct

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and

any documents required under 14 CFR §§ 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.
6 

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure

that nonparticipating persons remain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operations must cease immediately in a manner ensuring the safety

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with

permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day
7 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

Enclosures 
RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition 

RDX Aerial Media, LLC., Los Angeles, CA- Section 333 Exemption Petition

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Jan. 31, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam, 

We, RDX Aerial, are writing pursuant to the FAA Modernization and Reform Act of

2012 and the procedures contained within 14 C.F.R. 11, to request that RDX Aerial Media,

LLC., an owner and operator of small unmanned aircraft, be exempted from the

Federal Aviation Regulations (“FARs”) listed below so that We, RDX Aerial, may

operate our small ultra light weight unmanned aircraft system (“UAS”) commercially in

airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein RDX Aerial Media Members, are Certified Commercial Pilots in the

United States; experienced in flying hobby helicopters for recreational purposes. Our

Inventory includes a DJI Spreading Wings Octocopter with a Canon Mark III camera with

the intent for aerial videography/cinematography to enhance academic community

awareness for those individuals and companies unfamiliar with the geographical

layout of the Southern California area, and augment real estate listing videos; following

exemption and approval by the FAA. Thereby enhancing their academic research

experience for the Southern California area. 

Having flown small RC electric helicopters for over ten (10) years without incident. 

Committed to safety with each flight. RDX Aerial Media, LLC., exemption request would 

permit operation of ultra light weight, unmanned (piloted by remote control) and 

comparatively inexpensive UAS(s) in tightly controlled and limited airspace.3

Predetermined in areas away from general public, airports, heliports and vehicular traffic 

for community videos, and within property boundaries for individual homeowner real 

estate listing videos/photos. Currently, similar lightweight, remote controlled UAS's are 

legally operated by unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophe. We, RDX Aerial, has developed and inacted Standard

1

 Appendix A - DJI Spreading Wings Manual

2

 Appendix B - A2 Manual

3

 Appendix C - Futaba Controller Manual
RDX Aerial Media LLC., Los Angeles, CA - Section 333 Exemption Petition 

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Operating Procedures4 to avoid and prevent public hazard, as well as manned aircraft 

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight 

UAS's specific to real estate video and photography usage as We, RDX Aerial, 

record flight data and other information gained through permitted flight operations to 

share with the FAA through any required FAA reports to assist with future protocol and 

safety regulation. 

Granting our, RDX Aerial Media's, request comports with the Secretary of 

Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate 

UAS's into the national airspace system, but to “...establish requirements for the safe 

operation of such aircraft systems [UAS's] in the national airspace system” under 

Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor 

purposes. Further We, RDX Aerial, will conduct our operations in compliance with the

protocols described herein or as otherwise established by the FAA. 

For the reasons stated below, We, RDX Aerial, respectfully request the grant of an

exemption allowing us to operate ultra light weight, remote controlled UAS’s for 

academic community awareness to benefit/stimulate attraction to the Los Angeles

area and to enhance real estate listing videos for homeowners who cannot afford 

expensive manned aircraft for the same purpose. Both of which will promote local 

economic growth through increased employment and increased tax base. Both with 

public safety in mind by keeping heavier manned aircraft containing combustible fuel 

that poses potential public hazard.

I. Contact Information: 

RDX Aerial Media, LLC.

 Patrick Morehead

 1224 S. Corning St. Unit. 7 

 Los Angeles, CA 90035

Office: (651) 319-7933

Email: Patrick@rdxaerial.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which RDX Aerial Media, LLC. Requests Exemption are: 

14 CFR 21; 

14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 

14 C.F.R. 91, et seq.; 

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

4

 Appendix D - SOP (Standard Operating Procedures)
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III. The Extent of relief RDX Aerial Media seeks and the Reason He Seeks Such

Relief: 

We, RDX Aerial, submit this application in accordance with the Reform Act, 112 P.L. 95

§§ 331-334, seeking relief from any currently applicable FARs operating to prevent we,

RDX Aerial Media, LLC. contemplated commercial cinematic, academic 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. Our, RDX Aerial Media's, ultra light weight UAS

meets the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of our ultra light weight UAS is expressly contemplated by the

Reform Act. We would like to operate our light weight UAS prior to the time period by 

which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that 

can be administered uniformly to all real estate related UAS aerial video and 

photography. 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's; Whether the UAS will be 

operated near airports or heavily populated areas; and, Whether the UAS will be

operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an 

exemption for us, RDX Aerial. Our UAS utilizes eight (8) counter-rotating propellers for

balance, control and stability. Our UAS is equipped with GPS and auto return safety 

technology. Weighing less than fifteen (15) pounds (far below the max. 55 pound limit);

including camera with gimbal. 

RDX Aerial, considers safety as foremost with each flight. Our small unmanned aircraft

is designed to hover in place via GPS and operate in less than a 13 knot (15 mph)

wind. For safety, stability and fear of financial loss we will not fly in winds exceeding 

13 knot (15 mph). Built in safety systems include a GPS mode that allows our UAS to 

hover in place when radio controls are released. With three modes to choose from, We

utilize the Safe Mode5 for aerial videography/photography. This is the safest, most 

reliable and stable mode to prevent accident and hazard. When pilot communication is 

lost UAS is designed to slowly descend to point of take off. No UAS operations near

airports, Hospitals nor Police heliports, and do not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions 

and weather. We are constantly on alert for any manned aircraft (Police/Medical 

helicopters, etc.) and prepared to land/abort immediately to the nearest and safest 

ground point should a manned aircraft approach our location or we suspect manned 

aircraft may approach near our location. Our UAS is capable of vertical and horizontal 

operations, and are flown only within our line of sight of us, as the remote control pilot. 

Utilizing battery power rather than combustible fuels, flights generally last between ten

(10) to fifteen (15) minutes, with an altitude under three hundred (300) feet. We, RDX

5

 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home feature, and safety 

control to return home or land in the event of communication interruption between RC transmitter and UAS. See Appendix A - 

Operator Manual. 
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Aerial, utilize a fresh fully charged battery with each flight as a safety precaution; full

flight time limit for each battery is ten (10) to fifteen(15) minutes as tested. We do not 

operate our UAS at or below manufacture recommend minimum charge levels for 

operation; preferring to remain well within a safe operating range to insure adequate 

communication between radio control and UAS to eliminate potential for crash, loss of 

control or hazard. Reserve batteries are at hand with each exercise to insure 

replacement for sufficient safe level of operation. We do not believe in taking risk that 

may cause a crash, that could create hazard to the public/property/manned aircraft, 

and have no desire to lose an investment. We have clocked numerous practice flights in 

remote areas as a hobbyist simulating flights for future commercial use to gain 

familiarization with the characteristics of this specific UAS's performance under different 

temperature and weather conditions. We have also developed a traing course manual 

and outline for new members as well as current. All for the sake of safety. 

We, RDX Aerial Media's, are e xtremely cautious when operating our UAS/ultra light 

weight unmanned aircraft and will not “create a hazard to users of the national airspace 

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of our UAS

it falls well 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. RDX Aerial Media’s UAS, used in hobby flight, has a demonstrable safety 

record and does not pose any threat to the general public or national security. 

IV. How RDX Aerial Media’s Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness and for real estate marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. For small 

budget real estate companies and average homeowners the expense of such aerial 

videography is cost prohibitive. Only large companies and high end Realtors or luxury 

homeowners can afford to absorb such expense. Depriving non-luxury homeowners 

and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat 

to the public through potential catastrophic crash that the Los Angeles community has 

experienced in the past with military aircraft and medical helicopter crashes within the

SoCal area. Each resulting in loss of life. Each with combustible fuel that exploded 

and burned on impact. Police helicopters have made emergency hard landings within 

city limits. Our, RDX Aerial Media's, UAS pose no such threat since size and lack of 

combustible fuel alleviates any potential threat to the public. 

Congress has already proclaimed 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. Granting Our, RDX Aerial Media's, exemption request furthers the public 

interest through academic/visual awareness of the geographical benefits in and around 

the Los Angeles area. Our ultra light weight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of my ultra light weight

UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are 

heavy, contain combustible fuel and can cause catastrophic devastation to the public. 
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The public’s interest is furthered by minimizing ecological and crash threat by permitting 

aerial video/photo capture through our battery operated ultra light weight UAS's. 

Permitting us, RDX Aerial Media, to immediately fly within national air space furthers 

economic growth. Granting our exemption request substantially furthers the economic 

impact for the Los Angeles community for companies looking to relocate or build in the 

SoCal area as well as individuals looking to relocate for career advancement through

academic and geographical awareness. Both of which serve as a stimulus to the

community. 

V. Reasons Why RDX Aerial Media's Exemption Will Not Adversely Affect Safety 

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing 

Rule:

Our, RDX Aerial Media, exemption will not adversely affect safety. Quite the contrary,

for the reasons stated permitting us, RDX Aerial, to log more flight time in FAA

controlled airspace, with communication with the FAA, will allow us to contribute to the 

innovation and implementation of new and novel, as of yet undiscovered safety 

protocols for Realtors that can be embraced by the NAR6, CAR7, and BHLA8 for 

development in cooperation with the FAA. In addition We, RDX Aerial, submit the 

following representations of enhancements to current aerial videography and 

photography for real estate: 

 Our UAS weighs less than 15 pounds complete with gimbal and high resolution

Canon Mark III Camera; 

 We only operate our UAS below 300 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012); 

 Our UAS only operate for 10-15 minutes per flight; 

 We land our UAS prior to manufacturer recommended minimum level of battery 

power; 

 We pilot our UAS through remote control only by line of sight; 

 Our UAS has GPS a flight safety feature whereby it hovers and then slowly lands

if communication with the remote control pilot is lost; 

 We actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols; 

 We only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas; 

 We conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance; 

 We always obtain all necessary permissions prior to operation; and, 

 We have procedures in place to abort flights in the event of safety breaches or 

potential danger. 

6

 National Association of Realtors, http://www.realtor.org/ 

7 California Association of Realtors, http://www.car.org/ 

8

Beverly Hills/ Greater LA Association of Realtors, http://www.bhglaar.com/ 
RDX Aerial Media, LLC., Los Angeles, CA - Section 333 Exemption Petition 

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Our,RDX Aerial Media's, safety protocols provide a level of safety equal to or exceeding 

existing rules. It is important to note that absent the integration of commercial UAS into 

our national airspace system, helicopters are the primary means of aerial video and 

photography for community awareness and real estate. While the safety record of such

helicopters is remarkably astounding, there has been local incident involving loss of life 

as well as extensive property damage; it is far safer to operate a battery powered ultra 

light weight UAS. 

 First, the potential loss of life is diminished because UAS's carry no people on 

board and we only operate our UAS 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 our UAS allows us to

remotely pilot away from and avoid hazards quickly and safely. 

 Lastly, given its small size and weight, even when close enough to capture 

amazing images, our UAS need not be so close to the objects they are focused 

on through the technology and use of post editing software allowing pan and 

zoom. 

Accordingly, our UAS has been experimentally operated for familiarization/competency 

and will continue to operate at and above current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register: 

A. 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)(1). The size, weight and enclosed operational area of our, RDX Aerial

Media’s, UAS permits exemption from Part 21 because our UAS meets (and 

exceeds) an equivalent level of safety pursuant to Section 333 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 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. Our, 

RDX Aerial Media’s, current and projected 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 on board 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 
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safety/flight manual delineating areas of where safety can be defined.10 The FAA

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes

electronic global positioning systems with a barometric sensor. 

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 any such required certifications and

registrations by us, RDX Aerial Media. 

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. Our UAS 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 with dimensions smaller that

minimal lettering requirement. Regardless, We will mark our UAS in the largest possible

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R.

§45.29 (f) so that we the pilot, or anyone assisting me as a spotter with the UAV will see

the markings. The FAA has previously issued exemptions to this regulation through

Exemptions Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.F.R. § 61.133: Commercial Pilot Privileges and Limitations: PIC. 

Pursuant to14 C.F.R. § 61.133 (a - i, ii), Commercial pilots are not limited to commercial

operations. We, RDX Aerial, can achieve an equivalent level of safety as achieved by

current Regulations because our UAS does not carry any pilots or passengers. Further,

while helpful, our operaters are required to hold this certification to pilot UAVs. The risks

attended to the operation ofour UAS is far less than the risk levels inherent in the

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing us, RDX Aerial

Media, to operate our UAS and meet or exceed current safety levels in relation to 14

C.F.R. §61.113 (a) & (b). 

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. Our UAS will never

operate at an altitude greater than 300 AGL; safely below the standard of 400 AGL. 

We, RDX Aerial, will however operate our UAS in safe areas away from public and

traffic, providing a level of safety at least equivalent to or below those in relation to

minimum safe altitudes. Given the size, weight, maneuverability and speed of our UAS,

an equivalent or higher 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. 

10 Appendix F - Safety Procedures
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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 our, RDX Aerial Media's,UAS. However, as a safety precaution we inspect our

UAS before and after each flight as well as maintaining a maintanance log. 

A Summary The FAA May Publish in the Federal Register: A. 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)(1). The size, weight and 

enclosed operational area of our UAS permits exemption from Part 21 because our,

RDX Aerial Media’s, UAS meets an equivalent level of safety pursuant to Section 333 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 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. Our

UAS meets or exceeds 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. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software 

updates and curative measures for any damaged hardware. Therefore, an equivalent 

level of safety will be achieved. 

In summary, RDX Aerial Media seeks an exemption from the following 

Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.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.F.R. § 91.409 (a)(2); 14 C.F.R. § 

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate our, RDX 

Aerial's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness and real estate operations, and to develop economic platforms for real 

estate to enhance the experience of those seeking to relocate to the Los Angeles

area. Currently, area awareness and real estate aerial videography/photography relies 

primarily on the use of larger aircraft running on combustible fuel. Posing potential risk 

to the public. Granting our, RDX Aerial Media’s, request for exemption will reduce current 

risk levels and thereby enhance safety. Our UAS craft do not contain potentially 
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explosive fuel, is smaller, lighter and more maneuverable than conventional real estate

video and photographic aircraft with less flight time. Further, We operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and from 

established air fields. We, RDX Aerial Media have been informally analyzing flight 

information and will compile safety protocols and the implementation of a flight

operations manual for real estate usage that exceeds currently accepted means and 

methods for safe flight. Formal collection of information shared with the FAA will 

enhance the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board our, RDX

Aerial’s, UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. our, RDX Aerial Media’s, operation of our UAS, weighing less 

than 15 pounds and travelling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current FARs. Accordingly We, RDX

Aerial, respectfully request that the FAA grant our exemption request and are willing 

to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and 

the general public at large. 

Respectfully submitted, 

RDX Aerial Media, LLC.

Patrick Morehead 

1224 S. Corning St. Unit 7

Los Angeles, CA 90035