UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

RKGmedia, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 14 C.F.R. §§ 91.7(a), 91.119(c), 91.121, 91.151(b), 

91.405(a), 91.407(a), 91.409(a) and 91.417(a)

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on December 30, 2014 

RKGmedia, LLC

Attn: Richard Gillette

4 Marble Beach Rd. NW

Gig Harbor, WA 98332

Tel: (253) 370-6451

Email: RKGmedia@comcast.net
TABLE OF CONTENTS

Page

SUMMARY 1

INTRODUCTION AND INTERESTS OF PETITIONER 2

NAME AND ADDRESS OF PETITIONER 3

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RKGMEDIA, LLC

SEEKS EXEMPTION 3

THE EXTENT OF RELIEF RKGMEDIA, LLC SEEKS AND THE REASON 

RKGMEDIA, LLC SEEKS THE RELIEF 4

THE REASONS WHY GRANTING RKGMEDIA, LLC 'S REQUEST WOULD 

BE IN THE PUBLIC INTEREST 9

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 10

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT RKGMEDIA, LLC 'S REQUEST 11

CONCLUSION 11
SUMMARY

RKGmedia LLC (RKGmedia), a video production company, seeks exemption from the requirements of 

14 C.F.R. §§ 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a), 91.409(a) and 91.417(a). This 

exemption would permit RKGmedia, a privately held video production company, to operate its 

proprietary sUAS to safely collect various forms of aerial images for commercial use.

14 C.F.R. 91.7(a) Civil aircraft airworthiness

An equivalent level of safety will be provided given the size of the aircraft and the requirements 

contained in the Aircraft Information/Operator’s Manual for maintenance and use of safety checklists 

prior to each flight.

14 C.F.R. 91.119(c) Over other than congested areas

Operations of the sUAS will be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special purpose 

operations.

14 C.F.R. 91.121 Altimeter settings

Altitude of the sUAS will be provided to the PIC via a radio communications telemetry data link, which 

downlinks from the aircraft to the PIC for active monitoring of the aircrafts altitude.

14 C.F.R. 91.151(b) Fuel requirements for flight in VFR conditions

The sUAS will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 2 minutes.

14 C.F.R. 91.405(a) Maintenance required, 14 C.F.R. 91.407(a) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a) Inspections, 14 C.F.R. 91.417(a) 

Maintenance records

RKGmedia’s sUAS Aircraft Information/Operator’s Manual contains daily, preflight, monthly and yearly 

checks for the aircraft. Adherence to this Manual is sufficient to ensure that safety is not adversely 

affected.

RKGmedia will carry out its maintenance, inspections, and record keeping requirements in accordance 

with the Aircraft Information/Operator’s Manual. Maintenance, inspection, and alterations will be noted 

in the aircraft logbook, including total flight hours, description of work accomplished, and the signature 

of the authorized sUAS technician returning to service.

1
INTRODUCTION AND INTERESTS OF PETITIONER

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

C.F.R. Part 11, RKGmedia, LLC. (RKGmedia), a video production company, hereby applies for an 

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

Small Unmanned Aircraft Systems (sUAS) for aerial imaging, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333.

As detailed in this document and the attached proprietary Aircraft Information/Operator’s Manual, the 

requested exemption would permit the operation of sUAS under controlled conditions in airspace that is 

1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the 

collection of aerial media (photography, videography, infrared, etc.).

Approval of this exemption 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.

Richard Gillette is the owner and operator of RKGmedia and will serve as PIC. He holds a Commercial 

Pilot Certificate with Airplane Single and Multiengine Land; Instrument Airplane ratings. His associate is 

David Schilling and will serve as safety coordinator as well as VLOS spotter. Mr. Schilling is a retired 

Wild Land Firefighter with Heli-crew certifications. He has extensive experience in the building, testing 

and operation of similar sUAS as a hobbyist. RKGmedia has experimented, tested, and built many sUAS

in this category (in a non-commercial, hobbyist setting), followed industry advancements in safety and 

navigation, and employed this knowledge into the development of the Seahawk 1.2.

2
NAME AND ADDRESS OF PETITIONER

The name and address of the applicant is:

RKGmedia, LLC

Attn: Richard Gillette

4 Marble Beach Rd. NW

Gig Harbor, WA 98332

Tel: (253) 370-6451

Email: RKGmedia@comcast.net

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RKGMEDIA SEEKS EXEMPTION

14 C.F.R. 91.7(a)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(b)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)

14 C.F.R. 91.409(a)

14 C.F.R. 91.417(a)

3
EXTENT OF RELIEF RKGMEDIA SEEKS AND THE REASON RKGMEDIA SEEKS THE RELIEF

14 C.F.R. 91.7(a) Civil aircraft airworthiness

An equivalent level of safety will be provided given the size of the aircraft and the requirements 

contained in the Aircraft Information/Operator’s Manual for maintenance and use of safety checklists 

prior to each flight.

14 C.F.R. 91.119(c) Over other than congested areas

Operations of the sUAS will be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special purpose 

operations.

14 C.F.R. 91.121 Altimeter settings

Altitude of the sUAS will be provided to the PIC via a radio communications telemetry data link, which 

downlinks from the aircraft to the PIC for active monitoring of the aircrafts altitude.

14 C.F.R. 91.151(b) Fuel requirements for flight in VFR conditions

The sUAS will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 2 minutes.

14 C.F.R. 91.405(a) Maintenance required, 14 C.F.R. 91.407(a) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a) Inspections, 14 C.F.R. 91.417(a)

Maintenance records

RKGmedia’s sUAS Aircraft Information/Operator’s Manual contains daily, preflight, monthly and yearly 

checks for the aircraft. Adherence to this Manual is sufficient to ensure that safety is not adversely 

affected.

RKGmedia will carry out its maintenance, inspections, and record keeping requirements in accordance 

with the Aircraft Information/Operator’s Manual. Maintenance, inspection, and alterations will be noted 

in the aircraft logbook, including total flight hours, description of work accomplished, and the signature 

of the authorized sUAS technician returning to service.

4
RKGmedia supports its request with the following information, organized into three sections:

1) The unmanned aircraft system

2) The sUAS Pilot in Command (PIC)

3) The sUAS operating parameters

1) The Unmanned Aircraft System:

The Unmanned Aircraft System that RKGmedia intends to use is a custom built proprietary sUAS, The 

Seahawk 1.2, (see included Aircraft Information/Operator’s Manual) used primarily for aerial image 

acquisition.

The Seahawk 1.2 is a radio controlled, electric powered (battery), carbon fiber hexacopter measuring 36 

inches wide by 18 inches tall with 12 inch props. It weighs 5lbs. empty, 9lbs 2oz with camera and battery 

and has a maximum takeoff weight of 10lbs. The on-board controller is a DJI Naza M V2. The aircraft 

carries a Panasonic GH4 camera or similar device, stabilized by a 3 axis gimbal. Communications 

between the PIC and the sUAS will be accomplished using a standard hand held R/C transmitter on the 

ground and a receiver on the sUAS. This system operates on a frequency of 2.4 Ghz which is permitted 

by the FCC. The transmitter/receiver uses telemetry to send certain data, such as altitude and battery 

levels, back to the PIC via the transmitter. Further details of the use and maintenance can be found in the 

attached Aircraft Information/Operator’s Manual of the Seahawk 1.2. The sUAS it seeks to operate 

weighs no more than 10 pounds when fully loaded, operates under normal conditions, at speeds no greater 

than 50 knots, carries no explosive materials or flammable liquid fuels, operates exclusively within a 

secured area detailed in this application with no pilots or passengers on board. In the event of GPS or 

communication signal loss, the sUAS possesses the ability to return to a pre-determined location within 

the secured perimeter and land. The sUAS also can abort a flight in case of emergency, facilitated in part 

by an on-board parachute that can be deployed in the event of motor loss or other emergency. Parachute 

deployment deactivates the aircraft’s motors and enables the vehicle to float to the ground.

RKGmedia will perform maintenance by following procedures outlined in the Aircraft 

Information/Operator’s Manual. The Aircraft Information/Operator’s Manual prescribes required 

maintenance and requires the operator to keep a log pertaining to each flight. RKGmedia notes that 

because of the aircraft’s limited size, payload, and operational constraints, immediate landings can be 

performed in case of mechanical issues.

Given the size and weight of the sUAS, the fact that it has a limited range (20 min. max battery), carries 

no flammable fuel, carries no crew or passengers and employs redundant fail safe features, RKGmedia 

believes it can be operated within the NAS with minimal risk to persons and property in the air and on the 

ground.

5
2) The sUAS Pilot in Command (PIC):

RKGmedia proposes that, lacking any current sUAS PIC licensing procedures, the operator of its sUAS

should hold at least a FAA Commercial Pilot Certificate and a second-class airman medical certificate. 

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.

Richard Gillette is the owner and operator of RKGmedia and will serve as PIC. He holds a Commercial 

Pilot Certificate with Airplane Single and Multiengine Land; Instrument Airplane ratings. His associate is 

David Schilling and will serve as safety coordinator as well as VLOS spotter. Mr. Schilling is a retired 

Wild Land Firefighter with Heli-crew certifications. He has extensive experience in the building, testing 

and operation of similar sUAS as a hobbyist. RKGmedia has experimented, tested, and built many sUAS

in this category (in a non-commercial, hobbyist setting), followed industry advancements in safety and 

navigation, and employed this knowledge into the development of the Seahawk 1.2.

Anyone else that would be acting as PIC of RKGmedia’s Seahawk 1.2 would first have to demonstrate to 

Richard Gillette that he or she has met the qualifications outlined above and is capable to safely act as 

PIC of the sUAS.

3) The sUAS Operating Parameters:

Operations authorized by this grant of exemption would be limited to RKGmedia’s proprietary sUAS, the 

Seahawk 1.2, as described in the Aircraft Information/Operator’s Manual, which is included in this 

petition.

The sUAS will not be flown at an indicated airspeed exceeding 50 knots.

The sUAS will be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated 

by the procedures specified in the Aircraft Information/Operator’s Manual. All altitudes reported to ATC 

will be in feet AGL.

The sUAS will be operated within visual line of sight (VLOS) of the PIC at all times. 

All operations will utilize a visual observer (VO). The VO and PIC will be able to communicate verbally 

at all times. The PIC will be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the 

Aircraft Information/Operator’s Manual.

6
Prior to each flight the PIC will inspect the sUAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will be taken out of 

service until the necessary maintenance has been performed and the sUAS is found to be in a condition 

for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance 

and alterations will be properly documented in the aircraft records.

If the sUAS has undergone maintenance or alterations that affect the sUAS operation or flight 

characteristics, it will undergo a functional test flight in accordance with the Aircraft 

Information/Operator’s Manual. The PIC who conducts the functional test flight will make an entry in the 

sUAS aircraft records of the flight.

RKGmedia will carry out its maintenance, inspections, and record keeping requirements in accordance 

with the Aircraft Information/Operator’s Manual. Maintenance, inspection, and alterations will be noted 

in the aircraft logbook, including total flight hours, description of work accomplished, and the signature 

of the authorized Seahawk 1.2 technician returning the Seahawk 1.2 to service.

RKGmedia Seahawk 1.2 maintenance personnel will make a record entry in the sUAS logbook or 

equivalent document of the corrective action taken against discrepancies discovered between inspections.

The PIC will possess at least a FAA Commercial Pilot Certificate and a second-class airman medical 

certificate. The PIC will 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.

If the sUAS loses communications or loses its GPS signal, the sUAS will return to a pre-determined 

location within the private or controlled-access property and land or be recovered in accordance with the 

Aircraft Information/Operator’s Manual.

The PIC will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the 

Aircraft Information/Operator’s Manual.

The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough 

power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 2 minutes.

Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS

will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

7
The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the sUAS any time the aircraft is operating. These documents will be made available to 

the Administrator or any law enforcement official upon request.

The sUAS will remain clear and yield the right of way to all other manned operations and activities at all 

times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.).

sUAS operations will not be conducted during night, as defined in 14 CFR 1.1.

All operations will be conducted in Class G airspace.

All operations will be conducted under visual meteorological conditions (VMC). The sUAS will 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.

During operations in Class G airspace, the sUAS will not operate within 5 nautical miles of the 

geographic center of an airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will 

be made available to the Administrator upon request.

The sUAS will not be operated over congested or densely populated areas.

Operation of the sUAS will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures.

Operations of the sUAS may be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special purpose 

operations.

Operations of the sUAS may be conducted at distances less than 500 feet from unoccupied vessels, 

vehicles or structures owned by the land owner/controller when the land owner/controller grants such 

permission and the PIC makes a safety assessment of the risk from operations closer to these objects.

All operations will be conducted over private or controlled-access property with permission from the land 

owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

8
REASONS WHY GRANTING RKGMEDIA'S REQUEST WOULD BE IN THE PUBLIC INTEREST

RKGmedia submits this Petition to perform commercial operations using its sUAS for aerial image 

acquisition.

Our clients will be privately owned businesses such as those in the motion picture/television industry, 

agriculture, inspection and construction. Also benefitting will be government entities such as The 

Washington State Departments of Transportation, Fish and Wildlife, and Natural Resources. We will be 

assisting with the planning of freeway projects, traffic flow conceptual presentations, search and rescue, 

and fire prevention. Other fields of great potential lie in scientific research, wildlife monitoring, forestry, 

and the oil and gas industries.

The risk to life and property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the 

lack of aircrew members located onboard the aircraft, the sUAS, with its small size and weight, has less 

physical potential for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with a 

wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

These public and private entities will perform their jobs safer and at a lower economic cost than 

previously. This will in turn lower prices for consumers and conserve resources for the taxpayer, the 

general public.

REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

Many of the same reasons that this exemption would be in the public interest apply to why it would not

adversely affect safety. As previously stated, the risk to life and property in the air and on the ground, 

which is usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. Aside from the lack of aircrew members located onboard the aircraft, 

the sUAS, with its small size and weight, has less physical potential for collateral damage to life and 

property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial 

acquisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 

34 feet, and a fuel capacity of 180 gallons).

Properly using sUAS to perform the tasks outlined above would be safer than traditional methods.

9
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

RKGmedia LLC (RKGmedia), a video production company, seeks exemption from the requirements of 

14 C.F.R. §§ 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a), 91.409(a) and 91.417(a). This 

exemption would permit RKGmedia to operate its proprietary sUAS to safely collect various forms of 

aerial images for commercial use.

14 C.F.R. 91.7(a) Civil aircraft airworthiness

An equivalent level of safety will be provided given the size of the aircraft and the requirements 

contained in the Aircraft Information/Operator’s Manual for maintenance and use of safety checklists 

prior to each flight.

14 C.F.R. 91.119(c) Over other than congested areas

Operations of the sUAS will be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special purpose 

operations.

14 C.F.R. 91.121 Altimeter settings

Altitude of the sUAS will be provided to the PIC via a radio communications telemetry data link, which 

downlinks from the aircraft to the PIC for active monitoring of the aircrafts altitude.

14 C.F.R. 91.151(b) Fuel requirements for flight in VFR conditions

The sUAS will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 2 minutes.

14 C.F.R. 91.405(a) Maintenance required, 14 C.F.R. 91.407(a) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, 14 C.F.R. 91.409(a) Inspections, 14 C.F.R. 91.417(a) 

Maintenance records

RKGmedia’s sUAS Aircraft Information/Operator’s Manual contains daily, preflight, monthly and yearly 

checks for the aircraft. Adherence to this Manual is sufficient to ensure that safety is not adversely 

affected.

RKGmedia will carry out its maintenance, inspections, and record keeping requirements in accordance 

with the Aircraft Information/Operator’s Manual. Maintenance, inspection, and alterations will be noted 

in the aircraft logbook, including total flight hours, description of work accomplished, and the signature 

of the authorized sUAS technician returning to service.

10
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

RKGMEDIA'S REQUEST

The following statement from The Washington State Department of Transportation is included in this 

application.

To whom it may concern,

My name is Kurt Stiles. I am the Visual Communications Program Manager of the Visual Engineering 

Resource Group (VERG), GeoMetrix division of Washington State Department of Transportation 

(WSDOT). VERG provides clear and effective communication of project & program development, design 

and delivery issues through various forms of visual media.

We are very interested in using sUAS to supplement our aerial photography and video production. 

Currently we use full size piloted helicopters when capturing footage. I believe that by using sUAS, we 

will be able to gain unique, elevated visual perspectives that are impossible for full size helicopters to 

obtain. Also, by using sUAS, there will be far less personal risk and greatly reduced utilization costs. 

Lastly, using sUAS vehicles will strategically enhance visual analysis of damaged infrastructure during 

emergency situations – a work responsibility of VERG.

We look forward to working with RKGMedia and this emerging technology and aiding in its integration 

into our National Airspace System.

Sincerely,

Kurt Stiles

CONCLUSION

As set forth above, RKGmedia seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012, which will permit safe operation of its sUAS commercially,

for the special purpose of conducting aerial acquisitions. By granting this Petition, the FAA Administrator 

will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while 

also advancing the interests of the public, by allowing RKGmedia to safely, efficiently, and economically 

operate its sUAS commercially within the NAS.

11