### 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 OPERATIO N 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.netTABLE OF CONTENTS

Page

SUMMARY 1

INTRODUCT ION AND INTERESTS OF PETITIONER 2

NAME AND ADDRESS OF PETITIONER 3

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

SEEKS EXE MPTION 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

ADVERS ELY AFFECT SAFETY 9

SUMMARY THAT CAN BE PUBLISHED I N THE FEDERAL REGISTER 10

ANY ADDITIONAL I NFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT RKGMEDIA, LLC 'S REQUEST 1 1

CONCLUSION 1 1SUMMARY

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, t o fly after

that for at least 2 minutes.

14 C.F.R. 91.405(a) Mainte nance 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 dai ly, preflight, month ly 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

.

1INTRODUCTION 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. Par t 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

Sm all 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 establish ed 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) limite d 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 Trans portation’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 an d 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

W ild 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 set ting), followed industry advancements in safety and navigation, and employed this knowledge into the development of the Seahawk 1.2.

2NAME 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)

3EXTENT 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 con ducted 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 req uired, 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, prefl ight, 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.

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

1) The unmanned aircraft system

2) The s UAS Pilot in Command (PIC)

3) The s UAS 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, electr ic 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 oper ates 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 f lammable 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 wi thin 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 mot ors 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.

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### 2) The s UAS Pilot in Command (PI C):

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 require ments 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 Multie ngine 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 build ing, 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 t o safely act as
PIC of the sUAS

.



### 3) The s UAS 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 inclu ded 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 Manua l.

6Prior 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 mai ntenance 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 sU AS 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 wi ll 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 reco rd 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 PI C 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 In formation/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 s UA S will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

7The 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 operati ons 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 managem ent 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 str uctures.

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 ma y 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.

8REASO NS 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 Reso urces. 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 appro ximately 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 woul d not adversely affect safety. As previously stated, t he 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 t he 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.

9SUMMARY 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

e xemption w ould 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 aircraf t 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 les s 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 req uired, 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, prefl ight, 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.

10ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVA ILABLE TO SUPPORT

RKGMEDIA 'S REQUEST

The following statement from The Washington State Department of Transportation i s in cluded in this application.

To whom it may concern,

My name is Kurt Stiles. I am th e 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

a nd 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, w e 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 strategic ally 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.

Since rely,

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 ope ration of its sUAS commercially, for the special purpose of conducting a erial 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, efficient ly, and economically operate its sUAS commercially within the NAS.

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