R&D	Design	LA,	LLC- Section	333	Exemption	Request	 1

January	24,	2016

U.S.	Dept.	of	Transportation,	Docket	Operations	

West	Building	Ground	Floor,	Room	w12-140	

1200	New	Jersey	Avenue,	SE.,	

Washington,	DC	20590	

Re:	Exemption	Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	

Aviation	Regulations	

Dear	Sir	or	Madam,

On	behalf	of	R&D	Design	La	LLC. (“Applicant”),	and	Pursuant	to	Section	333	of	the	FAA	Modernization	

and	Reform	Act	of	2012	and	14	C.F.R.	Part	11,	I	David	K	Holtman,	Managing	Director,	am	seeking	an	

exemption	from 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).

As described	more	fully	below,	the	requested	exemption	would	permit	the	operation	of	Small	

Unmanned	Aircraft	Systems	(“sUASs”)	under	controlled	conditions	in	airspace	that	is:

1. Limited

2. Predetermined

3. Controlled	as to	access	

4. Providing	safety	enhancements	to	the	already	safe	operations	in	the	infrastructure	and	business	

operations	industry	presently	using	conventional	aircraft.	

Approval	of	this	exemption	would	thus	enhance	safety	and	fulfill	the	Secretary	of	Transportation	and	the	

FAA	Administrator’s	responsibility	to	“....establish	requirements	for	the	safe	operation	of	such	aircraft	

systems	in	the	national	airspace	systems.”	Section	333(c)	of	the	Reform	Act.	

APPLICANT	INFORMATION:

R&D	Design	La,	LLC.

Name:	David	K Holtman and	Ryan	Becnel

Phone:	978-835-1348

Email:	david@rddesignla.com

Business	Address:	1615	Poydras	St.	Ste	907,	New	Orleans,	La	70112

Operator	1	(PIC):	David	K	Holtman;	946	Harding	Dr.,	New	Orleans,	La	70119

Operator 2:	Ryan	Becnel;	4916	Lasalle	St., New	Orleans,	La	70115

BACKGROUND	INFORMATION:

R&D	Design	La	is	in	the	business	of	providing	high	quality	photography	and	videography	/	

cinematography	to	organizations	engaging	in	construction,	tourism,	commercials,	nature,	disaster	relief.	

The	Applicant	is	requesting	FAA	Exemption	for	the	UAS	for	safety,	inspection	and	photography	/	

videography	capture	usage.	

THE	UNMANNED	AIRCRAFT:

The	UAS	is	lightweight	(under	55lb.	gross	weight),	battery	operated	multi- rotor	copter	that	takes	off	

and	lands	vertically	and	has	the	ability	to	self	stabilize	in	one	location	while	in	flight.	
R&D	Design	LA,	LLC- Section	333	Exemption	Request	 2

• DJI	Inspire	1

o UAS	Cert	#:	FA3Y4ELHKA

o Issued:	12/24/2015

o Exp:	12/24/2018

THE	UAS	INCLUDES:	

• An	on-board	flight	computer	with	GPS navigation	and	location	ability	that	receives	signals	for	

flight	control	from	a	ground-based	transmitter/controller.	

• An	on-board	camera	and	sensor	package	used	to	document	physical	and/or	environmental	

conditions	of	structures	and	the	natural	environment.	

• An	on-board	telemetry	system	that	delivers	flight	data	from	the	on-board	flight	computer	to	the	

radio	transmitter	including	altitude	AGL,	horizontal	and	vertical	speed,	compass	direction	of	

flight	and	direction	back	to	its	launch	site.	

• A	2.4GHz	on-board	radio	transmitter	that	transmits	live	video	from	the	on-board	camera	plus	all	

the	flight	data	from	the	telemetry	system	described	above.	

• The	capability	to	return	at	a	predetermined	location	if	site	or	GPS	communications	are	lost.

• FAA	Certification	number	clearly	displayed.

THE	GROUND	STATION	PART	OF	THE	SYSTEM:	

• A	Pilot	in	Command	(PIC)	in	operational	control	of	a	mission	from	beginning	to	end,	and	who	

controls	the	UAS	while	in	the	air.	

• A	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	control	the	UAS	while	in	flight.	

• Ground	Station	(tablet	or	smart	phone	based	app:	DJI	GO)	which	receives	and	displays	video	and	

system	telemetry	real	time	from	the	UAS.	

• A	Visual	Observer	(VO),	a	person	who	provides	a	second	pair	of	eyes	to	visually	track	the	UAS	

while	in	flight.

QUALIFICATIONS	OF	PIC:

• Primary	PIC- David	Holtman	has	logged	over	100 non-commercial,	recreational	flights with	the	

UAS	and	averages	5	hours	of	flight	time	per	week	to	ensure	familiarity	and	increase	skill	and	

ability	with	the	maneuvering	of	the	UAS.	David	maintains	an	excellent	level	of	health	and	always	

uses	discretion	while	operating	the	UAS.	Currently	David	follows	all	safety	regulations	set	by	the	

FAA	while	flying	recreationally	and	continues	education	to	keep	up	with	any	changes	and	

expand	knowledge	of	regulations	and	safety	procedures.	This	experience	also	qualifies	David	as	

a	VO	when	the	UAS	is	not	being	operated	by	David.

• Secondary	PIC- Ryan	Becnel	has	logged	over	80	non-commercial,	recreational	flights	with	the	

UAS	and	averages	5	hours	of	flight	time	per	week	to	ensure	familiarity	and	increase	skill	and	

ability	with	the	maneuvering	of	the	UAS.	Ryan	maintains	an	excellent	level	of	health	and	always	

uses	discretion	while	operating	the	UAS.	Currently	Ryan	follows	all	safety	regulations	set	by	the	

FAA	while	flying	recreationally	and	continues	education	to	keep	up	with	any	changes	and	

expand	knowledge	of	regulations	and	safety	procedures. This	experience	also	qualifies	Ryan	as	a	

VO	when	the	UAS	is	not	being	operated	by	Ryan.

ADDITIONAL	SAFETY	MEASURES	TAKEN

• A	pre-flight	safety	inspection	will	occur	as	it	pertains	to	all	equipment.	

• Flights	will	be	operated	within	line	of	sight	of	the	PIC.
R&D	Design	LA,	LLC- Section	333	Exemption	Request	 3

• Maximum	flight	time	for	each	operational	flight	will	be	30	minutes	and	will	be	ended	when	

batter	level	reaches	25%	of	battery	reserve.	

• Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	or,	not	more	than	200	feet	

above	an	elevated	platform	which	flight	is	planned.

• The	UAS	pilot	will	be	and	is	a	specially	trained	staff	member	of	the	Applicant	knowledgeable	of	

the	airspace	which	the	flight	will	take	place	within.	

• A	briefing	of	the	flight	pattern	will	be	reviewed	prior	to	flight	with	specific	attention	to	safety.	

• Operator	will	obtain	consent	of	all	persons	involved	in	the	flight	and	only	consenting	individuals	

will	be	allowed	within	100	feet	of	the	flight	path.	This	radius	may	be	reduced	to	30	feet	based	on	

an	equivalent	level	of	safety	determination.	With	advanced	permission	of	the	relevant	FSDO,	

operations	at	closer	range	can	be	approved.	

• Pilot	and	observer	will	have	been	trained	in	operation	of	UAS	generally	and	received	up	to	date

information	on	the	particular	UAS	to	be	operated.

• All	required	permissions	and	permits	will	be	submitted	for	and	received	by	state,	county	or	city	

jurisdictions.

PRE	FLIGHT	SAFETY	INSPECTION	AND	FLIGHT	PROCEDURES:

The	following	steps	are	conducted	for	each	and	every	flight.

1. Visually	inspect	the	UAS/UAV	prior	to	all	flights

2. Inspect	the	blades	and	insure	they	are	installed	properly	and	free	of	any	damage

3. Confirm	that	all	the	batteries	are	fully	charged

4. Confirm	a	proper	communication	connection	between	the	UAS/UAV	and	the	controller	prior	to	

any	flight

5. Visually	inspect	the	flight	area	by	walking	the	entire	perimeter

6. Confirm	and	locate	a	safe	takeoff	and	landing	location

7. Discuss	flight	emergency	options	and	potential	hazards	with	the	Flight	Spotter	and	all	project	

participants

8. Test	the	flight	proficiency	of	UAS/UAV	first	by	flying	to	a	4-foot	height	level,	hover	for	1	min,	test	

the	Yaw,	Pitch	and	Roll.	Once safely	completed	land	the	aircraft	and	prepare	for	the	actual	flight

9. Log	the	flight	with	the	project	name,	purpose,	location,	time	and	date

10. Confirm	the	surrounding	conditions	are	safe	for	flight.	This	includes	people,	traffic,	telephone	

wires,	wildlife,	buildings	and weather

11. No	flight	will	ever	take	place	nor	will	any	control	of	any	UAS/UAV	ever	be	conducted	while	

under	any	influential	drug

12. Always	maintain	a	safe	distance	from	any	buildings	and	always	maintain	a	clear	line	of	site	while	

operating	a	UAS/UAV

13. Always	within	compliance	of	the	FAA	maintain	appropriate	distance	from	airports	unless	

otherwise	granted	permission	by	the	control	tower	of	airport	within	radius.	

14. While	in	flight	keep the	UAS/UAV	in	front	of	you,	never	fly	the	aircraft	behind	you

15. Confirm	that	the	FAA	assigned	UAS	certificate	number	is	in	tact	and	properly	placed	on	the	

aircraft

16. UAS/UAV	aircraft	is	required	to	always	remain	in	a	direct	visual	line	of	site	while	in	the	air

17. Pay	close	attention	to	UAS/UAV	distance,	battery	level	and	aircraft	location	throughout	the	

entire	flight

INTENDED	USE	/	PUBLIC	GOOD:	14	CFR	§11.81(d)

The	requested	exemption	would	allow	the	Applicant to	use	the	UAS	for	aerial	image	acquisition	to	

support	various	mapping	and	surveying	applications	as	well	as	video	documentation	for	the	public	good.	
R&D	Design	LA,	LLC- Section	333	Exemption	Request	 4

Typical	applications	would	include,	but	are	not	limited	to:	

• Aerial	Photography	

• Aerial	Mapping	

• Commercial	Videography

• Motion	Picture	Videography

• Special	Event	Videography	/	Photography

• Infrastructure	Inspections	

• Utility	Inspections	

• Construction	Site	Monitoring	

• Volumetric	Calculations	

• Search	and	Rescue	

• Education	

The	ability	of	the	UAS	to	capture	imagery	from	a	low	altitude	including	photos	and	video	from	several	

angles	is	far	more	effective	than	ground-based	imagery	for	displaying	the	characteristics	of	buildings,	

sites	and	properties.	Further,	UAS	can	access	locations	not	accessible	to	conventional	aircraft	due	to	

their	own	flight	restrictions	due	to	size.	The	applicant	produces	maps	from	aerial	imagery	that	public	

and	private	entities	use	for	infrastructure	assessment,	utility	inspections,	land	development	projects	and	

construction	site	safety	inspections.	These	images,	videography,	maps	and	other	products	produced	

from	UAS	are	used	to	better	the	local	economy	and	promote	local	business.	

PUBLIC	SAFETY:	

UAS	are	powered	by	batteries,	they	are	smaller,	lighter	and	more	maneuverable	than	larger	aircraft	

running	on	combustible	fuel;	they	operate	at	lower	altitudes	(under	400’)	with	no	people	on	board	

thereby	reducing	current	risk	levels	and	enhancing	public	safety.	With	a	small	payload	and	maximum	

flight	time	of	approximately	20	minutes.	UAS	offer	little	or	no	risk	to	national	security	due	to	their	size,	

payload	capacity	and	flight	duration.	

DJI	models	have	their	own	built	in	failsafe	functionality	which	will	cause	the	UAS	to	return	to	its	take-off	

location	and	land	before	the	battery	becomes	empty,	or the	system	loses	communication.	In	addition

DJI	uses	geo	fencing	technology	to	restrict	flight	operations	where	the	FAA	has	mandated	no	fly	zones	

such	as:	Airports,	National	Parks,	and	Stadiums.

PRIVACY:

All	flights	will	occur	over	private	or	controlled access	property	with	the	property	owner’s	prior	consent	

and	knowledge.	Infrastructure	and	construction	inspections	and	business	operations	will	be	performed	

for	people	who	have	also	consented	for	work	to	be	performed	or	otherwise	have	agreed	to	be	in	the	

area	where	UAS	flight	will	take	place.

SUMMARY	EXEMPTION REQUEST:	

This	request	follows	many	others	using	similar	systems	and	process	that	have	been	granted	previously.	I	
R&D	Design	LA,	LLC- Section	333	Exemption	Request	 5

am	requesting	the	FAA	issue	a	summary	grant	of	exemption	as	this	request	would	not	set	a	precedent.	

R&D	Design	La	LLC	respectfully	requests	that	the	FAA	grant	it’s	exemption	request.	

I	am	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	the	need	for	an	equivalent	level	of	

safety.	Please	contact	me	at	any	time	if	you	require	additional	information	or	clarification.	I	am	the	

primary	point	of	contact	for	this	request	and	look	forward	to	working	with	your	office.

David	K	Holtman

Cell:	978-835-1348

Email:	david@rddesignla.com