May 8, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

RE: Docket ID: FAA-2014-1081 

Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 

11.81 of the Federal Aviation Regulations 

Petitioner: 

PicWing, Inc.

1455 Vista Road

El Cerrito, CA 94530

Tel.: 415.755.0110

Email: patrick@ischool.berkeley.edu

Website: www.picwing.com

Dear Sir or Madam, 

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

and 14 C.F.R. Part 11.81, PicWing, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FARs") to allow commercial operation of its small, unmanned aircraft 

for photography, photogrammetry, inspection, and analyses. All operations shall be conducted 

within and under the conditions and limitations outlined previously by the FAA as required by 

Section 333 and conducted in compliance with the attached operator’s manuals. 

1. Sections from which exemptions are sought: 

Application is hereby made for exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 
2. Relief sought: 

a. PicWing wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial 

purposes to include (but not be limited to) photography, photogrammetry, industrial inspections 

and analyses. 

This relief is sought because commercial use of sUAS is currently prohibited by law unless 

performed under an exemption. 

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources: 

i. 3DR Iris+ (see https://store.3drobotics.com/products/IRIS) 

ii. DJI Phantom 2 (see www.dji.com/product/phantom-2) 

iii. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure 

inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging 

failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from 

manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 

45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All 

repair and maintenance work will be conducted or approved by qualified personnel such as those 

authorized by Robotic Skies (or equivalent), and will require a test flight after such work. 

Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. 
c. All flight operations will be conducted by at least two individuals (PIC and observer) who will 

maintain verbal communication capability with each other at all times during the flight, and who 

will remain stationary on the ground during the flight operations: 

i. A Pilot In Command (PIC) who possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA 

2. A Third Class medical certificate issued under 14 CFR 67. 

3. A bi-annual flight review under 14 CFR 61.56 

4. Successful completion of a UAS knowledge test in a specified form. 

5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or UAS fixed-wing 

in the case of fixed-wing flight operations under this exemption). Such cycles and hours may be 

gained during flights under this exemption if a safe distance is maintained from persons in 

accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being 

flown in the prior 90 days. Such cycles and hours may be gained during flights under this 

exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119. 

ii. A Visual Observer. 

iii. A Sensor Operator as necessary. 

d. All flight operations will be conducted in accordance with valid Certificates of Authorization. 

e. All flight operations will comply with the following: 

i. The manufacturers’ user manuals. 

ii. PicWing Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals 

(AFM) which include lost communication and other emergency and safety procedures. 

iii. Conducted in VMC conditions during daylight hours. 

iv. PIC and VO will maintain VLOS at all times. 
v. Pre-flight inspections (including ground control station, if any) and safety risk assessments 

will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take 

place within 5 nautical miles of an airport. 

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground

without their prior permission. 

x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever 

occurs first. 

xii. Any incidents will be reported within 24 hours of occurrence. 

xiii. PicWing will maintain liability insurance of at least $1,000,000 issued by a major aviation 

insurance underwriter. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with welldefined and tested lost link procedures. 

Please let us know if you have any additional questions or advise us of any additional 

information or changes that may be required. 

Sincerely, 

Dr. Patrick Riley, PhD 

CEO, PicWing