December 26, 2015 

U. S. Department of Transportation 

Docket Management System

 1200 New Jersey Ave, SE

 Washington, DC 20590

 Re: Section 333 of the FAA Reform Act of 2012 

Dear Administrator,

 I, Peter A. Wolford, herein referred to as (the petitioner), am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request 

that the petitioner, who is the owner and operator of a small unmanned aircraft system (UAS), petition 

for exemption from the Federal Aviation Regulations listed below and any regulation as required by the

FAA that is deemed necessary in order to conduct commercial UAS operations as described.

 The requested exemption would permit the petitioner to pursue, safe, professional, for profit services 

to private and public entities within the State of Hawaii and adjoining states utilizing a small 

unmanned aircraft system (UAS) for aerial still and video data capture for, but not limited to the 

following purpose:

 *Real Estate Sales

 *Residential/Commercial Roof inspections/Flare Stack inspections

 *Crop Inspection 

*Property Video Survey

 *Photo/Videography of rural contracted outdoor recreational activities on private and public use lands 

(Prior Permission and coordination Only)

 *Fire Survey and Rural Search Assist to local public and private entities.

 Peter Wolford, the proposed pilot and owner/operator, has flown RC gliders and airplanes since the 

1960's when we had only single impulse transmitters and is still flying RC gliders, planes and 

helicopters as well as the addition of quad-copters now with Spektrum DSM@ technology. He also is a

current ATP certified multiengine pilot, commercial single engine and glider rated as well as certified 

ground instructor, FAA Certificate # 3460364 and has a Restricted Radiotelephone Operator Permit 

FCC # 021184882. He also started up Paragon Air as a Part 135 Operation in Hawaii in 1980 and was 

the chief pilot and director of operations and had a perfect record with the FAA for his operation when 

he sold his company in 1990. 

Furthermore Peter Wolford currently pilots a C90B King Air for an air ambulance based on Maui. 

Peter Wolford has done aerial photography from single and multiengine aircraft since 1976 on Maui 

and has had his works in books, advertisements and art galleries and is well versed in what enhances 

aerial photographs and will be able to do this with more precision with a UAS. Before commercial use 

of RC helicopters were prohibited by the FAA Peter Wolford did aerial photography with large SLR 

Nikons mounted below gas engine RC helicopters. In addition, the safe integration of the UAS into the

national airspace without interference or hazard to manned aircraft is of utmost importance. The 

proposed services are offered with the intent of enhancing the development and safe operation of 

unmanned aircraft systems, realizing that current manned aircraft operations pose a much greater risk 

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of personal injury and or death and extensive property damage. The use of UAS could fulfill a service 

to consumers and small entities that would otherwise not exist due to the risks and costs involved with 

manned aircraft. 

The initial (UAS) to be utilized during the operations is a consumer class helicopter, quad-rotor aircraft 

or a quad-rotor aircraft with similar features. I will outline the features of the ProDrone Byrd Premium 

in this proposal. It is manufactured by ProDrone-tech and has the manufactures model designation 

Byrd. It is an advanced (UAS) with state of the art safety features, GPS lock, altitude, position hold 

stabilization, smart mode, manual mode follow me and return to home mode among others. The ground

station has telemetry with altitude, ground speed, GPS location and battery life for both the transmitter 

and aircraft as well as an alert and auto return for aircraft low battery. Aircraft also has LED visual alert

indicators for low battery, GPS loss, and communication loss. The UAS has a first person view via a 

tablet on the controller that enhances the ability to take precise photos by the PIC. The UAS 

communicates with the transmitter/controller which then has the ability to link with a smart phone or 

tablet for video link for the pilot and/or a third party to see what is going on . The UAS has separate 

radio frequencies for telemetry and video downlink and aircraft control. 

UAS are often seen as superior to manned helicopters and airplanes due to the smaller size and lower 

costs, reduced noise and as such, a much smaller environmental and safety impact. In addition, for 

safety the petitioner shall have a fire extinguisher on hand for all operations due to the hazard that 

Lithium Ion batteries present.

The petitioner requests exemption to operate a ProDrone Byrd (or similar quad-copter) equipped with a

three-axis Gimbal and Camera. This UAS has a Geo fence while in GPS Mode that has an adjustable 

distance limit from the controller as well as altitude ceiling. The altitude is displayed on the monitor 

and will be kept at altitudes granted by the FAA. Also being adhered to shall be AMA’s and FAA 

requirement for Visual Line of Sight limitation along with the AGL limitation. The ground station is 

also programmed in its firmware with a safety feature that will not allow the aircraft into airport 

airspace boundaries (this will be added to by review of sectionals for the given area of flight). The Byrd

also has the failsafe-automated feature of return to home in the event that communication is lost 

between the ground station and the aircraft. 

.....................................................................................................................................

Statistics for the ProDrone Byrd Premium are as follows:

Aircraft

Weight 1930 g

Rated Load 200 g

Max. Load 500 g

Wind Resistance 3 Grade

Max. Ascent Speed 6 m/s

Max. Speed 15 m/s

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Hover Precision (P Mode) +/- 0.2m (Vertical)

Hove Precision cont. +/-0.2 (Horizontal)

Max. Flight Altitude 4000 m

Endurance 29 min

Operating Temperature -10 C to 50 C

Gimbal

Controllable Angle Range Pitching: -90 to 0

Yawing: -45 to 45

Vision Positioning System

Velocity Range <8 m/s

Altitude Range 20 cm – 600 cm

Positioning Accuracy +/-3.0 cm (Horizontal)

+/-2.54 cm (Vertical)

Operating Environment Surface with clear pattern and

Adequate lighting

Remote Controller

Frequency 2405.5 Mgz~ 2438MHz

Max. Communication Distance 2000 m

Battery Voltage 7.4 V

Battery Capacity 5000mAh (2S)

Mobile Device Holder Support tablet & mobile phone

Equivalent Isotropically Radiated Power 18mW

(EIRP)

Operating Temperature -10C to 50C

Charger

Voltage/Current 16.8V/2.5A (Battery)

16.8V/1A (Remote Controller)

Rated Power 67.2 W

3
Battery

Capacity 7000mAh

Voltage 14.2 V

Energy 99.4Wh

Weight 500g

......................................................................................................................................

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The 

petitioner will-- 

a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of 

a visual aid other than corrective lenses.

b. Operate at an altitude no greater than that approved above the ground by the FAA.

c. Operate with due vigilance and known practiced see and avoid scanning techniques to 

avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating

area. The UAS flight will be immediately terminated if a potential conflict may exist.

d. Operate over private or public sites only with prior permission from property owner or 

owner’s agent or legal authorities as allowed by law. 

e. Terminate flight when any unsafe condition exists. 

f. Terminate flight when battery voltage drops to 30% of battery capacity or when the 1st 

low battery alert occurs per the Byrd Instruction Manual.

g. Operate at a ground speed of 0 to 35 mph during on site missions. 

h. Operate in accordance with the guidance and standards set forth by the AMA, the UAS 

manufacturer and the administrator. 

i. Operate with a minimum crew for each operation consisting of the PIC and a visual 

observer in direct communication utilizing appropriate verbal, radio or cell phone as needed.

j. Insure the UAS operator on the controls will be at least a current Private Pilot with at least

a class III medical or a valid State issued United States Driver License. 

k. Provide ground instruction with standards and content currently accepted by the 

administrator for private pilot knowledge testing, to the observer and or UAS. 

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot 

in Command Section (a). Although the petitioner is a current certified ATP pilot the petitioner 

may elect to utilize certified pilots with class III medicals to conduct operations with the UAS. 

In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a 

PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect 

operations in the NAS or present a hazard to persons or property on the ground. The petitioner 

requests the same consideration and limitations as previously granted. 

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is 

available for this UAS the petitioner requests exemption under this part utilizing a preflight 

inspection and the manufacturers documents for determining compliance of the UAS 

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airworthiness. The petitioner warrants compliance to part 91.7(b) in that the operation will only 

be conducted after a thorough preflight and premission planning inspection is completed, to 

include current and forecast weather, airspace, notams, TFR's, area of operations, and notice 

issued to non-participating persons in local proximity. The petitioner will utilize the ProDrone 

Byrd Instruction manual, quick start guide for preflight inspection needs. 

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes.

The petitioner requests exemption from Section (c) with the following conditions and 

limitations. The petitioner requests the exemption due to the scope of the operations to be 

performed and the requirement to operate below 400 feet AGL. The Petitioners primary mission

would be to record data or survey of persons, property or structures as listed above. The UAS 

size, weight, speed and limited operating times and area, as well as the soft materials used in the

construction of the UAS, would provide an equivalent or greater level of safety as intended 

under this part. The Byrd is a helicopter as defined by CFR Title 14, FAR Part 1, general 

definitions. The UAS has a vertical to near vertical descent in the event of a power failure. The 

Byrd is a very stable, low rotor speed UAS that maneuvers, under GPS lock, relatively slow 

compared to similar sized UAS. In an emergency the UAS would be quickly brought down per 

the loss of control procedure as described in the emergency procedures checklist, adequate time 

to complete the procedure would exist due to the 0 to 35 mph operational ground speed of the 

Byrd. The risk to persons 100 feet away would be at no greater risk than persons located 500 

feet away. The petitioner requests exemption from the 500-foot altitude restriction and the 500-

foot stand off restriction from persons, property or vessel applied to previous grants of 

exemptions. The exemption is requested with the following conditions and limitations in 

conducting the petitioners operations— — 

a. The UAS will be operated at an altitude of no more than 500 feet above ground level 

(unless in uncontrolled airspace). 

b. The UAS will be operated in view of the PIC at all times. 

c. The UAS will not be operated over any non-participating person. 

d. The UAS will not be operated over a non-participating property, structure or vessel 

without prior permission from the property owner or legal representative. 

e. The UAS will maintain a minimum slant distance of 100 feet from any non-participating 

person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no 

time will the UAS be operated closer than a 100-foot slant distance to a non-participating 

person unless that person is behind a protective barrier or shielded from possible debris in 

the event of a crash. 

f. A minimum of 2 hour notice will be distributed to all residences or businesses of a 

scheduled operation in an urban business or residential area within 500 feet of the operation,

informing of the time, location and safety hazards to persons or property, the notice will 

include a phone number to voice objections or concerns. 

g. The UAS will be operated over public rural lands with the same stand off distance and 

altitude restrictions afforded persons, property and vessels per e. above. 

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS 

will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to 

operate the UA within VLOS and at or below 500 feet AGL, combined with the petitioner’s 

intention to limit the altitude of the UAS through flight limit function on the UAS, has been 

previously ruled to be a sufficient method for ensuring the UAS operations do not adversely 

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affect safety. The altitude information will be generated by GPS equipment installed onboard 

the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude. 

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight 

in VFR conditions, prior relief has been granted for manned aircraft to operate at less than the 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar 

UAS-specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, 

Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that 

indicate the PIC must command the UA’s return to the launch point when low battery capacity 

voltage is reached. The UAS also provides 2 and 3rd increased intensity critical low battery 

warnings through audio indicating that the UA must be landed immediately, additionally a fail 

safe automatic landing will occur when the battery is at critical low voltage. The petitioner 

warrants that the UAS will be returned to land immediately upon the 1st low battery alert. The 

petitioner will not initiate a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and land the 

UA with 15% battery power remaining. 

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) Maintenance 

required, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records.

Currently the manufacturers maintenance procedures govern preflight with no limits other than 

on-condition. The petitioner will complete all authorized component replacements at the 

petitioner’s base of operations or in the field as required. The manufacturer or authorized repair 

center will complete any maintenance or repairs that cannot be completed by the petitioner. The 

petitioner will comply with any and all manufacturers updates for UAS and Ground station as 

well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be 

kept with the UAS ground station and base of operations as required. 

As previously stated the petitioner has demonstrated over 35 years of safe professional 

commercial service as a pilot. The petitioner requests the administrator to consider that the same

professional standards and safe practices utilized by this petitioner would be an asset and 

greatly benefit the development and integration of the UA system into the National Airspace. 

Furthermore it is of this petitioner’s best interest as a currently employed commercial pilot to 

insure safe, compliant and professional commercial operations for the furtherance of public 

safety in the aviation industry. 

Sincerely, 

Peter Wolford

1181 Pulehuiki Rd.

Kula, HI 96790

cell 503 383 9915 

peterwolford@gmail.com

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