U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E: 

Washington, DC 20590 

Petition for Exemption Under 14 CFR 5 11.81 

to Allow Commercial Use of Unmanned Aircraft Systems 

June 12, 2015 

Petitioner: 

Airo Productions 

Randy Quigley, CEO 

1671 E 1925 S 

Gooding, ID 83330 

Cell: 208 308-6922 

Email: randy.airoproductions@gmail.com 

Dear FAA, 

This application is for Petitioning for Exemption under Section 333 as a Civil operator. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from: 

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333 

b. 14 CFR Part 21, subpart H 

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

d. 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. Airo Productions wishes to operate Unmanned Aircraft Systems for commercial purposes to 

include (but not limited to) videography, photography, inspections and surveys. This 

relief is sought because commercial use of UAS's 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. DJI Phantom 2 Rotorcraft: Max Weight - 2 lbs 13 oz, Wheel Base -13.78 inches; please see 

attached user manual for specifications, navigational guidance, loss link procedures, flight 

termination system. 

ii. Other models to be added by future amendments to this exemption 
3. Public benefit: 

a. Use of UAS 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, such as 

power utility inspections and other dangerous activities requiring scaffolding or rigging for 

bridge or building 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: 

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 

 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. Prior to each flight, the PIC will conduct a pre-flight inspection to determine safe flight 

condition . 

d. All flight operations will be conducted by two individuals 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. The Pilot In Command will possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) 

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

3. A Bi-annual flight review under 14 CFR61.56 

4. A completion of a UAS instructional course for safe flying. 

5. The flight experience in a UAS rotorcraft (or UAS fixed-wing in the case of 

fixed-wing flight operations under this exemption). will be conducted if a safe 

distance is maintained from persons in accordance with 14 CFR 91.119. 

ii. A Visual Observer will be present during all flights 

e. All flight operations will comply with the following: 

i. The manufacturers' Aircraft Flight Manuals and operation guidelines 

ii. If UAS loses communication or loses the GPS signal, the UA will return to home base 

or a pre-determined location. 

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 operate within 5 miles of an airport unless a letter of agreement is obtained. 

ix. Not operate 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. 

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

xiii. Comply with any applicable local FSDO requirements. 

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

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data. 
Sincerely, 

Randy Quigley 

Randy Quigley 

Airman certificate #3429268 

CEO, Airo Productions