U.S. Department of Transpor tation, 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 Se ction 333 as a Civil operator.

1. Sections from which exempt ions 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 Unmanne d Aircraft Systems for commercial purposes to include (but not limited to) videography, phot ography, inspections and surveys. This relief is sought because commerc ial use of UAS's is currently prohibited by law unless performed under an exemption.

b. This exemption will cover use of the follo wing airframes, all of which will weigh less than 55 pounds including payload and energy sources: i. DJI Phantom 2 Rotorcraft: Max Weight - 2 lb s 13 oz, Wheel Base -13.78 inches; please see attached user manual for specif ications, navigational guidance, loss link procedures, flight termination system. ii. Other models to be added by futu re amendments to this exemption3. 

### 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 eliminat ing 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 t he 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 regulat ions concerned with t he 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