Name: Pedro Dorta

Acting on behalf of: Aireko Construction Co.

Adress: 

Las Casas Street, Lot #20

Bairoa Industrial Park

Caguas, PR 00725

Phone: (787) 653-6300

Email: padorta@aireko.com

The specific section or sections of 14 CFR from which you seek an exemption:

Petition for Exemption under Sec 333

The extent of the relief you seek:

Under section 333, the use of UAS for commercial purposes on private properties is prohibited. Aireko 

Construction Co. is therefore petitioning for an exemption of such section so that it may rely on the use 

of UAS for commercial purposes in which it will document, through aerial photography, the progress of 

the construction projects that are being developed and those that will be developed in the future.

Aireko seeks to further develop our core business through the use of Unmanned Aircraft System (UAS) 

that will help us achieve improvements in methods of construction as well as improvements in customer 

satisfaction. UAS will help us better document project progress as well as better analyze project/site 

conditions which will essentially provide a safer environment for our employees to work in as well as 

maximization of our project development strategies.

Reason for seeking such relief:

Aireko is a top-notch construction company that has been conducting business for more than 50 years. 

We are proud to be one of the leading construction companies in Puerto Rico with core principles such 

as integrity, zero accidents, and customer satisfaction. We seek to further develop our core business 

through the use of Unmanned Aircraft System (UAS) that will help us achieve improvements in methods 

of construction as well as improvements in customer satisfaction. UAS will help us better document 

project progress as well as better analyze project/site conditions which will essentially provide a safer 

environment for our employees to work in as well as maximization of our project development 

strategies. Nonetheless we want to set ourselves to the highest standards of requirements for when it 

comes to using UAS in order to insure that we keep in line with our core principles.
How this request is in the public interest:

Aireko’s request is in the public interest because the use of UAS will provide more tools for ensuring that 

every day we are providing an environment for our workers that is accident free. Aerial documentation 

will provide us with the means for ensuring the designated area of work is safe and accident free before 

employees even enter the designated area. Aireko is proud to employee over 500 people, yet the 

purpose of our company is to ensure that all workers are provided with the safest working environment.

How will your request benefit the public as a whole:

Aireko’s request will benefit the public as a whole by providing safer working conditions for our 

employees. Complying with any or all regulation relating to UAS will allow Aireko to be set to the highest 

standards of measurement. Having a certified RC Pilot in Command will also serve as an extended relief 

to any client that wishes to do business with Aireko. Providing clients with the evidence of certification 

indicating that Aireko is willing and capable of providing aerial documentation of a project will allow us 

to seek more clients and further extend its goal of being a company that is dedicated to integrity, zero 

accidents, and client satisfaction.
To whom this may concern,

I, Pedro Dorta, on behalf of Aireko Construction Co. would like to petition for an exemption to the FAA 

to operate unmanned aircraft in National Airspace System (NAS), under Section 333.

Aireko is a top-notch construction company that has been conducting business for more than 50 years. 

We are proud to be one of the leading construction companies in Puerto Rico with core principles such 

as integrity, zero accidents, and customer satisfaction. We seek to further develop our core business 

through the use of Unmanned Aircraft System (UAS) that will help us achieve improvements in methods 

of construction as well as improvements in customer satisfaction. UAS will help us better document 

project progress as well as better analyze project/site conditions which will essentially provide a safer 

environment for our employees to work in as well as maximization of our project development 

strategies. Nonetheless we want to set ourselves to the highest standards of requirements for when it 

comes to using UAS in order to insure that we keep in line with our core principles.

The UAS we seek to use in our company is the DJI Phantom 2 Vision +. Specifications for the aircraft are 

as follow:

 Aircraft:

o Weight (Battery & Propellers Included) – 3lbs

o Hover Accuracy (Ready To Fly) - Vertical: 0.8m; Horizontal: 2.5m

o Max Yaw Angular Velocity - 200°/s

o Max Tiltable Angle - 35°

o Max Ascent / Descent Speed - Ascent: 6m/s; Descent: 2m/s

o Max Flight Speed - 15m/s (Not Recommended)

o Diagonal Motor-Motor Distance -350mm

o Operating Frequency - 2412-2462MHz

o Communication Distance (Open Area) - 500-700m

o Transmitter Power - 20dBm

o Power Consumption - 2W

 Camera:

o Operating Environment Temperature - 0°C-40°C

o Sensor Size - 1/2.3"

o Effective Pixels - 14 Megapixels

o Resolution - 4384×3288

o HD Recording - 1080p30 & 720p

o Recording FOV - 110° / 85°

The use of UAS operations will be safely conducted in a manner that minimizes risk to the NAS or to 

persons and property on the ground. Furthermore, Aireko Construction has also implemented the 

following rules to company personnel who desire to use the UAS:

 UAS are to be used strictly for project documentation purposes. UAS will not be used for 

personal reasons or outside or project boundaries.
 The permission to use UAS will be granted only after a petition has been formally made to the 

project manager and the vice-president of operations. Only after such petition has been 

reviewed and approved, will the person requesting permission will be allowed to do so.

 During UAS PIC’s first flight, PIC will be supervised by project manager and adequate personnel 

who can instruct the PIC on better UAS use. If PIC demonstrates proper capability of UAS 

handling, then he/she will have permission to use UAS in future dates without any supervision.

 UAS is to be transported in its original packaging box and will not be assembled until the person 

using the UAS (PIC) has entered the legal boundaries of the project. The UAS PIC will also have 

to properly disassemble the UAS before exiting the legal project boundaries.

 A pre-flight procedure as well as a post-flight procedure will be requested to every PIC. 

Procedure includes:

o If UAS is to be used in a project for the first time, then PTP (Pre-Task-Planning) sheets 

are to be filled out, submitted, and approved prior to UAS piloting.

o Inspecting the UAS for any possible damages in the body and in the propellers.

o Making sure UAS battery and control remote battery is fully charged.

o Inspecting the project site for an ideal take-off location that is 20-30 ft. away from 

construction jobs that are taking place as well as electrical post and heavy machinery 

that is in the vicinity.

o Synchronizing the UAS with remote antenna and satellites, prior to lift-off, to verify that 

UAS will return to the take-off destination if signal is ever lost.

o When UAS is in the air, it will remain a minimum of 15-20ft away from any construction 

jobs that are taking place as well as electrical post and heavy machinery that is in the 

vicinity.

o Once UAS has been used and landed, PIC is to inspect the body and the propellers for 

any damages that may have occurred during flight as well as notify supervisor if he/she 

sees that there is a problem with the UAS. 

o A regular maintenance is to be done to the UAS body and propellers after UAS flight has 

taken place. This included but is not limited to removing any debris from the camera 

lense, removing any debris from the propellers, and removing any debris from the 

control remote.

 UAS is to be used during work hours. 

 UAS piloting will take place during the day in order to ensure a clear vision line of sight.

 PIC is always to maintain a visual line of sight with the UAS. If PIC does not have a clear vision 

line of sight with the UAS, then he/she is to bring it back to the take-off location and land it. 

Once this is done, PIC will personally transport the UAS to another site in the project where 

he/she can properly maintain a clear visual line of sight.

 UAS is not to exceed a flight speed over 10mph

 UAS is to be strictly piloted within project boundaries and will not exceed a height limit of 200 

ft.

 If visibility/performance of UAS piloting diminishes due to low lighting or weather conditions, 

PIC is to bring the UAS back to its original location and land it for no further use, until visibility 

and weather conditions have improved.