AirGo Media LLC

6738 Merwin Place

Columbus Ohio 43235

PH: 614.425.3381

U.S. Department of Transportation Docket Operations 

West Building Ground Floor Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Re: AirGo Media Petition for Exemption

AirGo Media was created to bring professionalism and safety to the UAS industry while providing a 

much needed service to those in need of aerial imaging. We believe that there is an overwhelming desire for 

aerial imaging within the corporate world as well as within our government. 

AirGo Media shares Congress's goal of getting small aerial vehicles (UAV’s) flying commercially within 

the United States as soon as safety allows. ln the FAA Modernization and Reform Act of 2012, Congress 

directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the National 

Airspace System, (NAS) and under Section 333 of that law, gave the FAA power to grant innovators 

"expedited operational authorization" to do so. By this petition, AirGo Media is seeking its first such 

authorization, in order to conduct additional research and development for our clients.

Granting AirGo Media an exemption to allow for testing within the National Airspace System is in the 

public interest because it advances Congresses goal of getting commercial UAV’s flying in the United States 

safely and soon. This exemption is a necessary step towards realizing the vast potential and services that 

UAV’s will provide not only to the US commercial industry but to build upon the U.S. aviation safety record. 

Furthermore, granting this request will do nothing more than allow AirGo Media to what thousands 

of hobbyists and manufactures of model aircraft do on a daily basis, though we will have to abide by more 

stringent safety measures then currently required by these groups. This exemption request essentially seeks 

FAA approval for AirGo Media to operate within the NAS in a safe, efficient and effective manner.

My experience as a retired 28 year Air Traffic Controller and 18 year pilot will not only lend to the 

operational safety concerns many will have concerning UAS operation but will greatly enhance the safety 

record that the FAA has established for the National Airspace System.

 
Information Supporting this Petition as Specified in 14 CFR § 11.81

1. Your name and mailing address and, if you wish, other contact information such as a fax 

number, telephone number, or e-mail address

AirGo Media LLC

6738 Merwin Place

Columbus, Ohio 43235

PH: 614-425-3381

FX: 888-329-6870

EM: gary@airgomedia.com

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

 14 CFR § 21.191(a) Experimental Certificates

 14 CFR § 45.23(b) Display of Marks, General

 14 CFR § 91.9(b) Civil aircraft flight manual, marking, and placard requirements

 14 CFR § 91.203(a) and (b) Civil Aircraft: Certifications Required

AirGo Media believes that the exemptions noted above will be sufficient to conduct the 

necessary R&D it requires. To the extent that the FAA may deem necessary, however, we also 

request an exemption from any regulations ancillary to the foregoing that may be need to 

facilitate the desired operations AirGo Media requires.

3. The extent of relief you seek, and the reason you seek the relief

We seek an exemption from several interrelated provisions of 14 CFR Parts 21,45 

and 91 to the extent necessary to engage in private, non-commercial R&D operations of 

UAV’s on our own property that would otherwise be permitted if conducted by a hobbyist or 

manufacturer producing UAV’s. We have detailed below a significant set of safeguards that 

will apply to our R&D operations. Operations under these safeguards will provide for a level 

of safety exceeding the level of safety required of similar UAV operations that the FAA 

authorizes currently without requiring compliance with the regulations from which we seek 

an exemption. Moreover our operations will not create a hazard to users of the National 

Airspace System or to the public or pose a threat to National Security and are thus consistent 

with the Congressional mandate in Section 333 of the FAA Modernization and Reform Act of 

2012, which give the FAA a mechanism to allow certain UAS to operate safely within the 

National Airspace System. 
4. The reasons why granting your request would be in the public interest; that is, how it would 

benefit the public as a whole

By leading the next generation of UAS operators into the future. By setting the 

example of safe, efficient and orderly operations within the National Airspace System and 

showing the public that flights with unmanned systems can indeed be safe while providing a 

valuable service to our nation’s economy.

5. The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption

AirGo Media operations would provide a level of safety that far exceeds that which is 

required of hobbyists and manufactures of model aircraft. Our protocols are as follows and 

would apply during all phases of R&D conducted under this exemption request:

Regarding the Unmanned Aircraft System

1. UAS Description:

a. Maximum weight of less than 55lbs

b. Maximum speed , less than 50mph

c. Battery operated

d. Break away Props used for safety (when required)

e. Will be registered and display markings in accordance with 14 CFR Part 45 

Subpart C

2. UAS Pilot Training:

a. All UAS Operators will be required to log a minimum of 10 Hours with UAS 

Simulator prior to flying live within the NAS (National Airspace System)

b. In addition all UAS Operators will be required to pass basic knowledge tests in 

reference to the following items:

i. National Airspace System layout and usage - 14 CFR Part 91.126 – Part 

91.138, 91.145

ii. Basic Weather Knowledge as it pertains to UAS flight

iii. Aeronautical Charts and Related Publications as outlined in the FAA’s 

Aeronautical Information Manual 

iv. Safety of Flight 
Regarding the Unmanned Aircraft System (cont.)

3. UAS Flight Procedures

a. Preflight and Post Flight Inspections prior to each UAS conducting flight 

b. Planned preventive maintenance and repair schedules of each UAS

c. Standard Operating Procedure Checklists for Pre-Flight, In-Flight and Post Flight 

Operations

4. Radio Spectrum Frequency

a. Current UAS’s employed by AirGo Media utilize the following radio spectrum:

i. 5.725~5.825 GHz

ii. 2.400~2.483 GHz

Regarding the Unmanned Aircraft PIC (Pilot in Command)

1. Qualifications:

a. Our sUAS testing under this exemption will be conducted under the direct 

supervision of a designated pilot in command (PIC) who has final responsibility 

for the operation in accordance with 14 CFR § 91.3 and either (A) holds a 

current FAA private pilot certificate issued under 14 CFR § Part 61, Subpart E, a 

higher FAA pilot certificate, or a FAA recognized equivalent or (B) has 

completed FAA private pilot ground instruction and passed the FAA private pilot 

written examination or FAA- recognized equivalent; and (C) using on those 

operators that have completed extensive training on the normal, abnormal 

emergency procedures in specific detail and have demonstrated proficiency 

with the UAS being operated.

b. PIC’s and Observers will also be required under this exemption to undergo 

training requirements set forth by AirGo Media’s Standard Operating 

Procedures Manual. (SOP) These requirements will include but are not limited 

to the following:

i. PIC / Observer must pass basic UAS knowledge test in reference to UAS 

being operated.

ii. PIC / Observer are required to log a minimum of 5 hours simulator flight 

time as well as 5 hours actual flight time under direct supervision prior 

to UAS certification by AirGo Media.

iii. All PIC’s will require a Class III medical certification as set forth by CFR § 

67.301 – 67.315
Regarding the Operation of the Unmanned Aircraft

Safety is at the core of not only AirGo Media’s request for exemption but will define our 

company as we progress into the future of UAS operations. AirGo Media wishes to work 

closely with the FAA in order to help define the rules and regulations that will ensure the 

safety and integrity of our National Airspace System. AirGo Media will take every precaution 

to ensure not only the safety of non-participating persons and property but we will take 

every effort to put in place procedures that will ensure the public safety of those within the 

operational boundaries of our UAS’s.

AirGo Media’s Operations Manual will included but not be limited to the following:

1. Preflight:

a. Clearly defined safety zone operational areas will be put in place for all phases of 

UAS operations.

b. Aviation facilities that may directly / indirectly be impacted by the operation of 

the UAS will be notified as to our intended area of operation and use per AC 91-

57 

c. Operators will maintain the UAS for safe operation and conduct pre-flight 

inspections prior to each flight so as to ensure that the UAS control station, data 

link equipment, payload and support equipment are in a condition for safe 

operation and in a configuration appropriate for the purpose of the intended 

flight in accordance with 14 CFR § 91.7(b).

2. In-Flight:

a. No operator or observer will engage in nor may an operator or observer permit 

any activity during a critical phase of flight which could distract any operator or 

observer from the performance of his/her duties or interfere in any way with the 

proper conduct of his/her duties.

b. Operators and observers will maintain two-way radio communications with each 

other during all operations, if unable to do so, or if any condition occurs that 

may otherwise cause the operation to be unsafe, the operator will conclude the 

operation.

c. If the communications link with the operator is lost, safety features built into the 

UAS will allow for the UAS to return safely to its departure point, land and power 

down. In addition each UAS operator and observer will have the ability to press a 

physical button that is within his/her reach at all times that will reduce the 

power of the UAS and force it to return to its departure point, land and power 

down.

d. All UAS operations will maintain a Visual Line-of-Sight with the vehicle in 

operation in accordance with the statutory mandate under Section 333(b) (1).

e. Maximum and Minimum speeds of UAS in an operational role will be in 

accordance with manufactures guidelines but will not exceed FAA FAR Sec. 

91.117. Proposed average operational speeds will normally be made between 0

(hovering) & 35 Knots

f. Altitude limitations will be that listed by the manufacture for the particular UAS 

in operation, though Minimum Safe Altitude as outlined in 14 CFR § 91.119 will 
be adhered to.

g. Weather requirements for operational use will follow FAR Sec. 91.155

Regarding the Operation of the Unmanned Aircraft (cont.)

h. Operational Proximity:

i. Operational areas of intended use will vary and each will require a 

preflight safety risk assessment in order to determine that the UAS 

would be in a condition safe for flight and that the planned operation 

can be conducted and completed safely. 

ii. Operational areas of intended use within the proximity of aviation 

related activities such as airports, heliports or active non-controlled 

flight areas will have a preflight safety risk assessment outlined in order 

to determine any impact on the services provided within these areas as 

well as those known to contain active flight operations. 

iii. Notification of FSS’s (Flight Service Stations), FSDO’s (Flight Standards 

District Offices), ATCT’s (Air Traffic Control Tower’s) or any other entity 

that may be impacted by UAS operations will properly be notified.

AirGo Media will effectively operate our UAS’s with additional safe guards that far exceed those that 

the FAA has provided for the public and our National Airspace System. AirGo Media will ensure that 

all operational UAS’s it operates will adhere to the strictest safety precautions to ensure protection 

of public persons and property. 

 

 

 

Respectfully Submitted,

Gary Bollinger (CEO)

AirGo Media LLC