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 ae rial veh icles (UAV’s) flying commercially within the United States as soon as safety allows . ln the FAA Modern i zation and Reform Act of 20 12 , Congress directed the FAA "to safe ly accelerate the integration of civil unmanned aircraft systems into the N atio na l Airspace System, (NAS) and under Section 333 of that law, gave t he FAA power to grant innovators " ex pedited operational autho r iza ti on" to do so . By this p etition, 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 exem ption 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.Informatio n 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
-4 25
-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 see**  **k, 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 t he 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 FlightRegarding 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 O perations **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 CF R § 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 a re 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 – 67.315Regarding 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 t he 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 t ake 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 operati on 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 whic h 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 wil l 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 particula r UAS in operation , though Minimum Safe Altitude as outlined in 14 CFR § 91.119 willbe 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.** Operation al 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 w ithin 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