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MARINE &. ENGINEERING CONSULTANTS

June 5, 2015 United States Department of Transportations Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590 London Offshore Consultants Inc. 16800 Imperial Valley Drive, Suite 280 Houston, TX 77060 United States of America T (+1) 281 987 7400 F (+1) 281 987 7438 E houston@loc-group.com www.loc-group.com

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation's Regulations 

### Applicant's name, address and contact number are: Business Name: London Offshore Consultants 16800 Imperial Valley Drive Suite 280, Houston TX 77060 Contact: Matt Riggs Email: m.riqqs loc-qroup.com Phone: (281) 987-7400 Purpose for Request: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, 1 Matt Riggs on behalf of London Offshore Consultants (LOC) hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below, to allow commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for conducting aerial inspections and surveys as part of vessel and barge evaluations in the maritime industry with the use of a DJI Phantom 3. Regulation: 

### The exemptions requested and/ or required are from 14 CFR and are as follows: 14 C.F.R. Part 21, Subpart H— Airworthiness Certificates and 14 C.F.R. 91.20 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 14 C.F.R. 91.7(a): Civil Aircraft Airworthiness 14 C.F.R. 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft 14 C.F.R. 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

### 14 C.F.R. 91.9(c): Civil Aircraft Flight Manual, Marking and Placard requirements 14 C.F.R. 45.23(b): Markings of the Aircraft14 C.F.R. 45.27(a): Rotorcraft

14 C.F.R. 91.103: Preflight Action 14 C.F.R. 91.119: Minimum Safe Altitudes 14 C.F.R. 91.121: Altimeter Settings 14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions 14 C.F.R. 405(a): Maintenance required 14 C.F.R. 409(a): Inspections 14 C.F.R. 417(a) &(b): Maintenance records 14 C.F.R. Part 61: Pilots, Flight Instructors, and Ground Instructors 14 C.F.R. 61.3: Requirements for certificates, ratings and authorizations and Any other provisions out of Title 14, Code of Federal Regulations, that may be applicable to Applicant's specific use and not listed above

Public Interest: The exemption requested is in the public interest because the intended purpose of the operation of UAS will enhance the safety of the inspection process presently utilized by the applicant which may have required, from time-to-time, inspectors to be on scaffold structures or other dangerous environments, or exposed to other hazardous conditions, in order to perform the inspections which are necessary and required to comply with industry standards or governmental regulations.
Operator Requirements to provide a level of safety while piloting the UAV A. Applicant Propose to adopt:
a. A Pilot Operating Handbook and / or b. Flight Operations and Procedure Manual
c. UAV Check List B. Applicant proposes the following conditions
a. UA must weigh less than 55 pounds b. UA must operate within a visual line of sight (VLOS) of pilot in charge (PIC) or
c. Must operate with a visual observer (VO). The VO may be utilized only if the PIC can communicate with VO at all times d. The PIC will inspect the UAS to ensure it is safe for flight. AII maintenance and alterations should be properly documented.e. A functional test flight must be performed for any UAS that has undergone maintenance or alterations and be performed by the PIC f. The operator must follow the manufactures' UAS aircraft/ component, maintenance, overhaul, replacement inspection and life limit requirements. g. The operator must ensure that no persons are allowed within 500 ft. of the area except those consenting to be involved and who are part of the area being inspected h. Each operations must be completed within 30 minutes flight time or with 20% battery power remaining, whichever comes first.
Conclusion London Offshore Consultants are seeking an exemption from the following regulations 14 C.F.R. Part 21, Subpart H, 14 C.F.R. Part 27, 14 C.F.R. 917(a), 14 C.F.R. 91.9(b) (2), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.9(c), 14 C.F.R. 45.23(b), 14 C.F.R. 45.27(a), 14 C.F.R. 91.103, 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C. F. R. 91.151(a), 14 C. F. R. 405(a), 14 C. F. R. 417(a) &(b), 14 C. F. R. Part 61, 14 C.F.R. 61.3 and any other provisions out of Title 14, Code of Federal Regulations, that may be applicable to applicant's specific use and not listed above to commercially operate lightweight unmanned UAS during vessel, barges or other maritime industrial inspections and surveys. Granting London Offshore Consultants' request for exemption will help reduce the current risk levels and enhance the safety of personnel. The use of UAS assisted photography will provide a practical means to perform surveys and inspections for the marine industry that would be otherwise be hazardous to the employees of LOC. Inspecting marine equipment, incident damages or other areas in need will become easier and more efficient, providing our key services safely to our client and protecting our employees from excessive hazards.
Kind RecOrds, 

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~ z Matt Riggs Assistant HSEQ Manager