~•l 1, 

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 Aircraft 
14 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, 

gf6~z 

Matt Riggs 

Assistant HSEQ Manager