November 18, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act Crompco LLC 1815 Gallagher Rd Plymouth Meeting, PA 19462 610
- 278
-7203 Tracy.richmond@crompco.com Dear Sir or Madam: This petition is being submitted on our behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2 012 (the Reform Act), and 14 C.F.R. Part 11, Crompco LLC, a retail petroleum services company, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commerc ially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section333. The requested exemption would pe rmit Crompco to pursue its commercial interests in providing services to clients using a small advanced sUAV in the following areas:
 Real Estate
 Surveying
 Industrial
 Equipment Inspection Crompco states that all sUAS flights will occur over private or controlled access property will do so with the property owner’s consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where videography will take place. Additionally, all observers will attend a 40 hour t raining and certification course to insure the safety and observance of all FAA Laws, Rules, Guidelines and stipulations. At this training they will trained understand the proper roles of an observer, communication procedures, proper visual scan techniques, operations at non
-towered airports and emergency procedures.Regulations from which exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.401
- 91.417(a) & (b) EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Crompco requests an exemption from the following regulations as well as any additional regulations that may te chnically apply to the operation of the sUAV System: 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Un manned Aerial Systems, we request an experimental certificate be issued for the DJI Inspire 1 under either, or both, of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliabil ity requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commerci al purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a c onventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, S ubpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.14 CFR 45.23 Display of marks; general and 45.29 Size of marks

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certifi cate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two
- inch lettering will be impossible. The word “Experimental” will be place d on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of th e UAS as “Experimental.” 14 CFR 61.113 Private pilot privileges and limitations: Pilot inCommand and 61.133 Commercial pilot privileges and limitations. Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to operate under the supervision of a private pilot’s license holder rather than a commercial pilot’s license holder. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the GOM. The level of safety provided by the requirements included in the GOM exceed that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated wi th the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot in a supervisory role aiding the PIC exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b). 14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regula tion is inapplicable. 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to thisrequirement since the aircraft is not only too small to carry documentation; the documentation would

not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, o r preparing for, flight. 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests. The regulation states "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functio ning dual controls." The sUAS System ground

- based control station consists of a hand

- held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneo usly. With both student and instructor having "hands

- on" the controls during flight, this technique meets the intent 91.109 and provides an equivalent level of safety. 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populat ed areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate cl oser than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre

- planned has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, a n emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered i n granting the exemption. CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board compu ter to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- vFR conditions unless t here is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly more than 1/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve en ergy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness ce rtificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that i t is legible to passengers or crew." At a maximum gross weight of under 6.5 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that th e information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 14 CFR Subpart E 91.401

- 91.417
- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 req uire that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft fo r return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small crac ks, replacing a propeller, checking electrical connections and updating software and firmware for the on

board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed i n accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. All preflight checks will be signed, dated and retained and available at the request of the FAA. Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes pu blic safety. Crompco is petitioning for an exemption to operate five (5) s UAS Name: DJI Inspire 1 Model Number: T600 Total Weight: 6.5 Lbs. Battery Name / Model: Intelligent Flight Battery / TB48 Battery Capacity: 5700 mAh The DJI Inspire 1 features a bu ilt

- in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no

-flyzone feature. The DJI The DJI Inspire 1 also has a failsafe function that is triggered in the event

communication is lost between the sUAS and the main controller transmitter and secondary controller. At that time, the sU AS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually. The DJI Inspire 1 Remote Control: Name / Model Number: C1 Operating Frequency: 5.725~5.825 GHz and 2.400~2.483 G Hz Battery: 6000 mAh LiPo 2S The DJI Inspire 1 owners manual is available on the DJI Website: http://download.djiinnovations.com/downloads/inspire_ 1/en/Inspire_1_User_Manual_v1.0_en.zip The specifications o f t h e D J I I n s p i r e 1 meet with the Model Aircraft Operating Standards as set below:
 The petitioner will only operate its sUAS in line

-of

-sight of a pilot and/or observer and will operate at sites that are ‘sufficient distance’ from populated areas within the sterile area described in the FOPM. Such operations will ensure that the sUAS will “not create a hazard to users of the national airspace system or the public.”
 When flying the sUAS w ithin three (3) miles of an airport, airport operators will be notified and the operator will give the right

- of

-way to avoid flying in the proximity of full

-scale aircraft
 Maximum flight time for each operation will be 30 minutes.
 Flights will be terminate d when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS.
 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform from wh ich videography is planned.
 Minimum crew for each operation shall consist of: sUAS pilot
 The sUAS PIC will be an experience sUAS pilot
 The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).
 The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally.
 Given the small size of the sUAS and the restricted sterile environment within which it will operate, Crompco’s operations adhere to the Reform Act’s safety requirements. By providing this exemption Crompco will serve the public interest by providing information to clients that could prevent an environmental empact on the surrounding comm unity. Furthermore providing this exception will allow Crompco to provide inspection services that pose a danger to retail petroleum site personnel. Under the requested exemption, Crompco ensures all operators have completed sUAS education and training p rograms including all applicable regulations and guidance documents; includingaeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio

Communications Procedures; Human Factors and Crew Resource Management; Basic sUAS Aerody namics; Weather factors; Airmanship and Decision

- making and Safe Operations Procedures. We respectively request exemption under Section 333 to enable Crompco to operate efficient, limited, low

- risk commercial sUAS operations for the activities stated resp ecting at all times the space and privacy of citizens and property while keeping airspace safe. Respectfully Submitted,

Tracy L Richmond Crompco LLC 1815 Gallagher Rd Plymouth Meeting, PA 19462 610
- 633
-9003