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 2012 (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) commercially 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 permit 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 training 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 technically 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 Unmanned 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 reliability 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 commercial 

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 

conventionally 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, 

Subpart 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 certificate, 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 placed 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 the 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 with 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 Regulation 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 this 
requirement 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, or 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 functioning 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 simultaneously. 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 populated 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 closer 

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, an 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 in 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 

computer 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 there 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 

energy 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 certificate, 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 it 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 the 

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 require 

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 for 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 cracks, 

replacing a propeller, checking electrical connections and updating software and firmware for the onboard computer. All other maintenance will be performed by the manufacturer or their designated 

repair facility. The PIC will document work performed in 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 public safety.

Crompco is petitioning for an exemption to operate five (5) sUAS

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 built-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-fly 
zone 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 sUAS 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 GHz

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 within 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 terminated 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 which 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 community. 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 programs including all applicable regulations and guidance documents; including
aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio 

Communications Procedures; Human Factors and Crew Resource Management; Basic sUAS 

Aerodynamics; 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 respecting 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