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September 03 , 2012



### Petition for exemption f

rom Federal Aviation Regulation p art 91.319 ( a) (Aircraft having experimental certificates: Operating limitations), to permit the carriage of a methane gas leak detector over natural gas pipelines in sparsely populated areas for com pensation or hire while util izing the experimental amateur - built category Lockwood Aircraft Corporation Air Cam aircraft .

PETI TI ONER : HoundDogAir LLP

North East Loop 410 Suite 903 San Antonio, TX 78217Page 2 of 8 pages **PETITION SUMMARY** This petition seeks an exemption from the Federal Aviation Regulations (FARs) to permit the use of the twin - engine , two - place, experimental amateur - built category aircraft, the Air Cam (Air Cam) , to carry a methane gas leak detector over natural gas pipeline s in sparsely populated areas of the United States for compensation or hire while utilizing one pilot , and one sensor operator when required . HoundDogAir, LLP (HDA ) is requesting an exemption to the following FAR: o Experimental Aircraft:  Part 91.319(a) “No person may operate an aircraft that has an experimental certificate

–  (1) For other than the purpose for which the certificate was issued; or  (2) carrying persons or property for compensation or hire.” If approved, this petition for exemption will permit HDA the use of the twin - engine Lockwood Aviation Corp Air Cam to carry a methane gas leak detector for compensation or hire over natural gas pipelines in sparsel y populated areas , a stated business purpose of HoundDogAir, LLP . The Air Cam’s safe and docile flying qualities, during both twin engine and single engine flight operations, are what make the Air Cam an ideal fit for the natural gas leak detection mission. We believe that flight safety will be greatl y enhanced by the redundancy of the Air Cam’s twin engine operation along with its low speed handling qualities. The fact that the Air Cam’s single engine climb rate is 300 fpm will greatl y enhance s afety while fl yi ng at low altitudes . This exemption request seeks to reach the higher level of safety that onl y the Air Cam can provide. The Air Cam provides the greatest set of safety redundancies, low - speed handling characteristics, and unlimited pilot panoramic views that exist today . We feel that the characteristics offered by the Air Cam far surpass every other platform in safety , low - speed handling, and pilot field - ofvision. The safety redundancies of fered by th e twin en gine Air Cam is unmatched b y every other aircraft available today . The Air Cam was specificall y designed for low and slow fl yi ng over the harsh terrain of the African Congo. For these man y reason s, we have concluded that the Air Cam provides , by a wide margin, the safest platform to conduct natural gas detection.

**R EASON FOR PETITION AND BACKGROUND**  The early and prompt detection of methane gas leaks along natural gas pipelines has recently been brought to national attention from the catastrophic gas line explosion in San Bruno, California . Coincidentally , o ur group has been developing a faster and more accurate methane detector to locate methane gas leaks fro m slow - fl ying aircraft . The airborne platform specifications that we have designed to are approximately 50 kts at 500 feet AGL. HDA ’s mission is to fly

at approximately 50 kts and 500 ft AGL over natural gas pipelines in sparsel y populated areas while identifying leaking methane gas. In order to identify as many methan e leaks as possible, our methane leak detectors require a safe , slow - flying platform that is maneuverable at low airspeeds. The aircraft that we have identified , the one that we believePage 3 of 8 pages

delivers the most safety , is the Air Cam, a two - place, twin - engine , experimental amateur - built category aircraft designed by the Lo ckwood Aviation Corp. The Air Cam was specifically designed as an IMAX photo platform for the filming of a National Geographic m ovie about Africa . The region of the African Congo that was ph otographed was considered unsurvivable in th e event that an aircraft was forced down. For that reason, the Air Cam was designed as a twin - engine aircraft with exemplary twin engine and single engine performance and handling characteristics with numerous redundancies . The safe and docile flying qualities, during both twin engine and single engine flight operations , are what make the Air Cam an ideal fit for the natural gas leak detection mission . We believe that flight safety

will be greatl y enhanced b y the redundancy of the Air Cam’s twin engine operation along with it s low speed handling qualities. The fact that the Air Cam’ s single engine climb rate is 300 fpm will greatly enhance s afety while flying at low altitudes . This exemptio n request seeks t o reach th e higher level of safety that the Air Cam will provide . The Air Cam provides the greatest set of safety redundancies, low - speed handling characteristics, and unlimited pilot panoramic views that exist today . We feel that the characteristics offe red b y the Air Cam far surpass any other platform in safety , low - speed handling, and pilot field - ofvision. The redundancy

of a twin that allows for low and slow fl yi ng over unlandable terrain is what the Air Cam can deliver like no other aircraft. This exemption is being requested due to the regulatory restrictions relating to the use of experimental category aircraft for compensation or hire. We ask that the FAA endorse HDA ’s use of the twin engine experimental amateur - built aircraft , the Air Cam, for the use during methane gas leak detection along the sparsel y populated areas of natural gas pipelines. HDA asks that the FAA grant an exemption from Section 91.319( a) of Title 14, Code of Federal R egulations (14 CFR) which permits HDA to operate an experimental category aircraft designed by the Lockwood Aircraft Corp, the Air Cam, as a methane leak detector platform for compensation or hire while flying over natural gas pipelines in sparsel y populated areas of the United States

. We ask that the FAA exempt HDA from Part 91.319 ( a) , allowing HDA to fly the Air Cam for compensation or hire over natural gas pipelines in sparsel y populated areas. o Experimental Aircraft:  Part 91.319(a) “No person may operate an aircraft that has an experimental certificate

–  (1) For other than the purpose for which the certificate was issued; or  (2) carrying persons or property for compensation or hire.” An FAA exemption as requested by HDA would allow a much safer, timelier , and accurate identification of hazardous natural gas leaks along our nation’s natural gas pipeline infrastructure as compared with an y other aircraft.Page 4 of 8 pages **SAFETY ISSUES** HDA feels strongl y that overall flight safety will be greatl y enhanced with the utilization of the Air Cam while performing airborne methane gas detection. This exemption request seeks to reach that higher level of safety b y utilizing the unique and favorable qualities of the Air Cam such as twin engine redun dancies, slow speed performance capabi lities, and unlimited panoramic views. HDA ’s methane gas detection missions will occur directly over the center of 150 foot - wide pipel ine swaths located in sparsel y po pulated areas throughout the U.S. wilderness es . Because of the remoteness of the planned pipeline surveying operations, rarel y will HDA methane gas leak detection Air Cams be in view or the proximity to the public while performing methane gas leak detection missions for compensation or hire. The following performance numbers illustrate the inherent safety provided in the ev ent that the Air Cam should encounter a forced landing and be required to land on or adjacent to the 150 wide foot pipeline swath.Page 5 of 8 pages **Lockwood Aircraft Corp. Air Cam Performance and Specifications**  **AirCam.com**

Horsepower 200 (Total) Gross Weight 1,680 lbs Empty Weight 1,040 lbs Useful Load 640 lbs Stall Speed 39 mph Top Speed (Vne) 110 mph Cruise Speed 50 to 100 mph Vne (never exceed speed) 110 mph Rate of Climb 1,500 fpm Rate of Climb Single Engine 300 fpm Fuel Capacity 28 gal Range 340 mi @ 70 mph Endurance 6 Hours Landing Roll 300 ft Takeoff Roll less than 200 ft Wing Span 36 ft Length 27 ft Height 8 ft 4 in Gear Width 8 ft 6 inPage 6 of 8 pages

Since HDA pipeline operations occ ur at approximately 500 ft AGL, it may at first appear that comparisons could be made to the Helicopter Emergency Medical Services ( HEMS) operations where they

operate in remote areas at low altitudes, thus exposed to many of the same risks . H owever the comparisons are few , as the HEMS industry operates in a much more extreme environment than HDA . HDA has selected the Air Cam for the increased safety provided from its sy stem redundancies , unlike those offered b y single - or multi - engine helicopters. Due to the emergency nature of HEMS, the ir crews must operate in an extremely difficult environment - at night, in inclement weather, landi ng in rural and isolated areas, with little time to flight plan. HDA does not intend to operate in the same harsh environments as HEMS must. T hese are all ty pes of operation s where HDA will not operate . HDA will only

conduct pipeline leak detection during Day VFR = 1,000’ ceiling and 3 miles visibility . Because of the nature of HDA ’s business model , the pilots will be provide d ample planning and preparation time prior to flying a pipeline route . All pipeline routes will be fully studied and the ir GPS coordinates will be uploaded into the HDA aircraft navigation sy stem and leak detection sy stems . The pipeline swath will be clearly visible to the pilot during the pipeline survey and if inclement weather is encountered, the mission will be scrubbed until a later time or date . Unlike most other aviation missions in other industries, there is no pressure upon HDA pilots to conduct flight operations under marginal circumstances; the weather must be dry , day , and VFR in order to adequately detect leakin g methane. In the event of inclement weather, the mission o f methane gas leak detection must always wait for another day when moisture - free atmospheric conditions exist , which are conducive for the detection of methane. The aircraft will be equipped to meet the requirements of Part 91.205, night and instrument flight, to provide additional flight safety in the event unforeseen circumstances would create a condition where these flight tools/instruments would be required to prevent an incident or accident. Flight tracking will be provided by the company dispatcher to maintain aircraft position and flight status. In order to provide enhanced safety from traffic collisions, the Air Cams will be equipped high visibility

paint schemes. No passengers will be carried in the Air Cam while conducting any revenue flight. The Air Cam is a two - place aircraft and only active crewmembers employed or contracted by HDA required for the pipeline survey

mission or pilot training, such as line checks, or maintenance, will be carried during revenue flights. T he Minimum Pilot Q ualifications to fly the Air Cam are Multi Engine Land Commercial Instrument with a Tail wheel E ndorsement with a current and valid FAA Class II medical certificate . o Pilot training.  All pilots will receive an initial checkout on the Air Cam to include single - engine operations, low - speed handling qualities , wind shear, low altitude fl yi ng, and tailPage 7 of 8 pages wheel operations, plus other Air Cam specific operating and mechanical procedures. This flight training will take approximately 5 hours of flight time to complete.  In addition, pilots will receive a night orientation flight and a unusual attitude recovery / instrument recovery / instrument approach orientation flight to ensure that extra level of safety i n the extremely rare case if these flight procedures and techniques were needed to safel y recover the aircraft and crew.  All pilots and sensor operators will receive sufficient ground school to enable the pilots and operators to understand the operating characteristics of the Air Cam and the mission profile of HDA .  All sensor operators will receive a mission orientation flight to ensure familiarity with the Air Cam operating characteristics and the mission profile of HDA .  Prior t o being released for their first gas detection mission , pilots will receive a mission profile line check.  Pilots will also receive an annual mission profile line check to en sure HDA flight and mission safety

standards are maintained. This mission profile line check will also meet the requirements of Part 61.56(a). HDA will ma intain the Air Cams as per the standards prescribed by Federal Aviation Regulations part 91.319 . It is anticipated that the Air Cams performing the HDA gas detection mission will fly

over 100 h ours annuall y, therefore HDA will conduct 100 Hour Inspections per scope and detail of Part 43, Appendix D on each aircraft. If an aircraft does not reach the 100 - hour flight level at the one - year mark then an annual condition inspection per the scope and detail of Part 43, Appendix D will be performed on the specific aircraft. A designated A&P mechanic, authorized b y Federal Aviation Regulations p art 65 or 145 , who is familiar with the Air Cam and Rotax engine , will perform all 100 H our and Annual Inspections . A&P mechanics that perform engine work will be sent to a Rotax engine school to learn the intricacies of the Rotax engine. The Rotax engines will not be operated on pipeline survey s past the manufacture ’ s recommended TBO. **PUBLIC INTEREST ISSUES** The public benefit of allowing HDA to utilize an Air Cam as the airborne platform to carry the Methane Gas Leak Detector is quite substantial. The Air Cam will deliver the slow speed, maneuverability , and redundant safety features that will provide the ability to detect methane gas leaks faster and more accurate ly than ever before. Natural gas pipeline leaks pose serious public safety threats . Every small leak has the potential to result in catastrophic conflagrations that generate spectacular headlines and many times prove deadl y . These explosions are of course very spectacular and are of serious cause for public concern however; m ore common are the thousands of hard - to - ident ify natural gas leaks that are slow and insidious in their destruction and modification to the atmosphere by what many scientists classify

as global warming. Additionally, on a lesser scale, b y locating the leaks in a timely manner, economic savings for all of us occurs through the saving of a natural resource.Page 8 of 8 pages

The Air Cam provides the optimum platform for HDA ’ s methane gas leak detector . The slow flight characteristics of the Air Cam will insure a safe, efficient, and quick detect ion of natural gas leaks th erefore increasing public safety by providing greater protection from natural gas explosions, reducing the effects of methane upon the atmosphere, and reducing the loss of a natural resource.

Dated: August 1 6 , 2012

Grant Pitzer 223 Cloverleaf Ave San Antonio, TX 78209 210 - 569 - 9203 grantpitzer@gmail.com HoundDogAir LLP North East Loop 410 Suite 903 San Antonio, TX 78217 Primary points of contact are: Grant Pitzer. 210 - 569 - 9204, grantpitzer@gmail.com Tom Kelly 210 - 606 - 7677 , tom@tkellyco .com