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September 03, 2012

Petition for exemption from Federal Aviation Regulation part 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 

compensation or hire while utilizing the experimental amateur-built category 

Lockwood Aircraft Corporation Air Cam aircraft .

PETITIONER: HoundDogAir LLP

North East Loop 410

Suite 903

San Antonio, TX 78217
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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 pipelines 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 sparsely 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 greatly 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 greatly enhance safety while flying at low altitudes. This 

exemption request seeks to reach the higher level of safety that only 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 offered by the twin engine Air Cam is unmatched by every

other aircraft available today. The Air Cam was specifically designed for low and slow flying 

over the harsh terrain of the African Congo. For these many reasons, we have concluded that the 

Air Cam provides, by a wide margin, the safest platform to conduct natural gas detection.

REASON 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, our group has been developing a faster and more accurate methane 

detector to locate methane gas leaks from slow-flying 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 

sparsely populated areas while identifying leaking methane gas. In order to identify as many

methane 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 believe 
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delivers the most safety, is the Air Cam, a two-place, twin-engine, experimental amateur-built 

category aircraft designed by the Lockwood Aviation Corp.

The Air Cam was specifically designed as an IMAX photo platform for the filming of a National 

Geographic movie about Africa. The region of the African Congo that was photographed was 

considered unsurvivable in the 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 greatly 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 greatly enhance safety while flying at low altitudes. This exemption 

request seeks to reach the 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 offered by 

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 flying 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 sparsely 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 

Regulations (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 sparsely 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 sparsely 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 any other aircraft.
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SAFETY ISSUES

HDA feels strongly that overall flight safety will be greatly 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 by utilizing the unique and favorable qualities of the Air Cam 

such as twin engine redundancies, slow speed performance capabilities, and unlimited panoramic 

views.

HDA’s methane gas detection missions will occur directly over the center of 150 foot-wide 

pipeline swaths located in sparsely populated areas throughout the U.S. wildernesses. Because of 

the remoteness of the planned pipeline surveying operations, rarely 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 event that the 

Air Cam should encounter a forced landing and be required to land on or adjacent to the 150 

wide foot pipeline swath.
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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 in
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Since HDA pipeline operations occur 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.

However 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 system redundancies, 

unlike those offered by single- or multi-engine helicopters. Due to the emergency nature of 

HEMS, their crews must operate in an extremely difficult environment - at night, in inclement 

weather, landing 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. These are all types of operations

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 provided ample 

planning and preparation time prior to flying a pipeline route. All pipeline routes will be fully

studied and their GPS coordinates will be uploaded into the HDA aircraft navigation system and 

leak detection systems. 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 leaking methane. In the event of inclement weather, the 

mission of 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.

The Minimum Pilot Qualifications to fly the Air Cam are Multi Engine Land Commercial 

Instrument with a Tailwheel Endorsement 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 flying, and tail 
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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 in the extremely rare case if these flight procedures and 

techniques were needed to safely 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 to 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 ensure 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 maintain 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 hours annually, 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 by Federal Aviation Regulations part 65 or 145, who is familiar with the 

Air Cam and Rotax engine, will perform all 100 Hour 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 surveys 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 accurately 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 

deadly. These explosions are of course very spectacular and are of serious cause for public 

concern however; more common are the thousands of hard-to-identify 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, by locating the leaks in a 

timely manner, economic savings for all of us occurs through the saving of a natural resource.
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The Air Cam provides the optimum platform for HDA’s methane gas leak detector. The slowflight characteristics of the Air Cam will insure a safe, efficient, and quick detection of natural 

gas leaks therefore 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 16, 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