Petition for Exemption Filed Under Section 333

14 Code of Federal Regulations

Part 21 Airworthiness Certification 

Part 61 Certification: Pilot, Light Instructors, and Ground 

Instructors.

Part 91 General Operating and Flight Rules

91.103(b)(2)Preflight Actions

91.105 Flight Crewmembers at Stations

91.109 Flight Instruction

91.119 Minimum Safe Altitudes

91,121 Altimeter Settings

91.151 Fuel Requirements

91.405 Maintenance Required

91.407 Operations After Maintenance

91.409 Inspections

91.417 Maintenance Records 2ii, iii, v, vi, 3d.

Requested By:

Radan V. Dolph

11369 CR 37

Fort Lupton, CO 80621

01 July 2015
Petition for Exemption Filed Under Section 333

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The reason for this request of exemption under Section 333 is to 

operate a small business providing the oil and gas industry a 

safer and more cost efficient means to inspect their facilities. 

1. Prior to conducting any air operations the UAS PIC will 

complete any and all safety training that the company that 

you are providing services for require.

Prior to arrival on location the PIC will schedule a time 

to conduct business that has the least amount of foot 

traffic. Optimally, the location should be clear of 

personal. Always require at least one operator of the 

facility to be inspected present during flight operations.

To ensure safe and successful flying, always fly in 

accordance with your location regulations and these best 

operating practices. Before you fly, determine the 

boundaries of your safe flying area.

Always fly UAS at least 100 feet away from people, 

vehicles, and buildings. Always fly the UAS at least 5 

miles away from airports and other areas where pilots 

operate manned aircraft. Make the safety of people and 

property your first priority!

Always fly below 200 feet and within your visual line of 

sight. Don’t let the UAS get too far away from you; make 

sure you can always see its orientation. 

Don’t fly in low light, high winds, rain, or other 

conditions that might impede visibility.

If the UAS moves outside the designated area or exhibits 

instability in flight, switch to standard mode and land the 

UAS manually.

As the operator, it’s PIC’s responsibility to recognize and 

avoid obstructions while flying. Always be ready to regain 

manual control of the UAS in the event of an unsafe 

situation.

The following information can found on the designated pages 

of attached flight manual:

Operating Limits, p.13.

Mission Planning, p.28-30. 

Vehicle Specifics, p.33.
Petition for Exemption Filed Under Section 333

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2. A pre-flight check list will filled out and filled with 

the paper work before each flight. The check list will be 

maintained for at least one year after completion of 

services. A sample check list has been attached to this 

file.

All corrective maintenance will be completed either on 

location or at the maintenance facility before the UAS 

conducts any flights. 

A record jacket will be created for each UAS in the 

inventory. This record jacket will be maintained for the 

duration of the UAS’s service.

3. Ground Station Radio:915 MHz or 433 MHz

4. I will be the main operator of the UAS until such a time 

a second operator is required in order to keep up with 

demand. I am a retired Marine Ordnance Officer and spent 15 

of my 21 years as an electro-optical ordnance technician. I 

am a certified operator/trainer of the DragonEye and 

operator of the Raven-B man portable UAV systems. I was an 

OIC of a Mobile Training Team with countless hours of 

flight time. 

An operator that I might employ in the future will have to 

complete a week long in house training course that will 

involve at least 20 hours of flight time.

5. Each operator must have 20/20 vision or be able to wear 

correctible eye glasses or ballistic protection. Also each 

operator must pass a mandatory drug test to be hired and 

pass semi-annual test throughout employment.

6. I have two intended operations for UAS operations. 

1. The main operation will be the inspection(s) of 

oil and gas production facilities. The high rise 

gel towers of LNG facilities require workers to 

climb the outside of the towers to ensure safe 

production. The UAS provides a safer platform and 

less expensive means of completing this task.

2. The secondary operation will be to provide mapping 

and inspection of agriculture (farms and ranches).

Also help land owners track the oil company’s 

progress before, during and after drilling 

operations. The oil companies are quick to drill, 

but slow to fix the land. 

The UAS operator will utilize the programmable failsafe 

feature described on pages 20 and 21 of the attached 

operations manual.
Petition for Exemption Filed Under Section 333

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7. The speed during mission is limited to 14.5 mph. The 

current wind speed has to be calculated in to the 

programing. No flight operations will be conducted if the 

local winds are greater than 20 mph. The winds will be 

measured by a hand held wind speed indicator. If the local 

winds are greater than the stated maximum limit the UAS 

could be pushed into the LNG towers or production tanks. 

The minimum flight visibility is set at 100 feet. It is 

very rare that clouds are lower than 200 feet in this 

location of the country. Flight operation will not be 

conducted or will be suspended when lightning is 5 miles or 

less from the operational location. This will prevent any 

damage to the facilities, the UAS and flight operators.
Petition for Exemption Filed Under Section 333

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8. Above is a layout of a typical oil field production 

facility (www.oilandgasproductionhandbook.blogspot.com). At 

the left side, we find the wellheads. They feed into 

production and test manifolds. In distributed production, 

this is called the gathering system. The remainder of the 

diagram is the actual process, often called the gas oil 

separation plant (GOSP). While there are oil- or gas-only 
Petition for Exemption Filed Under Section 333

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installations, more often the well-stream will consist of a 

full range of hydrocarbons from gas (methane, butane, 

propane, etc.), condensates (medium density hydrocarbons) 

to crude oil. With this well flow, we also get a variety of 

unwanted components, such as water, carbon dioxide, salts, 

sulfur and sand. The purpose of the GOSP is to process the 

well flow into clean, marketable products: oil, natural gas 

or condensates. Also included are a number of utility 

systems, which are not part of the actual process but 

provide energy, water, air or some other utility to the 

plant (www.oilandgasproductionhandbook.blogspot.com). 

Gas Plant

(www.oilandgasproductionhandbook.blogspot.com)

I think that everyone knows what utilities a farm or ranch 

operation has located within.

9. UAS operations will not be conducted near any airports.

10. In accordance with the statutory mandate under section 

333(b)(1) the UAS will be operated within visual line-ofsight (VLOS) by conducting a visual walk through and in 

depth flight plane before flight operations. If during preflight planning a problem arises that the UAS cannot be 

kept in VLOS at one launch point; I will utilize multiple 

launch points and planning.

11. Before flight operations can commence a complete preflight risk assessment will be completed. This will 

include, but not limited to, air temp, wind speed, 
Petition for Exemption Filed Under Section 333

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lightning/ storm location, if any. The presence of any nonessential personnel, proximity to any populated areas, 

airports, and any possible VLOS problems. Lastly completing 

a pre-flight check list and flight programing.

12. I do not intend to conduct any operations that should 

require coordination with the local FSDOs. If for any 

reason that I might need to contact the FSDO I will call 

the one in Denver, CO: (800) 847-3808

FSDO

26805 East 68th Ave.

Denver, CO 80249

13. Before conducting air operations I will obtain a 

Certificate of Waiver or Authorization (COA) from the FAA.
Petition for Exemption Filed Under Section 333

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References

1. www.oilandgasproductionhandbook.blogspot.com

2. 3DR X8+ Operations Manual

3. 3DR X8+ Flight Checklist

4. www.ecfr.gov

5. www.faa.gov/uas