**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 Requir** **ed 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** 

2 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 comp lete 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 yo u 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 safe ty of people and property your first priority!
Always fly below 200 f eet 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

c onditions 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**

3 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 mai ntenance 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. Gro und 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 ord nance 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

cor r ectible eye glasses or ballistic protection. Also each operator must pass a mandatory drug t est 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**

4 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 b e 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**

5 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). Whi le there are oil

- or gas - only**Petition for Exemption Filed Under Section 333**

6 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 varie ty 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 airpo rts. 10. In accordance with the statut ory mandate under section 333(b) (1) the UAS will be operated within visual line

- of

sight (VLOS) by conducting a visual walk through and in depth flight plane before flight operations. If during pre

flight 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 pre

flight risk assessment will be completed. This will include, but not limited to , air temp, wind speed,**Petition for Exemption Filed Under Section 333**

7 lightning/ storm location, if any. The presence of any non

essential 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 in tend 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 68 th 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**

8 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