Page i

September 16, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, D.C. 20590

Re: Petition of the Pennsylvania Turnpike Commission for an Exemption Pursuant to Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam :

Pursuant to Section 333 of the FAA Modernization and Reform Ac t of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, the Pe nnsylvania Turnpike Commission ( “ PTC ” ) hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) listed below
and described herein to allow operation of unmanned aircraft system s ( “ UAS ” ) for aerial
data collection. Specifically, t he requested exemption would permit the PTC to operate the DJI Inspire 1 and the Aeryon SkyRanger UAS for : (1) structure inspections, (2) aerial surveying, mapping, and videography

, (3) traffic incident management, and (4) accident

reconstruction.

The PTC requests exemption from the following regulations:

 14 C.F.R. Part 21, Subpart H

 14 C.F.R. Part 27

 14 C.F.R. 45.23

 14 C.F.R. 45.27(a)

 14 C.F.R. 91.9(c)

 14 C.F.R. 61.101(e)(4) & (5)

 14 C.F.R. 61.113(a) & (b)

 14 C.F.R. 61.315

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)(1)

 14 C.F.R. 91.203(a)(1)

 14 C.F.R. 91.405(a)

 14 C.F.R. 91.407(a)(1)

 14 C.F.R. 91.409(a)(1) & (2)

 14 C.F.R. 91.417(a) & (b)Page ii

This P etition incorporates the mater ial contained in the PTC UAS Flight Operation

Ma nual (the “Manual ”), which is submitted as an attachment. Also attached are the following documents for the DJI Inspire 1 : (1) User Manual, (2) Safety Guidelines, and (3)
Maintenance Manual. Please note tha t because of confidentiality and proprietary concerns, the User Guide for the Aeryon SkyRanger is not available to the PTC until purchase. However, the FAA has received the User Guide for the Aeryon SkyRanger with regard to exemptions granted at Regulator y Dockets Nos. FAA

- 2014

- 0642 (Aeryon Labs, Inc.) and FAA

- 2014

- 0732 (The City of Roswell Coalition)

.

The name and address of the applicant are:

Pennsylvania Turnpike Commission

Attention: John F. Dwyer, Assistant Counsel
Phone: 717

- 831

- 7343
Email: jdwyer @paturnpike.com Mailing Address: 700 S. Eisenhower Blvd.

, PO Box 67676, Harrisburg , PA 17106

- 7676Page iii

TABLE OF CONTENTS

1. LIST OF ACRONYMS

................................ ................................ ................... 1

2. DESCRIPTION OF PETIT IONER

................................ ................................ .. 2

3. DESCRIPTION OF PROPO SED OPERATIONS

................................ .......... 3

3.1. Structure Inspections

................................ ................................ ........................... 3

3.2. Aerial Surveying, Mapping, and Videography

................................ ...................... 3

3.3. Traffic Incident Management (TIM)

................................ ................................ ..... 4

3.4. Accident Reconstruction

................................ ................................ ...................... 5

4. STATUTORY AUTHORITY FOR REQUESTED EXEMPT IONS

................... 5

5. REGULATIONS FROM WHI CH EXEMPTION IS REQU ESTED

.................. 6

5.1. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. §91.203(a)(1)

................................ ................................ ................................ ................... 6

5.2. 14 C.F.R. Part 27

– Airworthiness Standards: Normal Category Rotorcraft

........ 7

5.3. 14 C.F.R. 45.23; 14 C.F.R. 45.27(a); and 14 C.F.R. 91.9(c)

– Aircraft Identification and Marking

................................ ................................ ................................ .................... 7

5.4. 14 C.F.R. 61.101(e)(4) & (5); 14 C.F.R. 61.113(a) & (b); and 14 C.F.R. 61.315

– Pilot C ertification and Compensation

................................ ................................ ............. 8

5.5. 14 C.F.R. 91.7(a)

– Civil Aircraft Airworthiness

................................ .................... 9

5.6. 14 C.F.R. 91.119

– Minimum Safe Altitudes

................................ ......................... 9

5.7. 14 C.F.R. 91.121

– Altimeter Settings

................................ ................................ . 10

5.8. 14 C.F.R. 91.151(a)(1)

– Fuel Requirements for Flight in VFR Conditions

.......... 10

5.9. 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) & (2); and 14 C.F.R. 91.417(a) & (b)

– Maintenance Inspections

................................ ....................... 10

6. PROPOSED OPERATIONAL PROCEDURES

................................ ........... 11

7. PUBLIC INTEREST

................................ ................................ ..................... 14

7.1. Reduced Costs

................................ ................................ ................................ .... 14

7.2. Enhanced Safety

................................ ................................ ................................ . 15

7.3. Reduced Travel Delay and Emissions

................................ ................................ . 15

8. PRIVACY

................................ ................................ ................................ ..... 16

9. FEDERAL REGISTER SUM MARY

................................ ............................. 16

10. CONCLUSION

................................ ................................ .......................... 17Page 1

1. LIST OF ACRONYMS

AGL Above Ground Level

ATO Air Traffic Organization

CCTV Closed

- Circuit Television

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

FAA Federal Aviation Administration

FARs Federal Aviation Regulations

FCC Federal Communications Commission

FHWA Federal Highway Administration

GPS Global Positioning System

ITS Intelligent Transportation Systems

NAS National Air space System

NTSB National Transportation Safety Board

PIC Pilot in Command

PTC Pennsylvania Turnpike Commission

TIM Traffic Incident Management

TOC Traffic Operations Center

UA Unmanned Aircraft

UAS Unmanned Aircraft System (s)

VFR Visual Flight Rules

VLOS Vi sual Line of Sight

VO Visual ObserverPage 2

2. DESCRIPTION OF PETITIONER

The Pennsylvania Turnpike is a limited

- access highway system , which first opened on October 1, 1940. The PTC was created in 1937 and is responsible for financ ing

, operat ing , and maintain ing the following highways as part of the Turnpike system:

 The Pennsylvania Turnpike Mainline signed as Interstates 70, 76, and 276.

 The Northeast ern Extension, signed as Interstate 476.

 The James E. Ross Highway (Beaver Valley Expressway), signed as Inte rstate 376.

 The Amos K. Hutchinson Bypass (Greensburg Bypass), signed as Pennsylvania

Route 66.

 The Mon/Fayette Expressway, signed as Pennsylvania Route 43.

 The Pittsburgh Southern Beltway, signed as Pennsylvania Route 576.

The map below highlights the highways that are part of the Turnpike system.

The Pennsylvania Turnpike SystemPage 3

The mainline of the Turnpike runs for 360 miles across the state, beginning at the Ohio state line in Lawrence County and ending at the New Jersey border at the Delaware

Ri ver

- Turnpike Toll Bridge over the Delaware River in Bucks County. Along with the
other sections described above , the entire system totals over 550 miles , and n early 525,000 motorists travel on it each day. In 2013, approximately 190 million motorists

trave led on the Turnpike.

3. DESCRIPTION OF PROPO SED OPERATIONS

The PTC intends to use the DJI Inspire 1 and the Aeryon SkyRanger UAS in the following applications:

 Structure Inspections

 Aerial Surveying, Mapping, and Videography

 Traffic Incident Management (TIM)

 Accident Reconstruction

This section describes how UAS will be used in each application :

3.1. Structure Inspections

A UAS will be used to perform inspections of bridges, microwave towers and ITS devices.
Without the use of UAS

, workers must inspect th e structure closely by harnessing themselves and climbing on the structure, which can pose a safety risk to the inspectors,

or by using a bucket truck construction vehicle.

With a UAS, the operator can perform inspections by remain ing on the ground and
f ly ing the UA around the structure, capturing detailed images and video using the
camera attached to the UA. Performing inspections with a UAS poses less safety risk,
since the operator remains on the ground . Moreover, inspections using a UAS can be complet ed in less time.

In addition, a UAS can be used to determine the best height and location to ins tall
closed

- circuit television (CCTV) systems. The UAS can be flown in an area where a CCTV will be installed, and by capturing video of different vantage poin ts, the height and location that provides the best view can be determined. By determining the best location for a CCTV before it is installed, the PTC will more efficiently spend money by eliminating possible viewing conflicts after the CCTV is constructed

.

3.2. Aerial Surveying, Mapping , and Videography

UAS have the ability to provide high

- resolution aerial imagery and videography. The images and videos that are captured will be used for engineering projects. During the design phase of engineering projects

, a UA S can be flown to obtain up

- to

- date high

-Page 4

resolution images and mapping to help engineers properly design construction plans. During the construction phase, a UA can be flown to allow the PTC to discover and correct problems early in the project, while the costs associated with correcting issues
are still low.

Finally, the PTC plans to use UAS to record videos for educational/training purposes and to use as part of public awareness campaigns

.

Without using UAS, obtaining aerial imagery and videos is only possible using manned aircraft or rotorcraft flights, which can be prohibitively expensive and create risk s associated with manned flights.

3.3. Traffic Incident Management (TIM)

The Federal H ighway Administration (FHWA) defines a traffic incident as “an emergency road user occurrence, a natural disaster, or other event that affects or impedes the normal flow of traffic”. Common examples include crashes, disabled vehicles, and roadway obstructi ons. Nationally, FHWA estimates that approximately 25% of all traffic congestion is caused by traffic incidents

, and traffic incidents account for 45% of all nonrecurring congestion.

When a traffic incident occurs, the PTC is notified through its Traffic Operations Center (TOC), located in Highspire, PA. The TOC is a traffic management and full dispatch center where personnel monitor Turnpike traffic conditions and deploy resources, as needed.
These resources include maintenance, f ire, EMS and towing , all of whom may be responding to a traffic incident in a coordinated manner.

During a major traffic incident, it may be challenging for personnel responding to the incident to understand everything that is occurring fr om a position on the ground. In addition, if there is no CCTV coverage of the area, personnel in the TOC may not have complete knowledge of the situation.

An aerial view of the entire traffic incident scene can provide enhanced situational
awareness for T IM. Specifically, an aerial view can help personnel:

• Determine the magnitude of the event.

• Determine appropriate personnel and equipment to dispatch.

• Coordinate and manage on

- scene resources.

• Identify secondary incidents , or crashes that occur wit hin the incident scene or traffic queue resulting from the original incident

.

• Accurately report the length of the backlog.

• Validate messages that are provided to the media and public.

• Investigate the cause of the crash.

• Direct the movement of emerg ency vehicles.Page 5

• Identify hazardous material spills.

These benefits all help to create effective TIM , which is characterized by:

 Increased driver and responder safety

.

 Reduced secondary accidents, fatalities, injuries and property damage

.

 Congestion reli ef

.

 More effective preparation for larger

- scale emergencies/disasters

.

 More efficient use of public resources.

 Reduced emissions

.

In the past , Pennsylvania State Police helicopters fl ew over the scene of major traffic
incidents to obtain aerial views , but flying piloted helicopters can be cost prohibitive for many situations. UAS can provide enhanced situational awareness and the
aforementioned benefits for TIM by obtaining an aerial view of the traffic incident scene without placing the general public or personnel at risk and without relying on piloted helicopters.

3.4. Accident Reconstruction

When a roadway crash occurs, investigators have the responsibility of containing the site, gather ing evidence, and possibly reconstruct ing the accident . Conventional
methods for accident reconstruction include detailed ground measurements which, for complex crash scenes, can take several hours. During this time, individual travel lanes, or the entire roadway, must be closed to traffic.

Using a UAS rath er than conventional reconstruction methods to assist with reconstructing accidents will allow the traffic conditions to return to normal sooner. A UAS can be used to collect aerial imagery and benchmark image

- based measurements in substantially less time. This will result in less driver delay and congestion cost and will be safer since ground personnel who are reconstructing the accident are exposed to traffic for a shorter period of time.

4. STATUTORY AUTHORITY FOR REQUESTED EXEMPT IONS

This Petition for E xemption is submitted in accordance with Section 333(a) through (c) of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.” Reform Act,

Section 332 (a)(1)

. Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of unmanned aircraft systems where it does not create a hazard to users of the national airspace system (“NAS”) or the public or pose a threat to national security ba sed on the following considerations:Page 6

 The UAS size, weight, speed and operational capability,

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within the visual line of sight of the operator.

Furthermore, the FAA Administrator has general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a

reques ted exemption is in the public interest. See 49 U.S.C. §106(f) (defining the authority of th e Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from
§§ 44701(a), (b) and §§ 44702

- 44716 et seq .). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. See 14 C.F. R. § 11.81 (petition for an exemption).

5. REGULATIONS FROM WHI CH EXEMPTION IS REQU ESTED

Pursuant to Section 333 of the Reform Act and 14 C.F.R. Part 11, the PTC s eeks exemption from several interrelated provisions of 14 C.F.R. Parts 21, 27, 45, 61, and 91
f or purposes of conducting the requested operations using the DJI Inspire 1 and Aeryon SkyRanger. Listed below are : (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards which will ensure a le vel of safety equal to or better than the rules from which exemption is sought. See 14 C.F.R. §11.81(e)

.

5.1. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R.

§91.203(a)(1 )

14 C.F.R. Part 21, Subpart H prescribes procedural requirem ents for the issue of
airworthiness certificates as required by FAR §91.203(a)( 1 )

. The FAA has previously stated that no exemption is needed from this section if a finding is made under the
Reform Act that the UAS selected provided an equivalent level of safety when compared to normal aircraft used for the same application. These criteria are met with this
Petition and therefore no exemption is needed. Moreover, t he FAA has previously ruled
that no exemption is needed for the proposed UAS (DJI Inspire 1 and Aeryon SkyRanger). See Regulatory Docket Nos. FAA

- 2015

- 0856 and FAA

- 2014

- 0642. If

, however, the FAA determines that an exemption is required for the proposed UAS , then the PTC requests the exe mption.

T he proposed UAS will be at least as safe, or safer, than a conventional aircraft with an
airworthiness certificate. Additionally, the PTC will inspect the UAS before and after each flight to ensure the UAS is in an airworthy condition.Page 7

5.2. 14 C.F.R. Part 27

– Airworthiness Standards: Normal Category Rotorcraft

The procedural requirements for airworthiness certification of normal category
rotorcraft are set forth in 14 C.F.R. Part 27. To the extent that both the DJI Inspire 1 and Aeryon SkyRang er would otherwise require certification under Part 27, the PTC seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

The PTC seeks exemption from 14 C.F.R . Part 27 because the UAS will be at least as safe, or safer, than an airworthy normal category rotorcraft.

5.3. 14 C.F.R. 45.23 ; 14 C.F.R. 45.27(a) ; and 14 C.F.R. 91.9(c)

– Aircraft Identification

and Marking

14 C.F.R. 45.23, “Display of marks; general,” sta tes:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed

must also be a Roman capital letter. (b) 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.

14 C.F.R. 45.27(a) states, “ Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by
§45.23. ”

14 C.F.R. 91.9(c) states, “ No person may operate a U.S.

- registered c ivil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. ”

The PTC seeks exemption from these regulations because the proposed UAS do not have cabins, cockpits, or pilot stations, and the size of the UAS would preclude t wo

- inch lettering. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provide d that the aircraft “have identification (N

Number) markings in accordance with 14 C.F.R. Part 45, Subpart C if the markings are as large as practicable .” See Regulatory Docket No. FAA

- 2014

- 0352

.

In order to maintain an equivalent level of safety, the PTC will mark all DJI Inspire 1 and Aeryon SkyRanger aircraft with their N

- Number in a prominent spot with markings as large as practicable.Page 8

5.4. 14 C.F.R. 61.101(e)(4) & (5); 14 C.F.R. 61.113(a) & (b) ; and 14 C.F.R. 61.315

–

Pilot Certification and Compensation

14 C.F.R. 61.101(e)(4) and (5) prohibits recreational pilot certificate holders from acting

as a Pilot in Command ( PIC ) f or compensation or hire.

14 C.F.R. 61.113, “Private pilot privileges and limitations: Pilot in command,” states:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an

air craft in connection with any business or employment if:

1. The flight is only incidental to that business or employment; and

2. The aircraft does not carry passengers or property for compensation or
hire.

14 C.F.R. 61.315 prescribes the privileges and limitatio ns of the sport pilot certificate, which includes prohibition from operating as PIC of a light

- sport aircraft for compensation or hire.

While the PTC employs private pilots who will act as PIC during UAS operations, exemption is sought from these regulations in order to allow an operator with a recreational pilot or sport pilot certificate to be compensated to act as PIC during UAS operations. The FAA has previously granted exemption from these requirements. See Regulatory Docket No. FAA

- 2014

- 0642

, p.8

- 9

.

An equivalent level of safety will be achieved because the risks associated with operating a UAS are less than the risks associated with operating a conventional aircraft
for commercial activities. Unlike conventional aircraft that carry a pilot and passengers, the proposed UAS are remotely controlled with no pilots, passengers or cargo onboard.
The area s of operation will be controlled and restricted, and all flights are planned and
coordinated in advance. Moreover, the PIC will not be permitte d to operate the proposed UAS unless th e PIC has met the training requirements as set forth in the
Manual , demonstrating that the PIC is able to safely operate the UAS in a manner
consistent with the operational procedures described in Section 6 of the Pet ition an d
the Manua l

.Page 9

5.5. 14 C.F.R. 91.7(a)

– Civil Aircraft Airworthiness

14 C.F.R. 91.7(a) states, “ No person may operate a civil aircraft unless it is in an airworthy condition. ”

Should exemption be granted for 14 C.F.R. Part 21, Subpart H, no standard will exist for
airworthiness. The FAA has stated that no exemption is required for 14 C.F.R. 91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. See Regulatory Docket No. FAA

- 2014

- 0352 . Accordingly, the PTC requests that the requirements for Section 91.7(a) be treated in accordance with 5.1 above.

In order to provide an equivalent level of safety, before and after each flight

, the PIC will inspe ct the UAS and determine if it is airworthy.

5.6. 14 C.F.R. 91.119

– Minimum Safe Altitudes

14 C.F.R. 91.119 prescribes the minimum safe altitude requirements under which an aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle or structure in non

- congested areas.

The PTC seeks exemption because the proposed UAS operation s require the UA to be positioned less than 500 feet from the PIC and structures. Additionally, the UAS will be operated less than 4 00 feet AGL.

Due to the lightweight nature and slow speed of the UAS, an equivalent level of safety is
achieved when opera tions are performed in accordance with the proposed operating procedures . UAS flights will be operated at a distance of at least 500 feet from any nonparticipating persons, vessels, vehicles, and structures unless:

 Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protec tion and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

 The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to tho se objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

T he PIC will stop any UAS operation if the UAS begins to act in an unpredictable manner
or if any unforeseen complication arises which may be a potential safety hazard to any

person

. Finally , any flight will be terminated if any nonparticipating person breaches the

500

- foot safety zone.Page 10

5.7. 14 C.F.R. 91.121

– Altimeter Settings

14 C.F.R. 91.121 requires aircraft to maintain cruising altitudes using an on

- board
altimeter.

The PTC seeks exemption from 14 C.F.R. 91.121 because the proposed UAS will not have
altimeters. An equivalent level of safety will be achieved because t he altitude of the UAS
will be reported and displayed using GPS.

5.8. 14 C.F.R. 91.151(a) (1)

– Fuel Requirements for Flight in VFR Conditions

14 C.F.R. 91.151, “ Fuel requiremen ts for flight in VFR conditions,” states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– 1. During the day, to fly after that for at least 3 0 minutes

...

The PTC seeks exemption from 14 C.F.R . 91.151(a)(1) because t he technical limitation of UAS battery power precludes the PTC from operating UAS as proposed while maintaining 30 minutes of reserve flight time. An equivalent level of safety will be achieved by operating the UAS in accordance wit h the specific operating manuals for the proposed UAS . Battery power will be monitored during flights and the PIC will ensure adequate power is available for a controlled landing. Exemptions f rom this requirement for the DJI Inspire 1 and Aeryon SkyRanger UAS have been granted by the

FAA in Regulatory Docket Nos. FAA

- 2015

- 0856 and FAA

- 2014

- 0642 , respectively

.

5.9. 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(1) & (2) ; and 14

C.F.R. 91.417(a) & (b)

– Maintenance Inspections

14 C.F.R. 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repa ired as prescribed in part 43 of this chapter ...”

14 C.F.R. 91.407(a)(1) states, “ No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service b y a person authorized under §43.7 of this chapter ...”

14 C.F.R. 91.409(a) states, “ Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has hadPage 11

(1) An annual inspection in a ccordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter;

or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. ”

14 C.F.R. 91 .417(a) and (b) detail the requirements for keeping maintenance records.

In summary, these regulations specify maintenance and inspection standards in
reference to 14 C.F.R. Part 43. The PTC seeks exemption from these regulations because

14 C.F.R. Part 43 only appl ies to aircraft with an airworthy certificate. The proposed UAS to be operated by the PTC will not have airworthiness certificates.

An equivalent level of safety will be achieved because t he PIC will perform maintenance inspections before and a fter every flight

. R equired maintenance and servicing will also be performed as recommended in the specific operating manuals for the proposed UAS.

A ny maintenance that is performed will be kept in a log , as required by the Manual

. In addition, test flight s will be flown after any maintenance is performed to ensure the UAS is airworthy.

6. PROPOSED OPERATIONAL PROCEDURES

The PTC proposes to operate the UAS within the limitations and performance specifications listed in the specific operating manuals for the proposed UAS and as described in this Petition and the Manuel

. The proposed operations are safer than conventional operations using helicopters or fixed wing aircraft which carry a pilot and
flammable fuel. Moreover, based on the small size of the UAS, t he restricted environment within which they will operate, and the procedures listed below, t he proposed operations would not create a hazard to users of the NAS or public or pose a threat to national security

. See Reform Act, Section 333(b)(1).

The PTC will operate two UAS for i ts planned operations : the DJI Inspire 1 and the Aeryon SkyRanger . The FAA has already approved both UAS for commercial use in Regulatory Docket Nos. FAA

- 2015

- 0856 and FAA

- 2014

- 0642 , respectively

.

The UAS will be operated at or below 400 feet AGL within the visual line of sight of the

PIC

. Moreover, the PTC believes that the majority of its proposed operations can be conducted within the 200 feet “blanket” COA that the FAA has been granting to 333 exemption holders since March 2 015. All proposed operations would be flown from and

over PTC

- owned or private or controlled

- access property . No operations will be conducted over private or controlled

- access property without express authorization from the property owner, controller, or authorized representative

.Page 12

When using UAS, t he PTC will adhere to the following operational guidelines

, restrictions and procedures to ensure an equivalent or higher level of safety compared to operations conducted under current regulatory guidelines. These guidelines are also
included in the Manual :

1. The DJI Inspire 1 weighs less than 7 pounds, fully loaded.

2. The Aeryon SkyRanger weighs less than 6 pounds, fully loaded.

3. All operations will be performed in Class G airspace.

4. Both the DJI Inspire 1 and Aeryon SkyRanger UAS will operate using radio frequencies (2.4 GHz) that comply with Federal Communications Commission (“FCC”) and other governmental agency requirements.

5. Each flight will have a minimum crew of two people

– a PIC and a VO.

6. Pilot in Comman d

– The PIC is responsible for operation of the UAS and safety during flight. Specific responsibilities and considerati ons of the PIC are listed
below:

a. The PIC must have at least a sport pilot certificate and a valid U.S. driver’s
license.
b. The PIC must ens ure the UAS is flying within the boundaries of the Certificate of Waiver or Authorization (COA) that is applicable to the flight.

c. The PIC must ensure the VO can perform required duties.
d. During UAS operations, the PIC must be able to access the latest copy of the PTC UAS Flight Operation Manual, the UAS manufacturer user manual(s), and any other documents needed to operate the UAS. These documents must also be made available to the FAA and any law enforcement officer upon request.

e. After a UAS operation is s tarted, the PIC cannot transfer designation or responsibilities to another person for the duration of the flight.
f. Before takeoff, the PIC must inspect the UAS to ensure it is airworthy.

g. The PIC shall not operate the UAS if the pre

- flight inspection revea ls an issue that affects the safe operation of the aircraft.

7. Visual Observer

– The VO is responsible for assisting the PIC by observing the UAS and providing situational awareness to the PIC during flight. The VO must be
able to discern the direction and a ltitude of the aircraft to assist the PIC during flight operations . During flights, the VO must be positioned close enough to the PIC in order to communicate by voice only. During landing, the VO is responsible for keeping the landing area and surrounding area clear of people and obstacles.

8. The UAS shall be operated during daylight only. Operations shall occur during daytime Visual Flight Rules (VFR) Meteorological Conditions, which are conditions in which operators have sufficient visibility to fly the air craft while maintaining visual separation from terrain and other aircraft. In other words, the PIC and VO must have sufficient visibility and control in order to safely operate
the aircraft.Page 13

9. The UAS shall be operated within VLOS of the PIC and VO at all ti mes. VLOS must be achieved using human vision unaided by any device other than corrective
lenses.

10. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

11. The UA shall not be operated at a speed exceeding 87 kno ts (100 miles per hour), or at a speed greater than the maximum recommended by the
manufacturer.

12. T he UA shall not be operated at a n altitude greater than 4 00 feet AGL.

13. The UA shall not be operated within 5 nautical miles of an airport, military
installat ion, prison, or helipad unless a specific COA is issued for the operation.

14. The UAS must not be operated from any moving vehicle.

15. For any operation over private or controlled

- access property, permission must be obtained from the property owner, controller, or authorized representative.

16. If an accident occurs during UAS operations, it must be reported to the National Transportation Safety Board (NTSB). The NTSB website, located at www.ntsb.gov , provides instructions for re porting accidents.

17. During UAS operations, all flight crew members must wear proper safety apparel
in accordance with the PTC Employee Safety Handbook.

18. Flights shall be operated at a distance of at least 5 00 feet from any nonparticipating persons , vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protecti on. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

19. At no time shall the UAS be operated so close to structures or vehicles as to present an undue hazard to the PIC or V O.

20. The PIC shall abort the flight by landing the UA if the UAS begins to act in an unpredictable manner or if an unpredicted obstacle is identified during normal flight.

21. A flight log must be kept for any training, test, or project

- related UAS operation.

22. All operations shall be conducted in accordance with an Air Traffic Organization (ATO)

- issued COA.

23. If the UAS loses communications or loses its GPS signal, the UA m ust return to a

pre

- determined location that is programmed before the flight operation begins.Page 14

24. Each aircraft will be identified by a serial number, registered with the FAA, and have identification markings as large as practicable.

7. PUBLIC INTEREST

Grant ing the PTC’s Petition for Exemption would further the public interest and support the PTC’s mission to operate a safe, reliable, customer

- valued

, limited

- access highway system that supports national mobility and commerce. National policy set by Congress
f avors early integration of UAS into the NAS in controlled, safe work ing environments
such as those p r o po sed by the PTC in this Petition. G ranting this Petition for Exemption
will he lp the FAA to fulfill Congress’ goal of permitting UAS to operate safely i n the NAS before completion of the plan and rulemaking required under Section 332 of the Reform

Act.

B y using UAS to perform structure inspections, obtain aerial surveying, mapping and videography , enhance TIM, and reconstruct accidents , t he public as a whole would
benefit through reduced costs, enhanced safety, and reduced travel delay and

emissions. The exemption will enhance safety by reducing risks to the operator, the general public and property owners from the hazards associated with performing the same type of work using conventional aircraft and rotorcraft or dangerous ground

based inspection m ethods

.

The following explains how the PTC’s proposed UAS operations would benefit the public

interest as a whole:

7.1. Reduced Costs

Using UAS will help reduce direct costs to the PTC as follows:

Inspections

– T he cost to perform inspections with UAS will be less compared to

con v entional methods of inspecting structures. Conventional inspections usually require teams of inspectors and bucket trucks. Alternatively, i f a UAS can be used, bucket trucks and multiple personnel would not be needed and the inspec tions can be performed
faster and cheaper

.

Aerial Surveying, Mapping, and Videography

– By using UAS for aerial surveying, mapping, and videography, costs will be reduced by obtaining aerial imagery more cheaply and efficiently than by using piloted airc raft or rotorcraft

. In addition, by using UAS to monitor construction work, problems can be discovered early in the construction phase. By finding problems early, they can be corrected more cost effectively than when they are found later in the construction.

Traffic Incident Management

– In the past, Pennsylvania State Police helicopters were used during major traffic incidents to obtain aerial views of the ground scenes, therebyPage 15

providing better situational awareness for incident management. A UAS is a more affordable alternative, expanding its use to other incidents, not just major incidents.

Accident Reconstruction

– Conventional accident reconstruction requires several hours of work to record detailed measurements and gather evidence. By using a UAS, the time required to collect high

- resolution aerial imagery and record measurements is reduced.

7.2. Enhanced Safety

UAS will enhance the sa fety of drivers using the Turnpike system and employees working at the PTC.

Inspections

– UAS will provide a level of safety to inspectors, because they will not need to harness themselves and climb on structures to perform dangerous inspections. UAS will also enhance safety for Turnpike custom ers, since it will reduce the duration of lane
closures to perform inspections.

Aerial Surveying, Mapping, and Videography

– Using UAS for aerial surveying provides an enhanced level of safety compared to a piloted aircraft. Also, using UAS to capture
vid eo will lead to better training for employees and public awareness campaigns.

Traffic Incident Management

– UAS will allow for better situational awareness for traffic incident management, providing an enhanced level of safety to first responders and
pot entially assisting with clearing crashes from the roadway faster compared to not using UAS. Clearing crashes faster reduces the probability of a secondary crash occurring and allows traffic flow to return to normal more quickly.

Accident Reconstruction

– Using a UAS to assist with reconstructing crashes will enhance safety by allowing traffic flow to return to normal sooner than by conventional reconstruction. In addition, ground personnel will be exposed to traffic for a shorter period of time.

7.3. Reduced T ravel Delay and Emissions

By incorporating UAS into PTC operations, the impact to traffic flow will be reduced compared to conventional practices. This will reduce travel delay and emissions due to engine idle time. Reduced travel delay saves drivers money considering the value of their time along with the cost of wasted fuel. Reduced emissions will help to improve air quality.

Inspections

– As stated previously, using UAS for inspections will reduce the duration of
lane closures resulting in reduced trav el delay and emissions

.Page 16

Aerial Surveying, Mapping, and Videography

– While using UAS for aerial imagery may not lead to a direct reduction in travel delay and emissions, using UAS to monitor construction has the potential to reduce delay. If a constructi on issue is recognized early, it can be addressed during the planned timeframe of the construction project. If a problem is discovered later in the project, the construction may last longer which would increase overall travel delay.

Traffic Incident Mana gement

– Using UAS for TIM will expedite clearing accidents from the roadway. Faster clearing of crashes allow s traffic flow to return to normal sooner,
which decreases overall travel delay and emissions

. Since approximately 25% of all traffic congestion is caused by traffic incidents and traffic incidents account for 45% of all nonrecurring congestion , UAS have significant potential for public benefit in this area.

Accident Reconstruction

– When reconstructing crashes, using UAS will shorten the

amount of time required to perform the work , in turn shortening the amount of time individual lanes or roadway sections are closed to traffic. T raffic flow will return to normal more quickly , which will decrease overall travel delay and emissions.

8. PRIVACY

All PTC UAS operations will be conducted in accordance with any applicable federal, state, or local laws regarding privacy. All flights will occur over the PTC’s limited access highway system or property owned by the PTC. In the event flight operations occur o ver property not owned by the PTC, notification and consent of the property owner will be obtained before any flight operations are conducted.

9. FEDERAL REGISTER SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

The Pennsylvania Turnpike Commission seeks an exemption from the following Federal Aviation Regulations to allow operat ion of unmanned aircraft systems for aerial data
collection to include (1) structure inspect ions, (2) aerial surveying, mapping and videography, (3) traffic incident management, and (4) accident reconstruction : 14 C.F.R. Part 21, Subpart H ; 14 C.F.R. Par t 27 ; 14 C.F.R. 45.23 ; 14 C.F.R. 45.27(a); 14 C.F.R. 91.9(c); 14 C.F.R. 61.101(e)(4) & (5); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.315; 14 C.F.R. 91.7(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.203(a)(1);

14 C.F.R. 91.405 (a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) & (2); 14 C.F.R. 91.417(a) & (b).Page 17

T he requested exemption would further the public interest by improving and enhancing safety by reducing risk s to the operator, the general public and property owners from the hazards associated with performing equivalent work using conventional aircraft and
rotorcraft. Using UAS for the purposes mentioned above will also reduce costs

, travel delay s and emissions

.

10. CONCLUSION

Pursuant to Section 333 of the Reform Act , the P TC seeks exemption from the following
rules found in Title 14 of the Code of F ederal Regulations : 14 C.F.R. Part 21, Subpart H ; 14 C.F.R. Part 27 ; 14 C.F.R. 45.23 ; 14 C.F.R. 45.27(a); 14 C.F .R. 91.9(c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 61.315; 14 C.F.R. 91.7(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.203(a)(1); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409 (a)(1) and (2); and 14 C.F.R. 91.417(a)
and (b).

The PTC is requesting exemption so that it can operate UAS for aerial data collection

, which will include : (1) structure inspections; (2) aerial surveying, mapping and videography; (3) enhance d TIM; and (4) accident reconstruct ion

. Based on the description of the proposed operations, procedures and supporting documents set forth in this Petition, the PTC’s proposed use of UAS does not create a hazard to the NAS or the public

, nor does it pose a threat to national security. Moreover , the satisfaction of
the criteria provided in Section 333 of the Reform Act regarding size, weight, speed, operating capabilities, proximity to airports and populated areas, and operations within visual line of sight

, provides more than adequate justification for granting the requested exemptions. In previous exemption decisions, t he FAA has approved the use of the DJI Inspire 1 and the Aeryon SkyRanger UAS for similar operations as proposed by the PTC

in its Petitio n.

Finally, a s set forth at length in the Petition, g ranti ng the requested exemption will benefit the public interest as a whole by (1) reduc ing costs, (2) enhanc ing safety, and (3)
reduc ing travel delay s and emissions. Accordingly , the P TC respectfully requests that the FAA grant the exemption without delay.

Respectfully submitted,

John F. Dwyer, Assistant Counsel Pennsylvania Turnpike Commission
700 South Eisenhower Boulevard

PO Box 67676 Harrisburg, PA 17106

- 7676 jdwyer@paturnpike.com