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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 Act of 2012 (the “Reform 

Act”) and 14 C.F.R. Part 11, the Pennsylvania 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 systems (“UAS”) for aerial 

data collection. Specifically, the 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)
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This Petition incorporates the material contained in the PTC UAS Flight Operation 

Manual (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 that 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 Regulatory 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 17106-7676
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TABLE OF CONTENTS

1. LIST OF ACRONYMS ...................................................................................1

2. DESCRIPTION OF PETITIONER..................................................................2

3. DESCRIPTION OF PROPOSED 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 EXEMPTIONS...................5

5. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED ..................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 Certification 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 SUMMARY.............................................................16

10. CONCLUSION..........................................................................................17
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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 Airspace 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 Visual Line of Sight

VO Visual Observer
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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 financing, 

operating, and maintaining the following highways as part of the Turnpike system:

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

 The Northeastern Extension, signed as Interstate 476.

 The James E. Ross Highway (Beaver Valley Expressway), signed as Interstate 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 System
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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 

River-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 nearly 

525,000 motorists travel on it each day. In 2013, approximately 190 million motorists 

traveled on the Turnpike. 

3. DESCRIPTION OF PROPOSED 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 the 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 remaining on the ground and 

flying 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 

completed in less time.

In addition, a UAS can be used to determine the best height and location to install 

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 points, 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 UAS can be flown to obtain up-to-date high-
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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 risks

associated with manned flights. 

3.3. Traffic Incident Management (TIM)

The Federal Highway 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 obstructions. 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, fire, 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 from 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 TIM. 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 within 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 emergency vehicles.
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• 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 relief.

 More effective preparation for larger-scale emergencies/disasters.

 More efficient use of public resources.

 Reduced emissions.

In the past, Pennsylvania State Police helicopters flew 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, gathering evidence, and possibly reconstructing 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 rather 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 EXEMPTIONS

This Petition for Exemption 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 based on the following considerations:
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 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 

requested exemption is in the public interest. See 49 U.S.C. §106(f) (defining the 

authority of the 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 WHICH EXEMPTION IS REQUESTED

Pursuant to Section 333 of the Reform Act and 14 C.F.R. Part 11, the PTC seeks 

exemption from several interrelated provisions of 14 C.F.R. Parts 21, 27, 45, 61, and 91 

for 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 level 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 requirements 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, the 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 exemption. 

The 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. 
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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 SkyRanger 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,” states:

(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 civil 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 two-inch 

lettering. In a previous Grant of Exemption, the FAA determined that exemption from 

these requirements was warranted provided that the aircraft “have identification (NNumber) 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. 
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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) for 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 

aircraft 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 limitations 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 areas of operation will be controlled and restricted, and all flights are planned and 

coordinated in advance. Moreover, the PIC will not be permitted to operate the 

proposed UAS unless the 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 Petition and 

the Manual. 
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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 

inspect 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 operations require the UA to be 

positioned less than 500 feet from the PIC and structures. Additionally, the UAS will be 

operated less than 400 feet AGL. 

Due to the lightweight nature and slow speed of the UAS, an equivalent level of safety is 

achieved when operations 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 protection 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 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.

The 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. 
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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 the 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 requirements 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 30 minutes ...

The PTC seeks exemption from 14 C.F.R. 91.151(a)(1) because the 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 with 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 from 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 repaired 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 by 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 had 
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(1) An annual inspection in accordance 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 applies 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 the PIC will perform maintenance 

inspections before and after every flight. Required maintenance and servicing will also 

be performed as recommended in the specific operating manuals for the proposed UAS. 

Any maintenance that is performed will be kept in a log, as required by the Manual. In 

addition, test flights 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, the restricted 

environment within which they will operate, and the procedures listed below, the 

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 its 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 2015. 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.
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When using UAS, the 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 Command – The PIC is responsible for operation of the UAS and safety 

during flight. Specific responsibilities and considerations 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 ensure 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 started, 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 reveals 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 altitude 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 aircraft 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.
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9. The UAS shall be operated within VLOS of the PIC and VO at all times. 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 knots (100 miles per 

hour), or at a speed greater than the maximum recommended by the 

manufacturer. 

12. The UA shall not be operated at an altitude greater than 400 feet AGL. 

13. The UA shall not be operated within 5 nautical miles of an airport, military 

installation, 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 reporting 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 500 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 protection. 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 VO.

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 must return to a 

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

Granting 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 

favors early integration of UAS into the NAS in controlled, safe working environments 

such as those proposed by the PTC in this Petition. Granting this Petition for Exemption 

will help the FAA to fulfill Congress’ goal of permitting UAS to operate safely in the NAS 

before completion of the plan and rulemaking required under Section 332 of the Reform 

Act.

By using UAS to perform structure inspections, obtain aerial surveying, mapping and 

videography, enhance TIM, and reconstruct accidents, the 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 groundbased inspection methods.

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 – The cost to perform inspections with UAS will be less compared to 

conventional methods of inspecting structures. Conventional inspections usually require 

teams of inspectors and bucket trucks. Alternatively, if a UAS can be used, bucket trucks 

and multiple personnel would not be needed and the inspections 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 aircraft 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, thereby 
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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 safety 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 customers, 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 

video 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 

potentially 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 Travel 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 travel delay and emissions. 
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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 construction 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 Management – Using UAS for TIM will expedite clearing accidents from

the roadway. Faster clearing of crashes allows 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. Traffic 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 over 

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 operation of unmanned aircraft systems for aerial data 

collection to include (1) structure inspections, (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. 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).
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The requested exemption would further the public interest by improving and enhancing

safety by reducing risks 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 

delays and emissions.

10. CONCLUSION

Pursuant to Section 333 of the Reform Act , the PTC seeks exemption from the following 

rules found in Title 14 of the Code of Federal 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) enhanced TIM; and (4) accident reconstruction. 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, the 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 Petition. 

Finally, as set forth at length in the Petition, granting the requested exemption will

benefit the public interest as a whole by (1) reducing costs, (2) enhancing safety, and (3) 

reducing travel delays and emissions. Accordingly, the PTC 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