VALERO 

~ 

November 13, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Electronically Submitted via 

www .regulations.gov 

Regarding: Valero Services, Inc. Petition for Section 333 Exemption 

pursuant To Section 333 of the FAA Reform Act of2012 and Part 11 of 

the Federal Aviation Regulations from 14 CFR Patt 21; 61.113(a) and (b); 

91.103; 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(l); 

91.409(a)(1) and (2); 91.417(a) and (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Refonn Act of 2012 (the 

"Reform Act") and 14 C.F.R. Part 11, Valero Services, Inc. ("Valero" or "Petitioner") hereby 

submits this petition for exemption to authorize_ civil operations of small Unmanned Aircraft 

Systems ("sUAS") for the purposes of: 

1. Aerial Video and Photography; 

2. Disaster Response and Emergency Management; 

3. Environmental Monitoring; 

4. Facilities Security; 

5. Land Planning; 

6. Precision Agriculture; 

7. Training, Research and Development; and 

8. Wildlife and Game Management 

Aerial Inspections of: 

9. Construction sites; 

10. Oil, Gas, and Ethanol Infrastructures; 

11. Petroleum Transmission and Storage; and 

12. Wind Fmm Facilities 

Operations will be conducted by Valero within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

As described below, the requested exemption would permit the operation of sUAS for 

inspection of facilities operated by Valero; Valero's wholly-owned subsidiaries; properties of 

interest where coordination and petmission has been granted in writing by the owner; and 

Valero Energy Partners LP in the United States. Hereinafter refered to as "Facilities." The 

sUAS will provide Valero and its wholly owned subsidiaries with high-resolution imagery 

within the secured confines of Valero's Facilities. Such sUAS operation will provide safety 

Valero Services, Inc .• 1000 Skyplace Blvd . • San Antonio, Texas 78216 • Telephone (2 10) 377- III I 
Valero Services, Inc. Petition for Section 333 Exemption 2 

enhancements in the facility, surrounding areas, and increase efficiency and reliability of 

Facilities inspections. The use of sUAS will reduce the risk of inspections by eliminating the 

need for human inspection by personnel on permanent and temporary elevated structures 

cunently being performed by rope access, scaffolding, bucket trucks, and ladders. SUAS 

operation will improve efficiency and reliability of inspections by allowing for higher quality 

inspections which serve the public interest by providing accelerated awareness of hazardous 

unexpected events that could impact Facilities personnel, the sunounding environments, and 

communities. 

The Reform Act gives the Secretary of Transportation the authority to detetmine if certain 

sUAS may operate safely in the national airspace system ("NAS") before completion of the 

FAA's plan and rulemaking to integrate sUAS into the NAS. The Act directs the Secretary to 

consider which types of sUAS as a result of their size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation within visual line of sight do not 

create a hazard to users of the national airspace or a threat to national security. If the 

Secretary determines that such vehicles may operate safely in the NAS, the Secretary "shall 

establish requirements for the safe operation of such aircraft." Valero's request for exemption 

falls within the Section 333 requirements. 

The granting of this exemption request will provide immediate benefit to Valero by 

authorizing highly controlled sUAS og_erations within a very restricted secured environment 

at Valero's owned and operated facilities. Failure to grant this exemption will cause 

unnecessary delay of an active program within Valero to develop methods and standards for 

sUAS operations. 

Valero is not an indirect service provider or contractor, but is a direct operator with an 

immediate need for the requested sUAS exemption. The scope of this request is nan·ow; it is 

limited to facilities owned and operated by Valero, Valero's wholly-owned subsidiaries, and 

Valero Energy Partners LP. The operation and inspection of Valero's Facilities will comply 

with all Federal, State, and Local regulations. This operation will not be for compensation or 

hire. 

Given the direction of Section 333 of the Reform Act, the strong equivalent level of safety 

sunounding the proposed operations, and the significant public interest benefits including the 

provision of more efficient and safer facility inspections, Valero respectfully requests that the 

FAA grant the requested exemption. 

The name and address of the applicant is: 

Valero Services, Inc. 

Attn: Richard J. Murphy 

Senior Manager Corporate Aviation Services 

I 000 Skyplace Blvd. 

San Antonio, TX 78216 

Fax:210-377-1146 

Phone: 210-345-5441 

Email: richard.murphy@valero.com 

Valero Services, Inc . • I 000 Sky place B I vd. • San Antonio, Texas 78216 • Telephone (2 1 0) 377- 1111 
Valero Services, Inc. Petition for Section 333 Exemption 3 

Valero Summary 

Valero Energy Corporation, through its subsidiaries, is an international manufacturer and 

marketer of transportation fuels, petrochemical products and power. Valero subsidiaries 

employ approximately 10,000 people, and assets include 15 petroleum refineries with a 

combined throughput capacity of approximately 2.9 million barrels per day, 11 ethanol plants 

with a combined production capacity of 1.3 billion gallons per year, and a 50-megawatt wind 

farm. More than 7,400 outlets cany the Valero, Diamond Shamrock, Shamrock and Beacon 

brands in the United States and the Caribbean; Ultramar in Canada; and Texaco in the United 

Kingdom and Ireland. Through subsidiaries, Valero owns the general pa1iner of Valero 

Energy Partners LP, a midstream master limited partnership. Valero is a Fortune 20 company 

based in San Antonio. 

Valero Aviation Experience and Prior Efforts 

1. Valero currently operates and has operational control of its own internal Corporate 

Flight Department which it has operated for more than thirty-nine years. Currently 

Valero operates three (3) Gulfstream 550 aircraft under 14 CFR Part 91 in the 

furtherance of its U.S. Operations. 

2. Valero directly em{>loyees nine (9) FAA c~rtificated Airline Transport Pilots and 

seven (7) FAA certificated Airframe and Powerplant Technicians in support of this 

operation. The current staff has over 45,000 accident free hours of flight experience 

and more than 150 years of technician experience. The Flight Depruiment has been 

monitoring the progress of commercial sUAS operations in the USA and 

Internationally. This proposed sUAS operation shall be directed by Valero's 

Corporate Flight Department and shall only be used for the benefit of Valero, 

Valero's wholly-owned subsidiaries, and Valero Energy Partners LP and its wholly 

owned subsidiaries. 

3. This request for exemption authority is a continuation of Valero's research and 

development efforts to employ sUAS for Facilities inspections. FAA's grant of this 

request is a necessary step in order to continue the vital work that Valero has done to 

date, which will assist in protecting the public, Valero employees and infrastructure. 

4. Valero has worked in close cooperation with Lone Star UAS Center of Excellence 

(LSUAS) and Texas A&M Engineering Extension Service (TEEX) to develop 

processes and procedures for the use of unmanned aircraft at Facilities. 

5. Valero understands that the FAA may be revising its views on private-public 

cooperation of this type, and this makes the granting of this exemption request even 

more important to achieving the safety and efficiency objectives that are being 

pursued to expand benefits to Facilities. Given the highly secured and regulated 

nature of Valero's Facilities, the limited risk posed by such operations, and the 

essential role Valero played in working with LSUAS and TEEX to develop standards 

and guidelines for the safe and effective use of sUAS, Valero is requesting this 

exemption be given full consideration by the FAA. 

6. Valero operates in a highly regulated environment. Valero has a robust regulatory 

Valero Services, Inc . • I 000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- II II 
Valero Services, Inc. Petition for Section 333 Exemption 4 

compliance culture and a keen understanding of the importance of extensive security, 

planning, documentation and control of operations in a chemical Facilities 

environment; and as such Valero has the unique capability of developing and 

exercising the necessary procedures for safe and effective operations of sUAS at such 

facilities. 

7. Valero's Facilities where flights would occur have restricted access and perimeter 

security. This includes a perimeter fence system, manned access gates, identification 

badges that must be displayed at all times on site, a site security force, and other 

measures to ensure that only authorized personnel are allowed within the site. Visitors 

are escmted at all times. With these measures, Valero is fully able to establish safe 

zones for flights, and to exclude from those safe zones anyone whose presence is not 

necessary for purposes of the flight. 

8. Valero maintains compliance with all laws and regulations that govern its operations. 

This includes security of Facilities as directed by the Depa1tment of Homeland 

Security. Valero has already studied and developed procedures for integrating sUAS 

operations in a manner that complies with those laws and regulations. This 333 

exemption request continues Valero's commitment of compliance in working with the 

FAA to serve the public interest, maintain the integrity of the NAS, and will not be a 

threat to national security. 

Valero Inspections by s U AS Serves the Public Interest 

1. SUAS inspection is safer than human inspection. Facilities inspection without sUAS 

requires qualified inspectors to be in close proximity to Facilities infrastructure and 

equipment, including flare stacks, elevated pipelines and power lines, tanks, and roofs 

within the secured confines of Valero's Facilities. Inspectors need to climb towers or 

otherwise perform elevated work, which exposes them to the risk of dangerous falls. 

In addition, proximity to the equipment involves a risk of exposure to hazardous 

chemicals or oxygen-deficient atmospheres, bums from steam or from hot equipment, 

and other mechanical hazards associated with industrial equipment. 

2. SUAS inspection is of higher quality, more reliable, and can be reviewed by Subject 

Matter Experts (SMEs). SUAS inspections allow for the collection, dissemination and 

storage of visual and other sensory data with greater precision and duration. 

3. SUAS inspection is more efficient and less costly. 

4. SUAS inspection is safer than traditional manned commercial aircraft. In cases where 

commercial helicopters are employed for Facilities inspection, a significant flight 

equipment malfunction can result in severe collateral damage to the Facilities and 

personnel. SUAS's are less likely to cause damage in the event of contact. 

Valero Services, Inc. • I 000 Skyplace B I vd. • San Antonio, Texas 78216 • Telephone (21 0) 377- Ill I 
Valero Services, Inc. Petition for Section 333 Exemption 5 

sUAS Descriptions 

1. Aeryon SkyRanger 

From the Internet site of the vendor: "The Aeryon SkyRanger is a small Unmanned 

Aerial System (sUAS) that sets the standard in aerial inspection. With an intuitive touch 

screen user interface and autonomous intelligence, SkyRanger enables you to be in 

control of a professional quality aerial inspection. The Aeryon SkyRanger provides 

reliable flight performance even in demanding weather conditions." 

Up to 50-minute flight time (with 

Endmance payload) 

Wind tolerance +40 mph 

Environmental temperature range -22- 122°F (-30- 50°C) 

Launch & recovery method Vertical Take-Off and Landing (VTOL) 

Deployed: 40 in. Diameter, 9.3 in. 

Dimensions Height 

Weight (without payload): 5.3 lbs 

Radio frequencies: 900 MHz, 2.4 GHz, 5.8 GHz 

2. AirRobot AR-180 

From the AR-180 operators manual and vendor website: ''The AR180 has extensive 

automated functions using AirRobot's proprietary and proven flight management system 

for stabilization and positioning. As a result, safe and intuitive operation can be achieved 

without overwhelming training requirements. Due to its high thrust to weight ratio (up to 

62% thrust over weight) it is very agile and stabile in high winds." 

"The AR180 is a derivation of AirRobot's proven system ARlOOB, which has been in 

service since 2006 and is deployed in great numbers with military forces, law 

enforcement agencies and first responders worldwide. The AR100 shares the flight 

management and sensor package, the command control and communication structure and 

the ground station with the AR180." 

"The ground control station is built into the hand controller with a whole new integrated 

on screen interface that is user friend! y and suits operational needs. Within the interface 

way points can be plotted and changed in-flight via touch, maps of locations can be 

downloaded and all data is shown on screen. Simply all the equipment the pilot will need 

for an operation is the hand controller,battery,payload and flight platform." 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- III I 
Valero Services, Inc. Petition for Section 333 Exemption 6 

Up to 42-minute flight time (with 

Endurance payload) 

Wind tolerance +40mph 

Environmental temperature range 10- 120°F (-12- 49°C) 

Vertical Take-Off and Landing 

Launch & recovery method (VTOL) 

Deployed: 75 in. Diameter, 18 in. 

Dimensions Height 

Weight (without payload): 6lbs 

Radio frequencies: 900 MHz, 2.4 GHz, 5.8 GHz 

3. DJI Phantom 2 Vision Plus 

From the operations manual and vendor website: "The Phantom 2 Vision + is the next 

evolution of the Phantom 2 Vision. It features the same App enabled First Person View 

(FPV), high performance camera, remote camera control and in-flight content sharing, 

but adds to it a high pe1formance 3-axial camera stabilization system. It's ideal for aerial 

creativity wheter photo or video. In addition, it provides ground station function which 

allows users to plan the flight mission and enables aircraft to flight automatically." 

Up to 25-minute flight time (with 

Endurance payload) 

Wind tolerance +40 mph 

Environmental temperature range 32- l04°F (0- 40°C) 

Vertical Take-Off and Landing 

Launch & recovery method (VTOL) 

Deployed: 13.7 in. Diameter, 10 in. 

Dimensions Height 

Weight (without payload): 2.8lbs 

Radio frequencies: 5.728- 5.85 GHz 

4. DJI Inspire 1 Version 2 

From the operations manual and vendor website: "The Inspire 1 is brand new quadcopter 

capable of capturing 4K video and transmitting an HD video signal (up to 2km) to 

multiple devices straight out of the box. Equipped with retractable landing gear, it can 

capture an unobstructed 360 degree view from its camera. The built-in camera has an 

integrated gimbal to maximize stability and weight efficiency while minimizing space. 

When no GPS signal is available, Vision Positioning technology provides hovering 

precision. " 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- Ill! 
Valero Services, Inc. Petition for Section 333 Exemption 

Up to 18-minute flight time (with 

Endurance payload) 

Wind tolerance 22mph 

Environmental temperature range 14- 104°F (-10- 40°C) 

Vertical Take-Off and Landing 

Launch & recovery method (VTOL) 

Deployed: 17.2 in. Diameter, 17.7 in. 

Dimensions Height 

Weight (without payload): 6.5 lbs 

Radio frequencies: 2.40 - 2.483; 5.728 -5.85 GHz 

Note: Aeryon Sky Ranger, Aii·Robot AR-180, DJI Phantom 2 Vision Plus, and DJI Inspire 

User Manuals are available upon request. 

7 

Valero Should be Authorized to Operate sUAS to Inspect its Facilities in the United 

States 

1. Valero proposes to directly operate sUAS by Valero employees only for the benefit of 

Valero, Valero's wholly-owned subsidiaries, and Valero Energy Partners LP and its 

wholly owned subsidiaries located in the United States. Valero shall not provide any 

----srTA servtces or compensat10n or ire. 

This Exemption Request Is for Use of sUAS Subject to Extensive Operational and 

Safety Requirements 

1. Safety 

a. The sUAS PIC shall possess at least a private pilot certificate and at least a cunent 

third-class medical certificate. 

1. The PIC shall also meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on their pilot certificate. 

11. The PIC shall be trained in the operation of the specific Make and Model of the 

sUAS being piloted. 

iii. The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

§ 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a s U AS 

pilot. Prior documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement. 

iv. The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

§ 61.51 (b), a minimum of five hours as sUAS pilot operating the make and 

model of sUAS to be utilized for operations under the exemption and three takeoffs and three landings in the preceding 90 days. 

v. Training, proficiency, and experience-building flights can also be conducted 

under this grant of exemption to accomplish the required flight cycles and flight 

time. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (21 0) 377- Ill L 
Valero Services, Inc. Petition for Section 333 Exemption 8 

1. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered non-participants, and the P IC 

must operate the sUAS with appropriate distance from non-participants m 

accordance with 14 CFR § 9 L.ll9. 

b. The PIC and Visual Observer (VO) will be designated before each flight 

i. Minimum crew for each operation will consist of the sUAS PIC and the VO. 

c. The PIC and VO will always be within visual line of sight (VLOS) of each other and 

in direct verbal communication at all times. 

d. Safety Briefings will be conducted before each day's activities to include, but not 

limited to: 

1. Designated roles of PIC and VO 

u. Risk Management and Mitigation 

iii. Prior to the sUAS flight(s), a team comprised of the PIC and YO will visually 

inspect the flight path and surrounding area and equipment to identify potential 

concerns. sUAS safety checklists will be completed by the review team to ensure 

all areas of concern have been identified and addressed. A flight will NOT be 

conducted if a concern cannot be resolved. 

2. sUAS Specifications and Design: 

a. All sUAS flown under this exemption shall be less than 55 pounds including aircraft 

and payload. This exemption requests permission with respect to the specific use of 

the Aeryon SkyRanger, AirRobot AR-180, DJI Phantom 2 Plus, and DJI Inspire 

which all weigh less than 15 pounds including payload. 

b. The radio frequency spectrum used for operation and control of the sUAS shall 

comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

c. Maximum speed shall be no more than 50 knots. 

d. The sUAS shall be equipped with Inertial Navigation Sensor(s) 

(IRS/IR U/ Accelerometer). 

e. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source). 

f. The sUAS shall be equipped with a Global Positioning System (GPS) guidance 

system. 

g. The sUAS shall be designed, should it lose communications or lose its GPS signal, to 

return to a pre-determined location within the security perimeter and land or be 

Valero Services, Inc .• 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (2 10) 377- II II 
Valero Services, Inc. Petition for Section 333 Exemption 

recovered in accordance with Valero's sUAS Operations Manual. 

3. Maintenance 

9 

a. Maintenance will be performed by Valero employees or the OEM in accordance with 

the OEM recommended maintenance practices. 

b. Valero shall follow the manufacturer's sUAS maintenance, overhaul, replacement, 

inspection, and life limit requirements to include but not limited to: 

1. Airframe 

ii. Powerplant(s) (motors) 

iii. Propellers 

iv. Flight Controller 

v. Actuators I Servos 

vi. Electronic speed controller(s) 

vii. Batteries 

vtu. Radio Transmitters 

ix. Radio Receivers; and 

x. Ground control station 

c. Valero shall comply with all manufacturer Safety Bulletins or equivalent pertaining to 

their sUAS. 

d. Valero will document and maintain a record of the sUAS maintenance, preventative 

maintenance, alterations, status of replacement/overhaul component parts, and the 

total time in service of the sUAS. 

e. Maintenance or repairs that may affect the sUAS operation or flight characteristics 

shall undergo a test flight in accordance with Valero's sUAS Operations Manual. 

This test flight shall be recorded in the sUAS's maintenance records. 

f. The PIC shall perform a preflight inspection of the sUAS, controller, and ground 

control station prior to each flight to ensure it is operational with no safety of flight 

discrepancies. If the preflight inspection has any discrepancies that may affect a safe 

operation, repairs or maintenance shall be performed prior to flight. The sUAS will 

only be operated if it is free of all discrepancies that affect safety of flight. 

h. All sUAS shall be registered in accordance with 14 CFR part 47, and have identification 

(N-Number) markings in accordance with 14 CFR part 45, Subprut C, except with respect 

to the size of the markings. Markings shall be as large as practicable. 

4. Permitting and Notifications 

a. All required pennissions and permits shall be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, or other appropriate 

governmental agencies. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (2 1 0) 377- II II 
Valero Services, Inc. Petition for Section 333 Exemption 10 

b. Valero shall request a Notice to Ainnan (NOTAM) not more than 72 homs in advance, 

but not less than 48 hours prior to the operation. The NOTAM request may include a 

written Plan of Activities to the local flight standards district office (FSDO) with 

jurisdiction over the area of the proposed flight. The written Plan of Activities may be 

waived with the concurr-ence of the FSDO. 

1. The plan of activities shall include at least the following: 

1. Dates and times for all requested flights 

2. Name and phone number of Valero sUAS Flight Operations 

3. Name and phone number of the PIC responsible for the on-scene operation of 

the sUAS 

4. Make, model, and N-number of sUAS to be used 

5. Name and certificate number of sUAS PICs involved in the flight 

6. A statement from Valero that it will be operating on its own propetty where 

the flight will be conducted; the list of those who gave permission shall be 

made available to the inspector upon request. 

7. Signature of exemption-holder or representative 

8. A description of the flight activity, including maps or diagrams of any area 

over which flights will be conducted, the relationship of that area to any 

near y city, town, etc., an t e a tifUcles essential to accomp ish t e operation. 

9. Documents required under 14 CFR § 91.9 and§ 91.203 shall be readily 

available to the PIC any time the aircraft is in operation. These documents 

shall be made available to the Administrator or any law enforcement official 

upon request. 

10. Valero shall obtain an Air Traffic Organization (A TO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this 

exemption request. 

11. Valero shall obtain the consent of all persons involved in the operation and ensure 

that only consenting persons be allowed within 200 feet of the "Safe Zone". 

5. Operations 

a. The sUAS shall not operate in Class B, C, or D airspace without written approval 

from the FAA. The sUAS shall not operate within 5 nautical miles of the geographic 

center of a non-towered airport as denoted on a cunent FAA-published aeronautical 

chart unless a letter of agreement with that airport's management is obtained, and the 

operation is conducted in accordance with a NOTAM as required by the operator's 

COA. This letter of agreement with the airport management shall be made available 

to the Administrator upon request. 

b. The sUAS will only operate within the lateral boundaries of Facilities. Confined 

"Safe Zones" within those boundaries will be established for each flight. These zones 

will be free of unnecessary hazards or risks and non-participating personnel. 

1. The sUAS shall only operate within a pre-defined "Safe Zone" that shall be 

thoroughly inspected by the PIC for buildings, overhangs, obstacles, wires, poles, 

people, vehicles, sun angle, shadows, glare, reflective smfaces, clouds, smoke, 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- 1111 
Valero Services, Inc. Petition for Section 333 Exemption II 

and tenain among other potential hazards. 

11. The PIC and VO shall have cutrent Valero specific safety training for the area in 

which sUAS operations will take place. 

c. Flights shall be conducted under day visual meteorological conditions (VMC). 

1. In addition, the sUAS shall not be operated less than 500 feet below or less than 

2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC. 

11. sUAS operations shall not be conducted during night, as deftned in 14 CFR § 1.1. 

iii. Flights shall not be conducted under special visual flight ru les (SVFR). 

d. Flights shall be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedmes specified in Valero's sUAS Operations 

Manual. 

e. The PIC shall be prohibited from operating the sUAS from any moving device or 

vehicle. 

f. The sUAS shall be operated within visual line of sight (VLOS) of the PIC. 

1. The PIC shall maintain VLOS without the aid of telescopes, cameras or other devices. 

n. The PIC will maintain VLOS with their own vision, which includes the use of 

eyeglasses or conective lenses as specified on the PIC's medical certificate. 

g. The sUAS shall remain clear and yield the right of way to manned aerial operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.). 

b. Valero will require the PIC and Visual Observer (VO) to have successfully completed a 

qualification process, as outlined in the Valero sUAS Operations Manual. 

1. The PIC's primary responsibility while in flight is the safe operation of the sUAS. 

6. Flight Time 

a. Each sUAS operation shall be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first. 

Valero Services, (nc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- II II 
Valero Services, Inc. Petition for Section 333 Exemption 

Richard J. Murphy 

Senior Manager Corporate Aviation Services 

Valero Services, Inc. 

1000 Skyplace Blvd. 

San Antonio, TX 78216 

Fax: 210-377-1146 

Phone:210-345-5441 

Email: richard.murphy@valero.com 

References available upon request: 

Aeryon SkyRanger Manufacturers User Guide 

AirRobot AR-180 Manufacturers User Guide 

DJI Phantom 2 Plus Manufactmers User Guide 

Included: 

Exhibit A- Regulation for which exemptions are requested 

Exhibit B -Valero sUAS Operations Manual 

12 

Valero Services, Inc. • I 000 Skyplace B I vd . • San Antonio, Texas 78216 • Telephone (2 1 0) 377- II I I 
Valero Services, Inc. Petition for Section 333 Exemption 13 

Exhibit A 

Regulations for Which Exemptions are Requested 

1. Unless otherwise requesting an exemption, Valero, the PIC, the VO, and the sUAS shall 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 

6 1, and 91. 

2. Valero is requesting exemptions from the following Federal Aviation Regulations to 

the extent necessary to enable the requested sUAS operations for the reasons 

detailed below. 

Relief sought by Valero (14 CFR) Valero Reasoning 

Part 21 Stated Below 

6l.ll3(a) and (b) Stated Below 

9 1. 103 Stated Below 

9l.l l9(c) Stated Below 

91. 121 Stated Below 

9l.1 5l(a)(l) Stated Below 

9l.405(a) - Stated ow - -

91.407(a)(J) Stated Below 

91.409( a)(l) and (2) Stated Below 

9 1.417(a) and (b) Stated Below 

14 CFR Part 21- Requirements to Secure Airworthiness Certificates 

I. Ce1tificate exemptions should be given because size, weight, and operation areas of 

the sUAS meet the level of safety necessary for exemption under Section 333 of the 

Reform Act. 

2. FAA has the authority to exempt aircraft from airworthiness certificate requirements 

under the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. 

14 CFR § 61.113 (a) and (b)- Private Pilot Privileges and Limitations; Pilot in 

Command 

1. Due to the fact that there are no standards for private or commercial sUAS operations, 

Valero requests to utilize at least private pilots with third class medicals in support of 

its own operations on its own property. 

2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), 

along with the ability to physicall y manipulate the controls of the sUAS are the 

critical aspects of the requested operation. Valero feels this can be accomplished with 

a private pilot that has specific training on the sUAS operated in accordance with the 

Valero sUAS Operations Manual, and has satisfactorily completed the required 

training. 

Valero Services, Inc. • l 000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (2 1 0) 377- l Ill 
Valero Services, Inc. Petition for Section 333 Exemption 14 

3. The risks associated with the operation of the sUAS are so diminished from the level of 

risk associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the 

present level of safety achieved by 14 C.P.R. §61.113 (a) & (b). 

4. Equivalent or better safety levels can be achieved as there will be no human beings 

on board the sUAS and the sUAS will be operated to mitigate risks on the air and on 

the ground. 

5. FAA has authority to waive pilot requirements for commercial operations under 49 

U.S.C §4470l(f). 

14 CFR § 91.103- Preflight Action 

1. The PIC shall perform a preflight inspection of the sUAS system in accordance with 

the manufacturers recommendations and Valero sUAS Operations Manual prior to 

each flight to ensure it is free of safety of flight discrepancies. 

2. Equivalent safety levels will be met through preparation and compliance according to 

Valero's sUAS Operations Manual; including but not limited to, weather repo11s and 

forecasts, battery requit·ements, alternatives avatlable ihhe planned flighr-cammt be 

completed, and other reliable information appropriate to the aircraft relating to 

aircraft performance under expected site conditions; landing and touchdown zone 

slope; aircraft gross weight; wind; and temperature. 

14 CFR 91.119(c) - Requirements for Minimum Safe Altitudes for Civil Aircraft 

Operation 

1. The sUAS will be operated only within Facilities below 400 feet AGL. 

2. Valero shall obtain the consent of all persons involved in the operation and ensure 

that only consenting persons be allowed within 200 feet of the "Safe Zone." 

3. The sUAS will only operate within the lateral boundaries of Facilities. Confined 

"Safe Zones" within those boundaries will be established for each flight. These zones 

will be free of unnecessary hazards or risks and non-participating personnel. 

4. Given the size, weight, speed, material, and operation of the sUAS, equivalent levels 

of safety will be achieved. 

14 CFR 91.121- Altimeter Settings 

1. sUAS may not have a barometric altimeter, and may use a GPS altitude read out 

indication instead, so an exemption may be needed. 

2. An equivalent level of safety will be achieved by the operator as the sUAS uses AGL 

height from its initialization (launch) point, cross-referenced with Mean Sea Level (MSL) 

altitude of the launch point. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- I J II 
Valero Services, Inc. Petition for Section 333 Exemption 15 

CFR 91.151 (a)(1) - Fuel Requirements for Flights in VFR Conditions 

I. As the sUAS are capable of a maximum of 50 minutes flight time, an exemption will be 

necessary. 

2. As the sUAS are flown within Facilities below 400 feet AGL under controlled conditions 

as defined by the Valero sUAS Operations Manual, we feel an equivalent level of safety 

can be obtained by terminating the flight prior to 25% battery power remaining. 

3. Valero feels an adequate reserve is provided at 25% battery power which will allow for 

sufficient time to land the aircraft safely within a "Safe Zone." 

4. The Aeryon SkyRanger, Aii·Robot AR-180, DJI Phantom Vision Plus, and DJI 

Inspire 1 Version 2 have a second level of safety that is achieved through the use of 

an aircraft battery monitoring system. The aircraft system will alert the operator of 

low battery voltage and retum the aircraft to its take off location before battery 

capacity is depleted. 

5. Valero will not conduct sUAS operations at night. 

6. Similar exemptions nave been granted to other operation , including .E:xemptions 

2689F, 5745, 10673, and 10808. Given the small size and operational purposes of the 

sUAS, it does not bear the same risks associated with this section's requirements. 

7. FAA has previously issued exemptions for fuel requirements in VFR conditions; 

exemption numbers 10808, 2689F, 5745, & 10673. 

14 CFR 91.405 (a) Maintenance Required 

1. This section and Part 43 apply only to aircraft with an airwmthiness certificate, 

therefore these sections will not apply. 

2. Maintenance will be accomplished by Valero pursuant to the manufacturer's 

recommendations and Valero's sUAS Operations Manual. 

3. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained Valero personnel or the OEM. 

4. The sUAS shall be free of safety of flight discrepancies prior to initiating any flight. 

5. If a mechanical issue arises the sUAS can land safely within the "Safe Zone." 

6. Valero shall be the most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

7. The Valero sUAS Operations Manual details how to log scheduled and unscheduled 

maintenance or test flights that are performed. 

8. An equivalent level of safety will be achieved because these sUAS are limited in 

size and will and shall fly only above Facilities below 400 feet AGL. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- I I I I 
Valero Services, Inc. Petition for Section 333 Exemption 16 

14 CFR 407 (a) (1) - Operation After Maintenance, Preventive Maintenance, 

Rebuilding, or Alteration 

1. This section and Part 43 apply only to aircraft with an airworthiness certificate, therefore 

these sections will not apply. In the absence of regulatory provisions dealing with sUAS 

operation after maintenance, preventive maintenance rebuilding or alteration, Valero has 

developed requirements to address this topic. Those requirements are stated in Valero's 

sUAS Operations Manual. 

2. Maintenance will be accomplished by Valero pursuant to the manufacturer's 

recommendations and Valero's sUAS Operations Manual. 

3. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained Valero personnel or the OEM. 

4. The sUAS shall be free of safety of flight discrepancies prior to initiating any flight. 

5. If a mechanical issue arises the sUAS can land safely within the "Safe Zone." 

6. Valero shall be the most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

7. The Valero sUAS Operations Manual details how to log scheduled and unscheduled 

maintenance or test flights that are performed. 

8. An equivalent level of safety will be achieved because these sUAS are limited in size 

and will and shall fly only above Facilities below 400 feet AGL. 

14 FR 409 (a) (1) and (2) - Inspections. 

1. This section and Part 43 apply only to aircraft with an airworthiness certificate, 

therefore these sections will not apply. In the absence of regulatory provisions dealing 

with sUAS inspections, Valero has developed requirements to address this topic. 

Those requirements are stated in Valero's sUAS Operations Manual. 

2. Maintenance will be accomplished by Valero pursuant to the manufacturer's 

recommendations and Valero's sUAS Operations Manual. 

3. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained Valero personnel or the OEM. 

4. The sUAS shall be free of safety of flight discrepancies prior to initiating any flight. 

5. If a mechanical issue arises the sUAS can land safely within the "Safe Zone." 

6. Valero shall be the most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- 1111 
Valero Services, Inc. Petition for Section 333 Exemption 17 

7. The Valero sUAS Operations Manual details how to log scheduled and unscheduled 

maintenance or test flights that are performed. 

8. An equivalent level of safety will be achieved because these sUAS are limited in size 

and will and shall fly only above Facilities below 400 feet AGL. 

14 CFR 417(a) and (b)- Maintenance Records. 

1. This section and Part 43 apply only to aircraft with an airworthiness certificate, 

therefore these sections will not apply. In the absence of regulatory provisions dealing 

with sUAS inspections, Valero has developed requirements to address this topic. 

Those requirements are stated in Valero's sUAS Operations Manual. 

2. Maintenance will be accomplished by Valero pursuant to the manufacturer's 

recommendations and Valero's sUAS Operations Manual. 

3. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained Valero personnel or the OEM. 

4. The sUAS shall be free of safety of flight discrepancies prior to initiating any flight. 

5. If a mechanical issue arises the sUAS can land safely within the "Safe Zone." 

6. Valero shall be the most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

7. The Valero sUAS Operations Manual details how to log scheduled and unscheduled 

maintenance or test flights that are performed. 

8. An equivalent level of safety will be achieved because these sUAS are limited in size 

and will and shall fly only above Facilities below 400 feet AGL. 

§91.417 Maintenance Records. 

1. This section and Part 43 apply only to aircraft with an airworthiness certificate, 

therefore these sections will not apply. In the absence of regulatory provisions dealing 

with sUAS inspections, Valero has developed requirements to address this topic. 

Those requirements are stated in Valero's sUAS Operations Manual. 

2. Maintenance will be accomplished by Valero pursuant to the manufacturer's 

recommendations and Valero's sUAS Operations Manual. 

3. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained Valero personnel or the OEM. 

4. The sUAS shall be free of safety of flight discrepancies prior to initiating any flight. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- II II 
Valero Services, Inc. Petition for Section 333 Exemption 18 

5. If a mechanical issue arises the sUAS can land safely within the "Safe Zone." 

6. Valero shall be the most familiar with the aircraft and best suited to maintain the 

aircraft in an airw01thy condition to provide the equivalent level of safety. 

7. The Valero sUAS Operations Manual details how to log scheduled and unscheduled 

maintenance or test flights that are performed. 

8. An equivalent level of safety will be achieved because these sUAS are limited in size 

and will and shall fly only above Facilities below 400 feet AGL. 

Other Regulatory Provisions. 

Valero has noticed that other petitions have requested exemption from a wide variety of 

additional regulations, as to which the FAA has concluded that the request was not needed. 

In light of this, Valero has refrained from requesting exemption from provisions that we 

believe the Agency will say simply do not apply. Examples include: 

• Requirements for lights. (Valero's sUAS flights will occur only in daylight.) 

• Requirements for safety belts, shoulder harnesses and child restraint systems. 

• Requirements relating to emergency exits. 

• Requirements relating to safety instructions for passengers. 

• Requirements for dual controls. 

• Requirements to place markings in several locations on the aircraft. 

• Requirements for the flight manual to be on board the aircraft. 

• Requirements for the aircraft to physically "carry" and "display" documents showing 

certification and registration. 

If Valero has judged incorrectly and the FAA believes that exemption from additional 

regulations is necessary for Valero's proposed sUAS operations, Valero will modify this 

application in response to feedback from the Agency. 

Additionally, there are a number of regulatory provisions that will not apply to Valero's 

proposed sUAS operations, but Valero is not requesting exemption. This is because, if the 

regulations ever did apply (which Valero believes will never happen), Valero will comply 

with these provisions. Examples include: 

• Requirements relating to flights over the Atlantic Ocean. 

• Requirements relating to flights over Cuba. 

Valero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- 1111 
Valero Services, Inc. Petition for Section 333 Exemption 19 

• Requirements relating to flights in restricted airspace, such as that associated with 

military facilities. 

If the FAA feels that Valero should mention such regulations more specifically m this 

application, we will do so. 

Valero Services, Inc. • I 000 Skyplace Blvd. • San Antonio, Texas 78216 • Te lephone (210) 377- Jill