BY HAND 

U.S. Department of Transportation 

Docket Management Facility 

West Building Ground Floor 

CONFIDENTIAL TREATMENT 

REQUESTED FOR EXHIBITS 

Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. FAA-2014-0638 

Supplement No. 1 to Petition of 

Oceaneering International, Inc. for Exemption 

In accordance with the Federal Aviation Administration's ("FAA") Supplemental Guidance on the 

Submission of Petitions under Section 333 of the FAA Modernization and Reform Act of 2012 

("Supplemental Guidance"), Oceaneering International, Inc. ("01") hereby supplements the petition 

which it filed on August 26, 2014 requesting an exemption authorizing it to engage in commercial 

operations with the Wookong DJI S800 and Aeronavics X4 Titanium unmanned aerial systems ("UAS"). 

01 provides the following information in further support of its pending exemption petition. 

Exemption Request- Supplemental Guidance 

In addition to the FAA regulations from which 01 requested an exemption in its original petition, 

01 also requests an exemption from the following regulations, in accordance with the Supplemental 

Guidance. 

1. 14 C.F.R. § 103(b)(2)- Preflight Action 

This regulation requires a pilot in command, before beginning a flight, to become familiar with 

information regarding runway lengths at airports of intended use, including takeoff and landing distance 

information and other performance information appropriate to a particular aircraft model under 

expected elevation and prevailing wind and temperature conditions. 

Equivalent level of safety analysis: Prior to initiating any flight involving commercial UAS operations, 

Ol's pilot in command will complete an extensive pre-flight checklist that includes a detailed inspection 

of the aircraft to be used for a specific operation. The checklist is included as Attachment A toOl's 

exemption petition. Attached as Exhibit A to this supplemental submission is Ol's RAV Flight Process 

Zuckert, Scoutt & Rasenberger, L.L.P. 
p

y 

y 

g 

g 

personnel and 01 safety representatives, as well as a risk analysis that identifies potential obstacles and 

prevailing weather conditions. All flights will be conducted during daylight hours, in accordance with 

Class G airspace visibility requirements with wind speeds measured at 25 knots or less. 

01 has previously stated in its exemption petition that it will not conduct UAS operations in close 

proximity to any airports. Prior to conducting operations within three miles of an airport runway, 01 will 

contact the airport tower and the airport operator. 01 will not operate UAS aircraft within five nautical 

miles of the geographic center of a non-towered airport without notice and approval from the FAA. 

2. 14 C.F.R. §91.105- Flight Crewmembers at Stations 

Under this regulation, crewmembers are required to be at assigned duty stations during takeoff 

and landing and while en route, with seat belts fastened. 

Equivalent level of safety analysis: Ol's operations manual requires a minimum three-person crew for 

commercial UAS flights, including a pilot-in-command, a visual observer and an on-site technician. The 

pilot-in-command and the visual observer must be able to communicate verbally at all times. The pilotin-command must remain with the control station at all times during a UAS flight. Both the pilot-incommand and the visual observer must maintain visual contact with the UAS aircraft during all phases of 

a commercial operation. Neither the pilot-in-command nor the visual observer will wear a seat belt or 

shoulder harness while conducting UAS operations, as this would impede their ability to perform 

required duties. FAR 91.105(b}(2) creates an exception to the requirement for crewmembers to wear 

seat belts or shoulder harnesses when doing so would interfere with a crewmember's performance of 

required duties. 

Exemption Request- Public Guidance 

In addition to the Supplemental Guidance regarding exemption petitions for commercial UAS 

operations, the FAA also has issued Public Guidance for Petitions for Exemption Filed under Section 333 

("Public Guidance"). 01 provides the following supplemental information to demonstrate_the 

conformance of its proposed UAS operating procedures with the FAA's Public Guidance. 

Regarding the Unmanned Aircraft System 

The FAA's Public Guidance requested the following information regarding the UAS that a 

petitioner plans to operate for commercial UAS operations: 

1. Petitioners should describe how the proposed UAS operation will be safely 

conducted to minimize risk to the NAS or to persons and property on the ground. 

Specifically, petitioners should describe the design and operational characteristics 

for the types of UAS they intend to operate, e.g., aircraft performance and 
p

p

p

Flight Manual or similar document. 

2. Petitioners should describe any procedures they would implement, such as preflight inspections, maintenance, and repair, to ensure that the UAS is in a condition 

for safe flight. This could be provided in the petition, an Aircraft Flight Manual, a 

Maintenance and Inspection Manual, or similar document. 

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control 

of the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, 

etc.) and whether it complies with Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

01 Supplemental Information: In addition to the information addressing the above points previously 

provided by 01 in its original exemption petition and the attached operating manuals, 01 provides the 

following supplemental information: 

• Both of the UAS aircraft which 01 intends to use for commercial operations are small 

UAS weighing less than 55 pounds, including the energy source and related equipment 

• Prior to each commercial operation, Ol's pilot-in-command will complete a pre-flight 

checklist that will include a thorough examination of the condition of the UAS aircraft 

• Ol's operating manual requires that any discrepancies noticed in the condition of the 

UAS aircraft during the pre-flight inspection be documented in the aircraft records 

• All inspections and maintenance events conducted by 01 will be the subject of written 

aircraft records that 01 will maintain for a minimum ofthree years 

• Any UAS that has undergone maintenance or alterations since its last flight that affect 

the UAS's operation or flight characteristics will undergo a functional flight test before 

any subsequent commercial operations, which will be the subject of an entry in the 

aircraft records 

• The requirements and procedures for a functional flight test and aircraft entry record 

have been added toOl's UAS operating manual 

• 01 will maintain the DJI 5800 and the Aeronavics X4 in accordance with the manuals and 

handbooks provided by the respective manufacturers 
• Ol's exemption petition states that all pre- or post-flight maintenance, alterations, 

equipment failures, charge/cycle logs, fault/repair logs, inspections and general 

maintenance will be documented in aircraft records that will be kept on file for a 

minimum of 3 years 

• 01 will log the number of hours that a UAV is in service to ensure proper monitoring of 

total time in service and service life of components and power packs 

• The radio frequencies which 01 uses for commercial operations with the DJI S800 and 

the Aeronavics X4 has been approved by the FCC. The ground control radio link uses 2.4 

GHz Spread Spectrum on the ISM band, the video downlink is 5.8 GHz on the ISM band, 

and the telemetry downlink is 900MHz on the ISM band. 

Regarding the Unmanned Aircraft PIC 

The FAA's Public Guidance requested the following information regarding the pilot-in-command 

that will conduct commercial operations with Ol's UAS aircraft: 

1. Petitioners should describe the qualifications of any PIC(s) who will be directly 

responsible for the operation of the UAS, including information such as: the level of 

airman certificate held; any applicable training related to the operation; and any 

minimum hours of flight experience required by the PIC(sL both total flight time and 

time with the particular UAS. If the operation would use visual observers, 

petitioners should describe their roles and qualifications. 

2. Petitioners should describe the medical standards and certifications ofthe PIC(s) 

directly responsible for the operation of the UAS. 

01 Supplemental Information: In addition to the information addressing the above points previously 

provided by 01 in its original exemption petition and the attached operating manuals, 01 provides the 

following supplemental information: 

• Any PIC conducting commercial operations with Ol's UAS aircraft will possess at least a 

private pilot certificate and a third-class medical certificate 

• Ol's PIC will also meet the flight review requirements for the specific UAS aircraft model 

for which the PIC is rated on his or her pilot certificate 

• Ol's PIC must have accumulated a minimum of 200 flight cycles {landings and takeoffs) 

and 25 hours of total flight time as a UAS rotorcraft pilot and must have logged at least 
p

• Ol's PIC must have accumulated a minimum of 5 hours as a pilot of the make and model 

UAS aircraft to be used for commercial operations and must have performed three 

takeoffs and landings with the same make and model UAS aircraft within the preceding 

90 days 

• Prior to conducting any commercial operations, the PIC and the Visual Observer ("VO") 

required for Ol's commercial UAS operations must have successfully completed a 

qualification process outlined in Ol's RAV Personnel Competency Program 

• A record of completion by each PIC and VO of Ol's qualification process must be 

documented and maintained by 01 

• Prior to conducting any commercial UAS operations, Ol's PIC must complete a flight 

demonstration with the UAS aircraft in accordance with procedures specified in Ol's 

flight operations manual 

• Successful completion ofthe flight demonstration will be documented by 01 

• Ol's operating manual requires that VOs and UAS technicians involved in Ol's 

commercial UAS operations must complete a minimum of 25 hours of flight time with 

UAS aircraft. 

Regarding the Operation of the Unmanned Aircraft 

The FAA's Public Guidance requested the following information regarding commercial 

operations with Ol's UAS aircraft: 

1. Petitioners should fully describe their intended UAS operation(s). Petitioners should 

describe how the proposed operation(s) would not adversely affect safety, or how 

they would provide a level of safety at least equivalent to that provided by the rule 

from which exemption is sought. Petitioners should address any plans to implement 

clearly defined operational borders and procedures to ensure public safety, which 

includes persons and property both in the air and on the ground. This can be 

described in the petition, in an Operations Manual, or similar document. 

2. Petitioners should specify the proposed maximum operating speed and altitude, 

and describe minimum flight visibility and distance from clouds for their intended 

operation(s). Petitioners should describe the potential hazards and safety 
addressed in t

e pet

t

o

, a

Ope

at

o

s 

a

ua

, o

s

a

docu

e

t

3. Petitioners should describe the characteristics of the area of intended operation(s) 

and the associated potential hazards, in accordance with the statutory mandate 

under Section 333 regarding proximity to populated areas. These issues can be 

addressed in the petition, an Operations Manual, or similar document. 

4. Petitioners should describe if they intend to operate in the proximity of any airports, 

in accordance with the statutory mandate under Section 333 regarding proximity to 

airports. 

5. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the 

statutory mandate under Section 333(b)(1). Petitioners should describe how they 

intend to comply with this mandate. 

6. Petitioners should describe any procedures they would implement for conducting a 

preflight safety risk assessment to determine that the UAS is in a condition for safe 

flight (14 C.F.R. § 91.7(b)) and that the planned operation can be completed safely. 

These procedures can be addressed in the petition, an Aircraft Flight Manual, 

Operations Manual, or similar document. 

7. If petitioners intend to conduct operations which have existing requirements to 

notify Flight Standards District Offices (FSDOs) prior to operation- such as motion 

picture and television filming, or pipeline and powerline patrol- petitioners should 

describe their intended coordination in this regard for their proposed operation(s). 

8. The FAA intends to require entities who obtain an exemption under this process to 

also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic 

Organization prior to conducting operation(s) in the NAS. 

01 Supplemental Information: In addition to the information addressing the above points previously 

provided by 01 in its original exemption petition and the attached operating manuals, 01 provides the 

following supplemental information: 

• Ol's UAS aircraft will not be flown at a ground speed exceeding SO knots when 

conducting commercial operations 

• Ol's exemption petition states that all UAS commercial flights will be conducted in Class 

G airspace at or below 400 feet above ground level 
flights 

• Ol's operations manual requires that all commercial UAS operations be conducted with 

a three-person crew including a Visual Observer (VO) 

• The PIC and VO will be able to communicate verbally at all times 

• Ol's RAV Flight Operations Procedure for Simultaneous Operations states that UAS 

aircraft may not be operated directly overhead 01 or customer personnel and are not to 

be operated at any more than a 30-degree angle above any person 

• 01' s RAV Flight Operations Procedure for Simultaneous Operations provides for a 

minimum separation of 500 feet between an 01 UAS and any non-participating persons, 

which may be reduced to a separation of 200 feet with the FAA's prior approval 

• 01'5 RAV Flight Operations Procedure for Simultaneous Operations provides that if a UAS 

loses its communications or GPS signal, it must be programmed to return to a location 

within the security perimeter established for that operation in order to be recovered in 

accordance with Ol's operating procedures 

• Ol's operating manual requires that a UAS must abort its flight in the event of 

unplanned obstacles or emergencies, including a loss of power 

• Ol's exemption petition states that Ol's UAS aircraft have a maximum operating time of 

20 minutes 

• Ol's RAV Flight Operations Procedure for Simultaneous Operations requires 01 to obtain 

a Certificate of Waiver or Authorization issued by an FAA Air Traffic Organization prior to 

conducting any operations in the NAS 

• 01 will request a Notice to Airmen not more than 72 hours in advance of, but not less 

than 48 hours prior to, a commercial UAS operation 

• Ol's UAS aircraft conducting commercial operations will be identified by serial number, 

will be registered with the FAA, and will display N-number markings in accordance with 

FAA regulations, as modified as requested in Ol's exemption petition due to the small 

size of Ol's UAS aircraft 

• The registration certificate for the UAS aircraft will be available to the PIC at the ground 

control station at all times during any commercial UAS operations 
 Ol

s operating manual requires that each commercial UAS operation will be the subject 

of a written Plan of Activities filed with the local FSDO at least three days prior to the 

planned UAS operation 

• Ol's exemption petition states that commercial UAS operations will be conducted during 

daylight hours only 

• Ol's exemption petition includes a restriction on commercial UAS operations to Class G 

airspace visibility requirements 

• Ol's exemption petition states that all required manuals for its UAS aircraft will be 

downloaded on the PIC's computer an accessible at all times during any commercial UAS operations 

• Ol's UAS aircraft conducting commercial operations will yield the right of way to all 

manned aircraft operations at all times 

• 01 will not conduct commercial UAS operations from any moving vehicle 

• 01 UAS aircraft conducting commercial operations will 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 

• 01 will not conduct commercial UAS operations in Class B, CorD airspace 

• 01 will not conduct commercial UAS operations within 5 nautical miles of the geographic 

center of a non-towered airport 

• 01 will report to the FAA's UAS Integration Office within 24 hours any incident, accident 

or flight operations that transgress the lateral or vertical boundaries of the operational 

area defined in the COA applicable to a commercial UAS operation 

• 01 agrees to amend its UAS operating manual to include any additional requirements 

identified in the conditions or limitations imposed by the FAA in connection with the 

approval of Ol's exemption request. 
location of the corresponding equivalent level of safety analysis in this supplemental submission and in 

the exemption petition previously filed with the FAA. 

Regulation from which exemption 

is requested Equivalent level of safety analysis 

14 CFR Part 21, Subpart H-Airworthiness Exemption Petition, pp 7-8 

Certificates 

14 CFR Part 61- Pilot Certification Exemption Petition, pp. 8-9; Supplement, pp. 

4-5 

14 CFR § 91.103(b)(2)- Preflight action Supplement, pp. 1-2 

14 CFR § 91.105- Flight crewmembers at station Supplement, p. 2 

14 CFR § 91.109- Flight instruction Exemption petition, p. 10 

14 CFR § 91.119- Minimum safe altitudes Exemption petition, p. 11 

14 CFR § 91.121- Altimeter settings Exemption petition, p. 11 

14 CFR § 91.151- Fuel requirements for flights in Exemption petition, pp. 11-12, Supplement, 

VFR conditions p. 7 

14 CFR § 91.405- Maintenance required Exemption petition, pp. 12-13 

14 CFR § 91.407- Operation after maintenance Exemption petition, pp. 12-13, Supplement, 

pp. 3-4 

14 CFR § 91.409- Inspections Exemption petition, pp. 12-13, Supplement, 

pp. 3-4 

14 CFR § 91.417- Maintenance records Exemption petition, pp. 12-13, Supplement, 

pp. 3-4 

In support of its exemption request, 01 is also submitting revised and updated manuals attached 

to this supplemental submission as follows: 

Exhibit A: 

Exhibit B: Exhibit C: Exhibit D: 

Exhibit E: Exhibit F: 

General Procedure for the Operation of RAV Systems 

RAV Flight Operations Procedure for Simultaneous Operations 

RAV Flight Process Procedure RAV Personnel Competency Program 

RAV Risk Assessment 

Equipment Failure Report 

All exhibits to this exemption petition are submitted to the FAA with a request for confidential 

treatment as they constitute commercially-sensitive proprietary data. 
Respectfully submitted, 

fl...-

Malcolm L. Benge I 

Counsel for 

Oceaneering International, Inc.