# ~ VALERO November 13, 2015 U.S. Department of Transportation Dock et Operations West Building Ground Floor, Room W12 -140 1200 New Jersey Ave., SE Washington, DC 20590 E lectronically S ubmitted 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 R egulations 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 authori ze_ c ivil operations of small Unmanned Aircraft Systems ("s UAS ") for the purposes of: 1. Aerial Video and Photography ; 2. Di sas ter Re sponse 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 M anagement Aerial In spection s of: 9
. Construction sites; 10. Oil , Gas, and Ethanol Infrastructures; 11. Petroleum Transmiss ion and Storage; and 12
. Wind Fmm Facilities Operations will b e conducted by Valero within and under the condition s outlined herein or as may be establi shed by the FAA as required by Section 333. As described below, the requested exemption would permit the operation of sUAS fo r inspection of facilities operated by Valero; Valero's wholly-owned subsid iaries; 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 "Facilitie s." The s UAS will provide Valero and its wholly owned subsid iaries 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 IValero 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 struct ures 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 s UAS as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation with in 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 serv ice 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 regulation s. This operation will not be for compensation or hire. Given the direction of Section 333 of the Reform Act, the stro ng equivalent level of safety sunounding the proposed operations, and the s ignificant 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
Va lero Services, Inc. • I 000 Sky place BIvd. • San Antonio, Texas 78216 • Telephone (2 1 0) 377- 1111Valero Services, Inc. Petition for Section 333 Exemption 3 

### Valero Summary Valero Energy Corporation, through its s ub sidiarie s, is an international manufacturer and marketer of transportation fuel s, petrochemical products and power. Valero subsidiarie s employ approximately 1 0,000 people, and assets include 15 petroleum refineries with a combined throughput capacity of approximately 2
. 9 million barrels per day, 1 1 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, D iamond Shamrock, Shamrock and B eacon 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 P artners LP , a midstream master limited partnership. Valero is a Fortune 20 company based in San Antonio. 

### Valero Aviation Experience and Prior E fforts 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 1 50 years of technician experience. The Flight D epruiment has been monitoring the progress of commercial sUAS operations in the USA and Internationally. Thi s 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 subs idiarie s, and Valero Energy Partners LP and its wholly owned subs idiarie s. 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 T exas 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 s UAS , Valero is reque sting 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, T exas 78216 • Telephone (210) 377- II IIValero Services, Inc. Petition for Section 333 Exemption 4 compliance culture and a keen understanding of the importance of extensive security, p lanning, 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 purpo ses of the flight. 8. Valero maintains compliance with all law s and regulations that govern its operat ions. This include s 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 sU AS Serves the Public Interest 1. SUAS inspection is safer than human inspection. Facilities inspection without s UAS 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. In spectors need to climb towers or otherwise perform elevated work, which exposes them to the risk of dangerous falls. In addition , proximity to the equipment involve s a risk of exposure to hazardous chemical s or oxygen-deficient atmospheres, bums from steam or from hot equipment, and other mechanical hazards associated with industrial equipment. 2. SUAS in spection 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 vis ual 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 Servi ces, Inc. • I 000 Skyplace B Ivd. • San Antonio, Texas 78216 • Telephone (21 0) 377- Ill IVal e ro Se rvices, Inc. Petition for Section 333 Exe mption 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. Dimens ion s 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 AR 1 80 is a derivation of AirRobot's proven system ARlOOB , which has been in s ervice s ince 2006 and i s 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 stat ion 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 , Texa s 78216 • T e l ephone (210) 377- III IValero Services , Inc. Pe tition for Section 333 Exe mption 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, 1 8 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 sharin g, but adds to it a high pe1formance 3

- axial camera stabilization system . It 's ideal for aerial creat ivity 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

- O ff and Landing Launch & recovery method (VTOL) D eployed: 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 In sp ire 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. "

Va lero 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 Ins pire 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 subsidia ries , 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 sU AS p ilot. 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 (2 1 0) 377

- Ill LValero Services , Inc. Pet ition 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 Vi s ual Observer (VO) will be designated before each flight i. Minimum crew for each operation will consist of the sUAS P IC and the VO.
c. The PIC and VO will always be within visual line of s ight (VLOS) of each other and in direct verbal communication at all times. d. Safety Briefing s will be conducted before each day's activities to include, but not limit ed to:
1. D esignated role s of PIC and VO
u. Ri sk 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 conce rns . 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 S p ecifi cati ons and Design :
a. All sUAS flown under this exemption s hall be le ss than 55 pounds including aircraft and payload. Thi s exemption requests permission with respect to the s pecific use of the Aeryon SkyRanger, AirRobot AR-180, D JI 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 s UAS shall comply with the Federal Communications Commi ss ion (FCC) or other appropriate government over s ight agency requirements.
c . Maximum speed shall be no more than 50 knots. d. The sUAS sh all be equipped with Inertial Navigation Sensor(s ) (IRS/IRU/ Accelerometer).
e . The s UAS shall be equipped with a Compass (Magnetometer/Heading Source). f. The s UAS shall be equ ipped with a Global Position ing System (GPS) guidance s ystem. g. The sUAS shall be des igned, should it lose communications or lo se its GPS s ignal , to return to a pre-determined location within the security perimeter and land or be Va ler o Services, Inc .• 1000 Skyp lace Blvd. • San Antonio, Texas 78216 • Tel ephone (2 10) 377- II IIValero Services , Inc. Petition for Section 333 Exempti on 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 Servo s 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 Bulletin s or equivalent pertaining to their sUAS
. d. Valero will document and maintain a record of the s UAS 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 s UAS' s maintenance records
. f. The PIC shall perform a preflight inspection of the s UAS , controller, and ground control sta tion prior to each flight to ensure it is operational with no safety of flight discrepancies . I f the preflight in spection has any discrepancies that may affect a safe operation, repairs or maintenance shall be performed prior to flight. Th e sUAS will only be operated if it is free of all discrepancies that affect safety of flight. h. All sUAS s hall 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 s ize 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 IIValero 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. 1 1. 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. Op er at

ions
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, g lare, reflective smfaces, clouds, smoke, Valero Ser vices, Inc. • 1000 Skyplace Blvd
. • San Antonio, Texas 78216 • Telephone (210) 377- 1111Valero Services, In c . 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 p lace. 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 co nducted under special visual flight ru l es (SVFR). d. Flights shall be operated at an altitude of no more than 400 feet above ground level (AG L) , as indicated by the procedmes specified in Valero's s UAS 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 (V LOS ) 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 v ision, which includes the use of eyeglasses or conective lenses as specified on the PIC's medical certificate. g. The sUAS shall remain clear and y ield the right of way to manned aeri al operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). b. Valero wi ll require the PIC and Visual Observer (VO) to have successfully complet ed a qualification process, as outlined in the Valero s UAS Operation s Manual.
1. The PIC' s primary responsibility while in flight is the safe operation of the s UAS. 

### 6. Flight Ti me
a. Each sUAS operation shall be completed within 30 minutes flight time or with 25 % battery power remaining, whichever occurs first.

Va lero Se rvices, (nc. • 1000 Skyp lace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- II IIValero 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 Plu s 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 IVa l ero Services, Inc
. Petiti on for Section 33 3 Ex e mption 13 

## Exhibit A Regulations for Which Exemptions are Requested 1. Unle ss otherw ise requesting an exempti on, Valero , the PIC, the VO , and the sUAS s h all comp ly with a ll applicable parts of 14 CFR including, bu t not limited to , parts 45 , 47 , 6 1, and 91. 2. Valero is requesting exemption s from the foll owing Federal Aviation R egulations to the extent necessary to enable the reques ted s U AS operations for the reas o ns deta iled below
. 

### Relief sought by Valero (14 CFR) Valero Reasoning P art 21 Stated B elow 6l.ll3(a) and (b) Stated B elow 9 1. 103 Stated B e low 9l.l l 9(c) Sta ted B elow 91. 121 Stated B elow 9 l.1 5l(a)(l ) Stated B elow 9l.405(a) - Stated**ow** - - 91.407(a)( J) S tated B elow 91.409(a)(l) and (2) Stated B elow 9 1. 417(a) and (b) Stated B elow 

### 14 CFR Part 21- Requiremen ts to Secure Airworthiness Certificates I
. Ce1tificate exemptions should be given because s i ze, weight, and operation areas of the sUAS meet the l evel of s afety neces s ary for exemption un der Sectio n 333 of the Reform Act. 2
. FAA has the au thority to exempt aircraf t from airworthine ss certificate requirements under the Act (49 U.S
.C. § 4470 1 (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 s tand ards for private or commercial s UAS operations , Valero requests to uti lize at l east private pi lots with third class medica ls in s upport of its own operations on its own property. 2. Know ledge of flight characteri s tics and the F ederal Aviation Regulations (FAR s) , along with the abil ity to p hy s ica ll y manipu late the contro ls of the sUAS are the critical as pects of the requested operation. Valero feels th is can be accomplished with a private pilot that has specific training on the sUAS operated in acco r dance with the Valero s UAS O peration s M anual , an d has s ati sfactorily completed the required t raining
. Valero Services, Inc. • l 000 Skyp l ace Blvd. • San Antonio , T exa s 782 16 • T el ephone (2 1 0) 377

- l IllVal ero Services, Inc. P etition 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 s UAS Operations Manual prior to each flight to ens ure it is free of safety of flight discrepancies. 2
. Equivalent safety levels will be met through preparation and compliance according to Valero's s UAS 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 s lope; 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 w ill be established for each fl ight. 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 IIValero Services, Inc. Petition for Section 333 Exemption 1 5 

### CF R 91 . 151 (a) (1) - Fuel Requiremen ts for Flights in VFR Conditions I. As the sUAS are capable of a maximum of 50 minutes flight time, an exemption wi ll be necessary . 2. As the sUAS are flown within Facilities below 400 feet AGL under controlled conditions as defined by the Va l ero sUAS Operations Manual, we fee l 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 wi ll all ow for sufficient time to land the aircraft safely within a "Safe Zone." 4. The Aeryon SkyR anger, Aii·Robot AR-180, DJI Phantom Vision Plus, and D JI Inspire 1 Version 2 have a second level of safety that i s 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 requ irements in VFR conditions; exemption numbers 10808, 2689F, 5745 , & 10673
. 

### 14 CFR 91 .405 (a) 

### Maintenance Required 1. This section and Part 43 apply on ly to ai r craft 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 a lteration will be successfully accompli shed by trained Valero personnel or the OEM. 4. T he sUAS shall be free of safety of flight discrepancies prior to initiating any flight. 5. 

### If a mechanical iss ue arises the s UAS 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 a i rworthy 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 wi ll be achieved because these sUAS are limited in size and wi ll and shall fly only above Facilities below 400 feet AGL. Va lero Se rvices, Inc. • 1000 Skyplace B lvd. • San Antonio, Texas 78216 • Telephone (210) 377- I I I IValero 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 section s 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. I f 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 detail s how to log schedu led 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 airworthine ss certificate, therefore these sect ion s 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 purs uant 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 s UAS 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- 1 1 11Valero Services, Inc. Petition for Section 333 Exemption 17
7. The Valero s UAS Operations Manual details how to lo g 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 s UAS 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 s UAS Operations Manual details how to log schedu l ed 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 regu latory provisions dealing with sUAS inspections, Valero has developed requirements to address this topic. Those requirements are stated in Valero's s UAS 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.

Va lero Services, Inc. • 1000 Skyplace Blvd. • San Antonio, Texas 78216 • Telephone (210) 377- II IIValero 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. Ot her 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 simp ly do not apply. Examples include:
• Requ irements for lights. (Valero's sUAS flights will occur only in daylight.)
• Requirements for safety belts, shou lder harnesses and chi ld 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 "car ry" and " di splay" 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 reques ting 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
. Va lero Services, Inc. • 1000 Skyplace Bl vd. • San Antonio, Texa s 78216 • Tel e phone (210) 377- 1111Vale ro Services, Inc. Petition for Section 333 Exemption 19

• Requirements relating to flights in restricted airspace , such as that as soc iated with military facilities. If the FAA feel s that Valero should mention such regulations more specifically m th is application, we 

### will do so.

Valero Services, Inc. • I000 Skyplace Blvd. • San Antonio, Texas 78216 • T e lephone (210) 377

- Jill