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1VLARINE & ENGINEERING CONSULTANTS 

December 18, 2015 

United States Department of Transportations 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

London Offshore Consultants Inc. 

16800 Imperial Valley Drive, Suite 280 

Houston, TX 77060 

United States of Arnerica 

T (+1) 281 987 7400 

F (+1) 281 987 7438 

E liouston@loc-group.com 

www.loc-group.com 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation's Regulations 

Applicant's name, address and contact number are: 

Business Name: London Offshore Consultants 

16800 Imperial Valley Drive Suite 280, Houston TX 77060 

Contact: Matt Riggs 

Email:m.riqqs loc-qroup.com 

Phone: (281) 987-7400 

Purpose for Request: 

Dear Sir or Madam, I, Matt Riggs on behalf of London Offshore Consultants (LOC), am writing 

pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, to request that LOC's an owner and operator of small unmanned aircraft, be exempted 

from the Federal Aviation Regulations 

("FARs") listed below so that LOC, may operate our small ultra-lightweight unmanned aircraft system 

("UAS") in commercially regulated airspace by the Federal Aviation Administration ("FAA"). 

Following exemption and approval by the FAA, LOC, will primarily use our professionally built DJI 

Phantom 3, DJI Inspire 1, DJI Matrice 100 UAS equipped with cameras for the following applications: 

conduction aerial inspections and surveys as part of vessel and barge evaluations in the maritime 

industry, augmentation of real estate listing videos; and the creation of visual and topography layout 

videos for Search and Rescue (SAR) missions for state and local agencies, education, agricultural 

inspections and building and construction zone inspections. 

Regulation: 

The exemptions requested and/ or required are from 14 CFR and are as follows: 

14 C.F.R. Part 21, Subpart H—Airworthiness Certificates and 14 C.F.R. 91.20 

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. 91.7(a): Civil Aircraft Airworthiness 
14 C.F.R. 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft 

14 C.F.R. 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

14 C.F.R. 91.9(c): Civil Aircraft Flight Manual, Marking and Placard requirements 

14 C.F.R. 45.23(b): Markings of the Aircraft 

14 C.F.R. 45.27(a): Rotorcraft 

14 C.F.R. 91.103: Preflight Action 

14 C.F.R. 91.119: Minimum Safe Altitudes 

14 C.F.R. 91.121: Altimeter Settings 

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions 

14 C.F.R. 405(a): Maintenance required 

14 C.F.R. 409(a): Inspections 

14 C.F.R. 417(a) &(b): Maintenance records 

14 C.F.R. Part 61: Pilots, Flight Instructors, and Ground Instructors 

14 C.F.R. 61.3: Requirements for certificates, ratings and authorizations and 

Any other provisions out of Title 14, Code of Federal Regulations, that may be applicable to 

Applicant's specific use and not listed above 

Public Interest: 

The exemption requested is in the public interest because the intended purpose of the 

operation of UAS will enhance the safety of the inspection process presently utilized by the 

applicant which may have required, from time-to-time, inspectors to be on scaffold structures 

or other dangerous environments, or exposed to other hazardous conditions, in order to 

perForm the inspections which are necessary and required to comply with industry standards or 

governmental regulations. 

Operator Requirements to provide a level of safety while piloting the UAV 

A. Applicant Propose to adopt: 

a. A Pilot Operating Handbook and / or 

b. Flight Operations and Procedure Manual 

c. UAV Check List 

B. Applicant proposes the following conditions 

a. UA must weigh less than 55 pounds 

b. UA must operate within a visual line of sight (VLOS) of pilot in charge (PIC) or 

c. Must operate with a visual observer (VO). The VO may be utilized only if the PIC 

can communicate with VO at all times 
d. The PIC will inspect the UAS to ensure it is safe for flight. AII maintenance and 

alterations should be properly documented. 

e. A functional test flight must be performed for any UAS that has undergone 

maintenance or alterations and be performed by the PIC 

f. The operator must follow the manufactures' UAS aircraft/ component, maintenance, 

overhaul, replacement inspection and life limit requirements. 

g. The operator must ensure that no persons are allowed within 500 ft. of the area 

except those consenting to be involved and who are part of the area being inspected 

h. Each operations must be completed within 30 minutes flight time or with 20% battery 

power remaining, whichever comes first. 

Conclusion 

London Offshore Consultants are seeking an exemption from the following regulations 14 

C.F.R. Part 21, Subpart H, 14 C.F.R. Part 27, 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b) (2), 14 

C. F. R. 91.203(a) and (b), 14 C. F. R. 91.9(c), 14 C. F. R. 45.23(b), 14 C. F. R. 45.27(a), 14 C. F. R. 

91.103, 14 C. F. R. 91.119, 14 C. F. R. 91.121, 14 C. F. R. 91.151(a), 14 C. F. R. 405(a), 14 C. F. R. 

417(a) &(b), 14 C.F.R. Part 61, 14 C.F.R. 61.3 and any other provisions out of Title 14, Code 

of Federal Regulations, that may be applicable to applicant's specific use and not listed above 

to commercially operate lightweight unmanned UAS during vessel, barges or other maritime 

industrial inspections and surveys. 

Granting London Offshore Consultants' request for exemption will help reduce the current risk 

levels and enhance the safety of personnel. The use of UAS assisted photography will provide 

a practical means to periorm surveys and inspections for the marine industry that would be 

otherwise be hazardous to the employees of LOC. Inspecting marine equipment, incident 

damages or other areas in need will become easier and more efficient, providing our key 

services safely to our client and protecting our employees from excessive hazards. 

Kind Regar~ds, 

Matt Riggs 

Assistant HSEQ Manager