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August 14, 2015 Anadarko Petroleum Corporation

U.S. Department of Transportation

Federal Aviation Administration

Document Management System

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Petition of Anadarko Petroleum Corporation for an Exemption to Operate an 

Unmanned Aircraft System Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations

Dear Sir or Madam:

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

Pub. L. No. 112-95, 126 Stat.11 (amending 49 U.S.C.) and 14 C.F.R. Part 11, Anadarko 

Petroleum Corporation hereby applies for an exemption from the Federal Aviation Regulations

identified below to allow commercial operation of small unmanned aircraft systems (sUASs), 

specifically the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Phantom 2. The requested 

exemption would provide safety enhancements to Anadarko’s inspection, safety and monitoring 

operations. 

Anadarko would use the sUASs for aerial data acquisition to facilitate inspections of oil and gas 

pipelines, flare stacks, stock tank roofs, and other critical infrastructure. The sUAS applications 

would include safety and security monitoring, leak detection, surveying and mapping. The

sUASs would be used to collect imagery (photography, video, infrared, etc.), electronic 

measurements (precision surveying, RF analysis, etc.), chemical measurements (particulate 

measurement, etc.) and other pertinent data.

Use of the sUASs for these activities would reduce the need to operate conventional aircraft for 

the same purposes and provides extremely high quality imagery and modeling at a fraction of 

the price and time for the same activities done by other means. Most importantly the use of the 

sUASs for these purposes results in enhanced efficiency, improved environmental compliance, 

and increased safety in Anadarko’s operations.

In order to ensure a level of safety that is equivalent to the currently authorized operations 

using manned aircraft, all sUAS operations will be subject to the strict operating 

requirements defined in the Anadarko UAS Flight Operations Manual and Preflight 

Checklist (Anadarko will provide these documents if required, but requests that the FAA 

treat them as proprietary under 14 C.F.R. 11.35(b) and not include this document in the 

public docket). Additionally, this petition for exemption is supported by the information 
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contained in the Phantom 2 Vision+ User Manual, Phantom 2 User Manual, Phantom 2 

Vision Pilot Training Guide, and the Smart Flight Battery Safety Guidelines (hereafter 

collectively referred to as “Manufacturer’s Operations Manuals”). 

The Anadarko UAS will only be operated by a pilot in command (PIC) who holds one of the 

following. An airline transport, commercial, private, recreational, or sport pilot certificate 

and a current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC will meet the flight review requirements specified in 14 CFR § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate or the PIC will annually 

complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) 

covering regulations and issues pertinent to commercial operation of the Phantom 3, 

Phantom 2 Vision+ and Phantom 2 sUAS.

The PICs will also have successfully completed Anadarko’s UAS Training Program (the 

Anadarko UAS Training Program Outline will be submitted separately if required and 

Anadarko requests that the FAA treat this document as proprietary under 14 C.F.R. 11.35(b) 

and not include this document in the public docket).

The characteristics of the sUAS, the detailed sUAS operator requirements, and the sUAS 

operating parameters given below will ensure that all Anadarko UAS operations are 

carried out with an equivalent or higher level of safety than is currently authorized for 

manned aircraft operations. The details below regarding Anadarko’s UAS applications 

are intended to provide evidence that approval of this exemption is in the public interest.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Anadarko requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;

 14 C.F.R § 45.23(b);

 14 C.F.R. § 45.27(a);

 14 C.F.R § 61.113;

 14 C.F.R § 91.7(a);

 14 C.F.R § 91.9(b)(2);

 14 C.F.R § 91.9(c);

 14 C.F.R § 91.103;

 14 C.F.R § 91.109(a);

 14 C.F.R § 91.119;

 14 C.F.R § 91.121;

 14 C.F.R § 91.151(a) & (b)

 14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).
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II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the 

FAA Administrator is to permit operation of an unmanned aircraft system where it does not 

create a hazard to users of the national airspace system (NAS) or the public or pose a threat to 

national security based on the following considerations:

 The size, weight, speed and operational capability;

 Operation in proximity to airports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant 

exemptions from the agency’s safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 

44701-44716, et seq. A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety 

or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81.

III. DESCRIPTION OF ANADARKO AND ITS SERVICES

Anadarko is among the world's largest independent oil and natural gas exploration and 

production companies. The Company is engaged in the exploration, development, 

production, and marketing of natural gas, oil, condensate, natural gas liquids (NGLs), and 

anticipated production of liquefied natural gas (LNG). Its assets include United States 

onshore resource plays in the Rocky Mountains area, the southern United States, the 

Appalachian basin, and Alaska. The Company has three segments: Oil and gas 

exploration and production, Midstream and Marketing. Oil and gas exploration and 

production segment explores for and produces natural gas, oil, condensate, and NGLs, 

and plans for the development and operation of its LNG project. The Midstream segment 

engages in gathering, processing, treating, and transporting oil, natural-gas, and NGLs 

production. The Marketing segment sells oil, natural-gas, and NGLs production. 

Anadarko is also an independent producer in the deepwater Gulf of Mexico. Proper 

inspections, maintenance, surveying and mapping are integral to the safe performance of 

Anadarko’s activities. 

The contact information for Anadarko regarding UAS operations is as follows:

Mr. Michael J. Floyd

Chief Pilot

Houston, TX

Houston Hangar

+1 281-784-6705

+1 832-696-1609 (US) 

michael.floyd@anadarko.com
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Mr. Adam W. Schmid

Aviation Safety Advisor

The Woodlands, TX

Allison Tower 09098

+1 281-784-6703

+1 936-900-7017 (US) 

adam.schmid@anadarko.com

Writer’s Direct Contact

Mr. Jan Van Sickle

+1 (303) 915 4669

jvansickle@anadarko.com

IV. DESCRIPTION OF THE sUASs

The Phantom 3, Phantom 2 Vision+, and Phantom 2 are similar, however, the Phantom 3 

and Vision+ both include an integrated camera, while a third party camera can be affixed 

to the Phantom 2. The Phantom 2 Vision+ and Phantom 2 have a diagonal motor-tomotor distance of approximately 14 inches. The Phantom 3 is approximately 27 inches 

across, measured diagonally and including the propellers. The construction of all three UA 

is primarily frangible plastic. They weigh less than 3 pounds each. The Vision+ and 

Phantom 2 are powered by a 5200 mAh 3S LiPo battery. The Phantom 3 is powered by a 

4480 mAh 4S LiPo battery.

The max flight speed of the Phantom 2 Vision+ and the Phantom 2 is approximately 34 

mph, while the max flight speed of the Phantom 3 is approximately 36 mph. All three UA 

contain an on-board GPS and an inertial measurement unit for flight stabilization and

automatic failsafe return to home in the event of a control signal loss. These UAS offer 

geo-fencing and max altitude restrictions which can limit the vertical and horizontal 

distance the aircraft will fly from its home point. The Phantom 3 and Vision+ systems 

have the capability to display real time flight data, including battery status, altitude and 

distance from home, within the DJI App.

Each sUAS operated by Anadarko for commercial use will be registered in accordance 

with 14 C.F.R Part 47, and will be marked in accordance with 14 C.F.R. Part 45, , Subpart 

C, in a size as large as practical for the size of the sUAS.

All sUASs operated by Anadarko will be maintained in accordance with the 

manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements 

for the aircraft and aircraft components and all pertinent instructions in the user manuals. 

Repairs, component changes, and software/firmware updates will be recorded in the 

sUAS’s maintenance log. Maintenance log entries will include the date, sUAS ID number, 
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registration number, current sUAS flight time, a description of work performed, and the 

name of the individual who completed the work. Any sUAS that has undergone 

maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. 

replacement of a flight critical component, must undergo a functional test flight, prior to 

use in any commercial operations. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. The PIC who conducts 

the functional test flight must make an entry in the aircraft records. 

A pre-flight inspection of the sUAS will be completed by the PIC prior to each flight 

operation as specified in the Anadarko sUAS Flight Operations Manual. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. 

All Anadarko sUAS operations will comply with all applicable manufacturer safety 

bulletins. Additional information on the aircraft specifications, performance limitations, 

operating procedures, and pre-flight inspections is contained in the attached documents. 

The safety and reliability of the sUASs are further supported by the fact that numerous 

FAA exemptions have previously been approved for their use in commercial operations. 

V. OPERATOR REQUIREMENTS

All Anadarko sUAS PICs will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate and a current FAA airman medical certificate or a valid 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC will meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate or will annually complete and log at least 4 hours of ground instruction with a 

certified flight instructor (CFI) covering regulations and issues pertinent to commercial 

operation of the Phantom 3, Phantom 2 Vision+ and Phantom 2 sUAS.

The PICs will also have successfully completed Anadarko’s UAS Training Program to

ensure safe operations. Anadarko will not allow any PIC to operate a sUAS unless that PIC 

has demonstrated that he/she is able to safely operate the sUAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

The individual acting as PIC of a sUAS will be identified prior to any flight and will not 

change once the flight has begun. The PIC is the individual in operational control of the 

flight operation from beginning to end and is responsible for safe flight of the sUAS. All 

PIC flight hours used to demonstrate qualifications and currency will be logged in a 

manner consistent with 14 CFR § 61.51(b).

In order to act as PIC, all ANADARKO sUAS operators will hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government.
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V. OPERATION PARAMETERS

In order to provide for a level of safety at least equivalent to operations conducted using 

manned aircraft, all Anadarko commercial sUAS operations will be conducted in 

accordance with the following specific operating limitations:

 The sUAS may not be operated at a speed exceeding 30 knots (34 miles per 

hour). In no case will the sUAS be operated at airspeeds greater than the 

maximum sUAS operating airspeed recommended by the aircraft manufacturer.

 All operations shall be conducted in accordance with an Air Traffic Organization 

(ATO) Certificate of Waiver or Authorization (COA). Anadarko will apply for a new 

or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the granted COA.

 All sUAS operations will occur at or below 400 ft. AGL or the maximum altitude 

specified in the COA limitations, unless the purpose of the flight is to inspect a 

building or structure which is taller than 400 ft. If the purpose of the flight is to 

inspect a structure which is taller than 400 ft. then the max altitude of the sUAS 

will be restricted to 20 ft. above the highest point of that building or structure. All 

altitudes must be reported in feet AGL.

 No sUAS will be operated within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 

the current FAA published aeronautical chart, unless a letter of agreement with 

that airport’s management is obtained or otherwise permitted by a COA issued to 

Anadarko. The letter of agreement with the airport management must be made 

available to the Administrator or any law enforcement official upon request.

 No sUAS will be operated within class B, C, D or E airspace unless a letter of 

agreement from the controlling ATC office is obtained or the flight is otherwise 

permitted by a COA issued to Anadarko. The letter of agreement from ATC must 

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

request.

 The sUAS must be operated within visual line of sight (VLOS) of the pilot in 

command (PIC) at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the PIC’s 

FAA-issued airman medical certificate or U.S. driver’s license.

 All operations must utilize a visual observer (VO). The UA must be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO 

may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC must be able to communicate 
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verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must ensure 

that the VO can perform the duties required of the VO.

 All operating documents and a grant of exemption must be accessible during 

sUAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the grant of 

exemption and the procedures outlined in the operating documents, the 

conditions and limitations in the grant of exemption take precedence and must be 

followed. Otherwise, the PIC must follow the procedures as outlined in the 

operating documents. Anadarko may update or revise its operating documents. 

However, it is Anadarko’s responsibility to track such revisions and present 

updated and revised documents to the Administrator or any law enforcement 

official upon request. Anadarko must also present updated and revised 

documents if it petitions for extension or amendment to the grant of exemption. 

If Anadarko determines that any update or revision would affect the basis upon 

which the FAA granted the exemption, then Anadarko must petition for an 

amendment to the grant of exemption.

 sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. 

All operations must be conducted under visual meteorological conditions 

(VMC). Flights under special visual flight rules (SVFR) are not authorized. The 

sUAS may 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.

 Prior to each flight, the PIC must conduct a pre-flight inspection and determine 

the sUAS is in a condition for safe flight. The pre-flight inspection must account 

for all potential discrepancies, e.g., inoperable components, items, or equipment. 

If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. All 

maintenance and alterations must be properly documented in the aircraft records.

 Any sUAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations under 

this exemption. Functional test flights may only be conducted by a PIC with a VO 

and must remain at least 500 feet from other people. The functional test flight must 

be conducted in such a manner so as to not pose an undue hazard to persons and 

property. The PIC who conducts the functional test flight must make an entry in 

the aircraft records.

 If the UAS loses communications or loses its GPS signal, the sUAS must return 

to a predetermined location.
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 The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies.

 The PIC is prohibited from beginning a flight unless the sUAS’s battery level is 

at 75% or higher. The PIC must begin returning the sUAS to the designated 

landing area when the battery level drops below 25% and will be safely landed 

with no less than 20% battery life remaining.

 Documents used by the operator to ensure the safe operation and flight of the 

sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the sUAS any time the 

aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request.

 The sUAS must remain clear and give way to all manned aviation operations and 

activities at all times.

 The sUAS may not be operated by the PIC from any moving device or vehicle.

 sUAS will not be operated directly over nonparticipating persons unless barriers 

or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. UA will not be operated over 

any open-air assembly of people.

 Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

 The sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and 

life limit requirements for the aircraft and aircraft components will be followed.

 Each UAS operated under this exemption will comply with all manufacturer 

safety bulletins.

 Each UAS will be identified by serial number, registered in accordance with 14 

CFR part 47, and have identification (N−Number) markings in accordance with 

14 CFR part 45, Subpart C. Markings must be as large as practicable.

V. THE PUBLIC INTEREST

The requested exemption would allow Anadarko to operate the DJI Phantom 3, Phantom 

2 Vision+, and Phantom 2 for the purposes of inspections, maintenance, surveying and 
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mapping. Use of sUAS for these applications will offer significant advantages related to 

safety, time, and cost. Current options for gathering the data which under this exemption 

would be collected using sUAS, include use of ladders, lifts, and manned aircraft. Use of 

ladders and lifts are inherently dangerous and result in numerous injuries each year. Use 

of manned aircraft is sometimes infeasible for particular applications. In most cases the

use of a sUAS is more efficient, less expensive, yields better information and is safer than 

the other alternatives. The three models of the DJI Phantom mentioned are small, light,

carry no volatile fuel, create no harmful emissions, make very little noise and 

subsequently pose a very low risk of damage to persons or structures on the ground. 

VI. SPECIFIC FAR EXEMPTIONS REQUESTED

Anadarko seeks an exemption from several interrelated provisions for purposes of 

conducting operations using Phantom 3, Phantom 2 Vision+, and Phantom 2 sUAS: Listed 

below are (1) the specific FAR sections for which exemption is sought, and (2) the 

operating procedures and safeguards that Anadarko has established which will ensure a 

level of safety better than or equal to the rules from which exemption is sought. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a) (1)

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the 

size of the sUAS, its light weight, and the limited operating area associated with its 

utilization the airworthiness process under Part 21 Subpart H is unnecessary to achieve 

or exceed current safety levels. Such an exemption meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas 

of the sUAS involved. 

Equivalent Level of Safety: Phantom 3, Phantom 2 Vision+, and Phantom 2 sUAS are

safe when taking into account their size, weight, speed, and operational capability. They 

are light weight (3 pounds each) flown at speeds less than 36 miles per hour in visual line 

of sight of the operator. They do not carry pilots, passengers, explosive materials, or 

flammable liquid fuels and will be operated within the parameters of the Manuals. The 

proposed operations will be at least as safe as, or safer than, conventional aircraft and/or 

rotorcraft operating with an airworthiness certificate without the restrictions and 

conditions proposed here. The proposed operations will be as safe, or safer, than 

traditional surveying or inspection activities.

14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification 

Requirements
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14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words “limited,” “restricted,” “light-sport, 

“experimental,” or “provisional,” as applicable.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified 

in accordance with part 45 of this chapter.

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

requirements was warranted provided that the aircraft “have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as 

practicable.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.

Equivalent Level of Safety: Anadarko will mark all Phantom 3, Phantom 2 Vision+, and 

Phantom 2 with their N-Number in a prominent spot on the fuselage with markings that 

are as large as practicable.

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

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot 

in Command; Commercial Pilot Privileges and Limitations

The regulation stipulates that no person may serve as a required pilot flight crewmember 

of a civil aircraft of the United States, unless that person:

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in 

that person's physical possession or readily accessible in the aircraft when exercising the 

privileges of that pilot certificate or authorization. However, when the aircraft is operated 

within a foreign country, a pilot license issued by that country may be used.

The regulation provides also that no person that holds a private pilot certificate may act 

as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if:

(1)The flight is only incidental to that business or employment;

(2)The aircraft does not carry passengers or property for compensation or hire.

Equivalent Level of Safety: Given the size, weight, speed, operational limitations, and 

range of the sUAS, Anadarko proposes that operators of the UAS not be required to hold 

a commercial pilot certification. Instead, operators should be required to hold at least an 

FAA issued private, recreational, or sport pilot certificate. All operators will either meet 

the flight review requirements specified in 14 CFR § 61.56 or will annually complete 

and log at least 4 hours of ground instruction with a certified flight instructor (CFI) 

covering regulations and issues pertinent to commercial operation of the Phantom 3, 

Phantom 2 Vision+ and Phantom 2 UAS.
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14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Anadarko seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required to the 

extent that the requirements of Part 21 are waived or found inapplicable. 

Equivalent Level of Safety: Accordingly, Anadarko requests that the requirements for Section 

91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 

11062, p. 19.

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

Pursuant to 14 C.F.R. § 91.9(b) (2):

(b) No person may operate a U.S.-registered civil aircraft -

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by §

21.5 of this chapter, unless there is available in the aircraft a current 

approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it 

has within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible 

to passengers or crew.

(c)

Equivalent Level of Safety: Anadarko notes that, in accordance with FAA Office of Chief 

Counsel’s Opinion dated August 8, 2014 held that the UAS flight manual, registration 

certificate and other documentation kept at the control station with the PIC during flight 

constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, 

pp. 19-20, and Grant of Exemption No. 8607.

14 C.F.R. § 91.103: Preflight action

Anadarko seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on 

board. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. Under 

these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption 

No. 11062, p. 20. An exemption is requested to the extent that an FAA-approved Flight Manual 

is required.
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Equivalent Level of Safety: An equivalent level of safety will be provided by following the 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, aircraft performance 

data, and contingency landing areas - before initiation of flight. The Manuals will be kept at 

the ground station with the operator at all times.

14 C.F.R § 91.105: Flight Crewmembers at Stations

The regulation stipulates that crewmembers must be at their stations in the aircraft 

during specific portions of a flight. Anadarko proposes that this regulation does not 

apply as sUASs carry no crewmembers. 

Equivalent Level of Safety: An equivalent level of safety will be maintained by ensuring 

that the PIC is identified prior to any flight and that the PIC does not change during a 

flight. The PIC will maintain control of the UAS for the duration of the flight.

14 C.F.R. § 91.109(a): Flight Instruction

Anadarko seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o person 

may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of the Ground Control System consisting of the antenna with the 

command and control link and the data link, a case with a built-in joystick, and a back-up 

controller that communicates with the aircraft via radio modem communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on the 

aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety 

hazard. Given the size and speed of the Phantom 3, Phantom 2 Vision+, and Phantom 2 sUAS

an equivalent level of safe training can still be performed without dual controls because no 

pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the 

event that the aircraft experiences any difficulties during flight instruction. In addition, 

Anadarko will conduct flight training at a remote facility away from population centers. These 

training flights will comply with the provisions in the Manuals. Accordingly, Anadarko’s 

proposed method of operation provides superior levels of safety.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

Anadarko requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure. The FAA has already determined that relief 

from Section 91.119(c) is warranted for UAS operations in uncongested areas. See Grant of 

Exemption No. 11062, p. 20-21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft/aircraft weighing 

far more than the maximum weights proposed herein, and given the lack of flammable fuel, 

any risk associated with these operations is far less than those that presently existing with 
13

conventional aircraft. An equivalent level of safety will be achieved given the size, weight, 

and speed of the Phantom 3, Phantom 2 Vision+, and Phantom 2 sUAS as well as the 

locations where they are operated. In order to avoid any risk to aircraft, flight operations will 

be restricted to 400 feet AGL or below. This is airspace where other aircraft do not normally 

operate. All persons who are not involved with Anadarko’s operations will be required to be 

at least 500 feet from flight operations.

14 CFR 91.121 – Altimeter settings

This section requires that each person operating an aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating below 18,000 feet MSL to:

 The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

 If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station;

 In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-ofsight in addition to GPS based altitude information relayed in real time to the operator. See 

Grant of Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the DJI Phantom 2 

will be operated at or below 400 feet AGL and otherwise comply with the limitations in the 

Grant of Exemption No. 11062.

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

Anadarko requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in 

VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The aircraft is battery powered and will not be flown unless there is at least 75% battery 

power at the beginning of a flight and will land on or before the battery power reaches 

25%.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided 

if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and 

terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 

11062, p. 21-22. 

14 C.F.R. §§ 91.405(a), 91.407(a) (l), 91.409(a) (2); 91.417(a) and (b): Maintenance 

Inspections
14

Anadarko seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a) (l), 91.409(a) (2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections ... have 

discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these 

regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the Phantom 3, Phantom 2 Vision+, and Phantom 2 sUAS 

will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because 

the maintenance, as well as preflight inspections of the sUAS will be accomplished by the 

PIC. All maintenance will be conducted and logged in accordance with the manufacturer’s 

specifications. This includes maintenance, overhaul, replacement, and inspection 

requirements for the aircraft and procedures to document and maintain maintenance records 

for the aircraft. This also includes preflight inspection procedures as flights will not be 

conducted unless a flight operations checklist is performed that includes all of the aircraft’s 

components. See Exemption No. 11062, Docket No. FAA 20140352, at p. 14-15.

VII. SUMMARY FOR THE FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: Anadarko seeks an 

exemption from the following rules for the commercial operation of a small unmanned 

aerial system.

14 C.F.R Part 21, Subpart H; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 

C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 

91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 

91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 

C.F.R § 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the operator, the general public and 

property owners from the substantial hazards associated with performing equivalent work using 

conventional aircraft and rotorcraft.

IIX. CONCLUSION 

Anadarko respectfully requests that the FAA grant the exemption sought in this request. 

Anadarko believes that considering the small size involved, the restricted environment 

within which they will operate, the strict operating guidelines and the PIC 

training/certification requirements stipulated above the sUASs will be operated in the 

national air space (NAS) with an equivalent or greater level of safety than manned 

aircraft. In making this request Anadarko has attempted to satisfy the criteria provided in 
15

Section 333 of the Reform Act - size, weight, speed, operating capabilities, proximity to 

airports, operation within visual line of sight, and security considerations. 

Granting the requested exemption will benefit the public interest as follows: (1) 

significantly improving safety and reducing risk by alleviating human exposure to danger; 

(2) improving the quality of services Anadarko can provide to its customers; (3) 

decreasing operating costs related to survey and inspection activities; and (4) reducing 

environmental impacts aerial surveys and inspections. 

Respectfully Submitted,

Jan Van Sickle

Anadarko Petroleum Corporation

Attachments:

Anadarko’s Phantom Pre-Flight Checklist 

Phantom_2_Vision_Plus_User_Manual_v1.8 

Phantom_2_Vision_Plus_Pilot_Training_Guide_v1.1

Phantom_2_Vision_Plus_Quick_Start_Guide