1

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 Co r

poration 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 w ould be used to collect imagery (photography, video, infrared, etc.), electronic

measurement s (precision surveying, RF analysis, etc.), chemical measurement s (particulate

m easurement, 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 f

or 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 information2

c ontained 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 U AS will only be operated by a pilot in command (PIC) who hold s one of the following. A n 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

sta te, 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 PI C 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 REQ UESTED

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).3

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 conside rations:

 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 explor ation 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 play s 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 p roduces natural gas, oil, condensate, and NGLs, and plans for the development and operation of its LNG project. The M idstream 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 inform ation for A nadarko regarding UAS operations is as follows:

Mr. Michael J. Floyd

Chief Pilot

H ouston, TX Houston Hangar

+1 281

- 784

- 6705

+1 832

- 696

- 1609 (US) michael.floyd@anadarko.com4

Mr. Adam W. Schmid Aviation Safety Advisor

T he Woodlands, TX

A llison 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

- to

motor distance of approximately 14 inches. The Phantom 3 is approximatel y 27 inches across, measured diagonally and including the propellers. The construction of a ll 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 i s 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

. T hese 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+ sy stems 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 b e 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, an d software/firmware updates will be recorded in the sUAS’s maintenance log. Maintenance log entries will include the date, sUAS ID number,5

registration number, current sUAS flight time, a description of work performed, and the

name of the individual who co mpleted the work. Any s UAS 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 operat ions. 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 n ecessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

All Anadarko s UAS operations will comply with all applicable manufacturer safety

bulletins. Additional information on the aircraft specifications, performa nce 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

certif icate 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 e xemption, 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 ha s 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 consiste nt 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.6

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 4 00 ft. AGL or the maximum altitude specified in the COA limitations, unless the purpose of the flight is to inspe ct a building or structure which is taller than 4 00 ft. If the purpose of the flight is to inspect a structure which is taller than 4 00 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.

 N o 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 ai rport 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 observe r (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 communicate7

verbal ly 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 a nd 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 t he 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 proh ibited 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 maintenanc e 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.8

 The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

 The PIC is prohibi ted 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 remain ing.

 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. T hese 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 a ny 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 b e 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 oper ate the DJI Phantom 3, Phantom 2 Vision+, and Phantom 2 for the purposes of inspections , maintenance, surveying and9

mapping . Use of sUAS for these applications will offer significant advantages related to safety, time, and cost. Current options for gather ing 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 infe asible for particular application s

. In most cases the

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

the other alternative s. The three models of the DJI Phantom mentioned are sm all , 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 operati ng 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 require ments 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 conside ration 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, we ight, 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 wi ll 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 he re. The proposed operations will be as safe, or safer, than traditional surveying or inspection activities.

1 4 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requirements10

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 air craft 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:

N o 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 P hantom 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 tha t 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 compensat ion 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 propert y 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, operator s 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 in struction 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.11

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness Anadarko seeks an exemption fr om 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

Counse l’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. 1106 2, 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 FAA

approved 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 dat a 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.12

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 crewm embers 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 en suring 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 1 4 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 t heir 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 ba ck

- 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 i nstruction. 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 cl oser 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 Safet y: 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 with13

conven tional 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 opera tions 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:

 T he 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 appropr iate 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

- of

sight 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 attache d 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 exem ption 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 Inspections14

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 i n 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 discrepancie s 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

w ill 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 proced ures as f lights 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 2014 0352, at p. 14

- 15.

VI I

. 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 fro m 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 in15

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 qua lity 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,

J an 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