D ALE S TAGG

H UNTSMAN P ETROCHEMICAL

2701 S PUR 136

P ORT N ECHES

, T EXAS 77651

409

- 723

- 3298

DALE

_ STAGG @ HUNTSMAN

. COM

Dear Sir or Madam,

Dale Stagg representing Huntsman Petrochemical Company is petitioning the Federal Aviation Administration (FAA) for an exemption to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR part 11

. The exemption would allow commercial operation of the DJI

Phantom 2 vision and/or DJI Inspire 1 unmanned aircraft systems (UAS) for the purpose of aerial

video graphy a nd photography for constructions sites, project planning and engineering, facility flare inspections

, insurance claims due to natural disasters

, incident investigations, emergency response preparation

, and chemical process equipment photography and videography.

Dale Stagg agrees to operate within the boundaries set forth by this exempt ion. Dale Stagg would provide a service in the aerial photography and video graphy field for Huntsman Petrochemical Site s

usage

. Dale Stagg will provide a low cost bu siness alternative to Huntsman Petrochemical

manufa cturing sites to be more efficient and a much safer alternative to using a manned aircraft or personnel lift equipment

. Please Allow Dale Stagg to offer UAS operations to its company’s chemical manufacturing facilities to promote the safe

, efficient and responsible use of UAS.

The Aircraft, specifications, and levels of safety and maintenance.

Dale Stagg will operate the DJI Phantom 2 Vision and/or Inspire 1 and will provide a professional and

safe manner of collecting photos and videos.

1. The safe operation of the UAS will be the first priority before, during and after every operation.

2. The Phantom 2 and Inspire 1 has numerous safety features such as Failsafe mode, automa tic landing should signal between PIC and UAS be i nterrupted, GPS based altitude and distance locks, Flight Limits function and low battery warnings at 2 0% that automatically returns to

home.

3. Operations utilizing the Phantom 2 and/or Inspire 1 will provide a benefit to the general public

and serve the public interest by providing the service of aerial photographic images and video

to Huntsman Petrochemical for considerably less than the previously only available option of utilizing manned aircraft at an equi valent level of safety

. 4. The device utilizes GPS to establish its home points for takeoff and return to home when battery levels reach 20%.5. The device, equipped with a failsafe should something go wrong, will go to its designated home point set before each flight.

6. The weight of the DJI Phantom is less than 3 pounds and is powered by a 5200mah battery which is used to power the 4 electric motors. The batteries enable a flight time of 20 to 28

minutes.

7. The weight of the DJI Inspire 1 is less than 6 .5 pounds and is powered by a 57 00mah battery which is used to power the 4 electric motors. The batteries enable a flight time of 20

– 28

minutes.

8. All UAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 400

feet AGL.

9. No UAS operations will be conducted within 5 NM of an airport.

10. No UAS operations shall occur over densely populated areas, large assemblies of people, stadiums, government buildings, power lines, or major roads.

11. All n onparticipating persons shall be a minimum of 500 feet from the UAS.

12. If a nonparticipating person comes within 500 feet of the UAS, flight operations will cease immediately.

13. All UAS operations shall take place during daylight hours under conditions equival ent to Visual Flight Rules (VFR) with the UAS no more than 3/4 NM from the

PIC.

14. The UAS will yield to all manned aircraft at all times.

15. A pre

- flight inspection by the PIC will be performed prior to each flight to assure that the UAS is safe for flight. A p ost

- flight inspection will also be performed as an added level of safety. An aircraft check will also occur after every two hours of flight.

16. At no time shall the UAS be operated with missing or manufacturer unapproved parts, or in any condition that could pose a hazard to any other aircraft or structure or person on the ground.

17. The DJI Phantom 2 Vision has a weight of les s than 3 pounds, a length of 16 inches and a width of 16 inches, height of 8 inches, and has a max speed of 15 m/s mph

. 18. The DJI Inspire 1 has a weight of les s than 6.5 pounds, a length of 17.3 inches and a width of

17.3 inches, height of 11.8 inches, and has a max speed of 22 m/s mph

.

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.3 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b) 14 CFR § 91.215 14 CFR § 91.405 (a)14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b)

Flight Profiles

Dale Stagg ’ s flight profile varies per location , and not every flight path will be the s ame. Each flight will have a specific need for the services Dale Stagg provides. And with such a wide range of options for the company , a needs assessment will be provided to assure satisfaction as well as notification to proper authorities when needed. Often tim es I could provide services for social networking to promote the importance of the use of drones and the benefits they provide for other services

. T he use of the DJI Phantom 2 Vision and DJI Inspire 1 will provide a benefit to the general public and serve the public interest by providing the service of safe aerial photo graphic images and video to t he facility at considerably less money, noise and

visual awareness than the previously only available option of utilizing manned aircraft at an equivalent level of safety as well as minimize exposure of personnel and public in locatio ns during emergency responses in training or actual response to a situation

.

Conclusion

Dale Stagg is requesting an exemption for the purpose of providing aerial photography, videography, mapping, flare inspections , insurance claims, incid ent investigations, and

emergency response monitoring . This exemption would allow Dale Stagg to provide the aerial footage necessary for facility inspections

, a quicker turn around after a natural disaster, as well

as that other valued aerial photograph of facility property including emergency response planning, training and live responces for safe response without using personnel in hazardous

locations

. With over 2 years of UAV equipment experience, I fee l I am qualified to provide

this service as needed

.

## Appendix

S ection Subject Justification

14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft;

not suitable for off

- the

- shelf

UAS 14 CFR § 61.3 Requirement for pilot

certificate Part 61 requirements des igned for manned aircraft, not UAS;

p etition describes training for UAS operator 14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft;

not suitable for off

- the

- shelf

UAS 14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual

14 CFR § 91.103(b) Requirement for crew

members to be onboard Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls during flight instruction No one aboard to operate

controls 14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation

below these altitudes 14 CFR § 91.121 Altimeter settings No one aboard to read

altimeter 14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel
14 CFR § 91.203 (a) & (b) Requirement for registration

and airworthiness certificates

to be onboard No one aboard to read

certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read