DALE STAGG

HUNTSMAN PETROCHEMICAL

2701 SPUR 136

PORT NECHES, TEXAS 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

videography and 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 exemption. Dale Stagg would 

provide a service in the aerial photography and videography field for Huntsman Petrochemical Sites

usage. Dale Stagg will provide a low cost business alternative to Huntsman Petrochemical

manufacturing 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, automatic

landing should signal between PIC and UAS be interrupted, GPS based altitude and distance 

locks, Flight Limits function and low battery warnings at 20% 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 equivalent 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 5700mah 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 nonparticipating 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

equivalent 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 post-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 less than 3 pounds, a length of 16 inches and a

width of 16 inches, height of 8 inches, and has a max speed of 15m/s mph.

18. The DJI Inspire 1 has a weight of less 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 22m/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 same. 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 times I could provide services 

for social networking to promote the importance of the use of drones and the benefits they 

provide for other services. The 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 photographic images and video to the 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 locations 

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, incident 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 feel I am qualified to provide 

this service as needed. 
Appendix 

Section 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 designed 

for manned aircraft, not UAS; 

petition 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