James M. Sweeney I Chairman David M. Snelten I Secretary 

~AND SKILL 

IMPROVEMiN'I'PROGIWt\ Operating Engineers Loca/150 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

July 7, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption Request; Section 333 of the FAA Modernization & Reform Act and Part 11 

of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103; 

91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam, 

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

and 14 C.F.R. 11, ASIP Local 150 ("Petitioner") hereby applies for an exemption from Federal 

Aviation Regulations ("FARs") to allow commercial operation of-small unmanned aircraft 

systems ("sUAS") in airspace regulated by the Federal Aviation Administration ("FAA") for use 

in a variety of commercial applications so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

As described more fully below, the requested exemption would permit the commercial 

operation of sUAS under controlled conditions in airspace that is: 

1) limited; 2) predetermined; and, 3) controlled as to access. The exemption would also 

provide safety enhancements to the safe operations currently performed by those presently 

using conventional manned aircraft. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to 

" .... establish requirements for the safe operation of such aircraft systems in the national 

airspace system." Section 333(c) of the Reform Act. 

1. Name and Address of the Petitioner 

ASIP Local 150 

Attn: Martin Turek 

19800 W. South Arsenal Dr. 

Wilmington, IL. 60481 

Tel: 815.722.3201 

Email: mturek@asiplocal150.org 

79800 W. South Arsenal Road • Wilmington, IL 60481 • 815/722-3201 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

··-~~SJQU. 

····~~· . 

. ~ 

Operating Engineers Loca/750 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

Background 

ASIP Local 150 (ASIP) is a non for profit organisation under the supervision of the United 

States Department of Labor based in Wilmington IL. ASIP local150 specialises in education 

and training solutions for the construction industry. 

ASIP supports the development and application of Unmanned Aircraft Systems and robotics 

to satisfy Governmental and Commercial needs. Our program assists in providing public 

awareness for new career paths and education tracks that are new and evolving resulting 

through crossover technologies of robotics, air, ground and water. Following approval of this 

exemption request would enable ASIP the use of sUAS to conduct operations within a variety 

of industry/business applications such as education and training for the following industry 

sectors, education, aerial survey and imaging, ground maping,aerial inspection, power and 

pipeline patrol,search and rescue,mining survey, quarry survey, visual and infrared 

infrastructure inspection, general photography and special events, so long as such operations 

are conducted within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333. 

All flights will be conducted over our controlled access property or with the consent and 

knowledge of the property owner or controlling party. All flight operations will maintain a 500 

foot buffer from all nonparticipating persons, vessels, vehicles, and structures unless 

sufficient barriers are in place to protect nonparticipating persons from undue harm. Flight 

operations will also only be operated near vessels, vehicles, and structures where the 

property owner/controller has granted permission and a safety assessment has been made. 

All of ASIP flight operations will be conducted by pilots that are holding current FAA Private or 

Commercial Licenses with appropriate medical certificates. All visual observers (VO) will be 

trained to perform their required duties before flight operations begin. 

79800 W. South Arsenal Road • Wilmington, IL 60487 • 8751722-320 7 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKILL 

IMPROVEMENT PROGRAM Operating Engineers Loca/150 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

Regulations from which the exemption is requested, If such regulations apply to 

sUASs. 

14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 91.7(a); 

14 C.F.R. 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 C.F.R. 91.151(a); 

14 C.F.R. 91.203(a) & (b); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a) & (b). 

Statutory Authority for Exemptions 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes civil aircraft as the term is defined under §401 01 of the Act, 

including sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption in the public interest. 49 USC §44701 (f). See also 49 

USC §44711 (a); 49 USC §44704; 14 CFR §91.203(a)(1 ). 

Section 333(b) of the Reform Act assists the Secretary in determining whether sUAS may 

operate in the National Airspace System (NAS) without creating a hazard to the user, the 

public, or pose a threat to national security. In making this determination the Secretary 

must consider: 

• 

• 

• 

The sUAS's size, weight, speed, and operational capability; 

Whether the sUAS operates within visual line of sight of the operator; 

Operation of the sUAS in close proximity to airports and populated 

areas. 

Lastly, if the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." /d. §333(c). 

19800 W. South Arsenal Road • Wilmington, IL 60487 • 875/722-320 7 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKILL 

IMPROVEMENT PROGRAM Operating Engineers Loca/750 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

Unmanned Aircraft Systems 

Due to the low cost of operation, increased safety to surrounding persons and property, 

reduced noise and environmental impact, and the versatility of the sUAS platform, we believe 

that a sUAS can be a great solution to consumers who would, otherwise, have to hire a larger 

aircraft, such as a helicopter, in order to capture the data that they need. 

ASIP will maintain a maintenance log book for each sUAS that documents maintenance 

history. In addition to PIC pre-flight inspections conducted before each flight our personnel 

will conduct annual aircraft inspection and maintenance checks. This includes review of 

system and telemetry data files logged from prior flights, inspection for loose or worn 

components, balancing of props, cleaning of motors, battery voltage and cell balancing 

checks, etc., and performing any needed system repair and upgrades to include software/ 

firmware for the GPS, Flight Controller/Autopilot, Radio Transmitter, and Ground Control 

Station. All scheduled or unscheduled maintenance and repair actions are documented within 

the sUAS maintenance log book. Upon completion of any repair, modification or upgrade, the 

aircraft is test flown by a qualified PIC and documented within the maintenance log book prior 

to return to service. 

ASIP will equip each of its small unmanned multi rotor aircraft for aerial photography, primarily 

for use in the inspection of towers and inferstructure that would otherwise require great risk to 

the personnel involved in the inspection process, the stability and maneuverability of UASs 

afford additional public saftey not only to the personel contracted to do inspection bt to the 

greater pubic good through better maintained inferstructure, ASIPs sUASs may be used by 

law enforcement personnel, for search and rescue training as well by other first responders for 

other photography including video. 

As identified, similar lightweight, remote controlled sUAS's are legally operated by amateurs 

with no flight experience, safety plan or controls in place to prevent catastrophe. ASIP 

provides a level of safety at least equal to existing rules, and in nearly every instance, greater 

than existing rules. It is important to note that absent the integration of commercial sUAS's 

into our national airspace system, helicopters are the primary means of aerial photography. 

While the safety record of such helicopters is remarkably astounding, it is far safer to operate 

a battery powered lightweight sUAS. 

19800 W. South Arsenal Road • Wilmington IL 60481 • 8151722-3201 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKIU 

IMPROVEMENT PROGRAM Operating Engineers Local 7 50 Apprenticeship Fund 

•

.. 1!1 I • P' 

1!1 . 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

Secondary Documentation 

The following secondary documentation is provided for reference as supplemental 

information pertaining to this Petition: 

1. ASIP sUAS Flight Standards 

2. ASIP Preflight Inspection & Operations Check List 

3. Phantom 3 Professional User Manual 

4. Blade Chroma RTF User Manual 

5. Blade 180 QXHD RTF 

6. MAVinci SIRIUS sUAS User Manual 

7. SenseFiy EBee sUAS User Manual 

These documents will be retained at the ground control point accessible by the pilot in 

command (PIC). 

ASIP proposes within this petition the use of three different Muti Rotors sUAS platforms, 

DJI'sPhantom 3 Professional and Horizon Hobbie's Blade Chroma, and Blade 180 QXHD and 

two Fixed wing sUAS platforms MAVinci,s SIRIUS, and SenseFiy E-bee to support varied 

mission, payload configurations, and training purposes, 

General specifications are as follows: 

• Phantom 3 Professional 

Airframe: 

Weight: 

Propulsion: 

Propellers: 

Power: 

Speed: 

Flight Time: 

Autopilot: 

Data Link: 

Video: 

Telemetry: 

Quad X Rotor- 960mm Diameter 

1280g 

Four 920 KVEiectric Motors 

plastic 8"_ 

15.2 Volt, (4S) Lithium-Polymer 

0- 31 knots 

23 minutes 

GPS/GLONASS 

FCC approved 2.4 GHz 

FCC approved 5.8 GHz 

Voltage, Current, Altitude, GPS Lat/Long, Ground Speed 

• Blade Chroma: 

Airframe: 

Weight: 

Propulsion: 

Propellers: 

Power: 

Speed: 

Flight Time: 

Autopilot: 

Data Link: 

Video: 

Telemetry: 

Quad Rotor 580mm Diameter 

45.9 oz 

Four 780KV Electric Motors 

Carbon Fiber 1 0" 

11.1 Volt, (3SJ Lithium-Polymer batteries 

0-45 knots 

30 minutes 

GPS/GLONASS 

FCC approved 2.4 GHz _ 

FCC approved 5.8 GHz 

Voltage, Current, Altitude, GPS Lat/Long, Ground Speed 

19800 W. South Arsenal Road • Wilmington, /L 60481 • 8151722-3201 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKILL 

IMPROVEMENT PROGRAM Operating Engineers Loca/750 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiplocal750.org 

• 

I ' P' 

[!] . 

• Blade 180 QXHD RTF (used for learning flight controls) 

Airframe: 

Weight: 

Propulsion: 

Propellers: 

Power: 

Speed: 

Flight Time: 

Autopilot: 

Data Link: 

Carbon Fiber Hex Rotor- 355mm Diameter 

3.35 oz 

Four Electric Motors 

136MM 

7 Volt, (1 S) Lithium-Polymer batterie 

0-25 knots 

5 minutes 

GPS Flight Controller/Autopilot 

FCC approved 2.4 GHz 

MAVinci SIRIUS 

Airframe: 

Wingspan: 

Weight: 

Propulsion: 

Power: 

Speed: 

Flight Time: 

Autopilot: 

Data Link: 

Fixed high wing with convetional tail 

163cm 

6 pounds 

Single 900W Brushless DC Motor 

18.5 Volt, (4S) Lithium-Polymer batterie 

0-35 knots 

45 minutes 

GPS/IMU aided 

FCC approved 2.4 GHz 

• Sensef/y E-Bee 

Airframe: 

Wing Span: 

Weight: 

Propulsion: 

Power: 

Speed: 

Flight Time: 

Autopilot: 

Data Link: 

Fixed Swept Wing Pusher Prop 

96cm 

1.52 pounds 

160W Brushless DC Motor 

11.1 Volt, (3SJ Lithium-Polymer batteries 

0-49 knots 

50 minutes 

GPS/GLONASS 

FCC approved 2.4 GHz 

7 9800 W. South Arsenal Road • Wilmington, /L 6048 7 • 8 7 5/722-320 7 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENnCESHIP AND SKILL 

IMPROVEMENT PROGRAM Operating Engineers Loca/750 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/150.org 

Operation of the Unmanned Aircraft 

The PIC will be an FAA licensed airman with at least a private pilot's certificate and third 

class medical. Additionally, the PIC will have a minimum of 10 hours sUAS multi rotor 

experience of which at least 5 hours are with the specific make/model sUAS to be operated 

per the ASIP Preflight and Operations Checklist, to ensure the sUAS is in safe condition for 

flight. 

The pre-flight will include physical inspection of components, battery voltage level checks, 

motor run-up, payload system, ground control station and communications checks in 

preparation of flight. If the inspection reveals a condition that prohibits safe operation, the 

PIC will remove the aircraft from service until the necessary maintenance has been 

performed and documented and the sUAS is found to be in a condition for safe flight. 

Training of PIGs who do not meet the sUAS multirotor experience will be gained within 

dedicated training sessions through use of a multirotor computer simulator (ground training) 

and the sUAS platform(s) (logged flight time) as requested through this exemption. 

Flight currency will be maintained by the PIC having logged 30 minutes flight time within the 

proceeding 90 days with the specific make/model UAS platform. Regaining currency will be 

achieved in dedicated training/currency sessions. In addition to flight proficiency, the PIC 

will be trained in use of the radio control transmitter, ground control station, pre-flight 

inspection of the sUAS, and operational procedures per ASIP sUAS Flight Standards 

document paraphrased as follows. 

Minimum crew for each flight operation will consist of the sUAS PIC and Visual Observer 

(VO). Flights will be conducted within VLOS of the PIC at all times with VO duties assisting 

PIC in maintaining VLOS and situational awareness of obstructions, hazards and avoiding 

other aircraft. Communication between the PIC and VO wi!l be maintained through direct 

voice communications and/or through use of two-way radio or cell phone throughout the 

duration of flight. 

Prior to each flight the PIC will conduct a thorough pre-flight inspection, per the ASIP Preflight 

and Operations Checklist, to ensure the sUAS is in safe condition for flight. 

19800 W. South Arsenal Road o Wilmington, /L 60481 o 8151722-3201 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKILL 

IMPROVEM£NT PROGRAM Operating Engineers Loca/150 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

The pre-flight will include physical inspection of components, battery voltage level checks, 

motor run-up, payload system, ground control station and communications checks in 

preparation of flight. If the inspection reveals a condition that prohibits safe operation, the 

PIC will remove the aircraft from service until the necessary maintenance has been 

performed and documented and the sUAS is found to be in a condition for safe flight. 

The PIC will conduct pre-flight planning to include obtaining weather briefings, identifying 

hazards and obstructions, and establishing predetermined mission flight path and limited and 

controlled area for safe operation. The Petitioner will submit to the Air Traffic Organization 

(ATO) a Certificate of Waiver or Authorization (COA) prior to conducting any flight operations. 

The Petitioner will request a Notice to Airman (NOT AM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. 

All flight operations will be conducted within a limited area that is strictly controlled over 

private or controlled-access property with permission from the land owner or their authorized 

representative for each flight to be conducted. The PIC will conduct pre-flight safety 

briefings with all personnel supporting flight activities in regard to the planned sUAS 

operations and mission plan prior to each flight. Flight operations will typically be conducted 

at least 500 feet from all nonparticipating flight operation people, vessels, vehicles, and 

structures unless there are barriers or structures that safely protects nonparticipating 

persons in event of accident. In the event nonparticipating persons leave such protection 

and are within 500 feet of the sUAS, the PIC will immediately cease flight operations. 

Additionally, if owner of vessels, vehicles, or structures provides permission and the PIC 

determines safe operations can be conducted with undue risk to operating personnel then 

flight operations may be conducted closer than 500 feet. 

ASIP will not conduct flight operations over congested or densely populated areas, or within 

5 miles of an airport unless a letter of agreement is obtained from the airport management 

and per NOT AM. All flights will be conducted under visual meteorological conditions (VMC) 

during daylight hours, at less than 50 knots airspeed and an altitude no greater than 500 

feet AGL, and will 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. Maximum flight time for each operational flight will be 40 minutes and 

allowing for no less than 20% battery as indicated by real-time telemetry voltage/current 

data relayed by the aircraft sensors to the PIC control station. 

In event the PIC losses data link communications, the GPS equipped sUAS have the 

capability to return to a pre-determined location and land and provides the PIC capability 

to abort flight and initiate loiter and return-to-home functions. If an in-flight emergency 

occurs, the PIC will immediately abort flight and initiate landing procedures. 

79800 IN. South Arsenal Road o Wilmington IL 60487 o 8751722-320 7 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKILL 

IMPROVEMENT PROGRAM Operating Engineers Loca/150 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/150.org 

By adhering to these operational procedures, ASIP will achieve a safety level equivalent to, 

or greater than that, directed by the rules in which they seek exemption. sUAS are inherently 

safer in all facets due to the fact they are much smaller, fly at much slower speeds, have no 

human operators or occupants on board and no flammable fuels to be concerned of in event 

of crash. As sUAS processes are further refined, and commercial flight experience gained, 

the operations will serve to enhance an already higher level of safety compared to manned 

flight operations in which serves the public's best interest in the FAA's pursuit to integrate 

UAS into the NAS. 

Due to the small size of the sUAS involved, ability of the PIC to control and set flight 

parameters, and the controlled and limited environment in which they will operate, the 

Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of 

sUAS to commence immediately. Additionally, due to the Private Pilot rating of the PIC, 

the size of the sUASs, limited payload capacity and flight durations, the use of batteries 

versus flammable fuels, and the limited and tightly controlled areas in which the sUASs will 

operate, approval of the application presents no national security issue. 

Given the clear direction in FRMA §333, the authority contained in the Federal Aviation Act, 

as amended, the strong equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in environmental impacts 

due to battery operation, and reduced costs of sUAS aircraft assets as compared to 

conventional aircraft, the grant of the requested exemptions is in the public interest. 

Accordingly, Advanced Robotics respectfully requests that the FAA grant the requested 

exemption without delay. 

Description of Specific Regulations 

Pursuant to 14 C.F.R. § 11.81 (e), ASIP seeks exemption from the below mentioned 

regulations and provides reason as to why the exemption should be approved based on the 

level of safety at least equal to that of which the rules require. 

• 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates 

~ Establishes: The procedural requirements for the issuance of 

airworthiness certificates as required by 14 C.F.R. § 

91.203(a)(1) 

19800 W. South Arsenal Road • Wilmington, IL 60481 • 8751722-3201 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SIOLL 

. IMPilOVIMiftTPROGRAM Operating Engineers Local 7 50 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiplocal150.org 

Given the small size of the sUAS, the controlled operating areas, limitations and 

conditions ASIP will adhere to during flight operations, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the "Reform Act" with consideration "of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular 

sUAS." 

• 14 C.F.R. § 45.23(b)- Aircraft Marking and Identification 

Requirements 

);;> 14 C.F.R. § 45.23{b), Markings of the Aircraft, states: 

When marks include only the Roman capita/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. 

The sUAS to be flown by ASIP have no airworthiness certificate, an exemption may 

be needed as the sUAS have no entrance to the cabin, cockpit, or pilot station on 

which the word "Experimental" can be placed. The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

• 14 C.F.R. § 61.113(a) and {b): Private Pilot Privileges and 

Limitations: Pilot in Command 

);;> Sections 61. 113 (a) and (b) limit private pilots to noncommercial 

operations. 

Because the sUAS will not carry a pilot or passengers, the 

proposed operations can achieve the equivalent level of safety 

of current operations by requiring the PIC operating the aircraft 

to have a private pilot's license rather than a commercial pilot's 

license to operate a sUAS. Unlike a conventional manned 

aircraft, a sUAS is remotely controlled by a ground-based 

operator. The operational area is controlled and restricted, and 

all flights are planned and coordinated in advance. The level of 

safety exceeds that provided by a single individual holding a 

commercial pilot's certificate operating a conventional aircraft. 

The risks associated with the use of a sUAS are so diminished 

from the level of risk associated with commercial operations 

contemplated by Part 61 allowing sUAS use by a private pilot 

as the PIC exceeds the present level of safety sought by 14 

C.F.R. §61.113 (a) and (b). 

19800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201 ~36 
•

. . 1!1 I • P' 

[!] . 

James M. Sweeney I Chairman David M. Snelten I Secretary 

Operating Engineers Loca/150 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiplocal750.org 

• 14 C.F.R. 91.7(a)- Civil Aircraft Airworthiness 

~ No person may operate a civil aircraft unless it is in an airworthy condition. 

There is no airworthiness certificate for the sUAS to be operated by ASIP To 

provide an equivalent level of safety, the PIC will conduct pre-flight inspections to 

ensure airworthiness. During flight, the PIC will adhere to§ 91.7(b) and abort air 

operations immediately upon identification of an in-flight anomaly or emergency. A 

Licensed A&P will conduct annual inspections. Maintenance log books will be 

maintained for each sUAS thereby achieving an equivalent level of safety. 

• 14 C.F.R. § 91.9 {b) (2): Civil Aircraft Flight Manual in the Aircraft. 

~ Section 91.9 (b) (2) provides: No person may operate a U.S.- registered 

civil aircraft .. (2) For which an Airplane or Rotorcraft 

Flight Manual is not 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. 

The sUAS, given their size and configuration have no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft platform. The 

equivalent level of safety will be maintained by keeping the sUAS documentation at 

the ground control point where the PIC will have access to it. The FAA has issued 

the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A,9565,95658, 10167, 10167A, 10602,32827,and 10700. 

• 14 C.F.R. 91.103- Pre-flight Action 

~ Each pilot in command shall, before beginning a flight, become familiar with 

all available information concerning that flight. This information must 

include- (paragraphs a, b, 1 and 2) 

The PIC will take all actions, to include flight and mission planning, reviewing 

weather, flight battery requirements, safe take-off and landing areas, and aircraft 

performance data before commencement of flight. In addition, the PIC will verify the 

sUAS is ready for flight by conducting a pre-flight inspection and run up of systems 

and data-link communications checks prior to each flight. 

The exemption requested for this section is specifically addressed 

19800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201 ~36 
~~ 

. · AfiPRENTICESHIP AND SKIU 

IMPROVEMENT PROGRAM 

I~ 

IUINOIS 150 

r- NORTHERN 

INDIANA 

·James M. Sweeney I Chairman David M. Snelten I Secretary 

Operating Engineers Loca/150 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiplocal7 SO.org 

toward the requirements which do not apply to sUAS operations such as runways 

and air traffic control integration. The airport manager will be notified and approval 

obtained prior to any operations being executed less than five statute miles of an 

operating airport. 

14 C.F.R. §91.109: Flight instruction 

~ Section 91.109 provides that no 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. 

sUAS and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a radio transmitter or 

ground control station that communicates with the aircraft via a receiver in the sUAS. 

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption numbers 5778K & 9862A. The equivalent level of safety provided by the 

fact that neither a pilot nor passengers will be occupants in the aircraft and by the 

small size and slow speed of the sUAS. 

• 14 C.F.R. 91.119- Minimum Safe Altitudes 

~ Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (c) Over other than congested areas. 

An altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. This exemption is for a sUAS and the 

exemption requests authority to operate at altitudes up to 500 AGL underneath 

navigable airspace and in class E and G airspace maintaining safe separation from 

manned aircraft, an exemption may be needed to allow such operations. 

sUAS as well as the limited and controlled location where it is operated. 

Compared to flight operations with manned aircraft weighing far more than the 

maximum 55 pounds proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with 

conventional manned aircraft. In addition, the low-altitude operations 

79800 W. South Arsenal Road • Wilmington, IL 60481 • 8751722-3201 ~36 
James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKILL 

IMPROVEMENT PROGRAM Operating Engineers Loca/750 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiplocal750.org 

The equivalent level of safety will be achieved given the size, weight, speed of 

theof the sUAS will ensure separation between it and operations of conventional 

manned aircraft that must comply with Section 91.119. 

• 14 C.F.R. §91.121 Altimeter Settings 

>- This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set " ... to the elevation of 

the departure airport or an appropriate altimeter setting available before 

departure." 

As the sUAS do not have an adjustable barometric altimeter an exemption is 

required. An equivalent level of safety will be achieved by the PIC, confirming the 

altitude of the launch site via the sUAS GPS. 

• 14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR 

Conditions 

>- 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; 

This regulation is written based on the capabilities of a traditional aircraft which 

have flight times of several hours or greater; therefore, with the majority of sUAS 

which have flight times of only an hour or less, this regulation would effectively 

deny the ability of the air vehicle to operate. 

To meet the intent, ASIP, will limit its sUAS flights to 40 minutes, or no less than 

20% remaining battery power, which ever occurs first, to ensure safe landing and 

retrieval of the air vehicle and providing at least an equal level of safety. Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 

57 45, 1 0673, and 10808. 

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

Registration 

>- The regulation provides in pertinent part: 

(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. 

79800 W. South Arsenal Road • Wilmington, IL 60481 • 8151722-3201 ~36 
. 

~~ 

· ·APf»RRNTTCESMi AND SKILL 

1MI'ROVIMENT PROGRAM 

~ 50 

N 

A 

James M. Sweeney I Chairman David M. Snelten I Secretary 

Operating Engineers Loca/750 Apprenticeship Fund 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

The sUAS fully loaded weighs no more than 55 lbs. and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point 

where the PIC will have immediate access to them, to the extent they are applicable 

to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption numbers 9565, 9665, 

9789, 9789A, 9797, 9797A, 9816A, and 10700. 

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) Maintenance 

Inspections 

};> 91.405(a) States: Each owner or operator of an aircraft-( a) 

Shall have that aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections, except as provided in paragraph 

(c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter. 

};> 91.407(a)(1) States: (a) No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or 

alteration unless-(1) It has been approved for return to service by a 

person authorized under§ 43. 7 of this chapter. 

;. 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, 

no person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had-(2) An inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. No inspection 

performed under paragraph (b) of this section may be substituted for any 

inspection required by this paragraph unless it is performed by a person 

authorized to perform annual inspections and is entered as an "annual" 

inspection in the required maintenance records. 

};> 91.417(a) & {b) States: (a) Except for work performed in accordance with 

§§ 91.411 and 91.413, each registered owner or operator shall keep the 

following records for the periods specified in paragraph (b) of this section: 

(paragraphs 1 (i- iii), 2 (i- vi)); (b) The owner or operator shall retain the 

following records for the periods prescribed: (paragraphs 1 - 3) 

Pre-flight inspections and routine maintenance will be accomplished by the PIC to 

ensure the sUAS is in good working order prior to flight. 

19800 W. South Arsenal Road • Wilmington IL 60481 • 8151722-3201 ~36 
;·----------·~=========================================== 

James M. Sweeney I Chairman David M. Snelten I Secretary 

APPRENTICESHIP AND SKilL 

IMPROVEMENT PROGRAM Operating Engineers Loca/750 Apprenticeship Fund 

Local 

• 

I • P' 

[!] . 

A Joint Effort of Labor and Management to Further the Aim of Industry 

www.asiploca/7 SO.org 

If mechanical issues or emergency situations arise the sUAS can land immediately 

and given its small size poses very little risk to persons or property. Upon completion 

of any repair, modification or upgrade, the aircraft is test flown by a qualified PIC and 

documented within the maintenance log book prior to return to service. Annual 

inspections and maintenance will be conducted and documented within the sUAS 

maintenance log book by licensed A&P personnel to meet the intent of these 

regulations and provide an equivalent level of safety. 

9. Summary the FAA may publish in the Federal Register 

ASIP seeks an exemption from the following Regulations: 14 C.F.R. Part 21; 14 

C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) 

(2); 91.1 03; 91.1 09; 91.119; 91.121; 91.151 (a); 91.203(a)&(b ); 91.405(a); 

91 .407 (a) ( 1 ); 91 .409( a) (2 ); 91 .417 (a )&(b) to commercially operate its small 

unmanned aircraft systems to support a variety of industry and business 

applications, to include, but not limited to, Education and Training, Survey/ 

Inspection and Imaging, Agricultural, Forestry, Law Enforcement, and Search and 

Rescue. Granting ASIP request for exemption will reduce current risk levels and 

thereby enhance safety. 

Further, ASIPs sUAS operates at lower altitudes, up to 500 feet AGL, in 

predetermined and controlled airspace, weighing less than 55 pounds and traveling at 

speeds less than 50 knots. They will provide at least an equivalent level of safety as 

that achieved under current FARs. 

ASIP Local 150 respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to issue the exemption sought by ASIP Local150 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Martin Turek 

ASIP Local150 

19800 W. South Arsenal Dr. 

Wilmington IL. 60481 

Tel: 815.722.3201 

Email: mturek@asiplocal150.org 

79800W.SouthArsena!Road • Wifmington,IL60481 • 8151722-3201 ~36