GARNER ENVIRONMENTAL SERVICES, INC.

CORPORATE OFFICE : 1717 W. 13TH STREET, DEER PARK, TX 77536  281

- 930

- 1200  800

- 424

- 1716

March 25, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request under Section 333 of the Federal Aviation Administration Modernization and Reform Act of 2012 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) and 14 C.F.R. Part 11, Garner Env ironmental Services, Inc., operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for the purpose of emergency response to incidents involving hazardous materials, industrial services, disaster services and support, to pographical surveying, and mapping, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein o r as may be established by the FAA as required by Section 333.

These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure specifically, a safety enhancement to aerial imagery and videography conducted by manned aviation operations.

The use of Small Unmanned Aerial Systems (“sUASs”) for aerial imagery and videography by Garner Environmental Services, Inc. reduces the need to use manned aircraft activities to perform the same f unction. Furthermore, the ability to use sUASs reduces the exposure risk to personnel operating in a hazardous environment by negating the need to make reconnaissance entries into areas without adequate intelligence. Therefore, it is in the best

interest o f the Public for the FAA to approve the requested exemptions.

Sincerely,

Thomas Dickey sUAS Manager Garner Environmental Services, Inc.

1717 West 13 th Street Deer Park, Texas 77536 (281)930

- 1200

Page 1 of 15UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTAT ION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.______________________________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: GARNER ENVIRONMENTAL SERVICES, INC.
FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a), 61.133(b), 91.119(c), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1)&(2), 91.417(a), 121 CONCERNING OPERATION OF UNMANNED
AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND
REFORM ACT OF 2012

Submitted on ________________________

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Page 2 of 15Table of Contents

Glossary of Abbreviations

........................ ......... .................................................4

List of Attachments........................

......... ..........................................................5

Introduction and Interest of Petitioner.............................................

......... ...........5

Unmanned Aerial Systems.................................................................................5

Unmanned Aircraft Pilot in Co mmand (PIC)..........................................................7

Operation of sUAS...

.............................................................................. . ..........8

Requested Exemptions from Re gulations...........................................................10

Public Interest......... ........................................................................................13

Conclusion............... ......................................................................................14

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Page 3 of 15Glossary of Abbreviations

AGL Above Ground Level
ATC Air Traffic Control
COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation
NAS National Airspace System
NOTAM Notice To Airmen
PIC Pilot in Command
PQS Personnel Qualification System
Section 333 FAA Moderniza tion and Reform Act of 2012, Section 333
SOP Standard Operating Procedures
sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules
VMC Visual Meteorological Conditions
VO Visual Observer
VLOS Visual Line of Sight

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Page 4 of 15List of Attachments

(1) DJI Phantom 2 Operating Manual

(2) DJI S1000 Operating Manual

(3) DJI Ground Station User’s Manual

(4) DJI 5.8Ghz Bluetooth Link Manual

(5) FAA Registration for DJI Phantom 2 Number N5334G

(6) FAA Registration for DJI S1000 Number N534VG

The six attachments listed are referenced in the request for exemption and contain trade secret and commercial proprietary information that Garner Environmental Services, Inc. has not and will not share with others except under appropriate confidentiality agreemen ts. The Garner Environmental Services, Inc. Health and Safety Manual attachment contains operating conditions and procedures that have been developed exclusively by Garner Environmental Services, Inc., and that are not available to the public. Garner Envir onmental Services, Inc. is requesting that these attachments be treated as proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that they are protected from release under the Freedom of Information Act. See 5 U.S.C. 555 et seq.

Secti on 1: Introduction and Interest of Petitioner

Garner Environmental Services, Inc. is a leading provider of emergency response services for oil spills, hazardous materials releases, and natural and man

- made disasters. Furthermore, Garner

Environmental Services, Inc. provides industrial services to the petrochemical industry, including inspections, mapping, aerial imagery, and reconnaissance for incidents. Our safety record and professionalism for every job is what has set us apart as an emergency respon se company.

Garner Environmental Services, Inc. does not currently have any FAA approved COAs. However, we will be filing following this exemption request

.

Section 2: Unmanned Aerial Systems

General Information Pertaining to All Proposed sUAS

Garner En vironmental Services, Inc. will operate less than fifty five pound sUAS, with the ability to conduct aerial imagery and videography, with payloads capable of supporting this mission.

Prior to each flight, the PIC shall inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the sUAS is

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Page 5 of 15found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in aircraft records. All discrepancies noted shall be documented as described in the Garner Environmental
Ser vices, Inc. Health and Safety Plan.

Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, shall undergo a functional test flight in accordance with the manufacturer’s manual and the Garner Environmental Services, Inc. Health and Safety Plan. The PIC who conducts the test flight shall make an entry in the sUAS aircraft logbook of the flight.

Garner Environmental Services, Inc. shall follow the manufacturer’s sUAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals.

Garner Environmental Services, Inc. shall carry out their maintenance, inspections and record keeping requirements, in accordance with the operator’s manual. Maintenance, inspection, and alterations must be noted in the aircraft log book, including total flight h ours, description of work accomplished, and the signature of the authorized maintenance technician returning the sUAV to

service.

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and Safety Bulletin.

Garner Enviro nmental Services, Inc. technicians will receive and document training referenced in the manufacturer’s operations manual.

Garner Environmental Services, Inc. technicians shall make a record entry in the sUAS logbook or equivalent document of the correctiv e action taken against discrepancies discovered between inspections.

Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS shall comply with the Federal Communications Commission (FCC) or other appropriate

g overnment oversight agency requirements.

DJI Phantom 2

Garner Environmental Services, Inc. seeks an exemption to operate DJI Phantom 2 sUAS, for compensation or hire. The DJI Phantom 2 is comprised of a quad rotor unmanned aircraft and a handheld gr ound control station. The Phantom 2 has a maximum gross weight of approximately 2.8 pounds, diameter (rotor span) of 23.75 inches, width of 12.5 inches, and a height of 8.1

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Page 6 of 15inches. The Phantom 2 is equipped with four rotors driven by four lithium polymer b attery powered electric motors.

Design and operational characteristics are provided in DJI Phantom 2 Operating Manual (Page 35). Flight crews shall conduct pre

- flight inspections as documented in Garner Environmental Services Health and Safety Plan and DJ I Phantom 2 Operating Manual (Page 24).

DJI S1000

Garner Environmental Services, Inc. seeks an exemption to operate a DJI

- S1000 sUAS for compensation or hire. The DJI S1000 is comprised of a multi

- rotor unmanned aircraft and two handheld ground control stations. The DJI

- S1000 has a maximum gross weight of approximately 24 pounds, diagonal wheelbase of 41.4 inches, and a height of approximately 18 inches. The DJI

S1000 is equipped with eight rotors driven by eight lithium polymer battery powered electric

motors.

Design and operational characteristics are provided in DJI

- S1000 Operating Manual (Page 22). Flight crews shall conduct pre

- flight inspections as documents in Garner Environmental Services Health and Safety Plan and DJI S1000 Operating Manual (Page 4).

Section 3: Unmanned Aircraft Pilot in Command (PIC)

All Garner Environmental Services, Inc. flight crews, including PIC and visual observers (VO), will be qualified as directed by the Garner Environmental Services, Inc. Health and Safety Plan.

All flight crew members, including the PIC and VO, will have an understanding of, and comply with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, applicable to the airspace where the sUAS will operate. Specifically, all fl ight crew members will receive training on the rules and responsibilities described in 14 CFR Part 91 Section 91.111, 91.113, and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including standard ATC phraseology and communication.

The PIC must possess at least a second class airman medical certificate and a Garner Environmental Services, Inc. Qualification Card for the specified aircraft. Additionally, the PIC must have completed an FAA

- approved Ground School for Pri vate Pilots, have attended advanced manufacture’s training, and have logged a minimum of 25 hours of total time as an sUAS pilot and at least ten hours as an sUAS pilot with a similar sUAS type (fixed wing or rotary).

Prior documented flight experience t hat was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience building flights are requested to be conducted under this grant of exception to accomplish the required flight cycles and flight time. During training, proficiency, and experience building flights, all persons not essential for flight operations will be considered non

- participants and the PIC will operate the sUAS with appropriate distance from non

- participants in accordance with 14 CFR Section 91.119.

Prior to operations conducted for the purpose of aerial imagery and videography (or similar operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR

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Page 7 of 15Section 61.51(b), a minimum of five hours as an sUAS PIC operating the make and model of the sUAS to be utilized for operations under this request exemption, and three take

- offs and landings in the preceding 90 days. Training, proficiency, experience building, and take

- off and landing currency flights are re quested to be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience building, and

take

- off and landing currency flights, all personnel not essential for flight operation s are considered non

- participants, and the PIC must operate the sUAS with appropriate distance from

the non

- participants in accordance with 14 CFR Section 91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VL OS) requirements as along as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. This condition and limitation is consistent with all FAA approved exemptions.

Section 4: Operation of sUAS

The sUAS s hall remain clear and yield the right of way to all other manned aviation operations

and activities at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes reported to ATC will be in feet.

The multi

- rotor sUAS shall not be flown at a ground speed exceeding 30 mph.

sUAS operations will be conducted under visual meteorological conditions (VMC). The sUAS will not be operated less than 500 feet below or less than 2000 feet horizontally from a c loud or when visibility is less than 3 statute miles from the PIC.

If the sUAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with Garner

En vironmental Services Health and Safety Plan.

The sUAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with operating documents.

The sUAS PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed t the intended landing point and land the sUAS with 25% battery power remaining.

The sUAS operated in accordance with this proposed exemption shall be identified by serial numbers, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practical.

The sUAS documents required under 14 CFR 91.9 and 91.203 shall be ava ilable to the PIC at the Ground Control Station of the sUAS anytime the aircraft is operating. Those documents shall be available to the Administrator or any law enforcement official upon request.

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Page 8 of 15Any sUAS incidents, accidents or flight operations that tr ansgress the lateral or vertical boundaries of the operational area as defined by the applicable COA shall be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board (NT SB) per instructions on the NTSB web

site: www.ntsb.gov

.

Unless otherwise specified in this petition, the sUAS PIC and the sUAS operations shall comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61 and 91.

The sUAS shall not be operated over congested or densely populated areas. These areas include, but are not limited to, the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Te rminal Area Charts (TAC). Each work site will

also be evaluated based on local conditions.

Operations of sUAS may be conducted at distances less than 500 feet from participating persons,

vessels , vehicles, or structures that perform an essential function in connection with these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons are permitted when operationally necessary ; but never so close to present an

undue hazard. This is consistent wit h Exemption No. 11138.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such permission, and the PIC makes a safety assessment of the risk from the operations and determines that it does not present an undue hazard to persons or property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all non

- participating perso ns unless barriers or structures are present that sufficiently protect non

- participating persons from the sUAS
and/or debris in the event of an accident. Garner Environmental Services, Inc. shall ensure that

non

- participating persons remain under such protection. If a situation arises where non

participating persons leave such protection and are within 500 feet of the sUAS, flight operations will cease immediately. This is consistent with Ex emption No. 11138.

All operations of sUAS shall be conducted with the permission from the land owner/controller or authorized representative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be con ducted.

The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a

current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in acc ordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request. This is consistent with Exemption No. 11159.

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC to be able to use human vision to see the sUAS unaided by any device other than corrective lenses, as specified on the PIC’s FAA issued medical certificate.

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Page 9 of 15All sUAS operations must utilize a VO. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC and the VO must be designated before the flight and cannot transfer his or her designati on for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in Garner Environmental Services, Inc. Health and Safety Plan.

The sUAS will not be operated by the PIC from any moving device or vehicle. Operations w ill not be conducted at night as defined in 14 CFR 1.1.

Garner Environmental Services, Inc. will conduct preflight safety risk assessments to determine that the sUAS is in a condition for safe flight (14 CFR Section 91.7(B)) and that the planned operations can be completed safely. Specific procedures are addressed in Garner Environmental
Service s, Inc. Health and Safety Plan and the sUAS Operators Manual.

Should operations require a notification to the Flight Standards District Office, such as pipeline or power line patrol, Garner Environmental Services, Inc. will notify the appropriate office v ia letter of intent at least 72 hours prior to the operation.

Garner Environmental Services, Inc. shall obtain an Air Traffic Organization issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this requested grant of exemption. Additionally, Garner Environmental Services, Inc. will request a Notice to Airmen (NOTAM) not more than 72 hours, but not less than 48 hours prior to the operation.

Section 5: Requested Exemptions from Regulations

Considered Regulation Title Recommended Action

14 CFR Part 21.185 Airworthiness Certificate Garner Environmental Services, Inc. recommends
that in consideration of the size, weight, speed and limited operating area

associated with these aircraft and their operation, the Secretary of Transportation
determines that these aircraft
meet the conditions of Section

333. Relief is not necessary.

14 CFR Part 45.23 (b) Display of marks Garner Environmental Services, Inc. sUAS shall 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.

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Page 10 of 15Markings will be as large as practical. Relief is not

necessary. 14 CFR Par t 61.113(a) Private pilot privileges and

limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with

limitations and conditions specified in this petition. 14 CFR Part 61.133(b) Commercial pilot privileges

and limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate opera ting a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with

limitations and conditions specified in this petition. 14 CFR Part 91.7(a) Civil Aircraft Airworthiness Garner Envir onmental Services, Inc. recommends

that in consideration of the size, weight, speed and limited operating area

associated with this aircraft and its operation, the Secretary of Transportation

determines that these aircraft
meet the conditions of Section

33 3. Relief is not necessary. 14 CFR Part 91.9(b)(2) &(c) Civil Aircraft Flight Manual, Marking, and Placard Requirements The FAA has previously
determined that relief from

these sections is not necessary. Relevant materials may be kept in a location
accessible to the PIC in compliance with the regulations. Relief is not

necessary.

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Page 11 of 1514 CFR Part 91.103 Preflight Action Garner Environmental Services, Inc. will perform. Relief is not necessary.

14 CFR Part 91.109(a) Flight Instruction Garner Environmental Services, Inc. will conduct all flight training through procedures specified in Training Instruction during dedicated training sessions. Based on previous decisions made by the FAA for sUAS petitions regarding this regulation, relief is not

necessary. 14 CFR Part 91.11 9(c) Minimum Safe Altitude Aircraft will be operated below 400 AGL, but not over congested areas. Request

relief with limitations and conditions specified in this petition.

14 CFR Part 121 Altimeter Settings The proposed aircraft have a

barometric altimet er and GPS derived altitude capabilities.
Garner Environmental Services, Inc. recommends

that the altimeter be set to
zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed

oper ations, request relief

with limitations and conditions specified in this petition. 14 CFR Part 91.151(a) Fuel Requirements in VFR Prior relief has been granted

for manned and unmanned aircraft to operate at less than prescribed minimums. Request relief with

limitations and conditions specified in this petition. 14 CFR Part 91.203(a) and (b) Certifications Required Original intent of these regulations was to display an aircraft’s airworthiness,

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Page 12 of 15certification and registration documents so they would be

ea sily available to inspectors and passengers. Based on

the FAA Memorandum subject, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, relief is not necessary.

14 CFR P art 91.405(a) Maintenance Required Request relief with

limitations and conditions specified in this petition. 14 CFR Part 91.407(a)(1) Operation After Maintenance Request relief with

limitations and conditions specified in this petition.

14 CFR Part 91.4 09(a)(1) and (2) Inspections Request relief with

limitations and conditions specified in this petition. 14 CFR Part 91.417(a) and (b) Maintenance Records Request relief with

limitations and conditions specified in this petition.

Public Interest

Garner Environmental Services, Inc. operations of sUAS to perform aerial imagery and videography will reduce risk to life and property by decreasing the requirements of personnel to operate manned aircraft to perform these tasks. Garner Environmental Services, Inc. will use battery

- powered sUAS that serve as safe and efficient alternatives to the manned aircraft commonly utilized to conduct aerial imagery and videography. Also, the flight data, inspection results, recorded observations and lessons learned from t hese operations will be compiled to further enhance its current safety program.

The applicant proposes that the exemptions requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. The limi tations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to aerial imagery and videography conducted by manned aircraft.

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, TX P ORT A RTHUR
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Page 13 of 15A Summary That Can Be Published In The **Federal Register** , Stating: The Rules From Which Garner Environmental Services, Inc. Seeks Exemption:

Garner Environmental Services, Inc. seeks exemption from the requirements of 14 C.F.R. §§ 61.113(a), 61.133(b), 121, 91.119(c), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a).

CONCLUSION

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Page 14 of 15As set forth above, Garner Environmental Services, Inc. seeks an exemption pursuant to 14 C.F.R. § 11.61 and Sectio n 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the above

- named sUAS commercially for the purpose of conducting aerial imagery and videography over other than congested areas. By granting this Petition, the

FAA wi ll allow Garner Environmental Services, Inc. to safely, effectively, and efficiently operate sUAS commercially.

Submitted on ___________________

Respectfully submitted,

Thomas Dickey sUAS Manager Garner Environmental Services, Inc.

1717 West 13 th Str eet Deer Park, Texas 77536 (281)930

- 1200

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