June 29, 2015

Exemption No. 11933

Regulatory Docket No. FAA–2015–1353

Mr. James P. Wold

Regulatory Compliance Engineer

Dyno Nobel Louisiana Ammonia LLC

10800 River Road

Waggaman, LA 70094

Dear Mr. Wold:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 20, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Dyno Nobel Louisiana Ammonia LLC (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial imaging.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 
2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Dyno Nobel Louisiana Ammonia LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, Dyno Nobel Louisiana Ammonia LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the 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.

6. All operations must utilize a visual observer (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 communicate verbally 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.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
4

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance 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.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS 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 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold 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 must also 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.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS 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.

16. The UA may not operate 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 airport 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 the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

22. All aircraft operated in accordance with this exemption must 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS 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 UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 20, 2015 

U.S. Department of Transportation Docket 

Management System 

1200 New J ersey Ave., SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119; 91.121; 

91.151(a); 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 (the Reform Act) 

and 14 C.F.R. Part 11, Dyno Nobel Louisiana Ammonia LLC, an explosive manufacture, hereby 

applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow 

commercial operation of its Small Unmanned Aircraft Systems ("sUAS") for aerial imaging for 

safety and monitoring of secured and controlled manufacturing site, 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 detailed in this document, the requested exemption would permit the operation of sUAS 

under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access 

and 4) would provide safety enhancements to the already best practices safety protocols followed by 

Dyno Nobel at its manufacturing facility in Louisiana. 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. 

The name and address of the applicant is: 

Dyno Nobel Louisiana Ammonia LLC 

10800 River Road 

Waggaman, Louisiana, 70094 

PH: 504-400-6035 

Email: James.Wold@am.dynonobel.com 
14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

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

14 C.F.R. 91.405 (a) 

14 C.F.R. 407 (a) (1) 

14 C.F.R. 409 (a) (2) 

14 C.F.R. 417 (a) & (b) 

I. STATUTORY AUTHORITY FOR EXEMPTIONS 

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

This statutory authority includes exempting civil aircraft, as the term is defined under 

§40101 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 ofthis title ifthe 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(£) 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 

a threat to national security. In making this determination, the Secretary must consider: 

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

• Whether the s UAS operates within the visual line of sight of the operator 

• Whether the s UAS operates outside of highly populated areas and away from close 

proximity to airports 

Reform Act §333(a). If the Secretary determines that a sUAS "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." I d. §333(c). 

Dyno Nobel's sUAS are multirotor vehicles (DJi Phantom 2), weighing 10 or fewer lbs. 

including payload. They operate under normal conditions at a speed of no more than so knots and 

have the capability to hover, and move in the vertical and horizontal plane simultaneously. The 

sUAS will operate only in the Pilot's visual line of sight at all times and will operate only within the 

boundary of Dyno Nobel manufacturing facility. Such operations will insure that the sUAS will "not 

create a hazard to users of the national airspace system or the public." Reform Act Section 333 (b). 
exemptions is in the public interest. 

Accordingly, Dyno N abel respectfully requests that the FAA grant the requested exemption without 

delay. 

II. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the NAS before completion of the 

rulemaldng required under Section 332 of the Reform Act. By granting an exemption the FAA will 

fulfill Congress's intent of allowing UAS to operate with significant safety precautions in low risk 

environments. 

The use of sUAS on a manufacturing site can significantly reduce the risk to workers of falls 

while inspecting, surveying, or monitoring site conditions. sUAS can inspect, photograph, and 

collect data on hard to get to areas that otherwise would require worker inspection. Falls are a 

leading source of workplace fatality and injury on construction sites1, and reducing falls through 

sUAS use for site imaging could save workers lives. 

Additionally, sUAS could replace the use of helicopters and small aircraft to monitor sites. 

The sUAS we propose to fly in this application are less than five pounds, and carry no combustible 

material on board, as opposed to the much larger conventionally powered small aircraft. Shifting to 

sUAS from helicopters presents a marked safety increase for our workers and the public. 

Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used 

for aerial imaging and data collection over a construction site. Our s UAS use rechargeable lithium 

ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are many hundreds 

of times heavier. 

III. EQUIVALENT LEVEL OF SAFETY 

Dyno Nobel proposes that the exemption requested herein apply to sUAS that have the 

characteristics and that operate with the limitations listed herein. These limitations 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 the already safe 

protocols followed on construction sites and imaging and surveying operations conducted with 

helicopters and other conventional aircraft. 

1 "Commonly Used Statistics", Occupational Safety & Health Administration. Available at: 

https: I lwww.osha.gov I oshstatsl commonstats.html 
5. Crew for each operation will consist of the sUAS Pilot who will keep the sUAS within his 

visual line of sight at all times. 

6. The sUAS Pilot will be trained in flight, operations, and safety procedures. 

7. The sUAS will only operate within a confined "Sterile Area" as defined by the boundary of the 

manufacturing facility. 

8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

production activities. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing. 

9. All onsite personnel will consent to the UAS flyover on site by waiver, and the operator will 

obtain additional verbal or written consent of all persons who will be allowed within 100 feet 

of the flight operation. 

10. Pilot will have been trained in operation of UASs generally and received up-to-date 

information on the particular UAS to be operated as required by Section F of the Manual. 

11 . Written and/ or oral permission from the relevant property holders will be obtained. 

12. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

13. If the s UAS loses communications or loses its GPS signal, it will have capability to enter "loiter 

mode" and hover, reestablish satellite connection, and return to a pre- determined location 

within the Security Perimeter and land. 

IV. DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will 

not cany a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the Pilot operating the aircraft to have completed a sUAS flight 

training course of 100 hours before flying a sUAS (See Section F of the Manual for more details). 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no living thing or cargo on board. Skycatch's sUAS is also operated by an autopilot, which 

greatly reduces the danger of human error. The area of operation is controlled and restricted to 

hard hat areas, and all flights are planned and coordinated in advance as set forth in the Manual. 

The sUAS to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within 
14 C.F.R. 91.103: Preflight Action 

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the Pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery requirements, 

checking takeoff and landing distances, and all other actions in the Preflight Checldist. These 

actions will provide an equivalent level of safety. 

14 C.F. R. 91.119: Minimum Safe Altitudes 

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 multirotor craft that flies similarly to a helicopter, with vertical take off and 

vertical landing, which will typically operate at altitudes of 200 AGL, so an exemption may be 

needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and 

will be in a restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre-obtained consent. See Manual for detailed procedures. 

The equivalent level of safety will be achieved given the size, weight, speed of the s UAS as well as 

the location where it is operated. No flight will be taken without the permission. Because of the 

advance notice to any onsite personnel, all affected individuals will be aware of the planned flight 

operations. Unlike flight operations with aircraft or rotorcraft weighing far more than the maximum 

10 lbs. proposed herein, our s UAS will not carry flammable fuel. In addition, the low-altitude 

operations of the sUAS will ensure separation between sUAS operations and the operations of 

conventional 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 depmture." As the sUAS may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be 

achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. 
Dyno Nobel believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small sUAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, 

with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) 

was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS 

flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough battery 

reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as 

determined by the on board monitoring system and the Pilot), whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections 

These regulations require that an aircraft operator or owner "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 ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Dyno Nobel. Maintenance will be accomplished by the operator pursuant 

to the flight manual and operating handbook An equivalent level of safety will be achieved because 

these small s UAS are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the sUAS can land 

immediately and will be operating from no higher than 400 feet AGL. The Pilot will ensure that the 

sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Moreover, the Pilot is the person most familiar with the aircraft and 
Approval of exemptions allowing commercial operations of s UAS in the manufacture industry 

enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater 

risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In 

contrast, a sUAS weighing fewer than 10 lbs. and powered by batteries eliminates virtually all of 

that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry 

no passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights. 

The operation of small sUAS, weighing less than 10 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements ofPm't 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and 

in a sterile environment and, as a result, are far safer than conventional operations conducted with 

turbine helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Images taken will be of individuals who have also consented to being 

filmed or otherwise have agreed to be in the area where aerial photography will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line 

of sight and national security - provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of applicant's sUAS in manufacturing 

industry. 

Sincerely, 

James P Wold 

Dyno Nobel Louisiana Ammonia LLC 

Regulatory Compliance Engineer