Wilson Construction Co.

PO Box 1190 Canby, OR. 97013

P 503-263-6882 F 503-263-6946

November 11, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request from Part 133 of the Federal Aviation Regulations

Dear Sir or Madam:

Wilson Construction Co. (“WCC”) a power line utility construction company, hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation 

of its UASs to conduct external load operations under FAR Part 133, 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.This request is filed in addition to an exemption request under 

section 333 submitted on August 14th 2015. (Tracking Number 1jz-8kjx-rhqm) 

As described more fully below, the requested exemption would support the addition of a small 

unmanned aerial vehicle to the company’s existing 133 Operating Certificate and operating 

specifications, and permit the commercial operation of small, unmanned UAS under controlled 

conditions in the NAS, specifically for the purpose of;

1. Part 133 external load operations – Wilson Construction Co. owns and operates 6 

helicopters for use in our power line construction activities and currently holds a Part 133 

Operating Certificate. WCC sees tremendous safety benefits to the utilization of UASs for 

particular external load operations, e.g. pulling light sock line in areas where the use of a 

helicopter is not practical or safe. These operations would be conducted exclusively within 

a power line right of way and with prior consent of the owner controlling utility. WCC’s 133 

certificate number is W9OL253L. 

The national power utility grid is in constant need of repair, updating and expansion as our need 

for electrical power is ever growing. Wilson Construction Co. has been committed to the 

development of industry best practices and enhanced work methods to improve worker and public 

safety in our industry. As a company with extensive aviation experience in the utility environment, 

we see the integration of UAS technologies as an essential component in our pursuit of increased 

safe working methods and a reduction in hazards to the general public.

Wilson Construction Co. has a long history of safe aviation operations and a close working 

relationship with the FAA. WCC is active within Helicopter Association International, as well as 

having current members of HAI’s UPAC and UAS committees. We can insure that the combination 

of WCC’s expertise and aviation experience, combined with the UASs lightweight, historically 

demonstrated flight performance and qualified flight personnel, ensures that the FAA can have 
Wilson Construction Co.

PO Box 1190 Canby, OR. 97013

P 503-263-6882 F 503-263-6946

confidence that WCC’s operation will have an equivalent or greater level of safety of manned 

aircraft performing the same missions.

WCC proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for an 

exceptional level of safety to operations. These limitations and conditions to which WCC agrees 

to be bound when conducting commercial UAS external load operations under an FAA issued 

exemption including:

 Will conduct all external load operation in accordance with the company’s approved 

RLCFM.

 Will conduct all external load operations within the lateral boundaries of the power line or 

other utility right of way.

 Flights will be operated within line of sight of operator.

 Maximum total flight time for each operational flight will be 30 minutes.

 Flights will be terminated at 15% battery power reserve. 

 Flights will be operated at an altitude of no more than 400 feet 

AGL

 UAS operator will be trained and certified in the proper safety and operations of the UAS.

 The operator will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated as required.

If the UAS loses communications or loses its GPS signal, the UAS will have capability to return 

to a pre-determined location within the Security Perimeter and land or hold position until signal is 

restored. Additionally, the UAS operator will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies.

The name and contact information of the applicant are:

Wilson Construction Co.

Ron Stewart Chief Pilot

PO Box 1190

Canby, OR 97013

P 503-263-6882

F 503-263-6946

rstewart@wilsonconst.com
Wilson Construction Co.

PO Box 1190 Canby, OR. 97013

P 503-263-6882 F 503-263-6946

Regulations from which the exemption is requested are as follows:

14 CFR 133.19

14 CFR 133.33(b)(1)

14 CFR 133.35

14 CFR 133.43

14 CFR 133.49(a)

14 CFR 133.51

Accordingly, WCC respectfully requests that the FAA grant the requested exemption and are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. We look forward to working with your office. Please contact us at any time if additional 

information or clarifications are needed.

Sincerely,

Ron Stewart

Director of Helicopter Operations

Wilson Construction Co.

Appendices:

A. Exemption Request and Equivalent Level of Safety
Wilson Construction Co.

PO Box 1190 Canby, OR. 97013

P 503-263-6882 F 503-263-6946

Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Wilson Construction Co. requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of its UAS’s.

14 CFR 133.19 Rotorcraft.

(a) The applicant must have the exclusive use of at least one rotorcraft that—

(1) Was type certificated under, and meets the requirements of, part 27 or 29 of this chapter (but 

not necessarily with external-load-carrying attaching means installed) or of §21.25 of this chapter 

for the special purpose of rotorcraft external-load operations;

(2) Complies with the certification provisions in subpart D of this part that apply to the rotorcraftload combinations for which authorization is requested; and

(3) Has a valid standard or restricted category airworthiness certificate.

(b) For the purposes of paragraph (a) of this section, a person has exclusive use of a rotorcraft if 

he has the sole possession, control, and use of it for flight, as owner, or has a written agreement 

(including arrangements for the performance of required maintenance) giving him that possession, 

control, and use for at least six consecutive months.

Even though the multi-rotor uav proposed does fit within the definition of “rotorcraft” as defined 

under FAR 1.1, the aircraft is not certified under part 27 or 29 and does not have an airworthiness 

certificate and shall be exempt under section 333.

14 CFR 133.33 Operating Rules

(b)(1) Requires that the rotorcraft complies with 133.19 and the requirements for 

airworthiness and certification. 

The proposed UAS will be exempt from certification requirements under section 333.
Wilson Construction Co.

PO Box 1190 Canby, OR. 97013

P 503-263-6882 F 503-263-6946

14 CFR 133.35 Carriage of persons.

(a) No certificate holder may allow a person to be carried during rotorcraft external-load 

operations unless that person—

(1) Is a flight crewmember;

(2) Is a flight crewmember trainee;

(3) Performs an essential function in connection with the external-load operation; or

(4) Is necessary to accomplish the work activity directly associated with that operation.

(b) The pilot in command shall ensure that all persons are briefed before takeoff on all pertinent 

procedures to be followed (including normal, abnormal, and emergency procedures) and 

equipment to be used during the external-load operation.

This regulation would not apply to the application of unmanned aerial systems.

14 CFR 133.43 Structures and design.

(a) External-load attaching means. Each external-load attaching means must have been approved 

under—

(1) Part 8 of the Civil Air Regulations on or before January 17, 1964;

(2) Part 133, before February 1, 1977;

(3) Part 27 or 29 of this chapter, as applicable, irrespective of the date of approval; or

(4) Section 21.25 of this chapter.

(b) Quick release devices. Each quick release device must have been approved under—

(1) Part 27 or 29 of this chapter, as applicable;

(2) Part 133, before February 1, 1977; or

(3) Section 21.25 of this chapter, except the device must comply with §§27.865(b) and 29.865(b), 

as applicable, of this chapter.

(c) Weight and center of gravity—
Wilson Construction Co.

PO Box 1190 Canby, OR. 97013

P 503-263-6882 F 503-263-6946

(1) Weight. The total weight of the rotorcraft-load combination must not exceed the total weight 

approved for the rotorcraft during its type certification.

(2) Center of gravity. The location of the center of gravity must, for all loading conditions, be within 

the range established for the rotorcraft during its type certification. For Class C rotorcraft-load 

combinations, the magnitude and direction of the loading force must be established at those values 

for which the effective location of the center of gravity remains within its established range.

This regulation would not be applicable to UAS operations due to the exemption from airworthiness 

certification requirements.

133.49 Markings and placards.

The following markings and placards must be displayed conspicuously and must be such that they 

cannot be easily erased, disfigured, or obscured:

(a) A placard (displayed in the cockpit or cabin) stating the class of rotorcraft-load combination for 

which the rotorcraft has been approved and the occupancy limitation prescribed in §133.45(a).

Section (a) of this regulation would not be applicable to UAS operations due to the fact that no 

cabin or cockpit area exists on the UAV.

133.51 Airworthiness certification.

A Rotorcraft External-Load Operator Certificate is a current and valid airworthiness certificate for 

each rotorcraft type certificated under part 27 or 29 of this chapter (or their predecessor parts) and 

listed by registration number on a list attached to the certificate, when the rotorcraft is being used 

in operations conducted under this part.

This part of this regulation requiring “valid airworthiness certificate for each rotorcraft type 

certificated under part 27 or 29 of this chapter (or their predecessor parts)” would not be applicable

to UAS operations due to the exemption from such requirements under the section 333.