December 22, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, S.E. Washington, DC 20590



## Petition for Exemption from Federal Aviation Regulations (“FARs”) and Request for Approval to Operate Unmanned Aircraft Systems Under Section 333 of the FAA Reform Act and Part 11 Of The FARs

Petitioner:

Amec Foster Wheeler Environment & Infrastructure, Inc. Donald B Chandler, P.E. Senior Vice President 4021 Stirrup Creek Drive, Suite 100 Durham, North Carolina 27703 Cell: 919-602-4904

Email: Donald.Chandler@amecfw.com

Website: www.amecfw.com

Dear Sir or Madam,

Amec Foster Wheeler Environment and Infrastructure, Inc. (“Amec Foster Wheeler”) is a national engineering consulting firm of more than 3,000 professionals providing comprehensive services in the primary practice areas of civil engineering, environmental engineering and sciences, and

water resources. Amec Foster Wheeler conducts site inspections, surveys, construction site monitoring, and other similar projects for c lients in the manufacturing, mining, power, public sector, real estate, and solid waste industries.

Amec Foster Wheeler seeks to operate small unmanned aircraft systems (“UAS”) for compensation or hire within the National Airspace System (“NAS”) for the purpose of conducting aerial acquisitions, including without limitation, site surveying, monitoring, and inspecting. Amec Foster Wheeler seeks an exemption to operate the Xactsense MAX-8 UAS and the DJI Inspire 1 for this purpose. The use of these two units will enable Amec Foster Wheeler to conduct aerial data acquisition for project sites in an efficient and safe manner and comply with laws and regulations. Use of the UAS is a low-cost solution with low environmental impact that protects surveyors and engineering personnel from the oft en hazardous conditions present at hazardous and civil engineering project sites, while optimizing the quality and effectiveness of the data collected. The aircraft manuals for the Xactsense MAX-8 UAS and the DJI Inspire 1 are presented in Appendix A of this document, and contain the manufacturer specifications, operations, andU.S. Department of Transportation, Do cket Operations December 22, 2015

Page 2 of 7 safety requirements. Additionally, we have in cluded Standard Operations Procedures (SOP’s) that are intended for use in conjunction with Condition and Limitations presented in the Exemption documentation, if approved.

This application is substantially based on the FAA’s findings in Exemption No. 11258 granted to Bechtel Equipment Operations, Inc. (FAA-2014-0898), Exemption No. 11299 Sevee & Maher Engineers, Inc. (FAA-2014-1008), Exemption No. 11566, CDM Smith (FAA-2015-0428), Exemption No. 11808, AECOM (FAA-2015-0473), Exemption No. 12040, Burns & McDonnell (FAA-2015-1248), Exemption No. 12089, Identified Technologies Corporation (FAA-2015-0556), Exemption No. 12371, Civil & Environmental Consultants, Inc. (FAA-2015-1971), Exemption No. 12732, Lockheed Martin (FAA-2015-1831), and in reliance on the analysis provided therein.

Amec Foster Wheeler Environment & Infrastructure, Inc. hereby petitions the Federal Aviation Administration (“FAA”) for an exemption from various Federal Aviation Regulations (“FARs”) and requests approval to operate the Xactsense MAX-8 Unmanned Aerial System and the Inspire 1 in the National Air Space pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C.S 44701(f) (the “Act”), and Title 14 of the Code of Federal Regulations (“CFR”), Part 11 (14 CFR Part 11) (the “Petition”).

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

1) Name and mailing address and other contact information including our telephone

number and e-mail address

Amec Foster Wheeler Environment & Infrastructure, Inc. Donald B. Chandler P.E. 4021 Stirrup Creek Drive, Suite 100, Durham, North Carolina 27703 Cell: 919-602-4904

Email: Donald.Chandler@amecfw.com

2) The specific section or sections of 14 CFR from which we are seeking an exemption

Amec Foster Wheeler is seeking exemption from the following 14 CFR sections:

i. 14 C.F.R. § 61.101(e)(4) and (5) - Recreational pilot privileges and limitations ii. 14 C.F.R. § 61.113(a) - Private pilot privileges and limitations iii. 14 C.F.R. § 61.23(a) and (c) - Medical certificates: Requirement and duration. iv. 14 C.F.R. § 61.315(a) - What are the privileges and limits of my sport pilot certificate? v. 14 C.F.R. § 91.7(a) - Civil aircraft airworthiness. vi. 14 C.F.R. § 91.119(c) - Minimum safe altitudes: General. vii. 14 C.F.R. § 91.121 - Altimeter settings. viii. 14 C.F.R. § 91.151(a)(1) - Fuel requirements for flight in VFR conditions.

ix. 14 C.F.R. § 91.405(a) - Maintenance required. x. 14 C.F.R. § 91.407(a)(1) - Operation after maintenance, preventive maintenance, rebuilding, or alteration. xi. 14 C.F.R. § 91.409(a)(1) and (2) - Inspections. xii. 14 C.F.R. § 91.417(a) and (b) - Maintenance records.U.S. Department of Transportation, Do cket Operations December 22, 2015

Page 3 of 7 Our request for exemption from the 14 CFR sections listed above is consistent with FAA’s granting of exemptions for the same sections in the following: Exemption No. 11258 granted to Bechtel Equipment Operations, Inc. (FAA-2014-0898), Exemption No. 11299 Sevee & Maher Engineers, Inc. (FAA-2014-1008), Exemption No. 11566, CDM Smith (FAA-2015- 0428), Exemption No. 11808, AECOM (FAA-2015-0473), Exemption No. 12040, Burns & McDonnell (FAA-2015-1248), Exemption No. 12089, Identified Technologies Corporation (FAA-2015-0556), Exemption No. 12371, Civil & Environmental Consultants, Inc. (FAA-2015- 1971), Exemption No. 12732, Lockheed Martin (FAA-2015-1831).

3) The extent of relief sought, and the reason for seeking such relief

Amec Foster Wheeler wishes to operate small UAS for commercial purposes to include (but not limited to) videography, photography, inspections, and analyses. This relief is sought because commercial use of UAS is currently prohibited by law unless performed under an exemption. Our operations will not "create a hazard to users of the national airspace system or the public or pose a threat to national security", and are thus consistent with the congressional mandate in Section 333 of the FAA Modernization and Reform Act of 2012, which gives FAA a mechanism to allow certain UAS to operate safely in the national airspace system.

4) Benefit to the public as a whole

Use of UAS technology to obtain imagery, information, and data currently obtained by use of manned flight or manual ground-based reconnaissance methods:

i. reduces statistical risk to human life due to manned aircraft accidents (e.g., power line inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections). ii. reduces the risk to environmental workers at hazardous waste sites by reducing the potential exposure. iii. reduces the cost of obtaining such information, which benefits consumers and the

economy. iv. reduces environmental impac t by eliminating sources of hydrocarbon emissions from manned aircraft.

For all these reasons, the UAS operations cont emplated by Amec Foster Wheeler achieve a level of safety equal to or greater than that which would be achieved by flying a much larger manned aircraft carrying crew and flammable fuel for the same purposes.

5) Safety

Amec Foster Wheeler is committed to safety associated with operating a UAS, and will conduct UAS operations in accordance with the following requirements:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved byU.S. Department of Transportation, Do cket Operations December 22, 2015

Page 4 of 7 qualified personnel such as those authorized by Robotic Skies (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by two individuals who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. An airline transport, commercial, private, recreational, or sport pilot certificate.

2. A current FAA airman medical certificate or valid U.S. driver license.

3. A Bi-annual flight review under 14 CFR 61.56

4. At least 50 cycles and 8 hours of flight experience in a UAS rotorcraft. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.

5. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the prior 90 days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR

91.119.

ii. A Visual Observer (VO).

d. All flight operations will be conducted in accordance with valid Certificates of

Authorization.

e. All flight operations will comply with the following:

i. The manufacturers’ Aircraft Flight Manuals and operation guidelines.

ii. Amec Foster Wheeler flight operations policies, including lost communication and other emergency and safety procedures.

iii. Conducted in visual meteorological conditions (VMC) conditions during daylight hours.

iv. PIC and VO will maintain visual line of sight (VLOS) at all times.

v. Pre-flight inspections (including ground control station, if any) and safety risk assessments will be conducted prior to each flight.

vi. Flight altitudes will remain at or below 400 feet above ground level.

## Appendix A

1. SOP- Operations Protocol - Verification Documentation

2. SOP- Pre-Flight sUAS-Site Check List

3. SOP- Pre-Flight- Site Condition Summary

4. SOP- Flight Procedure-Operatio n Overview- Photogrammetry Mission

5. SOP- Equipment Service Log

6. Xact Sense – MAX

‐ 8-Utility Remote-Piloted Aircraft Manual

7. DJI Inspire 1 User ManualAmec Foster Wheeler

E&I Americas Standard Operating Procedures



## Operations Protocol Verification Documentation

Amec Foster Wheeler operational restrictions for sUAS that ensure safe flight include the following:

1. Amec Foster Wheeler employee shall not fly, or prepare to fly a sUAS without having proper FAA Registration - Certifications of specific aircraft vehicles with proper marking and identifications. 2. Amec Foster Wheeler employee shall not fly, or prepare to fly any site or project without either being an experienced sUAS operator or having a minimum of 8 hours training with an experienced sUAS operator-trainer, or proven extensive personnel experience in the maintenance, care, operational uses within interior-exterior climate operations. 3. The sUAS will not be flown at night and will be operated under visual meteorological conditions ("VMC") or where visibility is at least 3 statute miles from pilot in command (PIC). 4. The PIC shall not begin a flight unless, considering wind and forecast weather conditions, there is enough power to fly at normal cruising speed over intended project, and land the sUAS with 30% battery power remaining. 5. The sUAS must be operated within visual line of sight (VLOS) of the PIC at all times, using human vision unaided by any devic e other than corrective lenses. 6. All operations must utilize a visual observer (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. 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 (with exceptions to medical or catastrophic causes). The PIC must ensure that the VO can perform the functions prescribed in the operating documents. 7. The operating documents and the grant of exemptions will be accessible during sUAS operations and made available to the Administrator (FAA) upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption shall govern. 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 upon request. The operator must also present updated and revised documents if it petitions for extension or am endment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to the grant of exemption. The FAA's UAS Integration Office (AFS-80) may beAmec Foster Wheeler

E&I Americas Standard Operating Procedures

contacted if questions arise regarding updates or revisions to the operating

documents. 8. A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It will be mandatory that all personnel who will be performing duties in connection with the operations be present for this briefing. 9. The operator will file any necessary paperwork in light of the exemptions with the appropriate Flight Standards District Office ("FSDO"). 10. Prior to each flight the PIC must 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 is prohibited from operating until the necessary maintenance has been performed and the sUAS is found 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 the aircraft records. 11. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the sUAS to service. 15. Each sUAS operated under this exemption mu st comply with all Manufacturer Safety

Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The sUAS will have redundancies and an independent flight termination system (FTS) that can be activated manually by the PIC to ensure the overall safety and predictability of the sUAS. 18. In the event of a loss of communications or signal, the sUAS is programmed to return

to its home base. 19. The sUAS will have the capability to abort a f light in case of unexpected obstacles or emergencies.

20. If the multirotor and its controller disc onnects during flight, the system's failsafe protection will come to the rescue and the multi-rotor and land automatically. 21. The sUAS will only be flown (i) in rural areas, away from any urban or congested locations, (ii) on secured private property with restricted public access, (iii) in areasAmec Foster Wheeler

E&I Americas Standard Operating Procedures

located more than 5 miles away from any airport, (iv) in Class G Airspace, and (v) in such locations where the property owner has approved the contemplated sUAS operations. 22. The PIC, VO, and any additional crew members will comply with any additional safety regulations and protocols as may be required by each Amec Foster Wheeler project site. 23. Amec Foster Wheeler will communicate information to an Air Traffic Control (ATC) three days prior to proposed flight, if subject site is within 5 - nautical miles of an airport with Tower. Provide the start time, duration, approximate area, and proposed AGL height. Amec Foster Wheeler will also communicate information to a non-- tower controlled airport if subject site is within 3 nautical miles of an airport with no

tower. 24. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable (see exemptions). 25. Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements (see exemptions). 26. The sUAS must remain clear and yield the right of way to all manned aviation operations and activities at all times. 27. Written and/or oral permission from the relevant property holders will be obtained,

confirmed and documented. 28. 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. 29. 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. 30. The sUAS will weigh less than 55 lbs. and not be flown at an airspeed exceeding 87

knots. 31. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the sUAS any time the sUAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request (see exemptions). 32. Flights will be operated at an altitude of no more than 400 feet Above Ground Level ("AGL"), with the majority of flights anticipated to be operated at no more than 250 feet AGL. No operation of the sUAS will be permitted if the cloud cover is located within 2,000 feet of subject site and I or less than a 1,000 foot ceiling height.Amec Foster Wheeler

E&I Americas Standard Operating Procedures

33. If the multi-rotor crosses the imaginary - established 500 ft. perimeter from the public, unit must overridden or forced to its staging area - home base.

Amec Foster Wheeler, Environment & Infrastructure, Inc.

It is understood that that I, ________________, of the _______________office, and located in ______________________, dated ________________, having been trained in required time and are familiar with the selected sUAS of this office, will adhere to the above guidelines and protocol in addition to the Amec Foster Wheeler/Client(s) safety programs. It is also understood that the general maintenance, cleaning, and pr eventive maintenance will be performed by me and other Amec Foster Wheeler sUAS operators on the specific unit in accordance with practices prescribed in the above documents and the OEM unit manual. Additionally, only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher level inspections, alterations, and maintenance per the operating documents - OEM standards. Amec

Foster Wheeler will document and maintain all maintenance of such records.

______________________ ______________________ Signature sUAS Trainer Signature

______________________ ______________________ Unit Manager Office Safety CoordinatorAmec Foster Wheeler

E&I Americas Standard Operating Procedures



## Pre-Flight sUAS Site Check List

Project Name: ________________________________ Project Number: _______________ PIC / VO: ________________________________/_______________________________ Date: ______________________ Wind Direction: ________________



### General Site Information

Site Type

Residential Site Yes ______ No ______

Governmental Site Yes ______ No ______ Federal Yes ______ No ______ State Yes ______ No ______ Local Municipality Yes ______ No ______ Military Yes ______ No ______

Industrial/Commercial Site Yes ______ No ______ Commercial/Retail Yes ______ No ______ Industrial/Manufacturing Yes ______ No ______

Hazardous Site (HAZWOPER) Yes ______ No ______ If Yes, Indicate PPE Level Level ____

More than 2 – miles HI Yes ______ No ______

More than 3 – miles ITA Yes ______ No ______

More than 5 – miles OTA Yes ______ No ______

Accuracy – level of detail _______________________________________

Approximate acreage of project _______________________________________

Proposed AGL _______________________________________Amec Foster Wheeler

E&I Americas Standard Operating Procedures



## Pre-Flight Site Condition Summary

The Amec Foster Wheeler PIC and VO to field review the pre-flight mission, establish an initial Staging area, and identify a safe "Home" base. This review process is required for each project to assure safety, minimize liabilities, safety of Amec Foster Wheeler employees, and safety of the public. The assigned PIC and VO will review: assigned “Home” - staging area for the PIC and VO , encompassing an area of not less than 50 foot square and void of vegetation, structures, improvements, utilities, and other personnel; within this staging area, provide an area measuring 20 foot square for the sUAS ("Home") to lift off and land; review of the flight plan and verify safe distances of more than 500 feet from any individuals in the area, residential – commercial – industrial – governmental buildings, and any overhead utilities, roads or highways that may be affected by this collection of data, unless it is part of, or known to the planned operations.

PIC - VO Site Comments



### Site Sketch - Ground Control Station

Provide rough sketch of site showing staging area, "Home" base, GCPs, setbacks if available, general lay of land, road access, public facilit ies, buildings, homes, any nearby utility - vertical structures, and any improvements that may be affected by the proposed flight of sUAS.



# NAmec Foster Wheeler

E&I Americas Standard Operating Procedures



## Flight Procedure Operation Overview Photogrammetry Mission

1. Meet at the security gate and or near the ground control station for set up and do a pre-flight security scan of the site. Ensure access to the ground control area is

controlled. 2. Ensure that all necessary documents, including the Flight Log, operating and flight manuals and checklists, and other do cuments are readily accessible. 3. PIC readies sUAS for flight - Set up the hand held weather station on a nearby tripod I other. Review existing cloud cover, achieving a minimum 1,000 foot ceiling height, and visibility greater than 3,000 feet a. Check over the airframe, connec tions, and propellers for any damage during transport in vehicle. b. Calibrate the camera and turn on and ready the GSC. c. Connect communication antennae to the GCS - open the Ground d. Station software and pull up the pre-planned photogrammetry flight path. e. Remove the battery for flight, measure current voltage, and log findings in the battery manual - strap battery securely into the sUAS (DO NOT ATTACH MAIN POWER). f. Set up traffic cones around the sUAS with a 20-foot (approximate) radius. This is the "Home" area; operators are not allowed inside this area while the electrical motors are running. g. Activate engine power without moving the throttle up - listen for power up sequence of beeps from the unit and motors. Follow sUAS guidelines for compass calibration procedure which records the "Home" point. h. Using the Ground Control Station, verify connection to the sUAS - the sUAS should appear on the screen, along with a recorded home point, battery voltage, current altitude relative to the ground, and current Velocity. i. Upload the flight path data to the sUAS and set a geo-fence around the jobsite so that when crossed the sUAS returns to Home. The Geo-fence will ensure that the sUAS never comes within the 500 ft. limit from the public. j. Verify good upload and connection completed and record the time /

weather. k. The sUAS is ready and prepared to go. l. Move sUAS to take off point, approximately 30 feet from crew and attach main power 4. While the PIC is readying the aircraft, the VO, or secondary crew member prepares the location of Ground Control Points ("GCPs") and walks the site. VO is also powering up - calibrating the GPS survey equipment and locating the center of eachAmec Foster Wheeler

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target with GPS. VO and review the site to make sure the site is clear of all personnel within vicinity.

5. The PIC double checks that the take-off area is clear. 6. The PIC takes off flying to the approximate survey altitude and instructs the VO to initiate the preprogrammed flight path. The VO verifies that the Ground Station has a good connection and is tracking the sUAS. 7. The PIC or VO turns on the camera to take pictures at a preset or continuous

interval. 8. During the entire preprogrammed flight, the PIC and VO always have VLOS and the PIC is prepared to take over flight operations as needed to ensure safe operations. The PIC's Ground Station has a flight battery monitor which is set to a minimum of 30% battery reserve. The timer begins from the point the throttle is moved out of its start position. 9. During flight, the VO monitors the Ground Station data (voltage, forward velocity, altitude, and estimated remaining time to complete the mission) and relays any sudden changes or alerts to the PIC. 10. As the mission completes, the PIC informs the VO he is taking back over control. · 11. The PIC or VO turns off the camera and the PIC begins to land the sUAS. 12. After safely landing, the PIC immediately unplugs the main power, reviews the pictures to verify if the pictures are good, and verifies mission - flight was successful. 13. If successful, the VO leaves to collect GCP (locate with GPS additional points if required). 14. The PIC checks battery voltage and records in battery log, records flight time in Flight Log and turns off Ground Control and camera. 15. The PIC looks over airframe, props, and cowling to see if any damage or loose connections resulted from the session - flight, recording findings. 16. The PIC and VO pack all sUAS and GPS equipment for safe transport.Amec Foster Wheeler

E&I Americas Standard Operating Procedures



## Equipment Service Log ( Upgrades - Malfunctions – Revisions) 

## Unit __________________ Serial # _________________

Name Date Field or Office? Comment