2400 West 75th Street, Prairie Village, Kansas 66208 USA

T 816 270–4700 F 816 270–4707 www.WireCoWorldGroup.com

January 11, 2016

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act of 2012

Dear Sir/Madam:

WireCo WorldGroup Inc. (“WireCo”) hereby requests an exemption pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, to safely operate an 

unmanned aerial system (UAS) to perform aerial data collection under the conditions of this petition or 

as otherwise established by the FAA. 

Applicant Information: 

WireCo WorldGroup Inc.

2400 West 75th Street

Prairie Village, KS 66208

Attn: Michelle Torline

Phone: 816-270-4814

Email: michelletorline@wirecoworldgroup.com

Background:

WireCo is a leading global manufacturer of both steel and synthetic rope, specialty wire, engineered 

products, electromechanical cable, and synthetic yarns, serving a diverse range of end markets, 

geographies and customers. Originally founded in 1931, the company has evolved into a global 

manufacturing leader. We maintain a broad portfolio of critical products across the end markets we 

serve, including, but not limited to, industrial and infrastructure, oil and gas (both offshore and 

onshore), fishing, mining, maritime, structures, poultry, and storage systems. Our highly engineered, 

specialized ropes are “mission-critical” equipment components used in applications, such as heavy 

lifting, pulling, mooring, supporting and suspension. We operate 23 manufacturing facilities in eight

countries, which are supplemented by a global network of distribution facilities, consignment centers, 

distributor partnerships and sales offices. 

Specific CFR Sections for Requested Exemption:

WireCo specifically requests an exemption from the following sections of 14 CFR, to the extent 

necessary to allow WireCo to operate a UAS to perform aerial data collection: 

14 CFR Part 21, Subpart H – Airworthiness Certificates 

14 CFR 45.23(b) – Display of marks

14 CFR 61.23 (a) and (c) – Medical certificates: Requirement and duration
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14 CFR 61.101(e)(4) and (5) – Recreational pilot privileges and limitations

14 CFR 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in Command

14 CFR 91.7(a) – Civil aircraft airworthiness

14 CFR 91.9(b)(2) – Civil aircraft flight manual, marking and placard requirements

14 CFR 91.103(b) – Preflight Action

14 CFR 91.109 – Flight Instruction; Simulated instrument flight and certain flight tests

14 CFR 91.119(c) – Minimum Safe Altitudes

14 CFR 91.121 – Altimeter Settings

14 CFR 91.151(a) – Fuel requirements for flight in VFR conditions

14 CFR 91.203 (a) and (b) – Civil aircraft; certifications required

14 CFR 91.405(a) – Maintenance required

14 CFR 91.407(a)(1) – Operation after maintenance, preventive maintenance, rebuilding, or alteration

14 CFR 91.409(a)(1) and (2) – Inspections

14 CFR 91.417(a) and (b) – Maintenance records

Similar Relief Granted by the FAA:

The UAS operations proposed herein will be consistent with previously granted UAS Section 333 

exemptions and FAA guidance. This request is similar in all material respects to the relief recently

granted by the FAA in Exemption Nos. 12469 (Mesa Associates, Inc.), 12729 (HSEarchitects), and 12761 

(Kenneth A. Stephens).

Proposed Use and Public Interest:

WireCo plans to use a DJI Phantom 3 Professional quadcopter (more details available at 

http://www.dji.com/product/phantom-3), for the purpose of safely conducting aerial inspections to 

detect potential product or operational issues at customer locations, in situations where it is difficult for 

personnel to conduct visual inspections due to safety or operating conditions, specifically on elevated 

structures such as cranes, drag lines, oil rigs, marine vessels, and other structures. 

The use of UAS aircraft significantly improves public safety and reduces risks associated with using 

alternative means, including manned aircraft. A traditional aircraft flying at low levels or in populated 

areas puts the public at increased risk of harm. On the other hand, a UAS is a lightweight aircraft which 

can fly safely in populated areas, operating at slow speeds, close to the ground, and in a controlled 

environment and, as a result, is far safer than conventional manned aircraft operating with significant 

levels of fuel in close proximity to the ground and people. 

The public interest is also advanced by reducing human exposure to death or serious injury associated 

with personnel performing such inspections. Inspection of WireCo products on cranes, oil rig masts,

surface mining equipment, fishing vessels and other structures currently involve safety harnesses, tie off 

systems and winches to aid in personnel safety while climbing ladders, stairs or other inclined surfaces.

WireCo employees who conduct these inspections are currently required to climb ladders and stairs to 

elevations upwards of 300 feet above the ground surface, where physical exertion, environmental 

concerns, and potential human error can significantly increase the risk to human life. The majority of

large scale machinery also needs to be shut down during inspections, which is very costly due to lost 

production time, because of the safety risks to personnel performing the inspections. As many of the 

equipment-heavy markets WireCo supplies to are commodity based, an increase in production cost for 

any particular end market can influence higher prices for public customers (for example; utility prices
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[mining/oil & gas], shipping costs [maritime and overhead craneage], food costs [fisheries & poultry 

suppliers], steel costs [heavy lifting], etc.). 

Use of UAS would allow a safe aerial video inspection of the equipment and operations to be conducted, 

at less risk and expense, with minimal impact to the surrounding environment. Commercial products 

produced by WireCo’s end-user customers with higher standards of safety and at a lower cost are in the 

public’s direct interest.

Operations:

The conditions under which WireCo would conduct commercial operations using the UAS under an FAA 

issued exemption include: 

1. The UAS weighs less than 5 pounds (actual size of the DJI Phantom 3 is 1,280 g or 2.82 pounds).

2. The maximum speed of the UAS is 36 mph, but will typically be operated at a speed of 5mph or 

less during the operations described herein.

3. All flights will be operated at an altitude of less than 400 feet above ground level.

4. UAS operations will occur during daylight hours only under visual meteorological conditions.

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

terminated at 20% battery power reserve, should that occur prior to the 30 minute limit.

6. Prior to each flight, a pre-flight inspection will be conducted to ensure proper conditions for a 

safe flight. The pre-flight inspection procedure will include a check of the flight area, weather, 

potential obstacles and hazards, flight time, mechanical components of the UAS, battery time, 

and any other information affecting the safety of flight.

7. Each flight will take place with a UAS Operator and a Visual Observer (VO). The UAS Operator 

will be the Pilot in Command (PIC) with an FAA sports pilot’s certificate or higher and will have 

completed the required FAA training, UAS manufacturer training including DJI’s Pilot Training 

Guide, and have a valid driver’s license. The PIC will be trained in flight, operations, and safety 

procedures as detailed in the user manual and other DJI supporting documentation for the UAS.

8. All flights will be operated within the visual line of sight of the PIC. 

9. The PIC and VO will be able to communicate verbally at all times.

10. A briefing will be conducted in regard to the planned UAS operations prior to each flight for all 

personnel who will be present in the flight operations area.

11. The UAS is equipped with various safety features and is programmed to automatically return to 

its launch site in the event of communications failure, loss of the Global Positioning System 

(GPS), or low battery. The UAS can be set to fly only within a given distance and altitude. The 

GPS capabilities of the UAS prevent accidental flight into unwanted areas or obstacles. The UAS 

is also programmed to prevent it from flying into a no fly zone.

12. The UAS will only operate in Class G airspace.

13. The UAS will not operate within five miles of an airport, unless approval from the local FAA 

Flight Standards District Office (FSDO) and airport controller has been obtained in advance.

14. The UAS will only operate within a confined controlled area of the flight operations area.

15. All required permissions and permits will be obtained from all persons involved, including 

relevant property owners, territorial, state, county, or city jurisdictions, including local law 

enforcement, fire, or other appropriate governmental agencies.

16. The UAS automatically logs the details of each flight, including route, time, distance, location, 

photos and videos.
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17. WireCo will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components, and will comply with all 

manufacturer safety bulletins.

Equivalent Level of Safety:

The operation of the UAS in the above conditions provides an equivalent or higher level of safety 

supporting the grant of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow 

speeds, close to the ground, and in a controlled environment and, as a result, are far safer than 

conventional manned aircraft operating with significant levels of fuel in close proximity to the ground 

and people. 

Federal Register Summary:

The following summary is provided for publication in the Federal Register, if needed: 

Applicant seeks an exemption from the following sections of the CFR, to the extent necessary to allow 

WireCo to operate a UAS to perform aerial data collection: 14 CFR Part 21, 14 CFR 45.23(b), 14 CFR

61.23 (a) and (c), 14 CFR 61.101(e)(4) and (5), 14 CFR 61.113(a) and (b), 14 CFR 91.7(a), 14 CFR

91.9(b)(2), 14 CFR 91.103(b), 14 CFR 91.109, 14 CFR 91.119(c), 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 

91.203 (a) and (b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(1) and (2), 14 CFR 91.417(a) 

and (b). Satisfaction of the criteria provided in Section 333 of the Reform Act, including 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 granting the requested 

exemptions allowing commercial operations. 

Granting the requested exemption will benefit the public interest by significantly improving safety and 

reducing risk by alleviating human exposure to danger, and by reducing the environmental impact 

associated with manned aircraft or other means of observation via elevated equipment. Under Section 

333 of the Reform Act, the authority contained in the Federal Aviation Act, the equivalent level of safety 

surrounding the proposed operations, and the public benefit, including enhanced safety, reduction in 

environmental impacts, including reduced emissions associated with allowing the UAS, the grant of the 

requested exemptions is in the public’s interest.

Thank you for considering this request. Please contact me if you have any questions or require 

additional information.

Sincerely,

Michelle Torline

Vice President, Legal