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

T 816 270

– 4700 F 816 270

– 4707 www.WireCoWorldGroup.com J anuary 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 operat e 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 75 th 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 appli cations, 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 an d sales offices.

Specific CFR Sections for Requested Exemption: WireCo specifically requests an exemption from the following section s 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 durationPage 2 of 4

14 CFR 61.101(e)(4) and (5)

– Recreational pilot privileges and limitations

14 CFR 61.113(a) and (b)

– Priv ate 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; certification s r equired 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 Gr anted 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. 1246 9 (Mesa Associates, Inc.), 12729 (HSEarchitects), and 12761 (Kenneth A. Stephens).

Proposed Use and Public Interest: WireCo plans to use a DJI P hantom 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 har m. 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 si gnificant 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 crane s, 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 incr ease the risk to human life. T he 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 risk s to personnel performing the inspections

. As many of the equipm ent

- 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 pricesPage 3 of 4

[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 surrou nding environment. Commercial products produced by WireCo’s end

- user customers with higher standards of safety and at a lower cost are in the

p ublic’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 weigh s 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 m ph , but will typi cally 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 me teorological 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 ot her 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 re quired 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 documentati on 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

p ersonnel 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), o r 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 U AS 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 wi thin 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
enfor cement, fire, or other appropriate governmental agencies.

16. The UAS automatically logs the details of each flight, including route, time, distance, location, photos and videos.Page 4 of 4

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 Registe r 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 collecti on: 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 inter est 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 wit h 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, L egal