ZutKERT ScouTT 

RASENBERGER 

MALCOLM L. BENGE 

BY HAND 

U.S. Department of Transportation 

Docket Management Facility 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

August 26, 2014 

888 Seventeenth Street NW, Suite 700 

Washington, DC 20006-3304 

Phone 202.298.8660 

Fax 202.342.0683 

www.zsrlaw.com 

DIRECT DIAL (202) 973-7904 

mlbenge@zsrlaw.com 

:. ., 

Re: Petition of Oceaneering International, Inc. for Exemption 

Pursuant to 14 C.F.R. Part 11, Oceaneering International, Inc. ("01" or "Petitioner") hereby 

applies for an exemption in order to conduct commercial use operations with the Wookong DJI 5800 and 

Aeronavics X4 Titanium unmanned aerial systems ("UAS"). In accordance with the requirements ofthe 

Federal Aviation Administration ("FAA"), Petitioner's UAS operations have been designed to achieve a 

level of safety equivalent to that provided by the FAA regulations from which an exemption is 

requested. In support of its exemption request, 01 provides the following information. 

Petitioner 

Established over 50 years ago, 01 has a long history of deep-sea safety and inspection operations 

using remotely-piloted vehicles. These operations have largely been conducted in support of the 

offshore oil and gas industry, with a focus on deepwater applications. Ol's operations have included 

drilling platform inspections, construction of deep-sea hardware and distribution systems, the 

installation of sub-sea blow-out prevention devices, Navy submarine rescue and recompression systems, 

and full service ship repair for the U.S. Government including submarines. Through these activities, 01 

has accumulated substantial expertise in the safe and reliable operation of underwater remotely-piloted 

vehicles for commercial applications. 01 is now proposing to expand its operation of remotely-piloted 

devices to include the commercial use of small UAS aircraft for various aerial inspection and surveying 

purposes. 

Proposed Commercial Uses 

01 proposes to use the Wookong DJI 5800 and Aeronavics X4 Titanium small UAS aircraft for 

multiple commercial applications, including safety inspections and aerial surveying of the following 

remote or difficult-to-access facilities: 

Zuckert, Scoutt & Rasenberger, L.L.P. 
ZucKERT ScouTT 

RASENBERGER 

• Oil and Gas platforms 

• Flare booms/stacks- both onshore and offshore 

• Refineries and processing stations 

• Pipelines 

• Power lines 

• Bridges and infrastructure including rail bridges 

• Wind turbines 

• Solar farms. 

August 26, 2014 

Page 2 

01 also envisions UAS operations in support of emergency response activities on behalf of the National 

Transportation Safety Board, the Department ofthe Interior's Bureau of Safety and Environmental 

Enforcement, the U.S. Coast Guard, and any other federal or state government agency which may 

require its services and personnel. 

All of Ol's proposed UAS operations are intended to facilitate safety inspections and aerial 

surveying in areas where the performance of those functions using current methods involves 

considerable expense and/or a substantial risk of injury. Many of these functions must be performed in 

hazardous environments. Others may be performed much more efficiently by an unmanned aircraft 

with the ability to hover and capture images at close range. The commercial UAS applications which 01 

proposes will therefore result in a significant enhancement of safety, by reducing the risks associated 

with current inspection methods and enhancing current inspection techniques. 

Proposed UAS Aircraft 

01 plans to conduct commercial UAS operations with the Wookong DJI S800 aircraft and 

Aeronavics X4 Titanium. The DJI S800 is a small UAS with a maximum takeoff weight of 15.41bs. The X4 

Titanium is a small UAS with a maximum takeoff weight of 28.6 lbs. At all times while conducting 

commercial operations, 01 will operate the DJI S800 and Aeronavics X4 Titanium under line-of-sight 

conditions with a hands-on control system, i.e., dual gimbals, in response to commands from an 01 

employee with specialized flight training; neither aircraft will perform commercial operations 

autonomously or in accordance with a pre-programmed flight plan. The DJI S800 has six batterypowered motors and the Aeronavics X4 has eight. If one ofthe motors on either aircraft experiences a 

power failure, the DJI S800 and the Aeronavics X4 will hover in place, orbiting around the motor that has 

failed. 

In the event that the signal between the control system and the DJI S800 or the Aeronavics X4 

Titanium is lost or disrupted, both aircraft are designed to hover for approximately 5 seconds 

attempting to regain the data link. If the UAS is equipped with a GPS communication system and is 

unable to re-establish contact with the control station, it will rely on an auto-pilot feature that returns 

the UAS aircraft to the home point via the original flight path from the launch point. This will eliminate 

"fly-away" incidents and other flight deviations that are known to occur with other types of UAS aircraft. 

Both the S800 and the X4 have been used extensively in Europe and the United Kingdom for 

commercial cinematography and survey work due to both platforms being stable and simple to operate. 

During the past Winter Olympics, the X4 was the primary system used for filming most of the events 
ZucKERT ScouTT 

RASENBERGER 

August 26, 2014 

Page 3 

from the air. Both systems have substantial commercial operating experience outside the U.S. and are 

known for being rugged with a history of reliability in flight. 

Operating Conditions 

01 will conduct commercial operations with the DJI 5800 and Aeronavics X4 Titanium only in 

accordance with a highly-detailed set of safeguards governing all phases of flight operations. 01 

employees responsible for UAS operations will always place a priority upon minimizing risk to personnel, 

equipment, assets and the environment. To ensure the highest level of safety, UAS flight operations will 

only be conducted after an extensive safety briefing (including 01 and customer personnel) and a risk 

analysis have been conducted. 

All UAS flights operated by 01 will be conducted by a minimum of three operational personnel, 

including a system supervisor. No flights may be initiated unless a preflight checklist has been 

completed and signed by all those 01 employees performing the checks. The checklist procedure 

includes a detailed inspection of the DJI 5800 and Aeronavics X4 Titanium prior to the initiation of any 

operations. Attached as Exhibit A to this exemption petition is a copy of Ol's pre- and post-flight 

checklist. 1

Any UAS operations to be conducted at an altitude of less than ten feet require the prior 

approval of 01 supervisory personnel. Most importantly from a safety perspective, operations directly 

overhead 01 and customer personnel are not permitted as the UAS aircraft must be operated at all times 

at no more than a 30 degree oblique to any personnel. 

There are several additional mandates that 01 employees must observe in connection with all 

commercial operations with the DJI 5800 and Aeronavics X4 Titanium, including the following: 

• No flights through an established Air Defense Identification Zone (ADIZ) 

• UAS flights shall not exceed 400 feet above ground or above the sea level per FAA 

Advisory Circular 91-57 

• All flights will be conducted in Class G airspace 

• All flights will be conducted within line-of-sight of UAS operator 

• All flights will be conducted in accordance with Class G airspace visibility requirements 

• Wind speed shall not exceed 25 knots 

• UAS operations will be conducted during daylight hours 

• A Notice to Airmen {NOT AM) will be filed with the FAA prior to each UAS operation 

• All 01 crews will have an air-air radio system for communication with low flying air traffic 

in the area surrounding UAS operations (programmed with 123.025 common Air-Air 

Frequency, and the local frequency for the area of operation) 

• All 01 crews will have an up to date Helicopter Safety Advisory Conference Air Frequency 

card 

1 All exhibits to this exemption petition are submitted to the FAA with a request for confidential 

treatment as they constitute commercially-sensitive proprietary data. 
ZucKERT ScouTT 

RASENBERGER August 26, 2014 

Page 4 

At no point in time will Ol's UAS aircraft be allowed to share airspace with commercial aircraft. Prior to 

conducting operations within three miles from any airport runway, 01 will notify the airport operator or 

the airport tower, as the case may be, in compliance with FAA Advisory Circular 91-57. 01 employees 

are instructed to terminate any UAS operations when an approaching commercial aircraft is within five 

nautical miles. 

As Exhibit B to this exemption petition, 01 is submitting a copy of its General Procedure for the 

Operation of RAV Systems. 

Operator Requirements 

Ol's commercial UAS operations will build on its years of experience as an underwater operator 

of remotely-piloted vehicles. Only 01 employees who have undergone and successfully completed a 

rigorous competency assessment evaluation will be selected to operate the DJI S800 and Aeronavics X4 

Titanium.2 Operators must demonstrate not only a superior knowledge of the technical issues · 

associated with UAS systems, including the full range ofthe capabilities and limitations ofthe DJI S800 

and Aeronavics X4 aircraft, but also must show sound piloting techniques and the ability to navigate 

around structures. In order to retain their status, 01 employees conducting UAS commercial operations 

must enforce compliance with the company's policy of "working under the more stringent rule." 

Some of the 01 employees selected to be operators ofthe DJI S800 and Aero navies X4 have 

previous significant experience as the operators of undersea remotely-piloted vehicles. In addition to 

their other qualifications, 01 employees who operate the DJI S800 and Aeronavics X4 will undergo an 

extensive program of simulator training as well as hands on flight training in a simulated inspection 

environment. Simulator training will allow these employees to gain experience with the specific flight 

characteristics of the DJI S800 and Aero navies X4 prior to any actual commercial operations. 

The following requirements will apply to any commercial UAS operations conducted by 01: 

• A pilot-in-command (PIC) will be designated at all times for each flight 

• The PIC will be directly responsible for, and have final authority over the operation of 

the UAS 

• The PIC will not perform concurrent duties as the visual observer 

• The PIC will be qualified on the DJI 5800 aircraft and Aeronavics X4 Titanium 

• The PIC will exercise control over the UAS as it will not maneuver autonomously. 

Given their experience with remotely-piloted vehicles, the amount of required simulator 

training, and the operational procedures applicable to 01 employees operating the DJI 5800 and 

Aeronavics X4 Titanium for commercial purposes, 01 PICs should not be required to hold an FAA pilot 

2 A copy of Ol's Competency Assessment Scheme is attached as Exhibit C to this exemption petition. 
ZucKERT ScouTT 

RASENBERGER 

August 26, 2014 

Page 5 

certificate. The commercial UAS operations by 01 will resemble the circumstances under which the FAA 

will issue a Certificate of Waiver or Authorization to UAS operators without requiring pilot certification. 

All operations will be in Class G airspace, conducted during daylight hours under visual line-of-sight flight 

procedures no more than one-half nautical mile laterally from the 01 PIC. All 01 PICs also will hold, at a 

minimum, a valid FAA second-class medical certificate. In accordance with the qualifications established 

by the FAA for the pilots of UAS aircraft operating pursuant to a COA under similar flight conditions, Ol's 

PICs should therefore be deemed qualified once they have successfully completed an FAA private pilot 

ground instruction course and passed the FAA Private Pilot examination or an FAA-recognized 

equivalent.3 

The manager for Ol's commercial UAS operations is Bryan Foster, a recognized UAS industry 

expert. Mr. Foster has over thirty years of experience building, flying and maintaining remotely-piloted 

systems, including 12 years as an instructor and 5 years of utilizing remotely piloted systems while in the 

U.S. Army Military Intelligence Corps. He has over 20,000 hours of experience operating remotelypiloted vehicles, and conducts between 500-750 UAS flights per year. This knowledge and experience 

has been incorporated into the training, flight procedures and maintenance record keeping developed 

for Ol's commercial UAS operations. 

Exemption Request 

01 is requesting an exemption from FAA regulations in order to conduct commercial UAS 

operations with a DJI S800 and Aeronavics X4 aircraft. Attached is a list of each FAA regulation from 

which 01 is requesting an exemption and the justification for each such exemption. In accordance with 

FAA requirements, in the case of each requested exemption, 01 is suggesting alternate methods of 

compliance that will provide a level of safety equivalent to that provided by the regulation from which 

an exemption is sought. 

Ol's request is consistent with the FAA's policies for the granting of exemptions. It also is in 

accord a nee with the direction provided by Congress in Section 333 of the FAA Modernization and 

Reform Act of 2012 (

11FAA Modernization Act"), instructing the Secretary of Transportation to determine 

which UAS aircraft operating 11Within visual line of sight" may be integrated into the National Airspace 

System rNAS") before the development of regulations governing the commercial use of other types of 

UAS aircraft.4 Because ofthe relatively small size, light weight, speed and operational capabilities of the 

DJI S800 and Aeronavics X4, as well as the strict visual line of sight protocols under which these UAS will 

be operated by 01, the OJI S800 and Aeronavics X4 aircraft may be safely operated without creating a 

hazard to other users of the NAS or a threat to national security. The DJI S800 and Aeronavics X4, 

operated as proposed herein, is therefore the type of UAS that ought to be the subject of operational 

3 See FAA Notice 8900.227 Unmanned Aircraft Systems Operational Approval, pp. 20-21. 

4 See, Pub. Law 112-95, 126 Stat. 11, § 333. 
ZucKERT ScouTT 

RASENBERGER August 26, 2014 

Page 6 

approval by the Department of Transportation prior to the issuance of regulations governing the 

operation of small unmanned aircraft systems generally. 

The UAS operations to be conducted by 01 pursuant to the requested exemption offer 

significant safety enhancements over current methods of providing the same commercial services. Ol's 

DJI 5800 and Aeronavics X4 aircraft have the ability to fly into difficult-to-access areas that present 

substantial hazards to other methods of data collection, including those involving close-up inspections 

by human beings. In evaluating Ol's request for an exemption, the FAA should consider not just the 

ability of 01 to achieve a level of safety equivalent to that afforded by the regulations from which an 

exemption is sought, but also the safety benefits to be derived from using UAS aircraft for services now 

performed by other means at substantially greater risk to human life. As demonstrated below, the FAA 

can allow these benefits to be realized without compromising its obligation to promote the highest level 

of aviation safety. 

Respectfully submitted, 

Counsel for 

Oceaneering International, Inc. 
ZucKERT ScouTT 

RASENBERGER 

OCEANEERING INTERNATIONAL, INC.- EXEMPTION REQUEST 

August 26, 2014 

Page 7 

Oceaneering International, Inc. requests an exemption from the following regulations of the 

Federal Aviation Administration: 

1. 14 C.F.R. § 45.23(b)- Display of marks; general 

This regulation requires the display of an "N" registration mark on any U.S.-registered aircraft. 

Additional markings are required for limited or restricted category aircraft, experimental aircraft or 

provisionally-certificated aircraft on the entrance to the cabin, cockpit or pilot station. 

Equivalent level of safety analysis: The FAA has yet to indicate whether UAS aircraft will be subject to its 

aircraft registration requirements. The FAA's Integration of Civil Unmanned Aircraft Systems in the 

National Airspace System (NAS) Roadmap published in November 2013 is silent on this point. As UAS 

aircraft are not currently required to be registered with the FAA, it is not necessary for Ol's UAS aircraft 

to be marked with an "N" registration number. 

The surface area of the DJI 5800 and Aeronavics X4 is not large enough to contain any of the 

markings required by the FAA for limited or restricted category aircraft, experimental aircraft or 

provisionally-certificated aircraft. One of the purposes served by these markings is to caution 

passengers on board such an aircraft (including any pilot) that it does not meet all of the FAA's 

requirements for a standard category certificate of airworthiness. As the DJI 5800 and Aeronavics X4 

will not carry any passengers, and otherwise will operate in accordance with strictly-controlled flight 

parameters, the absence of such a warning on the DJI 5800 and Aeronavics X4 will not result in any 

reduction in the overall safety of the operation. 

01 is willing to include any markings that may be required by the FAA in connection with its 

commercial UAS operations, with the understanding that the surface area of the DJI 5800 and 

Aeronavics X4 will not permit lettering that is larger than%- one inch in height. In addition, if requested 

by the FAA, 01 can place markings on each of the control stations used to operate Ol's UAS aircraft. 

2. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 C.F.R. § 91.203: Civil Aircraft: Certifications Required 

Under 14 C.F.R. § 91.203, all U.S.-registered aircraft are required to have a certificate of 

airworthiness issued by the FAA. Part 21, Subpart H of the FAA's regulations establishes the procedural 

requirements for the issuance of airworthiness certificates by the FAA. 

Equivalent level of safety analysis: The strict operational limitations under which 01 will conduct flights 

for commercial UAS applications (e.g., daylight operations, use of Class G airspace, all flights within lineof-sight of the operator) are at least as restrictive as the limitations that apply to the operation of 

limited or restricted category, experimental or provisionally-certificated aircraft. The DJI 5800 and 
ZucKERT ScouTT 

RASENBERGER 

August 26, 2014 

Page 8 

Aeronavics X4 do not carry a pilot or any other passengers and their small size and electric motor reduce 

the danger that any collisions with the ground or structures will involve anything more than the loss of 

the DJI S800 and Aeronavics X4. Automatic descent ofthe DJI S800 and Aeronavics X4 upon loss of the 

data link with its control station eliminates the potential for "fly away" incidents. The concerns behind 

the need for the certification of an aircraft's airworthiness are mitigated by the DJI S800's and 

Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in their 

construction, all of which reduce the risk of damage to surrounding structures. 

3. 14 C.F.R. § 61.133(a): Commercial Pilot Privileges and limitations 

FAA regulations generally require that an aircraft may engage in operations for compensation or 

hire only if it is flown by a person holding a commercial pilot certificate. 14 C.F.R. § 61.133(a). 01 

submits that hands-on experience with the flight characteristics of the DJI S800 and the Aeronavics X4 

and UAS aircraft generally are a far more effective guarantee of flight safety than a commercial pilot 

certificate would be in connection with Ol's proposed commercial UAS services. 

Equivalent level of safety analysis. A joy stick-operated UAS, such as the DJI S800 and Aeronavics X4, has 

flight characteristics substantially different from manned aircraft. The propulsion system and control 

surfaces on the DJI S800 and Aeronavics X4 respond to inputs that are transmitted remotely from the 

joy stick located on the control station. A commercially-licensed pilot would need to "unlearn" almost 

all the principles of flying a manned aircraft in order to successfully operate the DJI S800 and Aeronavics 

X4. On the other hand, an operator who had done all his or her "flying" on the DJI S800 and Aeronavics 

X4, with no previous flight experience with manned aircraft, would know no other type of airborne 

system but would be intimately familiar with maneuvering the DJI S800 and Aeronavics X4. 

01 therefore emphasizes UAS training and flight experience for those employees who will 

operate the DJI S800 and Aeronavics X4 for commercial services. An 01 employee will not be able to act 

as an operator of DJI S800 and Aeronavics X4 commercial services until successfully completing a 

minimum of 25 hours of UAS training flights (150 ten-minute flights). Successive levels of responsibility 

for UAS operations require additional hours of flight experience, as follows: 

Position 

Technician 

Pilot 

Senior Pilot 

Supervisor 

Superintendent 

Minimum Required Flight Experience 

25 hours of operations (150 ten-minute flights) 

75 hours of operations (450 ten-minute flights) 

150 hours of operations (900 ten-minute flights) 

250 hours of operations (1500 ten-minute flights) 

400 hours of operations (2400 ten-minute flights) 

The above-listed hours will be recorded in ASA-SP-30 pilot logbooks subject to inspection by FAA 

personnel at any time. Attached as Exhibit Dis a summary of Ol's training program for UAS operators. 
ZucKERT ScouTT 

RASENBERGER 

August 26, 2014 

Page 9 

By requiring extensive flight experience with the DJI 5800 and Aeronavics X4 prior to conducting 

commercial operations, 01 employees will have a better grasp of the handling of that aircraft and the 

available options in the event of an emergency than they would by holding a commercial pilot certificate 

for an entirely different type of airborne system. 

01 also conducts extensive simulator training and flight training for each of its DJI 5800 and 

Aeronavics X4 operators. Simulator training is in addition to the hands-on training experience required 

of each 01 employee prior to conducting commercial operations with the DJI 5800 and Aeronavics X4 

aircraft. The amount of training- under simulator conditions and hands-on- that 01 employees must 

complete before conducting commercial UAS services provides a level of experience specific to UAS 

flight operations that cannot be duplicated merely by holding a commercial pilot certificate. The 01 

operators of the DJI 5800 and Aeronavics X4 will thus be better prepared to conduct UAS flights than a 

commercially-licensed pilot who has never operated a UAS aircraft and is unfamiliar with its flight 

characteristics. 

In addition to UAS operational experience and simulator flight training, 01 also will require that 

before becoming a UAS operator an employee must complete an FAA-approved private pilot ground 

instruction course and have successfully passed the FAA Private Pilot written examination or an FAArecognized equivalent. Operators of 01 UAS aircraft will therefore receive instruction in aeronautical 

navigation, meteorology and aviation regulations prior to conducting commercial UAS operations. 

4. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. 

This regulation prohibits the operation of an aircraft unless it is in an airworthy condition. The 

DJI 5800 and Aeronavics X4 will not be the subject of an airworthiness certification process prior to their 

use by 01 for commercial UAS services. 

Equivalent level of safety analysis. The strict operational limitations under which 01 will conduct flights 

for commercial UAS applications (e.g., daylight operations, use of Class G airspace, all flights within lineof-sight of the operator) are at least as restrictive as the limitations that apply to the operation of 

limited or restricted category, experimental or provisionally-certificated aircraft. The DJI 5800 and 

Aeronavics X4 do not carry a pilot or any other passengers and their small size and electric motor reduce 

the danger that any collisions with the ground or structures will involve anything more than the loss of 

the DJI 5800 and Aeronavics X4. Automatic descent of the DJI.S800 and Aeronavics X4 upon loss ofthe 

data link with its control station eliminates the potential for 1/fly away" incidents. The concerns behind 

the need for the certification of an aircraft's airworthiness are mitigated by the DJI S800's and 

Aeronavics X4's limited operational range, small dimensions and the use of lightweight materials in their 

construction, all of which reduce the risk of damage to surrounding structures. 
ZucKERT ScouTT 

RASENBERGER August 26, 2014 

Page 10 

5. 14 C.F.R. § 91.9{b}(2): Civil Aircraft Flight Manual, Marking and Placard Requirements. 

This regulation requires that an approved flight manual, manual material, markings, placards or 

some combination thereof be placed on board the aircraft. Neither DJI S800 nor the Aeronavics X4 has a 

configuration suitable for compliance with this requirement. 

Equivalent level of safety analysis. The DJI S800 and Aeronavics X4 are linked to a computer that serves 

as the control station. The instruction manual for the DJI S800 and Aeronavics X4 can be downloaded to 

the computer and accessed by the operator, in much the same way that pilots of commercial airliners 

are able to access flight manuals on tablet devices that serve as "electronic flight bags." All manual 

material, markings and placards relevant to the operation of the DJI S800 and Aeronavics X4 can be 

displayed on the screen ofthe computer that serves as the control station, as required. The instruction 

manual for the DJI S800 and Aeronavics X4 will therefore be just as accessible as a flight manual carried 

onboard a commercial jet. 

6. 14 C.F.R. § 91.109(a) and 14 C.F.R. § 91.109{c): Flight Instruction: Simulated 

Instrument Flight and Certain Flight Tests. 

Under this regulation, aircraft used for training purposes must have dual flight controls, subject 

to certain exceptions. FAA regulations also require that whenever training is provided in a simulator, 

the simulator must have a second control seat occupied by a safety pilot who possesses at least a 

private pilot certificate with category and class ratings appropriate to the aircraft being flown. Neither 

Ol's UAS aircraft nor the simulator used by 01 for flight training purposes complies with these FAA 

requirements. 

Equivalent level of safety analysis. 01 has developed an extensive flight instruction training program for 

its employees who will conduct commercial UAS operations. Flight instruction is provided through 01 

and consists of ground instruction and flight training. Further training will be conducted with a 

computer flight simulator with a review of operator skills on a monthly basis. Pilots will be required to 

perform frequent training flights and refresher flights, at either an FAA-approved field or on 01 property 

with suitable objects for pilots to navigate to and around in a simulated commercial environment. 

As all operations of the DJI S800 and Aeronavics X4 are conducted with a joystick, a dulyqualified 01 employee with UAS flight experience at the Supervisor level will be able to observe all 

operator training by standing or sitting next to the computer that is used as the control station. 

Similarly, as flight simulations of the DJI S800 and Aeronavics X4 also are displayed on a computer 

screen, an 01 employee with high-level UAS flight experience is able to sit next to the operator and 

directly observe all phases of simulator training. In this manner, 01 will be able to satisfy the FAA's 

interest in having simulator training observed by a highly-experienced operator. 

The requirement for dual flight controls on an aircraft used for training purposes is mitigated by 

the DJI S800's and Aeronavics X4's limited operational range, small dimensions and the use of 

lightweight materials in their construction, all of which reduce the risk of damage to surrounding 

structures in the event of an operator error that results in the loss ofthe aircraft. 
ZucKERT ScouTT 

RASENBERGER 

7. 14 C.F.R. 91.119: Minimum Safe Altitudes: General 

August 26, 2014 

Page 11 

This regulation specifies the minimum altitude in various flight environments below which 

aircraft are not allowed to operate. 01 will conduct the commercial services it proposes to operate 

below the FAA-specified minimum of 500 feet above the surface and closer to vessels and structures 

than the minimum separation of 500 feet mandated by the FAA. 

Equivalent level of safety analysis. The operation of the DJI S800 and Aeronavics X4 aircraft exclusively 

in Class G airspace (i.e., below 500 feet) is intended as a safety measure to provide a level of separation 

between Ol's commercial UAS operations and the operation of manned aircraft at altitudes above 500 

feet. In this case, limiting the DJI S800 and Aeronavics X4 to flights below the 500 foot minimum will 

enhance safety rather than compromise it. 01 will need to operate the DJI S800 and Aeronavics X4 

closer than 500 feet to structures in order to conduct the inspections that will comprise a major part of 

Ol's commercial UAS services. However, Ol's flight procedures include the company's own 

requirements regarding the minimum level of separation between the DJI S800 and Aeronavics X4 and 

any nearby structures or facilities. In addition, the risk of damage to any nearby structures or facilities is 

reduced by Ol's S800's and Aeronavics X4's limited operational range, small dimensions and the use of 

lightweight materials in their construction. 

8. 14 C.F.R. § 91.121: Altimeter Settings 

Pursuant to this regulation, an aircraft that is operating below 18,000 feet above Mean Sea Level 

must contain an altimeter that is set to one of several designated altimeter settings prior to departure. 

Neither the DJI S800 nor the Aeronavics X4 includes an altimeter. 

Equivalent level of safety analysis: The operation of the DJI S800 and Aero navies X4 aircraft exclusively 

in Class G airspace (i.e., below 500 feet) away from commercial traffic and ATe-controlled airspace 

reduces the need for an altimeter on board Ol's UAS aircraft. The altitude of Ol's UAS aircraft above 

Mean Sea Level and its GPS coordinates will be displayed on the screen ofthe remote control station 

used by the 01 operator to perform any commercial services. The 01 operator will have continuous 

situational awareness of the UAS altitude and position as flight operations will be conducted under lineof-sight flight procedures. 

9. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. 

FAA regulations require that a rotorcraft operating under VFR conditions have sufficient fuel to 

fly to the first point of intended landing and, assuming normal cruising speed, to fly for at least an 

additional 20 minutes. Ol's DJI S800s arid Aeronavics X4 have a maximum operating time of 20 minutes. 

Equivalent level of safety analysis. The FAA's regulations require sufficient reserves of additional fuel to 

enable a rotorcraft to find the nearest suitable landing zone if the intended landing facility is not 

available. The additional time that a rotorcraft is required to be able to operate is less than the time 

required to allow fixed-wing aircraft to find a suitable landing field (30 minutes during the day, 45 

minutes at nightL reflecting the relative scarcity of landing fields for aircraft versus landing zones 

suitable for rotorcraft. By similar logic, the additional fuel required for UAS aircraft should be 
ZucKERT ScouTT 

RASENBERGER August 26, 2014 

Page 12 

dramatically less than for rotorcraft, as UA5 aircraft are small enough to land virtually anywhere. 

Because the DJI 5800 and Aeronavics X4 initiates an automatic spiral descent upon any loss of power, 

there is no need to require additional flying time for the DJI 5800 and Aeronavics X4 to find a suitable 

landing zone. The concerns behind the FAA's surplus fuel requirement for rotorcraft are mitigated by 

the DJI 5800's and Aeronavics X4's limited operational range, small dimensions and the use of 

lightweight materials in their construction, all of which reduce the risk of damage to surrounding 

structures. 

10. 14 C.F.R. § 91.203(a) & (b): Civil Aircraft: Certifications Required. 

The FAA requires that all civil aircraft have an appropriate and current airworthiness certificate 

and that the airworthiness certificate or special flight authorization for an aircraft be displayed at the 

cabin or cockpit entrance so that it is visible to passengers or crew. The DJI 5800 and Aeronavics X4 do 

not have a current airworthiness certificate nor do they have a surface area large enough to display a 

certificate of airworthiness or special flight authorization. 

Equivalent level of safety analysis. The strict operational limitations under which 01 will conduct flights 

for commercial UA5 applications (e.g., daylight operations, use of Class G airspace, all flights within lineof-sight of the operator) are at least as restrictive as the limitations that apply to the operation of 

aircraft that have been issued limited or restricted category, experimental or provisional certificates of 

airworthiness. The concerns behind the need for the certification of an aircraft's airworthiness are 

mitigated by the DJI 5800's and Aeronavics X4's limited operational range, small dimensions and the use 

of lightweight materials in their construction, all of which reduce the risk of damage to surrounding 

structures. 

One of the purposes served by the requirement to display a certificate or airworthiness on board 

an aircraft is to advise passengers (including any pilot) that the aircraft meets all of the FAA's 

requirements for a certificate of airworthiness. As the DJI 5800 and Aeronavics X4 will not carry any 

passengers, and otherwise will operate in accordance with strictly-controlled flight parameters, the 

absence of such a warning on the DJI 5800 and Aeronavics X4 will not result in any reduction in the 

overall safety of the operation. 

01 is willing to include any markings that may be required by the FAA in connection with its 

commercial UA5 operations, with the understanding that the surface area of the DJI 5800 and 

Aeronavics X4 will not permit lettering that is larger than%- one inch in height. 

11. 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Aircraft Maintenance and 

Inspections; Maintenance Records. 

FAA regulations impose various requirements regarding the maintenance of civil aircraft, 

including periodic inspections, approval for return to service by a qualified mechanic following 

maintenance or repair, an airworthiness inspection and certain rules concerning maintenance 

record keeping. Ol's maintenance of its DJI 5800 and Aeronavics X4 aircraft will not satisfy these 

requirements. 
ZucKERT Scourr 

RASENBERGER 

August 26, 2014 

Page 13 

Equivalent level of safety analysis. 01 will maintain the DJI 5800 and Aero navies X4 in accordance with 

the manuals and operating handbook provided by the manufacturer. Because of the DJI S800's and 

Aeronavics X4's small size and lightweight construction, 01 will be able to subject it to top-to-bottom 

examination after every flight. All pre- or post-flight maintenance, equipment failures, charge cycle logs, 

fault/repair logs, inspections and general maintenance records will be kept on file for a minimum of 

three years. 01 has developed a lengthy pre/post-flight checklist; any aircraft with is unable to meet all 

the requirements for safe operation will be removed from service immediately and will not return to 

service until any defects have been remedied. Moreover, if mechanical issues arise, the DJI 5800 and 

Aeronavics X4 can land immediately as they will be operating at an altitude no higher than 500 feet. 

The manufacturers periodically update parts and software for these UAS aircraft. Each time a 

UAS is tested in the office, 01 checks for the most recent stable software issued by the manufacturer {01 

will not use Beta software). If any parts have been updated by the manufacturer, 01 immediately places 

them on order to ensure its UAS aircraft have the most recent equipment and software. 

The number of hours that a UAS is in operation are logged by 01 to ensure proper life of 

components as well as the flight packs that provide power. Once a DJI 5800 and Aeronavics X4 aircraft 

has been removed from service its unique ID and serial number will not be re-issued.