August 13, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Marathon Pet role uri} ~oltlpiiny LP ·. .oi -~-:, - ·' ; i 

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Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Madam or Sir, 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform 

Act") and 14 C.F .R. Part 11, Marathon Petroleum Company LP ("MPC"), petitions for an 

exemption from the Federal Aviation Regulations ("F ARs") listed below: 

• 14 C.F.R. Part 21 Subpart H 

• 14 C.F.R. § 45.23 

• 14 C.F.R. § 61.3 

• Sections of 14 C.F.R. Part 91 (specifically§§ 91.7 (a), 91.9, 91.109 (a), 91.119, 91.121, 

91.151 (b), 91.403, 91.405, 91.407, 91.409, and 91.417). 

The requested exemption would authorize MPC to operate the unmanned aircraft system 

("UAS") DJI Spreading Wings S 1000 ("sUAS")- to support maintenance and inspection efforts 

as well as provide aerial data collection at MPC's refineries, terminals, office buildings and other 

corporate properties. 1 These operations will be subject to strict safety requirements set forth by 

MPC to ensure an equivalent level of safety is met to align with current regulations governing 

the use of manned aircraft. 

A detailed overview of the exemption requests and equivalent safety initiatives can be 

found in Appendix A of this document. 

Background on Marathon Petroleum Company LP 

MPC, headquartered in Findlay, OH, is one of the largest petroleum product refiners, 

marketers and transporters in the United States. MPC is the nation's fourth-largest refiner and 

the largest refiner in the Midwest. MPC's refining, marketing and transportation operations are 

concentrated primarily in the Midwest, Southeast, Northeast and Gulf Coast regions ofthe U.S. 

MPC is a leader in the Health, Environment, Safety and Security ("HES&S") field within 

the oil and gas industry. The company has the highest regard for the health and safety of the 

employees, contractors and neighboring communities. In addition, MPC is committed to 

1 On August 10,2015, this office granted Marathon Petroleum Company's request for exemption No. 12387 for 

operation of the DJI Phantom 2 Vision+. Marathon now respectfully requests exemption for operations with the DJI 

Spreading Wings S 1000. 

1 
Marathon Petroleum Company LP 

Environmental Stewardship by conducting business practices with the goal of minimizing the 

company's environmental impact. MPC is an American Chemistry Council "Responsible Care" 

company. Responsible Care companies are committed to worker safety. They are nearly six 

times safer than the average of the U.S. manufacturing sector as a whole, and three times as safe 

as the business of chemistry overall. Responsible Care companies have reduced process safety 

incidents by 55 percent over the past 19 years. 

Specifications of the DJI Spreading Wings SlOOO ("sUAS") 

• Lightweight and multi-functional aircraft (approximately 4 kg.) 

• Battery Powered 

• 15 minutes of max hoover time 

• High Strength performance engineered plastics 

• 40A electronic speed controller 

• Anti-vibration and stabilization technology 

• Retractable landing gear 

• DJI multi-rotor autopilot system 

Intended Use and Benefits to the Public 

MPC desires to utilize the sUAS for maintenance and monitoring operations at MPC 

refineries, terminals, oil tank farms and office buildings. MPC will also utilize the sUAS to 

provide aerial imaging for the monitoring of secured and controlled construction sites, including 

the ongoing MPC headquarters expansion project in Findlay, OH. The sUAS will operate in a 

line of sight and will operate only within controlled environments including, restricted 

perimeters around structures (pipelines, refineries, terminals) requiring aerial inspections, and 

restricted perimeters around office buildings requiring promotional video and/or photography. In 

addition, MPC will utilize the sUAS to provide aerial imaging for the ongoing MPC office 

headquarters expansion project in Findlay, OH. 

The sUAS will also assist in hazmat release response by giving emergency responders a 

better idea of the source or the release, and the extent and magnitude of a spill. By monitoring 

hazardous incidents remotely, emergency response personnel are less likely to be exposed to 

unseen dangers. Once the sUAS is in the air, it can provide real-time data back to emergency 

response personnel. This data can assist in making decisions by detailing the current status of the 

incident, where potential hazard expansion may occur, and risks to personnel and property. 

Conducting aerial photography and supporting maintenance, inspection and emergency 

response efforts with the sUAS, instead of a manned aircraft will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during traditional flights. The 

sUAS operates at slow speeds, close to the ground and in controlled environment and as a result 

is safer than conventional manned operations. 

2 
Marathon Petroleum Company LP 

Description of Operations and Safety Programs 

MPC requires any potential users to obtain initial safe operations training and require 

annual refresher training. MPC requires training on all operation systems as well as safe 

operation of the unit based on the manufacturer's recommendations and FAA regulations prior to 

anyone operating the unit. Additional requirements and/or operating conditions are as follows: 

Operations will be conducted over private or controlled-access property. 

All operations conducted within 5 miles from an airport shall only be initiated after 

verbal coordination with the airport authority or air traffic control. 

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

The sUAS will not be flown at a speed exceeding a ground speed of 50 knots. 

Pilot and observer will have been trained in operation of sUAS. 

All required permissions and permits will be obtained from state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

A pre-flight checklist and standard operating procedures are included in Appendix D. 

Conclusion 

MPC has the highest regard for the health and safety of its employees, contractors and 

neighboring communities. To ensure an equivalent level of safety is maintained during operation 

of the sUAS, MPC will require employees to be trained before deploying the unit. In addition, 

Standard Operating Procedures will be developed and reviewed on an annual basis. 

As UAS technology continues to evolve, it will be essential for MPC to adapt and utilize these 

innovations to support safety efforts across the company. By developing robust operating 

procedures and comprehensive training programs, combined with the overall benefit derived 

from deploying the sUAS, MPC can adequately justify the request for exemptions from the FAA 

pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") 

and 14 C.F .R. Part 11. 

Regards, 

Marland L. Turner 

Attorney -Law Operations 

Marathon Petroleum Company LP 

3 
539 S. Main Street 

Findlay, OH 45840 

Office: 419-421-3131 

mlturner(ivtnaratlwnpetroleum.com 

Marathon Petroleum Company LP 

4 
Marathon Petroleum Company LP 

Appendix A: Regulations From Which Exemption is Requested Equivalent 

Level of Safety Initiatives 

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

14 C.F.R. § 91.203(a)(1) 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR 14 C.F.R. § 91.203(a). The Federal 

Aviation Act and Section 333 gives the FAA authorization to exempt aircraft from the 

requirement for an airworthiness certificate upon consideration of certain characteristics. 

Given the size ofthe sUAS, being very light weight (approximately 8.8 pounds)and the 

limited operating area associated with its utilization, it is unnecessary to go through the certificate 

of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety 

levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate. 

The sUAS will operate exclusively within a controlled and secured area. The sUAS weighs 

approximately 8.8 pounds. It will not carry a pilot or a passenger. It will not carry explosive or 

flammable materials. Nor will it be operated at night. MPC has developed safety procedures, 

including a pre-flight checklist that will be followed before operating the sUAS. MPC has 

developed safety procedures that will be enforced before bringing the sUAS into service. 

An analysis of these different criteria demonstrates that the sUAS, operating without an 

airworthiness certificate under the conditions proposed in that exemption, will be at least as safe, 

or safer, than a conventional aircraft with an airworthiness certificate and pose no credible threat 

to national security due to its size, speed, and proposed operations. 

14 C.F.R. §§ 45.23 Markings of the Aircraft 

14 C.F.R § 45.23, states: 

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman 

capital letter "N" (denoting United States registration) followed by the registration number 

of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital 

letter. 

(b) When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 

6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

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Marathon Petroleum Company LP 

Given the size of the sUAS and small size of the airframe and components, this 

requirement is impossible to match. Accordingly, exemption from the above regulation is 

warranted because the sUAS has no entrance to the cabin, cockpit or pilot station on which the 

markings can be placed. 

14 C.F.R. § 61.3 Requirements for Certificates, Ratings and Authorizations 

The regulation provides that no person may serve as a required pilot flight crewmember of 

a civil aircraft of the United States, unless that person: 

( 1) Has a pilot certificate or special purpose pilot authorization issued under this part in that 

person's physical possession or readily accessible in the aircraft when exercising the privileges of 

that pilot certificate or authorization. However, when the aircraft is operated within a foreign 

country, a pilot license issued by that country may be used. 

Given the safety features of the sUAS and the stringently enforced operating and 

maintenance procedures described herein, MPC proposes that operators of the sUAS should not 

be required to hold a commercial or private pilot certification. Instead, an equivalent level of 

safety will be maintained because operators will be required to adhere to the s U AS safety 

standards set by MPC, and keep the sUAS in visual line of sight (VLOS) at all times. 

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

This regulation states that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing operation of the sUAS without an 

airworthiness certificate, no standard will exist for airworthiness of the sUAS. MPC will ensure 

that the s U AS operators are trained to use and adhere to the user manual provided by the 

manufacturer of the sUAS. An equivalent level of safety will be achieved by insuring compliance 

with the sUAS user manual for flight operations. 

14 C.F.R. § 91.9: Civil Aircraft Flight Manual, Marking, and Placard Requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. MPC assumes that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. The sUAS, 

given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot onboard, but because there is no room or capacity to 

carry such an item on the aircraft. 

MPC requests an exemption to this requirement since the aircraft is not only too small to 

carry documentation, but the documentation would not be available to the crew, as there is no 

flight crew on board. MPC will achieve an equivalent level of safety by keeping a hard copy of 

the sUAS user manual with the operator during all flights, and with the sUAS when not in flight. 

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Marathon Petroleum Company LP 

14 C.F.R. § 91.109(a): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." 

Flight instruction will be accomplished through a training program as required by MPC's 

safety procedures. The sUAS's light weight and slow speeds with no pilot or passengers on board 

will create less of a danger to the public than a conventional aircraft equipped with dual controls. 

Through safety procedures, on-ground training and flight simulation, MPC will achieve an 

equivalent level of safety for operator flight instruction. 

14 C.F.R. § 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas, the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. The sUAS will be utilized for 

aerial monitoring and inspection around MPC's refineries, terminals, pipelines, and other 

structures; therefore, MPC seeks an exemption to this requirement to allow the sUAS to be flown 

closer than 500 feet to a person, vessel, vehicle, or structure during emergency response training 

and actual emergency response incidents. 

The equivalent level of safety will be achieved because the sUAS will only fly over 

secured and controlled areas owned by MPC or other secured private property with the permission 

of the landowner. Before every flight over MPC controlled property, an MPC operator or official 

will assess the working area and restrict access prior to take-off. Also, any potential buildings and 

people within this working area will not be exposed to the operations without their pre-obtained 

authorization. Due to the small size of the sUAS, the material with which the sUAS is built and its 

specific safety procedures, the hazard to persons, vessels, vehicles, and structures is small and not 

comparable to hazards to persons or property posed by larger manned aircraft. 

14 C.F.R. § 91.121 -Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." 

Relief from Section 91.121 is sought to the extent necessary to allow flight operations of 

the sUAS with GPS and radar equipment. To provide an equivalent level of safety, MPC will 

keep the sUAS in VLOS at all times. In addition, MPC can utilize the radar and GPS function 

provided with the sUAS drone kit to help restrict the aircraft altitude during operation. Keeping 

the sUAS air operations to less than 500 feet in altitude greatly reduces the risk as compared to 

other larger aircraft operating at higher altitudes. 

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Marathon Petroleum Company LP 

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

Conditions 

The regulation provides that no person may begin a flight in an aircraft under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

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

least 15 minutes. Relief from Section 91.151(a) is requested to the extent required to allow 

flights of the battery powered sUAS during daylight hours in visual meteorological conditions. 

Given the area of operation for the sUAS, MPC submits that an equivalent level of safety 

is already achieved due to the fact that MPC will ensure the battery is properly charged before 

each use. In addition, the sUAS has a max flight time of 15 minutes, and this time limit and 

battery life will be monitored by the pilot in command and other ground personnel. 

14 C.F.R. § 91.405 (a);§ 407(a) (1); § 409(a) (2); § 417(a) & (b): Maintenance Inspections 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with Parts 39 and 43. Sections 91.407 

and 91.409 require the aircraft to be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. Section 91.409 requires an annual inspection for the 

issuance of an airworthiness certificate. Section 91.417 requires the owner or operator to keep 

records showing certain maintenance work that has been accomplished by certificated mechanics, 

under Part 43. MPC requests an exemption from the above referenced regulations because such 

regulations apply only to aircrafts with an airworthiness certificate. 

An equivalent level of safety will be achieved because the sUAS is small in size, it is not a 

complex mechanical device and does not carry any external payload other than the camera. MPC 

will maintain the sUAS in accordance with the sUAS user manual. In the event maintenance is 

required, it will be performed and recorded in a maintenance log specific to the sUAS. Qualified 

persons authorized by MPC will inspect the sUAS to ensure it is capable of operations before 

returning it to service after maintenance. These measures provide an equivalent level of safety as 

the FAA regulations specified above. 

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Marathon Petroleum Company LP 

Appendix B: Summary to publish in the Federal Register 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. 

Part 11, Marathon Petroleum Company LP ("MPC"), petitions for an exemption from the Federal 

Aviation Regulations listed below: 

• 14 C.F.R. Part 21 Subpart H 

• 14 C.F.R. § 45.23 

• 14 C.F.R. § 61.3 

• Sections of 14 C.F.R. Part 91 (specifically §§91.7 (a), 91.9, 91.109 (a), 91.119, 91.121, 

91.151 (a), 91.403, 91.405, 91.407, 91.409, and 91.417). 

The requested exemption would authorize MPC to operate the unmanned aircraft system -

DJI Spreading Wings S 1000 ("s U AS") - to support safety, maintenance, and inspection efforts as 

well as provide aerial data collection at MPC's refineries, terminals, office buildings and other 

corporate properties. These operations will be subject to the strict safety requirements set forth by 

MPC in this petition to ensure an equivalent or greater level of safety is met to align with current 

regulations governing the use of manned aircraft. 

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Marathon Petroleum Company LP 

Appendix C: Pre-Flight Checklist and Standard Operating Procedures 

Marathon Petroleum Company UAS Pre-Flight Checklist 

Crew Member Responsibilities 

Pilot- Responsible for turning on all equipment, and making sure the UAS is prepped and ready 

to operate. 

Co-Pilot- Responsible for all checklists, and ensures all equipment is functioning. 

Crew Member- Maintains flight logs, gathers extra equipment needed for pilot/co-pilot, 

monitors radios, accesses any other items needed to fly. 

Weather Conditions- VerifY the weather conditions are adequate for flight operations. (i.e. 

Wind, Time ofDay, Daylight, Precipitation, Area ofFlight) 

Flight Plan- Crew members will prepare a flight plan for the flight. The area, direction, 

altitude, speed, and any other factors will be recorded by either the co-pilot, or the crew 

member. The pilot's main job is to operate and control the aircraft. 

Pre-Flight Checklist 

The pilot and co-pilot will check the UAS out to ensure the following are attached properly 

and functioning properly. 

1. Landing Gear 

2. Camera/Gimbal 

3. Propeller Guards 

4. Propellers 

5. Controller and equipment 

VerifY there are multiple batteries charged and ready with the sUAS, also ensure Marathon ID 

stickers are placed on the UAS. If a flight plan is to be used, all members will be briefed on 

the path, as well as the home spot, which will be marked by a landing spot. The UAS will be 

calibrated to land at that spot if any emergencies occur. 

The UAS battery will alert when it gets to the Point of Safe Return ("PSR"). The UAS will 

automatically return when reaching this point. 

10 
Flight Checklist - Preparing To Operate 

When the pilot is ready to operate the sUAS, complete the following checklist: 

Action Complete Not Complete Comments 

1. Turn on GPS Tracker (an automatic email will be sent to 

the UAS flight duration folder) 

2. Turn on Wi-Fi Extender, 

3. Turn on Controller 

4. Turn on the UAS 

5. Verify the UAS responds appropriately to controls 

The pilot and co-pilot control units should be showing all the flight parameters ofthe UAS, as 

well as the live video feed. 

After completing these procedures, the pilot can begin the mission. 

Marathon Petroleum Unmanned Aircraft System Standard Operating Guidelines 

Scope of Operation: These standard operating guidelines will provide for the safety of 

Marathon Petroleum when operating an unmanned aircraft system (UAS). 

I. Marathon will not deploy and fly UAS until: 

A. Preflight checklist has been completed, weather conditions evaluated and 

approved by IC. 

B. A minimumoftwooperatorshave had bothpilotandco-pilottraining for UAS. 

• The proper permits are obtained and notifications are made Ensuring all 

airports within 5 miles are briefed of the flight area, and permission is 

obtained to operate the UAS. 

II. All personnel engaged in UAS operations shall record at minimum but not 

limited to: 

A. Time 

B. Date 

C. Operational Personnel 

D. Unit number 

E. Flight plan 

F. Altitudes 

G. Distance Flown 

H. Weather Conditions/ Visibility 

I. WindDirection/Speed 

J. Take off, Departure points 

K. Pre/Post Battery Life 

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III. Takeoff. in flight. and landing: 

A. Pilot and Co-pilot must agree on objectives, flight plan, and capabilities ofUAS. 

B. Memory cards must be blanked prior to take off. 

C. Scene survey for takeoff paying special attention to overhead obstructions. 

D. Height restrictions are to not exceed 400 feet and shall be determined 

prior to flight. 

E. Distance restrictions shall be no further than visual line of sight from Pilot, Copilot or Spotter. 

F. If staffing permits, a third trained person will be recording updates to flight log as 

well as maintaining communication with the staging officer. 

G. Prior to landing, the UAS Pilot and Co-pilot will agree on landing zone ("LZ"). 

H. Immediately after landing UAS the crew will replace batteries, upload aerial 

footage, and get U AS back into working order. 

I. A flight log with minimum requirements will be completed with every takeoff 

and every landing. If the UAS is landing for a battery switch a new flight log 

needs to be started. 

IV. Conditions in which flight may be grounded 

A. Any weather deemed hazardous by the IC. 

B. Winds inexcessof20mph. 

C. Insufficient man power. 

D. Insufficient number of qualified Pilots and Co-pilots. 

E. Temperatures under 32 degrees Fahrenheit 

F. Visibility is too low hindering Co-pilots line of sight of UAS. 

G. Any reason deemed unsafe by IC or other emergency response personnel. 

UAS Crew Member 

1. Ensure all equipment is available and pull equipment as requested by pilot/copilot 

2. Check weather reports for 

a. Temperature 

b. Wind speed and direction 

c. Humidity 

3. Secure charging spot for batteries 

4. Form perimeter at least 1 0 feet around launch site 

5. Announce when the UAS is at "bingo" fuel, and is returning to the helispot 

6. Gather extra batteries/equipment as needed while the UAS is on the ground 

7. When the UAS is ready to fly, return to step 6 

8. Post flight, assist with breaking down UAS/equipment, and finish flight logs 

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Flight Crew 

UAS Pre-Flight 

1. Determine fly/no-fly based upon conditions 

2. Check UAS 

a. Propellers/propeller guards 

b. Landing gear 

c. Gimbal/camera covers removed 

d. Girnbal/camerafree-spinningwhenoff 

e. GPS tracker and battery secured 

3. Check controller 

a. GPS unit charged 

b. Batteries inserted in controller 

c. S 1 and S2 switches both up 

d. Both control sticks return to neutral 

4. Find suitable "helispot" for UAS 

a. Checkforobstructions/hazards in the vicinity ofthe flight area 

UAS Flight Checklist 

1. Turn on GPS tracker 

2. Tum on Wi-Fi extender 

3. Tum on controller 

4. Tum on UAS 

5. Connect to device, and verify "home point" 

6. Create flight path if applicable 

7. Notify members that the UAS is going airborne 

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