August 13, 2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Ave., SE Washington, DC 20590 Marathon Petroleuri}

### ~oltlpiiny LP

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Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal AviationRegulations 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 AviationRegulations ("FARs") listedbelow:

• 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 S1000 ("sUAS")- to supportmaintenance and inspection efforts as well as provide aerial data collection at MPC'srefineries, 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 ofsafety is met to align with current regulations governing the use ofmanned aircraft. A detailed overview of the exemption requests and equivalent safety initiatives can be found inAppendix A ofthis 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 inthe Midwest, Southeast, Northeast and GulfCoastregions oftheU.S. MPC is a leader inthe 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 ofthe employees, contractors and neighboring communities. In addition, MPC is committed to

1On August 10,2015,this office granted Marathon Petroleum Company's request for exemptionNo. 12387 for operation ofthe DJI Phantom 2 Vision+. Marathon now respectfully requests exemption for operations withthe DJI Spreading Wings S1000. 1Marathon Petroleum Company LP Environmental Stewardship by conducting business practices with the goal ofminimizing 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 saferthan the average ofthe U.S. manufacturing sector as a whole, and three times as safe as the business ofchemistry overall. Responsible Care companies have reduced process safety incidents by 55 percent overthe past 19 years. Specifications ofthe DJI SpreadingWings SlOOO ("sUAS")

• Lightweight and multi-functional aircraft (approximately 4 kg.) • BatteryPowered • 15 minutes ofmax hoovertime • High Strengthperformance engineered plastics • 40A electronic speed controller • Anti-vibration and stabilizationtechnology • 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 ofsecured 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/orphotography. In addition, MPC will utilize the sUAS to provide aerial imaging for the ongoing MPC office headquarters expansionprojectin Findlay, OH. The sUAS will also assist in hazmat release response by giving emergency responders a better idea ofthe source or the release, and the extent and magnitude ofa 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 detailingthe current status ofthe incident, where potential hazard expansionmay occur, and risks to personnel and property. Conducting aerial photography and supporting maintenance, inspection and emergency response efforts with the sUAS, instead ofa manned aircraft will greatly benefit the public by drastically reducing the levels ofair 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 saferthan conventional manned operations.

2Marathon Petroleum Company LP Description ofOperations 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 ofthe unitbased onthe manufacturer's recommendations andFAAregulations priorto anyone operating the unit. Additional requirements and/or operating conditions are as follows: Operations will be conducted overprivate orcontrolled-accessproperty. All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority or airtraffic control. All flights will be operated withinthe visual line ofsight ofoperator. The sUAS will notbe flown at a speed exceeding a ground speed of50 knots. Pilot and observer will have beentrained inoperation ofsUAS. 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 operatingprocedures are included inAppendixD. Conclusion MPC has the highest regard for thehealth and safety ofits employees, contractors and neighboring communities. To ensure an equivalentlevel ofsafety is maintained during operation ofthe sUAS, MPC will require employees to betrained before deployingthe unit. In addition, Standard Operating Procedures will be developed andreviewed onan annual basis. As UAS technology continues to evolve, it will be essential for MPCto adapt andutilize these innovations to support safety efforts across the company. By developing robust operating procedures and comprehensivetraining programs, combined withthe overall benefit derived from deploying the sUAS, MPC can adequatelyjustifythe request for exemptions from the FAA pursuantto Section 333 ofthe FAAModernization and ReformAct of2012 (the "ReformAct") and 14 C.F.R. Part 11.
Regards,

MarlandL. Turner Attorney-LawOperations Marathon Petroleum CompanyLP

3539S. Main Street Findlay, OH45840 Office: 419-421-3131 mlturner(ivtnaratlwnpetroleum.com Marathon Petroleum Company LP

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### Appendix A: Regulations From Which Exemption is Requested Equivalent Level ofSafetyInitiatives

14 C.F.RPart21, SubpartH: 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 ofcertain 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 unnecessaryto 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 ofan equivalent level ofsafety under Part 11 and Section 333 ofthe 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 enforcedbeforebringing the sUAS into service. An analysis ofthese different criteria demonstrates that the sUAS, operating without an airworthiness certificate under the conditions proposed inthat 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 oftheAircraft 14 C.F.R § 45.23, states: (a) Each operator of an aircraft must display on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed by the registration number ofthe 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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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 canbe placed.
14 C.F.R. § 61.3 Requirements for Certificates, Ratings and Authorizations The regulation provides that no personmay serve as arequired pilot flight crewmemberof a civil aircraft ofthe United States, unless thatperson: (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, apilot 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 ofthe 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 sUAS safety standards set by MPC, and keep the sUAS in visual line ofsight (VLOS) at all times.

14 C.F.R. § 91.7(a): CivilAircraftAirworthiness 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 ofthe sUAS. MPC will ensure that the sUAS operators are trained to use and adhere to the user manual provided by the manufacturer ofthe sUAS. An equivalent level ofsafety will be achieved by insuring compliance with the sUAS user manual for flight operations.

14 C.F.R. § 91.9: CivilAircraftFlight Manual, Marking, and Placard Requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is inthe aircraft. MPC assumes thatthe intent ofthis 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 onthe 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 ofsafety by keeping a hard copy of the sUAS user manual withthe operator during all flights, and withthe sUAS when not in flight.

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14 C.F.R. § 91.109(a): FlightInstruction 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 atraining 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 ofa 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 ofsafety for operator flight instruction.

14 C.F.R. § 91.119: Minimum Safe Altitudes The regulationprovides that over sparsely populated areas, the aircraft cannotbe 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 exemptionto this requirementto allowthe sUAS to be flown closer than 500 feet to a person, vessel, vehicle, or structure during emergency response training and actual emergencyresponse incidents. The equivalent level of safety will be achieved because the sUAS will only fly over secured and controlled areas ownedby MPC or other securedprivate propertywiththe permission ofthe landowner. Before every flight over MPC controlled property, an MPC operator or official will assess the working area and restrict access priorto take-off. Also, any potentialbuildings and people within this working area will not be exposed to the operations without their pre-obtained authorization. Due to the small size ofthe sUAS, the material with whichthe 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 orpropertyposed by largermanned aircraft.
14 C.F.R. § 91.121 -AltimeterSettings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

... to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." Relieffrom 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 athigher altitudes.

7Marathon 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 ofintended 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 ofthe batterypowered sUAS during daylight hours invisual meteorological conditions. Given the area ofoperation for the sUAS, MPC submits that an equivalent level ofsafety 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 monitoredby the pilot incommand and other groundpersonnel.

14 C.F.R. § 91.405 (a);§407(a) (1); § 409(a) (2); § 417(a) & (b): MaintenanceInspections 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 returnto 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 onlyto aircrafts with an airworthiness certificate. An equivalent level ofsafety will be achievedbecause the sUAS is small in size, it is not a complex mechanical device and does not carry any external payload otherthan 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 ofsafety as the FAAregulations specified above.

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### Appendix B: Summary to publish in the Federal Register Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, Marathon Petroleum Company LP ("MPC"), petitions for an exemption from the Federal Aviation Regulations listedbelow:

• 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 S1000 ("sUAS")

- 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 subjectto the strict safetyrequirements setforth by MPC in this petition to ensure an equivalent or greater level ofsafety is met to align with current regulations governing the use ofmanned aircraft.

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### Appendix C: Pre-Flight Checklist and Standard Operating Procedures Marathon Petroleum Company UAS Pre-Flight Checklist
Crew Member Responsibilities Pilot-Responsible forturning onall equipment, andmaking suretheUAS ispreppedandready 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, AreaofFlight) Flight Plan- Crewmembers will prepare a flightplan for the flight. The area, direction, altitude, speed, and anyotherfactors willberecordedby eitherthe co-pilot, orthe crew member. Thepilot's main job is to operate and controlthe aircraft. Pre-Flight Checklist The pilot and co-pilot will checkthe UAS outto ensurethe following are attachedproperly and functioning properly. 1. Landing Gear 2. Camera/Gimbal 3. Propeller Guards 4. Propellers 5. Controller and equipment
VerifY there are multiple batteries chargedand ready withthe sUAS, also ensureMarathonID stickers are placed onthe UAS. Ifa flight plan is to beused, all members will be briefed on the path, as well as the home spot, whichwill bemarkedby a landing spot. TheUAS will be calibratedto land at that spot ifany emergencies occur. The UAS battery will alertwhen it gets to the Point ofSafe Return ("PSR"). The UAS will automatically return whenreachingthis point.

10Flight Checklist - Preparing To Operate Whenthe 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 sentto 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-pilotcontrol 

### units shouldbe showing allthe flight parameters ofthe UAS, as well as the livevideo feed. After completingthese procedures, thepilot canbeginthe 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 willnotdeploy andflyUAS until: A. Preflight checklist has been completed, weather conditions evaluated and approved by IC. B. A minimumoftwooperatorshavehadbothpilotandco-pilottraining for UAS. • The properpermits are obtained and notifications are made Ensuring all airports within 5miles are briefed ofthe flight area, and permission is obtainedto operatethe UAS. II. All personnel engaged inUAS operations shall record at minimum but not limited to: A. Time B. Date C. Operational Personnel D. Unit number E. Flightplan F. Altitudes G. DistanceFlown H. Weather Conditions/ Visibility I. WindDirection/Speed J. Take off, Departurepoints K. Pre/PostBatteryLife

{391569.DOCX 2}III. Takeoff. in flight. and landing: A. Pilot and Co-pilot must agree on objectives, flight plan, and capabilities ofUAS. B. Memory cardsmustbeblankedpriortotakeoff. C. Scene survey for takeoffpaying special attention to overhead obstructions. D. Heightrestrictions are to not exceed 400 feet and shallbe determined priorto flight. E. Distance restrictions shall be no further than visual line ofsight from Pilot, Copilot or Spotter. F. Ifstaffingpermits, athird trained person will be recording updates to flight log as well as maintaining communication with the staging officer. G. Priorto landing, theUASPilot andCo-pilotwill agree onlandingzone ("LZ"). H. Immediately after landing UAS the crew will replace batteries, upload aerial footage, and get UAS back intoworking order. I. A flight log with minimum requirements will be completed with every takeoff and every landing. Ifthe UAS is landing for a battery switch a new flight log needs to be started.

IV. Conditions in which flight may be grounded A. Anyweather deemedhazardous bytheIC. B. Windsinexcessof20mph. C. Insufficient man power. D. Insufficientnumber ofqualified Pilots and Co-pilots. E. Temperaturesunder 32 degreesFahrenheit F. Visibility is too low hindering Co-pilots line ofsight ofUAS. G. Anyreason deemedunsafeby IC orother emergencyresponse personnel.

UASCrewMember

1. Ensure all equipment is available and pull equipment as requested by pilot/copilot 2. Checkweatherreports for a. Temperature b. Wind speed and direction c. Humidity 3. Securechargingspotforbatteries 4. Formperimeter at least 10 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 neededwhile the UAS is on the ground 7. When the UAS is ready to fly, return to step 6 8. Post flight, assist with breaking downUAS/equipment, and finish flight logs

{391569.DOCX 2 }Flight Crew UAS Pre-Flight 1. Determine fly/no-fly based upon conditions 2. CheckUAS a. Propellers/propellerguards b. Landing gear c. Gimbal/cameracovers removed d. Girnbal/camerafree-spinningwhenoff e. GPS tracker and battery secured 3. Checkcontroller a. GPS unit charged b. Batteriesinsertedincontroller c. S1 and S2switchesbothup d. Both control sticks return to neutral 4. Find suitable "helispot" for UAS a. Checkforobstructions/hazardsinthevicinity oftheflight area UAS Flight Checklist 1. Turn on GPS tracker 2. Tum on Wi-Fi extender 3. Tum on controller 4. Tum onUAS 5. Connect to device, and verify "home point" 6. Createflightpathifapplicable 7. Notify members that the UAS is going airborne

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