Hogan 

Lovells 

March 25, 2015 

Hogan Lovells US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

T +1 202 637 5600 

F +1 202 637 5910 

www.hoganlovells.com 

By Electronic Mail and Electronic Submission (cover letter only) 

Mark W. Bury, Esquire 

Assistant Chief Counsel for Regulations 

Office of the Chief Counsel 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Re: Petition of Union Pacific Railroad for an Exemption from Certain FAR To Permit 

Unmanned Aircraft Systems Operations (Docket FAA-2014-1105) 

Dear Mr. Bury: 

In support of the above-referenced pending Petition for an Exemption, Union Pacific Railroad 

("UP") provides the FAA with the following enclosed documents: 

• (Exhibit 1) UP's UAS Standard Operating Procedure ("SOP") 

• (Exhibit 2) the FAA-approved AirCover QR425 UAS Operator/Pilot Manual 

• (Exhibit 3) the FAA-approved AirCover QR425 UAS Maintenance Manual 

• (Exhibit 4) AirCover's Quadrotor 425 Learning Objectives 

• (Exhibit 5) UP SOP Cross-Reference Chart (to facilitate the FAA's review of its SOP 

in light of the proposed conditions and limitations in its Petition). 1 

The SOP will be revised if necessary to reflect any additional conditions or limitations set forth in a 

UP UAS Exemption. In addition, the manufacturer's Learning Objectives document is provided as a 

sample only. UP will develop its own training program for UP's UAS crewmembers using this 

document as a starting point. 

As explained in the Petition, UP requests confidential treatment for the Maintenance Manual, 

Operator Manual, SOP, SOP Cross-Reference Chart, and Learning Objectives. Each of these 

documents contains information that is highly proprietary and confidential to AirCover and/or UP. 

UP will place a copy of this cover letter in the corresponding docket, but not the enclosed documents 

for which confidential treatment is requested. 

The Operator/Pilot Manual and the Maintenance Manual were approved by the FAA in the 

context of an experimental airworthiness certificate. 

Hogan Lovells US LLP rs a lrmrted liabrllty partnershrp regrstered rn the Drstrrct of Columbia "Hogan Lovells" 1s an rnternat1onal legal practrce that includes Hogan Lovells US 

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With this submission, UP requests that the FAA timely consider and rule on its Petition. 

Respectfully submitted, 

E. Tazewell Ellett 

Patrick R. Rizzi 

Counsel for Union Pacific Railroad 

tazewell.ellett@hoganlovells.com 

patrick. rizzi@hoganlovells. com 

D +1.202.637.8644/5659 

cc: James Williams, Manager, FAA UAS Integration Office 

Rob Pappas, Special Rules Coordinator, FAA UAS Integration Office 

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