CalPortland	Company	333	petition 1
, Submitted electronically

October 6, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

RE: Petition for Exemption from Certain Federal Aviation Regulations according

to Section 333 of the FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

CalPortland Company ( CALP ) is applying for an exemption from the Code of Federal

R egulations as detailed below allow CALP to conduct aerial inspections of its aggregate mining quarries as detailed below

The exemption would permit commercial operation of a small unmanned aircraft system ( sUAS ) in the national air s pace (NAS) as regulated by the FAA for aerial data

collection to include, but not limited to, the following uses :

I. R emote sensing and measuring by an instrument(s) aboard t he sUAS including

A. imagery (photo graphy, video, infrared, etc.)

B. electronic measurement (precision surveying, RF analysis, etc.)

C. chemical measurement ( particulate measurement, etc.)

D. or any other gathering of data by instruments aboard the sUAS

.

II. Assisting in maintaining public safety in times of emergency including

A. aerial photography and evaluation of emergency response scenes and operations with CALP agreement

B. emergency servi ces support and search and rescue with CALP agreementCAL333A1007 15 2 All operations performed by CALP are cost

- effective and protect the public by reducing the size of the aircraft from one weighing up to several tons to one weighing less than 55 pounds. In addition, the UA does not use flammable liquid fuel. Instead, it operates on high

- energy batteries. The UA is flown in the lower strata of controlled and uncontrolled airspace, at 400 ft. AGL and below. CALP commercial operations will be performed according to FAA regulations or amended FAA regulations as permitted under a Section 333 Grant of Exemption.

BACKGRO UND AND REFERENCES

The aggregates industry in the United States supplies two billion tons of materials yearly
to build its infrastructur e of homes, roadways, civil construction projects and initiatives protecting the environment. CALP is a vital provider of aggregates in the Western
United States

. In addition to supplying the needed materials for the purposes above, CALP also offers cement, asphalt, concrete, and prefabricated building material and performs earth moving and roadway construction se rvices.

Stockpiles and surges piles at mine and distribution terminal locations can present a continuous potential danger. Survey personnel and accompanying operations personnel

are exposed to the risks of fall, slide, and unintentional encounter s with heavy equipment. Spending less time on or near the stockpile can mitigate these risks . In these hazardous environments, the use of a small unmanned aircraft would offer a faster, safer alternative to human measurement and inspection.

In addition to the stockpile and surge risks, s urface mine a creage is also permitted for explosive materials requiring controlled a ccess with strict safety protocols.

Using a n sUAS provides the needed assist for this type of risk mitigation. It offers faster and safer inspections and measurements than manual survey, thereby reducing risk of

survey accidents

. Mine sites can encompass many hundreds to thousands of miles of acres. Properties are normally some distance from population, roadways, airports, and
low

- flying aircraft.

Stockpile survey techniques are of three general types:

1. Total stations and GPS with prism and reflector or reflectorless;

2. Terrestrial laser scanners, fixed

- position or mobile;

3. Aerial photogrammetry by manned aircraft.CAL333A1007 15 3 There are risks to personnel in all three practices.

The first technique, using total stations and GPS, is time

- consuming

, requires a ground

surveyor to ascend the stockpile with an instrument, and may require them to be accompanied by an experienced mining employee. Surveyors may be exposed to t he following hazards:

• Stockpiles are marginally stable surfaces, may conceal voids, and expose people to
falls and slides.

• Moisture and freezing change slope stability and allow it to stand at a steeper angle, then suddenly stress and collapse.

• Exposure to injury is not limited to standing on the top: loading out by heavy equipment at the bottom or face can create slides and the collapse of overhangs,
and the surveyor’s interaction with hea vy mining equipment is a potential hazard.

• The top s of piles , the dozer’s windrows, and the terraces or benches cannot be accurately surveyed unless measured from above as well as from lateral angles.

Because of the above hazards

, the United States Mine Safety and Health Administration (MSHA) regulates access to stockpiles, surge piles, and equipment

. In addition to the
MSHA , there are thirty States within the U.S. that have regulatory agencies monitoring the mining industry.

The second technique, using a laser scanner, involves setting up survey equipment on the ground or transporting it around in the mine in a vehicle for good measurement angles. Volumes may not be accurately measured from the bottom, and there are many obsta cles
to view.

The third technique, aerial survey by manned aircraft, allows a top view but oblique angle viewing is challenging. Descent into the mine with the manned aircraft is not an option. Many survey targets are 100 or more feet below the lip of the open pit

.

Active mining requires that the property perimeters be strictly controlled due to danger, including frequent explosive use. At a typical mid

- size mine more than 40 million cubic yards of noncommercial waste materials per year per site are nece ssary to be moved

.

With appropriate planning, mine s ites offer a sterile environment in which to operate a small unmanned aircraft: personnel and equipment onsite are under supervision and visual line of sight (VLOS) flight operations fit well within boundaries. Using a smallCAL333A1007 15 4 electric aircraft lets the pilot an d survey crew work at a safer standoff distance from potential hazards, and accomplishes tasks in less time than other ground

- based techniques. The risks of manned aircraft flight for survey are avoided, and the use of the NAS is consistent with the safety of other users.

CALP wishes to increase its effectiveness with its customers and still remain competitive economically by employing a small unmanned aircraft (UA) during many of its operations

. Therefore

, CALP is submitting this 333 exemption petition

.

In support of the petition and the FAA’s evaluation process, we reference previously granted 333 exemption petitions by the FAA with same or similar purposes as follows :

• Aerial digital imagery, survey, and inspection: exemption no

. 11992, Aerial
Check UA Vs

• Aerial mining and geological surveys: exemption no. 12090, Persistence Mining Inc.

• Aerial photography and evaluation of emergency response scenes and operations: exemption no. 12508, Castle Rock Fire and Rescue Department

• Emergency services support and search and rescue exemption no. 12515, RPA/UAS Consulting LLC

• Construction site inspection: exemption no. 12719, Drone Fleet

& Aerospace Management, Inc.

DESCRIPTION OF PETITIONER

CalPortland Company is a major diversified building materials and construction solutions provider to the Western United States and Canada. Since 1891, CalPortland has reliably provided quality innovative and efficient solutions to your greatest

constructio n challenges with its expertise in cement production and distribution, ready mixed concrete, construction aggregates, asphalt, construction services and other building materials. CalPortland products provide solutions everywhere; in buildings for shelter; roads and bridges that transport and link us; systems that provide electricity, water, gas and waste treatment; and other necessary infrastructure like hospitals, schools, railways and airports. CalPortland is creating solid foundations through the use of sustainable materials and renewable technologies.CAL333A1007 15 5 NAME OF PETITIONER

Steve Coppinger Vice President of Engineering Services CalPortland Company 2025 East Financial Way Glendora, CA, 91741

AGENT FOR CALPORTLAND COMPANY

For technical and administrative q uestions on this petition, please contact:

Mr. Brian Dyer

RPS

- West

Email: Brian.Dyer@RemotePilotSystems.com

CalPortland requests a Summary Grant of Exemption for the following aircraft:

A

– Aibot X 6

B

– Yuneec Typhoon Q500 4K

Thank you for your time and attention

.

Sincerely

Brian DyerCAL333A1007 15 6 DESCRIPTION OF UNMANNED AIRCRAFT SYSTEM S

CALP requests the following aircraft :

• The Aibot X6

• Yuneec Typhoon Q500 4K

as its survey aircraft.

The Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a vertical take

- off and landing hexacopter in a V

- 6 designed for aerial survey and inspection. Aibotix in Germany has delivered more than 200 aircraft since 2011. The flight control system used with the aircraft is designed and manufactured in Germany, has undergone continuous improvement and development, with all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency failsafe to controlled descent or, if GPS signal is sufficient, to return to point

of takeoff.

• The pilot may override waypoint programming with manual stick control in case of emergency or route adjustment.

• Telemetry is displayed on the pilot’s h andheld controller and maybe announced by voice.

• The X6 is optimized for aerial survey with safety features to reduce pilot workload, such as attitude stabilization, GPS satellite

- assisted navigation,

return to home and auto land.

The aircraft is less 1.2 meters, in diameter, is made of carbon

- fiber reinforced polymer in a high visibility color, with protective blade guards surrounding the six rotors, and is designed for a maximum takeoff weight of less than 15 pounds and a flight time of about

20 minutes with its dual

- battery power. Maximum speed is about 55 MPH, but CALP treats this limitation as an emergency reserve, and plans no flying at greater than 25 MPH. The aircraft carries no flammable liquid fuel.CAL333A1007 15 7 Radio control and video transmission systems meet FCC requirements for operation in the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings about interference from devices operating at or near these frequencies or their harmonics are

d ocumented in the manufacturer’s manual.

The Yuneec Typhoon Q500/Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of quadcopter design. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500
has the world's first Smart Transmitter (the "ST

- 10 series Ground Station" with 10 channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital video link. It operates on a built

- in Android touch screen. Safety features include Geo Fencing,

Home Mode and Return Home. Geo Fencing prohibits the aircraft from exceeding a programmed permitted radius. When activated, Home Mode will automatically return the

aircraft within a 10

- foot radius of its starting point. Should the transmitter signal be lost

or visual line of sight with the aircraft impaired, upon signal, Return Home will automatically take control of the aircraft and return it to the operator/base station. Takeoff weight with manufacture provided camera and gimbal payload and battery is 3.75

lbs.

The Typhoon Q500 dimensions are 16.5x16.5x8.3 inches with a diagonal of 22.2 inches without rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 11.1V lithium polymer battery. Radio control and video transmission systems meet FCC requirements for opera tion in the unlicensed spectrum of 5.8 GHz ranges. The operating manual of the Typhoon Q500 warns against using the aircraft in areas where radio interference is possible, along with procedures to ensure radio safety with the UAS.

EXTENT OF RELIEF SOUGH T AND WHY

CALP asks for relief from regulations tabled below, which the authority of the FAA has previously granted in exemption certificates number 11062 along with six others described as “in commonality”, and in number 11109, which are for use of electric

rotorcraft. Th is incorporates the conditions and limitations of these grants of exemption, and in some cases imposes stricter limits on its own operations.CAL333A1007 15 8 CFR CODE CITATIONS

14 CFR
PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SA FETY

61.113 (a) Private pilot privileges and limitations: pilot in

command (PIC). Holder of private pilot certificate may not act as

PIC for compensation or hire. Flying for compensation on survey missions is central to purpose of exemption

request. Characteristics of aircraft, VLOS, under 400 ft. AGL, trained visual

observer in radio communication with pilot; remote site, construction industry safety protocols enhanced by flight safety plan; PIC with airman’s certification, appropriate medical

and vi sion qualification, currency
in the aircraft listed on the certificate, pilot training, testing, proficiency with similar and same model UA; and inspection/maintenance are

defined in the Flight Operations

Manual (FOM ) and will ensure equivalent levels of s afety.CAL333A1007 15 9 14 CFR
PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SA FETY

61.113 (b) Private pilot privileges and

limitations: Pilot in

command Holder of private pilot certificate may act as PIC for compensation or hire if flight is incidental to business or employment and does not carry passengers for compensation or h ire. Flying for compensation on survey missions is central to purpose of exemption request, not
incidental to business or employment. There is no passenger or pilot on
board the UA , thus safety issues are different from a manned flight.

CALP’s aircraft ha ve programmable automated safety features and emergency responses, have pre

- flight checks for safety beyond commercial manned aircraft, can be geographically restricted by operator with programmable control points,

have communications with the PIC regardin g fuel loss and other flight hazards. PIC will have ground school training certificate and additional 25 hours logged flight time and 25 hours classroom
and field instruction as stated in

the FOM.

91.119 (c) Minimum safe
altitudes over other than congest ed

area Operating closer than 500 feet to a person, vehicle, or structure may be necessary for survey and equipment inspection. People will not be allowed over, under or within 500 feet laterally of the aircraft in flight. Some flights may require the

pa rticipation or guidance of industry personnel, positioned as

close as 200 feet. CALP will brief them on safety and obtain necessary consent. Industry site safety rules will be followed.CAL333A1007 15 10 14 CFR
PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SA FETY

91.121 Altimeter settings Procedures to set and

confirm altitude do not provide for operation of remote telemetry to s UAS pilot. An onboard air pressure sensor and software resolve height
differences as small as one

centimeter. Altitude is controlled by measuring air pressure and the

z

- axis accelerometer/GPS values. The starting point is a relative height measurement calculated by the flight controller. Altitude above ground is displayed on the pilot's handheld controller by telemetry, and alarms can signal
conditions of interest. 4 00 feet AGL is the maximum permissible

in the FOM , which describes altimeter procedures.CAL333A1007 15 11 14 CFR
PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SA FETY

91.151 (b) Fuel requirements for flight in VFR
conditions Rotorcraft under VFR must carry enough fuel to reach first landing point

and then another 20

minutes. The multirotor aircraft specified in this petition is designed to fly

missions of 25 minute

durations. On aircraft specified, battery voltage under load is displayed on the pilot's handheld controller during flight. Battery chemistry does not support adequat e current discharge below about 3 v per cell. Circuitry in the onboard flight controller measures voltage and will start a failsafe procedure to

land before summed minimums
are reached. In the event that one or more cells fail, these minimums may be reache d sooner than expected, due to rapid current drain against a smaller number of functioning cells. Pilots are trained to monitor voltage and recognize abnormal discharge in flight and

to land sooner than forced. If 20 minutes of flight time or 25% of reserve voltage under load is reached, pilot must commence landing.

91.405 (a) Maintenance required Required inspections and discrepancies repaired
between the required inspections pertain to
certificated manned aircraft and procedures conducted by licensed maintenance personnel. In
the absence of certification requirements for sUAS
and sUAS maintenance

personne l, reasonable
alternatives must be developed to maintain equivalent levels of safety. CALP will document maintenance, overhaul, replacement and inspection requirements in the
absence of manufacturer's requirements; will document and

maintain maintenance r ecords and technician qualification criteria in

the FOM.CAL333A1007 15 12 14 CFR
PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SA FETY

91.405 (b) Maintenance
records Qualifications for maintenance personnel for
sUAS were not contemplated by these regulations, and a
reasonable alternative must be developed to maintain equivalent levels of safety. Qualifications, competence and testing for maintenance personnel
are defined in the FOM

.

91.407 (a) (1) Operation after maintenance, preventive maintenance, rebuilding, or

alteration There is no authorization procedure for a person who can approve a return

to service of an sUAS , and

a reasonable alternative must be developed to maintain equivalent levels of safety. Proced ures for the PIC to test then approve a return to service
after maintenance are defined in

the FOM.

91.409 (a) (1) Inspections Annuals conducted by a qualified inspector require

authorization criteria for that inspector, not yet

defined for sUAS . A

reaso nable alternative must be developed to maintain equivalent levels of safety. Schedules for inspection and responsibilities of the PIC and qualified technician are described

in the FOM.

91.409 (a) (2) Inspections Issuance of airworthiness

certificates fo r sUAS under 55 pounds operated VLOS is not contemplated by these regulations Airworthiness is the responsibility

of the PIC and the technician as

defined in the FOM.CAL333A1007 15 13 14 CFR
PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SA FETY

91.417 (a) Maintenance
records Regulations do not contemplate requirements or approval processes for

maintenance and inspection of
uncertificated sUAS

, however a reasonable
alternative must be developed to maintain equivalent levels of safety. The operator will maintain records

accordi ng to the procedures specified in the FOM.

91.417 (b) Maintenance
records Retaining and transferring

records of maintenance and defects according to standards prescribed for

authorized maintenance and inspection is not contemplated in the regulations for sUAS . A
reasonable alternative is necessary to maintain equivalent levels of safety. Records and documentation will be kept for all maintenance performed, defects, and for all components specified in the

FOM.

PILOT IN COMMAND AND CREW

The PIC must hold an airman’s certification recognized by the FAA such as an airline transport, commercial, private, recreational, sport pilot, or glider pilot (powered or non

- powered). The PIC must hold a current FAA airman medical certificate as required by the class of airman certification. In the case of the sport pilot certification, the PIC must possess a valid U.S. driver’s license issued by a State, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must comply with the training and testing specified in the operator’s manual. The PIC must remain in radio communication with a visual observer who complies with the training and testing specified in the operator’sCAL333A1007 15 14 manual. The SUAS must be operated within VLOS of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. The PIC must operate within vis ual line of sight only, and be able to see the attitude and orientation of the aircraft. If GPS or magnetometer is compromised, certain safety features may not operate, and the pilot must understand by training and experience how to recover control.

OPERATION OF THE UNMANNED AIRCRAFT

The aircraft will be under the operational control of the CALP designated PIC.

As the operator of these aircraft, CALP is committed to the following conditions and limitations on its operations. CALP understands that failure to comply will be grounds for the immediate suspension or rescission any exemption granted.

1. 1.Operations are limited to the SUAS listed in the Appendix when weighing less than 55 pounds including payload.

2. Operations for the purpose of closed

- set motion picture and television filming are not approved.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed recomm ended by the aircraft

manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within VLOS of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s U.S. driver’s license.

6. All operations will utilize a visual observer (VO). The aircraft will be operated

within the VLOS of the PIC and VO at all times.CAL333A1007 15 15 7. All operating documents needed to operate the SUAS and will be accessible during SUAS operations and made available to the Administrator upon request. The operator will also present updated and revised documents if it petitions for

extensio n or amendment.

8. Any SUAS that has undergone maintenance or alterations that affect the SUAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations.

9. CALP is responsible for maintaining and inspecting the SUAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the SUAS is in a condition for safe flight.

11. CALP will f ollow the SUAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft
components.

12. Each SUAS operated under this exemption will comply with all manufacturer safety bulletins.

13. The PIC will h old a SUAS flight training certificate, in some cases training directly from the aircraft manufacturer, and a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government.

14. CALP will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the SUAS in a manner consistent with how the SUAS will be operated to acquire aerial data, including evasive and emergency maneuvers and maintaining appropriate di stances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). CALP will operate flights for the purposes of training CALP PICs and VOs (training, proficienc y,CAL333A1007 15 16 and experience building) and determining the PIC’s ability to safely operate the

SUAS.

15. SUAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).

16. The a ircraft will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted

on the current FAA

- publ ished aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA.

17. The aircraft will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibil ity is less than 3 statute miles from the

PIC.

18. If the SUAS loses communications or loses its GPS signal, the aircraft will
return to a pre

- determined location.

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power or fuel for the aircraft to conduct the intended operation and to operate after that for at least

five minutes or with the reserve power or fuel recommended by the manufacturer if greater.

21. All operations shall be conducted in accordance with an ATO

- issued COA if the blanket COA does not cover the intended operation.

22. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.CAL333A1007 15 17 23. Documents used by CALP to ensure the safe operation and flight of the SUAS

an d any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the SUAS any time the aircraft is operating.

24. The aircraft will remain clear and give way to all manned aviation operations

and activitie s at all times.

25. The SUAS may be operated by the PIC from a moving device or vehicle; however, specific requests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicle s, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the aircraft or debris in the event of an accident; or

b. The owner/controller/operator of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made an assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

27. The PIC, VO, operator trainees or essential persons will not be c onsidered nonparticipating persons under this exemption.

28. All operations conducted over private or controlled

- access property will be conducted with the permission from the property owner/controller or authorized representative. Permission from property ow ner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA

will be reported to the FAA's SUAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.govCAL333A1007 15 18 BENEFIT TO THE PUBLIC

Approval of th is petition allowing commercial operations of an s UAS will enhance public safety by reducing public safety risk. The use of a battery operated UA by

CALP for aerial inspection, geo

- mapping and image and film capture, is more environmentally sound and safe compared to a conventional, liquid

- fueled aircraft. It provides a smaller environmental footprint, decreases manpower and separates the aircraft operators from the aircraft. The use of the specified sUASs further protects the public by used in restricted e nvironments and reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFETY

The survey aircraft will be operated in accordance with FAA and CALP safety protocols

.

The survey aircraft carries no person, cargo, or flammable liquid fuel. Its size and weight are a small fraction of any manned aircraft, and its safety systems reflect best design practices in the sUAS industry.

In addition, CALP will keep the approved F light Manual at its ground control station. The PIC will have immediate access to it. Previous exemptions granted by the FAA concerning Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft Flight Manual is kept at the ground control station of a sUAS

, where it can be immediately accessed by the PIC.

When properly operated by trained pilots, a well

- designed sUAS and trained pilot can stay clear of people and property on the ground and in the air. Procedures, airmanship skills, training and testing requirements for sUAS personnel will let the operator achieve safety levels in the NAS and on the ground that are equivalent to or greater

than that in manned aviation

SUMMARY FOR PUBLICATION

The following summary may be p ublished in the Federal Register:CAL333A1007 15 19 CalPortland Company requests an exemption from:

14 CFR Parts 61.113 (a) and (b) 14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) (1), 91.409 (a) (2), 91.417 (a)

in order to operate a small unmanned aircraft system ( sUAS ) for purposes of aerial inspections and monitoring, aerial geo

- mapping and aerial imaging and filming and aerial data collection. The PIC will be appropriately qualified with a current FAA approved p ilot certificate for sUAS operation and specialized training.

Imagery, electronic measurement, chemical measurement or any other gathering of data to be done by instruments aboard the UA, are conventionally done by manned aircraft operations, which use l iquid fuel and weigh upwards of 5,000 lbs. These operations must fly the aircraft to and from the operation’s location. The use of the

Aibot X6 and the Yuneec Typhoon Q500 4K

, both of which are ultra

- light weight and

are equipped with electronic safet y fea tures that minimize the safety risk from that of a manned aircraft to people and property allowed within and outside the zone of operations

. Flight operations outside the secure areas are not allowed. T here are no impacts to privacy.