CalPortland	Company	333	petition 

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 

Regulations 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 airspace (NAS) as regulated by the FAA for aerial data 

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

I. Remote sensing and measuring by an instrument(s) aboard the sUAS including

A. imagery (photography, 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 services support and search and rescue with CALP agreement
2 CAL333A100715

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.

BACKGROUND AND REFERENCES

The aggregates industry in the United States supplies two billion tons of materials yearly 

to build its infrastructure 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 services.

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 encounters 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, surface mine acreage is also permitted for 

explosive materials requiring controlled access with strict safety protocols. 

Using an 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. 
3 CAL333A100715

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 the 

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 heavy mining equipment is a potential hazard.

• The tops 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 obstacles 

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 necessary to be moved. 

With appropriate planning, mine sites 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 small 
4 CAL333A100715

electric aircraft lets the pilot and 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 UAVs

• 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 

construction 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.
5 CAL333A100715

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 questions 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 X6

B – Yuneec Typhoon Q500 4K

Thank you for your time and attention.

Sincerely

Brian Dyer
6 CAL333A100715

DESCRIPTION OF UNMANNED AIRCRAFT SYSTEMS

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 handheld 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.
7 CAL333A100715

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 

documented 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 operation 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 SOUGHT 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. This incorporates the conditions and limitations of these grants of exemption, 

and in some cases imposes stricter limits on its own operations. 
8 CAL333A100715

CFR CODE CITATIONS 

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

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 vision 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 safety.
9 CAL333A100715

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

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 hire. 

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 have 

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 regarding 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 congested 

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 

participation 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. 
10 CAL333A100715

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.121 Altimeter settings Procedures to set and 

confirm altitude do not 

provide for operation of 

remote telemetry to sUAS

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. 400 feet 

AGL is the maximum permissible 

in the FOM, which describes 

altimeter procedures. 
11 CAL333A100715

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

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 adequate 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 reached 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 

personnel, 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 records and 

technician qualification criteria in 

the FOM.
12 CAL333A100715

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

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. 

Procedures 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 

reasonable 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 for 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.
13 CAL333A100715

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

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 

according 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’s 
14 CAL333A100715

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 visual 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 recommended 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.
15 CAL333A100715

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 

extension 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 follow 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 hold 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 distances 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, proficiency, 
16 CAL333A100715

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 aircraft 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-published 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 visibility 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.
17 CAL333A100715

23.Documents used by CALP to ensure the safe operation and flight of the SUAS 

and 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 activities 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, vehicles, 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 considered 

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 owner/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.gov
18 CAL333A100715

BENEFIT TO THE PUBLIC 

Approval of this petition allowing commercial operations of an sUAS 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 environments 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 Flight 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 published in the Federal Register: 
19 CAL333A100715

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 pilot 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 liquid 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 safety features 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. There are no 

impacts to privacy.