Page 1 of 12

February 18, 2015

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, D.C. 20590-0001

Subject: Amendment-1: Petition to the FAA for Section 333 Exemption

Dear Sir or Madam,

The purpose of this letter submitted today is to amend the previous submission, of January 28, 2015, by 

adding a request, fully described below, for an alternative to the requirements for PIC credentials.

CHANGE REQUESTED

We request that the FAA consider, as a practical alternative, that the following be substituted for the 

section entitled, “4. Qualifications for the Pilot in Command (PIC)”, on page 5 of our January 28, 2015 

letter. 

Revised language for the petition letter:

4. Qualifications For The Pilot in Command (PIC)

i. Operations will be conducted by a Pilot in Command (PIC) who has met the 

following requirements:

(1) Completed the Turner UAS Operator Flight Training in accordance with

attached procedure, “Turner Procedure for Unmanned Aircraft Systems 

Training.”

(2) Is in possession of a valid and current Transportation Workers Information 

Credential (TWIC® Card) showing evidence of security threat assessment 

screening by the Transportation Security Administration (TSA) of the 

Department of Homeland Security.

ii. The Flight Instructor for Turner UAS Operator Flight Training will possess at least a 

private pilot certificate, and at lease a third-class medical certificate, and will have 

logged hours and currency as follows:

(1) Logged Hours: The Flight Instructor will have accumulated and logged a 

minimum of 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Training, 

proficiency, and experience-building flights in dedicated training sessions 

will be included in the accumulated and logged hours. 
Page 2 of 12

(2) Currency: The Flight Instructor will have accumulated and logged a 

minimum of 5 hours as UAS pilot specifically operating the Phantom 2 

Vision+. The PIC will have accomplished, during dedicated training sessions,

3 take-offs and landings in the preceding 90 days (for currency purposes). 

(3) Is in possession of a valid and current Transportation Workers Information 

Credential (TWIC® card) showing evidence of security threat assessment 

screening by the Transportation Security Administration (TSA) of the 

Department of Homeland Security.

If this alternative set of qualifications is allowed by the FAA, the UAS Operating Procedure, contained in 

Appendix A of our January 28, 2015 letter, will be appropriately updated in the Qualifications section, 

pages 17 and 18. 

REASONS SAFETY NOT ADVERSELY AFFECTED

Turner believes that public and industrial worker safety is not adversely affected by this proposed 

alternative arrangement for Qualifications for the PIC for reason listed below. Furthermore, we believe 

that industrial worker safety is significantly improved by elimination of climbing, scaffold building, and 

manual inspections of difficult to reach or hazardous areas, which will be more extensively accomplished 

if the proposed alternative Qualifications are allowed. 

 The requirement of the law, specifically 49 USC § 44711.2, is that anyone serving as an airman 

for a civil aircraft must have an airman certificate. However, the FAA Administrator has the 

authority, by 49 USC § 44701(f), to grant an exemption from “any of sections 44702-44716 of 

this title,” (which includes 44711), “if the Administrator finds the exemption is in the public 

interest.” We believe that Turner’s exemption request has compelling public benefits as we 

listed in our original letter of January 28, 2015 on page 11. We also believe safety is not 

adversely affected as we explain below.

 Private pilot training achieves competence in aircraft operation required for safely operating 

airplanes through airports and a broad range of airspace classifications and flight conditions. 

Turner believes the full extent of this knowledge is not required to safely operate small UAS 

within private property boundaries of Turner or Turner Client properties within Class G airspace 

and below 400 ft. AGL. An instructor who possesses a private pilot certificate can take the 

applicable critical portions of that body of knowledge, as well as instruct aircraft training flight 

hours with Tuner’s UAS, and impart this knowledge to Turner’s UAS operators through the 

proposed formal documented training. 

 UAS operators in the U.S. Armed Forces are not required to be pilots but they receive extensive 

training to achieve the competency required for safety and mission success. Turner intends to 

apply similar care and diligence in the aforementioned Turner Flight Training.

 We believe the TWIC® card credential assures Homeland security concerns. Coast Guardcredentialed merchant mariners, port facility employees, long shore workers, truck drivers, and 

others requiring unescorted access to secure areas of maritime facilities and vessels regulated 
Page 3 of 12

by Maritime Transportation Security Act are required to get a TWIC® card. This is an ubiquitous 

credential carried by workers in most of the facilities that Turner serves and it satisfies security 

concerns of the Department of Homeland Security for those activities which are similar in nature 

and in location to what Turner plans to do with its UAS operations. 

PUBLIC BENEFIT

In our original submission of January 28, 2015, public benefits are listed on page 11 of that letter. These 

remain the same. What is of concern is reaping the full magnitude of the potential benefits. The 

proposed alternative described in this letter allows Turner to more fully implement their public-benefitproducing commercial opportunities which otherwise would be limited by the expense and difficulty in 

scheduling private pilots to operate Turner’s UAS. Allowing Turner to have a private pilot train Turner 

UAS operators enables a more commercially feasible and practically deployable service. As the activity 

of the Turner UAS service grows, and additional equipment is added as submitted and approved by the 

FAA, having large numbers of licensed pilots deployed at the number facilities where Turner currently 

operates makes commercial viability unattractive from both economic and practical viewpoints. A 

better solution is needed to reap the full benefits of this technology.

We believe that a practical solution in Turner’s case to satisfy FAA statutory imperatives, as well as 

satisfy homeland security concerns, is to apply airman certification requirements to only Turner’s 

Instructor who in turn trains and certifies Turner’s UAS operators, while requiring possession of valid 

TWIC® cards. 

Respectfully Submitted,

William B. Bispeck

Independent Contractor/Consultant to

Turner Industries Group, L.L.C.

John H. Lindsey

General Manager – Integrated Solutions Group

Turner Industries Group, L.L.C.

Please direct correspondence to William Bispeck. Contact information is on page 2 of the January 28, 

2015 petition letter.
Page 4 of 12

Page intentionally left blank
Page 5 of 12

Appendix 

Procedure for Unmanned Aircraft Systems Training
Page 6 of 12

Page intentionally left blank
Procedure UAS-002 ___________________________________________ ____ 

Page 7 of 12

Procedure for Unmanned Aircraft System Training

Procedure Number UAS-002 Type Training

Authored By Bill Bispeck Revision Number 0

Reviewed By John Lindsey Next Review Date 8-16-2015

Approved By John Lindsey Approved Date 2-16-2015

PURPOSE

The purpose of this procedure is to describe responsibilities and tasks required to train, qualify, and 

credential UAS operators.

This is a Critical Procedure which requires, as described herein, official sign off by the Turner Flight 

Instructor before any Turner UAS Operator has company permission to use the UAS equipment. 

To properly use this procedure, personnel must be aware of safety related information contained in the 

Health, Safety, and Environmental Precautions section of this document.

RESPONSIBILITIES

1. FLIGHT INSTRUCTOR (FI):

a. The Flight Instructor (FI) is responsible for training, qualifying, and certifying Turner UAS 

operators in the essential aviation knowledge needed for safe and successful UAS 

operations for the scope of Turner’s service business within Turner or Turner Client 

property. This includes classroom instruction in combination with actual flight operations of 

Turner’s UAS equipment.

b. The FI is responsible for testing UAS operator knowledge and skill, and documenting that

testing which demonstrates required competence. 

c. The FI will gather and prepare instructional materials needed for the subject training in 

order to cover all essential aspects of Turner UAS operations and in conformance to Turner’s 

Procedure UAS-001, Unmanned Aircraft Systems Operations. 

2. PILOT IN COMMAND (PIC): 

a. The Pilot in Command of the aircraft is directly responsible for, and is the final authority for 

the operation and safety of the flight. This procedure describes training which must be 

completed prior to assuming this duty.

b. In an in-flight emergency requiring immediate action, the PIC may deviate from any rule or 

procedure to the extent required to meet that emergency in order to protect life and 

property.
Procedure UAS-002 ___________________________________________ ____ 

Page 8 of 12

c. The PIC will assure that all Preflight Checks are completed and documented and execute full 

compliance with all manufacturer’s operation and maintenance documents.

d. The PIC will carry out the flight plan as agreed to and approved by site leadership.

e. The PIC is responsible for maintaining Visual Line-of-Sight (VLOS) with the aircraft during 

operations by direct view with human eyesight, and closely coordinate operations with the 

Visual Observer (VO) as fully described in Procedure UAS-001, Procedure for Unmanned 

Aircraft Systems Operations.

HEALTH, SAFETY AND ENVIRONMENTAL PRECAUTIONS

3. Personnel Protective Equipment: The FI and UAS Operator will at all times abide by local site safety 

rules regarding wearing of protective equipment. This typically consists of ANSI approved hard hats 

and safety glasses, but in many locations may also include fire resistant clothing (e.g. Nomex®) and 

safety shoes. 

4. Hazard Communication: Toxic substances used in the work area must be disclosed to personnel

under laws managed by OSHA. The UAS operation does not involve use of any hazardous materials. 

The site being surveyed may contain and process such materials. During the preflight planning 

meeting the FI and PIC should ask if there are any precautions required of them for personnel 

protection and comply with these. Material Safety Data Sheets (MSDS) should be available to aid in 

any awareness needed for specific substances. 

5. Permits: In compliance with local site safety procedures all required permits must be obtained and

approved. All safety and environmental requirements by those permits and referenced site 

procedures must be followed at all times.

6. Equipment Safety Inspection: Prior to each flight, the PIC will inspect the Phantom 2 Vision+, 

including the ground control station, in accordance with the Preflight Checklist to assure that the 

system is airworthy as determined by the PIC on the basis of these checks and manufacturer’s 

documentation. If the Preflight Check indicates any unsafe conditions or a non-functioning safetycritical part, the flight will not commence until the needed maintenance is performed and a 

satisfactory Preflight Check can be completed. 

7. Site Approval: No operations will start, including flight training, without review and approval of site 

leadership and communication of the flight plan and schedule with site personnel. 

8. Conditions: All operations must be in daylight hours and under visual meteorological conditions 

(VMC). No operations will be conducted less than 500 feet below or less than 2,000 feet 

horizontally from a cloud when visibility is less than 3 statute miles from the PIC.

9. Safe Power Levels: As standard operating procedure, the PIC will immediately return the Phantom 2 

Vision+ to the Home Point for a battery swap when the battery level reaches 25%.
Procedure UAS-002 ___________________________________________ ____ 

Page 9 of 12

10. Collision Avoidance: Altitude and distance limits will be entered into the Flight Control System prior 

to commencement of flight. This will restrict the operation to the Turner or Turner Client property. 

The Failsafe Function integral with the Flight Control System will assure the aircraft stays within the 

area deemed safe for operation, as well as assure altitudes do not exceed 300 feet AGL. By the 

Visual Line-of-Sight (VLOS) method the PIC with assistance of the VO will assure the aircraft avoids 

any other possible traffic, with clouds, obstructions and terrain. 

11. Proximity of Airports: Operations will be restricted to Class G airspace. No operations will occur 

within 5 miles of a non-towered airport reference point as denoted on a current FAA-published 

aeronautical chart, unless a letter agreement with the airport’s management is obtained, and the 

operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the 

Certificate of Waiver or Operation (COA). 

12. Emergencies: Operations will be aborted immediately if the PIC encounters unpredicted obstacles 

or emergencies. Safe descent and landing procedures will be followed in accordance with operating 

documents. 

13. Incident Reporting: 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 UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Site leadership will be notified immediately as specified by local procedures.

14. Qualifications and Training: The FI and the PIC will have logged hours and certifications as described 

in the Qualifications sections of this procedure. 

PREREQUISITES

15. Operation of the UAS cannot proceed without full compliance with

a. Health, Safety and Environmental Precautions

b. Qualifications for the Flight Instructor (FI) and provisionally for the Pilot in Command (PIC) 

under supervision of the FI. 

c. Preflight Planning 

d. Preflight Checklist
Procedure UAS-002 ___________________________________________ ____ 

Page 10 of 12

QUALIFICATIONS FOR THE FLIGHT INSTRUCTOR (FI)

16. The Flight Instructor for Turner UAS Operator Flight Training will possess at least a private pilot 

certificate, and at lease a third-class medical certificate, and will have logged hours and currency as 

follows:

a. Logged Hours: The Flight Instructor will have accumulated and logged a minimum of 25 

hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot 

with a multi-rotor UAS. Training, proficiency, and experience-building flights in dedicated 

training sessions will be included in the accumulated and logged hours. 

b. Currency: The Flight Instructor will have accumulated and logged a minimum of 5 hours as 

UAS pilot specifically operating the Phantom 2 Vision+. The PIC will have accomplished, 

during dedicated training sessions, 3 take-offs and landings in the preceding 90 days (for 

currency purposes). 

c. Is in possession of a valid and current Transportation Workers Information Credential 

(TWIC® card) showing evidence of security threat assessment screening by the 

Transportation Security Administration (TSA) of the Department of Homeland Security.

QUALIFICATIONS FOR THE UAS OPERATOR

17. Operations will be conducted by a Pilot in Command (PIC) who has met the following requirements:

a. Completed the Turner UAS Operator Flight Training in accordance with this procedure. Until 

such time as the required training is completed the UAS Operator will conduct operations 

for purposes of training only and under supervision of the FI. 

b. Has completed and passed the written test administered by the FI and has demonstrated to 

the satisfaction of the FI, by way of actual UAS operation under FI supervision, the required 

skill to safely and successfully operate the UAS.

c. Is in possession of a valid and current Transportation Workers Information Credential

(TWIC® Card) showing evidence of security threat assessment screening by the 

Transportation Security Administration (TSA) of the Department of Homeland Security.
Procedure UAS-002 ___________________________________________ ____ 

Page 11 of 12

CLASSROOM TRAINING

18. The FI will prepare instructional materials and conduct classroom training to thoroughly cover the 

following topics, as a minimum, via in-person training:

a. Turner’s procedure UAS-001, Unmanned Aircraft Systems Operations.

b. UAS Manufacturer’s User Manual and Pilot Training Guide. 

c. Visual Meteorological Conditions (VMC) requirements. 

d. Visual Line of Sight (VLOS) and Visual Observer (VO) requirements.

e. Preflight Planning.

f. Preflight Checks.

g. Collision Avoidance including proper use of the Flight Control System, Failsafe Function and 

proper setting of the Home Point.

h. Safe Power Levels.

i. Airspace restrictions, Proximity of Airports, Altitude and Distance restrictions.

j. Emergencies.

k. Incident Reporting.

IN-FLIGHT TRAINING

19. The FI will conduct hands-on in flight training separately with each UAS operator covering the 

following as a minimum:

a. Basic and Skilled flight maneuvers utilizing the ground control station and associated 

software.

b. Emergency maneuvers.

c. Camera and sensor operation.

20. The FI will assure the above hands-on in-flight training is accomplished with a minimum of 3 hours 

logged flight time. 
Procedure UAS-002 ___________________________________________ ____ 

Page 12 of 12

21. The FI will document completion of the aforementioned training and certify in writing that all 

requirements have been met for qualification and certification of each UAS operator. Paperwork 

will include signatures and dates for the FI and UAS Operator. Documentation, including all test 

records will be filed and retained for five years prior to current time. 

REFERENCES

 Turner’s procedure UAS-001, Unmanned Aircraft Systems Operations

 Phantom 2 Vision+ Specifications 

 Phantom 2 Vision+ Quick Start Guide

 Phantom 2 Vision+ User Manual V1.6 

 Phantom 2 Vision+ Pilot Training Guide