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10. Pilot and observer will at all times be able to communicate by voice and/or text.
11. Written and/or oral permission from the relevant property holders will be obtained.
12. All required permissions and permits will be obtained from territorial, state, county or city
jurisdictions, including local law enforcement, fire, or other appropriate governmental
agencies.
13. The sUAS will have the capability to abort a flight in case of unexpected obstacles or
emergencies.
14. If the multirotor and its controller disconnects during flight, the system’s failsafe protection
will come to the rescue and the multirotor will return to home and land automatically, rather
than flying off uncontrollably or landing at an unknown location.
Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight,
speed, operating capabilities, proximity to airports and populated areas and operation within visual
line of sight and national security – provide more than adequate justification for the grant of the
requested exemptions allowing commercial operation of applicant’s sUAS in the mining, oil, and
gas inspection industries pursuant to Nixon Engineering Solutions LLC’s rules of operation
appended hereto.
VI.
Public Interest and Safety
Use of the sUAS will increase ground safety by eliminating ground surveying on the mine
floor and help prevent wildfires and exposure to H2S gas at the well pads, Currently, under safety
regulations by the Mine Safety and Health Administration (MSHA), the coal stockpiles are
surveyed by employees who walks on the piles with survey grade GPS collection equipment. This
task takes two employees several hours to complete.
The surveyors currently face the following challenges:
A. In the stockpiles:
1. The piles are extremely steep and high – up to 100 feet above natural ground. The coal
material of the piles is loose and shifts easily, which makes the sides of the piles very
hazardous and can lead to unexpected coal slides, which endanger the workers.
2. Inventories of coal piles are collected on a monthly basis. The coal has not been run
through a crusher, and the size of the coal can range from dust to 5’ chunks, which
create a tripping hazard for people walking through the piles. Using the sUAS will
eliminate tripping hazards to the surveyors.
3. During August and September, the heat index routinely breaks 100ºF, which can lead
to heat related illness and injury. Using the sUAS instead will reduce the risk of heat
exhaustion to the surveyors as the time spent by the surveyors on the mine floor will
be reduced from up to three hours, to an hour or less.
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