December 18, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

Re: Exemption Request under Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

CB&I, INC., Inc. requests an exemption from the regulations listed below to allow CB&I, INC. to 

operate a small unmanned aircraft system (sUAS) for aerial imaging of secured construction 

sites as described herein and as otherwise prescribed by the FAA. 

This letter details our proposed operations including safety precautions to mitigate any hazards 

to the National Airspace System (NAS), non-participants, and the user, as well as why the use of 

this UAS is in the public interest. 

The petitioner's information is: 

Dino Cimetta 

CB&I, INC. 

255 North Main Street 

Hackberry, Louisiana 70645 

Phone: (337) 762-5073 

Email: dcimetta@cbi.com 

Regulations from which we seek exemption: 

• 14 CFR 61.23(a) and (c) 

• 14 CFR 61.101(e)(4) and (5) 

• 14 CFR 61.113(a) and (b) 

• 14 CFR 61.315(a) 

• 14 CFR 91.7(a) 

• 14 CFR 91.119(c) 

Description of Operations 

• 14 CFR 91.121 

• 14 CFR 91.151(a)(1) and (b) 

• 14 CFR 91.405(a) 

• 14 CFR 91.407(a)(1) 

• 14 CFR 91.409(a)(1) and (2) 

• 14 CFR 91.417(a) and (b) 

The UAS that CB&I, INC. would operate under the exemption, if granted, is a Phantom 2 Vision 

Plus model manufactured by DJI. Attached to this petition is the manufacturer's user manual, 

pilot training guide, and battery safety guidelines, which will all be adhered to in operating this 

UAS. 

1 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

The UAS weighs just under 2.75 pounds including the battery and all four rotors. The UAS is not 

capable of carrying a payload other than a camera. The operating frequency of the UAS is 

5.728GHz-5.85GHz and complies with FCC rules. The UAS would be flown as prescribed by the 

user manual and pilot training guide and in accordance with any further restrictions as may be 

specified by FAA. 

CB&I, INC., would use the UAS to monitor and document construction progress at construction 

sites. One purpose served by this aerial monitoring is identification and mitigation of hazards 

to protect worker and public safety and wellbeing. The UAS would only be operated within the 

limits of construction of the sites while in the unaided visual line of sight (VLOS) of the operator. 

CB&I INC., notes that the FAA has issued grants of exemption in circumstances similar in 

material respects to those presented in this petition, and specifically for the same UAS in 

Exemption Nos. 12170 and 12908. 

Regulatory Basis 

14 CFR Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). 

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular UA. In all cases, an analysis of these criteria demonstrates 

that the UAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft 

(fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions 

and conditions proposed. 

The UAS to be operated hereunder are rotorcraft weighing less than 55 pounds including 

payload; carries neither a pilot nor passengers; carries no explosive materials or flammable 

liquid fuels; and operates exclusively within visual line of sight (VLOS) of the pilot in command 

(PIC) and a visual observer (VO). The UAS will be operated at a speed of less than 50 knots and 

have the capability to hover and move in the vertical and horizontal plane simultaneously 

within a predetermined and protected flight area as described below. Such operations will 

insure that the UAS will not create a hazard to the users of the national airspace system. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the operator and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation. The FAA will have advance notice of 

all operations. These safety enhancements provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued 

under 14 CFR 21, Subpart H. Lastly, application of these same criteria demonstrates that there 

is no credible threat to national security posed by the UAS, due to its size, speed of operation, 

2 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry 

a substantial external load. 

The Secretary of Transportation has previously determined that these aircraft meet the 

conditions of Section 333. Therefore, the FAA has found that request of relief from 14 CFR 21, 

and any associated noise certification and testing requirements of part 36, is not necessary. 

This has been stated in exemptions to this regulation in Exemptions Nos. 11280, 11279, 11278, 

11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250 and 11230. 

The applicant proposes that the exemption requested herein applies to aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for 

at least an equivalent or even higher level of safety to operations under the current regulatory 

structure. 

These limitations and conditions to which the operator agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. The UAS Phantom 2 Vision Plus will weigh less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend the 

exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UAS will not be operated at a speed exceeding 87 knots {100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UAS be operated at airspeeds greater 

than the maximum UAS operating airspeed recommended by the aircraft manufacturer. 

4. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UAS must be operated within visual line of sight (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. 

6. All operations must utilize a visual observer (VO). The UAS must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO. 

3 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

7. The exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in the grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents must be 

accessible during UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the exemption and the procedures 

outlined in the operating documents, the conditions and limitations therein take precedence 

and must be followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating documents. It is the 

operator's responsibility to track such revisions and present updated and revised documents to 

the Administrator or any law enforcement official upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to the grant 

of exemption. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the exemption, then the operator must petition for an 

amendment to its grant of exemption. The FAA's UAS Integration Office {AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights 

may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. 

The functional test flight must be conducted in such a manner so as to not pose an undue 

hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g. inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. 

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS must comply with all manufacturer safety bulletins. 

13. A PIC must hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must also hold a current FAA airman medical certificate or 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. The PIC must also meet the flight review requirements specified in 

14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

4 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR 61.51(b). Flights for the purposes of training the 

operator's PICs and VOs (training, proficiency, and experience building) and determining the 

PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption are permitted under the terms of the exemption. However, 

training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations 

must be conducted under visual meteorological conditions (VMC}. Flights under special visual 

flight rules (SVFR) are not authorized. 

16. The UAS may 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 issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official 

upon request. 

17. The UAS may 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. lfthe UAS loses communications or loses its GPS signal, the UAS must return to a 

predetermined location within the private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UAS to conduct the intended operation and 

to operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO} Certificate of Waiver or Authorization {COA}. All operations 

shall be conducted in accordance with an A TO-issued COA. The exemption holder may apply for 

a new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the attached COA. 

5 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

22. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N- 6 Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

24. The UAS must remain clear and give way to all manned aviation operations and activities at 

all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must 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 UAS and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons. 

27. All operations shall be conducted over private or controlled-access property with 

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. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA's UAS 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. 

6 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

Unless otherwise specified in a grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91. 

Specific Regulations 

14 CFR 61.23(a) and (c) 

In view of the substantially different circumstances of ground-based, remote PIC operation of a 

UAS compared to PIC aboard and aloft, CB&I, INC. requests exemption from these medical 

certificate requirements. CB&I, INC. is seeking relief from 14 CFR 61.23(a) to allow a 

certificated pilot to operate a UAS with a U.S. issued driver's license, in lieu of an FAA-issued 

medical certificate. The FAA is also granting relief from 14 CFR 61.23(c) to allow sport pilot 

certificate holders to operate aircraft other than LSA with a U.S. issued driver's license. CB&I, 

INC. is seeking this relief as well. CB&I, INC. suggests that exemption from these regulations 

under the operating conditions identified herein and as otherwise imposed by FAA will not 

result in any reduction in level of safety. The FAA has issued the following exemptions to this 

regulation: Exemption Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 

and 11230. 

14 CFR 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations 

This section limits recreational pilots to non-commercial operations and provides that they may 

not act as PIC of a recreational aircraft for compensation or hire, or in furtherance of a business. 

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely 

controlled by the PIC with no living payload, passengers or crew. The area of operation will be 

predetermined and in a protected flight area under the permission of the property 

representative, and all flights will be planned and coordinated in advance. PICs will be CB&I, 

INC. employees and flights will be conducted for CB&I, INC. purposes only and not for other 

compensation, hire or business purposes. CB&I, INC. suggests that exemption from these 

regulations under the operating conditions identified herein and as otherwise imposed by FAA 

will not result in any reduction in level of safety. The FAA has issued under similar 

circumstances the following exemptions to this regulation: Exemption Nos.11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command 

Paragraph (a) of this section prohibits private pilots from serving as PIC for commercial 

operations except as provided in part (b). Unlike a conventional aircraft that carries the pilot 

and passengers, the UAS is remotely controlled by the PIC with no living payload, passengers or 

crew. The area of operation will be predetermined and in a protected flight area under the 

permission of the property representative, and all flights will be planned and coordinated in 

advance. PICs will be CB&I, INC. employees and flights will be conducted for CB&I, INC. 

7 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

purposes only and not for other compensation, hire or business purposes. CB&I, INC. suggests 

that exemption from these regulations under the operating conditions identified herein and as 

otherwise imposed by FAA will not result in any reduction in level of safety. The FAA has issued 

under similar circumstances the following exemptions to this regulation: Exemption Nos.11278, 

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR 61.315{a) What are the privileges and limits of my sport pilot certificate? 

This section limits sport pilots to non-commercial operations and that they may not act as PIC 

of an aircraft that is carrying passengers or property for compensation or hire, or in the 

furtherance of a business. They also may not carry more than one passenger, fly at night, and 

under other restrictions that are outside of the scope of intended flights of the UA. Unlike a 

conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled by 

the PIC with no living payload, passengers or crew. The area of operation will be 

predetermined and in a protected flight area under the permission ofthe property 

representative, and all flights will be planned and coordinated in advance. PICs will be CB&I 

employees and flights will be conducted for CB&I, INC. purposes only and not for other 

compensation, hire or business purposes. CB&I, INC. suggests that exemption from these 

regulations under the operating conditions identified herein and as otherwise imposed by FAA 

will not result in any reduction in level of safety. The FAA has issued under similar 

circumstances the following exemptions to this regulation: Exemption Nos.11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR 91.7: Civil Aircraft Airworthiness 

The regulation provides that no person may operate a civil aircraft unless it is in airworthy 

condition. CB&I, INC. proposes that preflight actions along with operation and maintenance of 

the UAS in accordance with manufacturer's specifications and as otherwise described in this 

application will provide an equivalent level of safety with respect to airworthiness during flight 

operations. The FAA has issued under similar circumstances the following exemptions to this 

regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 

and 11230. 

14 CFR 91.119{c): Minimum Safe Altitudes: General 

14 CFR 91.119 establishes minimum safe altitudes for operation of civil aircraft and paragraph 

(c), in particular, requires that aircraft be operated at a minimum altitude of 500 feet above the 

surface except over open water or sparsely populated areas. Paragraph (d) allows helicopters 

to operate at lower altitudes under certain conditions. Exemption from this regulation is 

requested as the minimum safe altitude for conventional aircraft is greater than the maximum 

altitude to which UASs have been restricted in other petitions, for example in Exemption Nos. 

11808, 12908, and 12170 where similar reasons for exemption were presented. In addition, 

the UAS is most similar to a helicopter with vertical takeoff/landing and hovering capabilities. 

8 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

This fact, along with the restricted flight area, small size of the aircraft, and absence of 

flammable fuel will result in an equivalent level of safety while flying below the minimums 

stated in 14 CFR 91.119. 

14 CFR 91.121: Altimeter Settings 

This regulation prescribes methods to be used for altimeter settings, lowest usable flight levels 

for altimeter settings, and adjustment factors. Altitude of the CB&I, INC. UAS is GPS-based. An 

equivalent level of safety will be achieved by the operator, pursuant to the manufacturer's 

published procedures, confirming the altitude of the launch site shown on the GPS altitude 

indicator before each flight and by visually monitoring altitudes during flights and correlating 

observations with altitude read-outs. In the event of any discrepancy between observed and 

reported altitudes, the flight will be immediately terminated. The FAA has issued under similar 

circumstances the following exemptions to this regulation: Exemption Nos.11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR 91.151(a)(1) and (b): Fuel Requirements for Flight in VFR Conditions 

This regulation specifies minimum fuel levels before beginning flights in terms of flight times. 

Exemption from this regulation is requested as the manufacturer of the UAS warrants that the 

approximate flight time on a fully charged battery is 25 minutes. Battery charge levels will be 

checked prior to each flight and flight durations will be limited to allow a minimum of 5 minutes 

of reserve battery capacity. This will provide reserve capacity that is equivalent to or greater 

than that required by the regulation. The FAA has issued under similar circumstances the 

following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 

11256, 11253, 11252, 11240 and 11230. 

14 CFR 91.40S(a); 407(a)(1); 409(a)(1) and (2); 417 (a) and (b): Maintenance and Inspections 

These regulations pertain to inspection, maintenance and repair of aircraft with airworthiness 

certificates. The requirements are not applicable to an UAS which, under a grant of exemption 

would not be required to have an airworthiness certificate. An equivalent level of safety will be 

achieved because the small UAS is limited in size and weight and will operate only in restricted 

areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and 

will be operating from no higher than 400 feet AGL and within VLOS of the PIC and VO. Prior to 

each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition 

for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. The 

operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components. The FAA has issued under 

9 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

similar circumstances the following exemptions to this regulation: Exemption Nos.11278, 

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

******************************************************* 

Privacy 

All flights will occur over private or controlled access property with the property representative 

or owner's prior consent and knowledge. Only persons that have provided consent to being 

filmed or otherwise have agreed to be in the area while aerial photography is taking place will 

be filmed. 

All flights will be made in compliance with any state or local laws regarding privacy. 

Why this exemption would be in the public interest 

Use of a UAS for our construction purposes as described herein would be in the public interest 

for a number of reasons: Use of the UAS would lower emissions of air pollutants and noise 

compared to traditional aerial photography and the use of airplanes or helicopters; have a 

positive impact by reducing congestion of NAS through low altitude flights that originate and 

conclude within project sites rather than traditional means involving landings, departures and 

flights from area airports; and reduce risk and improve safety of life and property in the air and 

on the ground. 

Why this exemption would not adversely affect safety 

The use of a UAS would result in an equivalent or better level of safety of the public or those on 

our construction sites. The UAS is an inherently safe option for aerial imaging compared to 

traditional means involving only a small, lightweight, unmanned aircraft operated in defined 

and spatially limited airspace in accordance with carefully prescribed operating conditions. 

Moreover, the small size of the UAS, low operating speeds and altitudes, and built in fail-safe 

features offer a solution to our needs while affording our workers and the general public 

equivalent or higher levels of safety than conventional alternatives. 

Summary for the Federal Register: 

The petitioner seeks exemption from the following FAA regulations under Section 333 of the 

FAA Modernization and Reform Act of 2012: 

14 CFR 61.23(a) and (c); 14 CFR 61.101(e)(4) and (5); 14 CFR 61.113(a) and (b); 14 CFR 

61.315(a); 14 CFR 91.7(a); 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a)(1) and (b); 14 CFR 

91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and {2); and 14 CFR 91.417(a) and (b). 

Brief Description of the Exemption we seek: 

10 
CB&I 

255 North Main Street 

Hackberry, Louisiana 70645 

Tel: +1 337 762 5700 

dcimetta@CBI.com 

The petitioner requests exemption from the regulations above to operate a small unmanned 

aerial system within the bounds of construction sites in order to track progress and create 

reports. 

Sincerely, 

Dino Cimetta 

Deputy Project Director- Cameron LNG Project 

CB&I, INC. 

Attachments 

Manufacturer's user manual 

Pilot training guide 

Battery safety guidelines 

11