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www.lockelord.com

T. Patrick Byrnes Direct Telephone: 312-443-0286

Direct Fax: 312-896-6286 pbyrnes@lockelord.com

March 7, 2016

U.S. Department of Transportation Docket Operations West Building Ground Floor

Room W12-140 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of th e FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the F ederal Aviation Regulations from: 14 CFR Part 21, Subpart H; 61.101(e)(4)&(5); 61.113(a) ; 61.315(a),(c)(1),(2)&(3); 61.23(a)&(c); 91.7(a); 91.119(c); 91.121; 91.151(a) (1); 91.405(a); 91.407(a)(1); 91.409(a)(1)&(2); 91.417(a)&(b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”), Subsection (f) of 49 U.S.C. § 44701, and 14 CFR Par t 11, Chicago Bridge & Iron (“CB&I”) seeks an exemption from the Federal Aviation Regulations (“FARs”) listed in Section II below to allow operation of its small Unmanned Aircraft Systems (“ sUAS”) for commercial purposes. 1

CB&I is the most complete energy infrastructure foc used company in the world. With 125 years of experience and the expertise of approximately 42 ,000 employees, CB&I provides reliable solutions while maintaining a relentless focus on s afety and an uncompromising standard of quality. In fact, CB&I is the first engineering, p rocurement and construction company to win the prestigious Green Cross for Safety medal awarded by the National Safety Council.

CB&I seeks to utilize its sUAS, the DJI Phantom 3 P rofessional and the DJI Inspire 1, to perform aerial imagery, inspection, surveying and data coll ection of its construction projects at various

controlled access sites. As set forth herein and i n the material submitted herewith, the requested exemption would permit the operation of s UAS under controlled conditions in airspace that is 1) limited, 2) predetermined, 3) c ontrolled as to access, and 4) would reduce environmental impact and provide safety enhancement s to the already best practices and safety protocols followed by CB&I. Approval of this petit ion would thereby enhance safety and fulfill

1 The small unmanned aircraft component of the sUAS i s referred to herein as the “sUA”.U.S. Department of Transportation

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the Secretary of Transportation’s responsibility un der Section 333(c) of the Reform Act to “... establish requirements for the safe operation of su ch aircraft systems in the national airspace system.” Moreover, the FAA has previously granted numerous exemption requests for sUAS uses similar to those proposed by CB&I, as well as exemption requests seeking to operate the same sUAS models as CB&I proposes. 2 See e.g., FAA Exemption Nos. 11109, 11469, 11743, 11846, 12272, 12946, 13729, 14011, 14510, 14569 (ex emptions involving similar operations); 11899A, 12851, 12876, 12903, 12912, 13976 (exemptio ns involving same model sUAS). Accordingly, CB&I respectfully requests that the FA A grant this petition for exemption without delay.

I. APPLICANT INFORMATION

The name, address and contact information of the pr imary contact for this petition is:

Angela M. Belden Senior Engineering Systems Manager

CB&I

2481 NW Boca Raton Boulevard Boca Raton, FL 33431

561.361.3152 Angela.Belden@cbi.com

II. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

• 14 CFR Part 21, Subpart H;

• 14 CFR 61.101(e)(4)&(5);

• 14 CFR 61.113(a);

• 14 CFR 61.315(a),(c)(1),(2)&(3);

• 14 CFR 61.23(a)&(c);

• 14 CFR 91.7(a);

• 14 CFR 91.119(c);

• 14 CFR 91.121;

• 14 CFR 91.151(a)(1);

• 14 CFR 91.405(a);

• 14 CFR 91.407(a)(1);

• 14 CFR 91.409(a)(1)&(2); and,

• 14 CFR 91.417(a)&(b).

2 CB&I has submitted with this petition the followi ng materials provided by DJI, the manufacturer of CB&I’s sUAS, which provide detailed information regarding the sUAS CB&I seeks to operate: Inspire 1 Series Safety Guidelin es and Disclaimer, V1.2, 2015.10; Inspire 1 User Manual, V2.0, 2015.11; Phantom 3 Safety Guidel ines and Disclaimer, V1.4, 2015.11; Phantom 3 Professional User Manual V1.6, 2015.10.U.S. Department of Transportation

Docket Operations March 7, 2016 Page 3

III. STATUTORY AUTHORITY FOR EXEMPTION

The Federal Aviation Act (the “Act”) expressly gran ts the FAA authority to issue exemptions such as those sought herein. See 49 U.S.C § 44701( f). This statutory authority includes exempting civil aircraft, as the term is defined un der §40102 of the Act, including sUA, from the requirements that all civil aircraft must have a cu rrent airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service. In particular, Section 44701(f) of the Act provides that “[t]he Ad ministrator may grant an exemption from a requirement of a regulation prescribed under subsec tion (a) or (b) of this section or any of

sections 44702–44716 of this title if the Administr ator finds the exemption is in the public

interest.” Id.

Section 333 of the Reform Act sets forth Congress’ mandate to accelerate the introduction of sUAS into the National Airspace System (“NAS”) if i t can be accomplished safely. The Reform Act specifically directs the Secretary of Transport ation to determine if certain sUAS may operate safely in the NAS before the rule making required u nder Section 332 of the Reform Act is completed. See Reform Act at §333(a).

In making this determination, the Secretary is requ ired to determine which types of sUAS do not create hazards to users of the NAS or the public, o r pose a threat to the national security in light of the following:

• The sUAS’s size, weight, speed and operational cap ability;

• Operation in close proximity to airports and popul ated areas; and,

• Operation within visual line of sight of the opera tor.

See Reform Act at §333(b)(1). If the Secretary det ermines that such sUAS “may operate safely in the [NAS], the Secretary shall establish require ments for the safe operation of such aircraft systems in the [NAS]”. Id. at § 333(c) (emphasis ad ded).

CB&I’s proposed sUAS utilize sUA that are multi-rot or vehicles, weighing less than 10 lbs. They will operate under normal conditions at a speed of no more than 50 mph, and have the capability to hover, and move in the vertical and h orizontal plane simultaneously. They will be operated only at controlled access sites within the visual line of sight of the pilot-in-command (“PIC”) and visual observer (“VO”), and only in acc ord with the procedures prescribed in CB&I’s Procedure for Small Unmanned Aircraft Systems Opera tions for the USA (“CB&I’s Procedures”). 3 Such operations will ensure that CB&I’s sUAS will “not create a hazard to users of the [NAS] or the public.” See Reform Act at § 33 3(b)(1). Further, due to the small size of the

sUA and the low altitudes and restricted areas in w hich they will operate, approval of CB&I’s petition presents no national security issue. The lack of any threat to national security is further

3 CB&I submits its Procedures along with its sUAS P re-flight Checklist, exemplar sUAS Flight Log, exemplar sUAS Maintenance and Repair Lo g, Incident Notification Procedure, and exemplar Job Safety Analysis form as confidential p ursuant to 14 CFR 11.35, as these materials contain confidential commercial and proprietary inf ormation that CB&I has not and will not share with others, is not available to the public, and is protected from release under the Freedom of Information Act, 5 U.S.C. § 552, et seq.U.S. Department of Transportation

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reinforced by the fact that all individuals who wil l operate the sUAS will hold at a minimum a sport pilot certificate and will thus have been sub ject to a security screening by the U.S. Department of Homeland Security. 49 U.S.C. § 44903( j)(2)(D)(i).

Given the small size of the sUA involved and the re stricted environment within which they will operate, CB&I’s petition falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exe mption, allow commercial operation of sUAS to commence immediately.

IV. PUBLIC INTEREST

This exemption petition is submitted to fulfill Con gress’ goal in passing Section 333: to establish requirements for the safe operation of sUAS in the NAS pending completion of the rulemaking required by Section 332 of the Reform Act. By gran ting CB&I’s petition, the FAA will fulfill Congress’ intent of allowing sUAS to operate with s ignificant safety precautions in low risk environments while the FAA works on completing the rulemaking process required by Section

332.

The use of sUAS at construction sites can significa ntly reduce the risk to workers of falls while inspecting, surveying or monitoring site progress. sUAS can inspect, photograph and collect

data on areas that are difficult to access and woul d otherwise require worker inspection. Falls are a leading source of workplace fatality and inju ry on construction sites, and the use of sUAS can minimize the need to expose individuals to high fall risk activities. 4

Additionally, sUAS can replace the use of helicopte rs and/or fixed-wing aircraft to conduct aerial imagery, inspection, surveying and data collection. Conventional operations using manned aircraft involve heavy aircraft that must transit f rom airports to the operational location, carrying significant amounts of combustible fuel, and a mult i-person crew. Manned aircraft are at risk of fuel spillage and fire in the event of an accident or incident, as well as potential injury to, or los s of life of, the pilot and photographer. By contras t, sUA such as those CB&I seeks to operate weigh less than 10 pounds, and carry no crew or com bustible material on board. Shifting to sUAS from manned aircraft clearly presents a marked safety increase for construction professionals, their contracting parties and the pu blic at large.

Finally, sUAS reduce the environmental impact by dr amatically decreasing the energy used for aerial imagery, inspection, surveying and data coll ection activities. sUAS such as those CB&I seeks to operate use rechargeable lithium ion batte ries, as opposed to fossil fuels burned in the operation of much heavier helicopters and small air craft.

V. EQUIVALENT LEVEL OF SAFETY

CB&I has tailored its operating procedures to compl y with the conditions and limitations imposed on similarly situated petitioners seeking t o use sUAS for aerial data collection. The operational limitations and conditions to which CB& I will adhere, and which will ensure an

4 “Commonly Used Statistics”, Occupational Safety & Health Administration. Available at https://www.osha.gov/oshstats/commonstats.html, las t visited March 7, 2016.U.S. Department of Transportation

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equivalent or higher level of safety to operations of small aircraft or helicopters for similar purposes under the current regulatory guidelines, i nclude the following:

1. The sUA will weigh less than 10 lbs. 2. Operations will be conducted at CB&I’s project s ites, to which third party access

is controlled. 3. All flights will be conducted by a PIC who will be assisted by a VO; the PIC and VO will be able to communicate verbally at all time s during flight. 4. The PIC will hold a minimum of a valid sport pil ot certificate issued by the FAA

and a valid state issued driver’s license. 5. The PIC will be trained in flight operations and safety procedures as detailed in

the CB&I Procedures. 6. The sUAS will be operated only during daylight h ours, under visual meteorological conditions, and with visibility of a t least 3 statute miles from the

PIC. 7. Flights will be operated within visual line of s ight of the PIC and VO. 8. Flights will be conducted at an altitude below 4 00 feet AGL. 9. The sUA will operate at least 500 feet below or more than 2,000 feet horizontally from any cloud. 10. Flights will maintain a distance greater than 5 nautical miles from any airport reference point as denoted in the current FAA Airpo rt/Facility Directory or for airports not denoted with an airport reference poin t, the center of the airport symbol as denoted on the current FAA-published aero nautical chart, unless appropriate approval has been obtained. 11. Flights will maintain a minimum distance of 500 feet from non-participating persons unless barriers or structures are present t hat sufficiently protect nonparticipating persons from the sUA and/or debris in the event of an accident. Flights will also maintain a minimum distance of 50 0 feet from vessels, vehicles,

or structures unless the owner/controller thereof h as granted permission for operating closer and the PIC has made a safety asse ssment and determined that the risk of operating closer to those objects does not present an undue hazard. 12. Flights will not begin unless there is enough p ower to conduct the intended operation and to operate after that for at least fi ve minutes or with the reserve power recommended by the manufacturer, if greater. 13. The sUA will not be operated at airspeeds great er than the maximum operating airspeed recommended by the manufacturer. 14. The sUA will remain clear and give way to all m anned aviation operations and

activities.

15. If the sUAS loses communication or loses its GP S signal, the sUA will return to a pre-determined location within private or controlle d access property. 16. The PIC will abort the flight in the event of u npredicted obstacles or emergencies. 17. The PIC will not be aboard any moving device or vehicle while operating the

sUAS. 18. Flights will not be conducted absent the writte n approval of the property owner/controller or the approval of the owner/contr oller’s authorized agent. 19. The sUAS will be registered and identified as r equired by the FAA prior to operation.U.S. Department of Transportation

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20. All maintenance, repair, overhaul, replacement, life limited requirements and

inspection of the sUAS will be accomplished in acco rdance with the CB&I Procedures and the manufacturer’s requirements, inc luding any manufacturer safety bulletins. Any sUAS that has undergone main tenance or alterations that affect sUAS operation or flight characteristics wil l undergo a functional test flight prior to conducting further operations of the sUAS. 21. Prior to each flight, a pre-flight inspection o f the sUAS will be conducted to confirm the sUAS is in a condition for safe operati on.

VI. SPECIFIC REGULATIONS FOR WHICH EXEMPTION IS SOU GHT & THE REASONS

THEREFORE

A. 14 CFR 21, Subpart H – Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, est ablishes the procedural requirements for the

issuance of airworthiness certificates. Small unma nned aircraft systems are not specifically

addressed in these rules.

Given the size and limited operating area associate d with the sUAS to be utilized by CB&I, CB&I respectfully submits that an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Sectio n 333 of the Reform Act. As noted above,

the Act and Section 333 of the Reform Act both auth orize the FAA to exempt aircraft from the requirement of an airworthiness certificate upon co nsideration of the size, weight, speed, and operational capability of the sUAS and proximity to airports and populated areas of the proposed operations.

A review of these factors makes clear that CB&I’s s UAS, operated without an airworthiness

certificate but in the restricted environment and u nder the conditions proposed herein, will be at least as safe as, if not safer than, a conventional aircraft (fixed-wing or helicopter) operating with

an airworthiness certificate without the restrictio ns and conditions proposed by CB&I. The sUA to be operated hereunder weigh less than 10 lbs ful ly loaded, carry neither a pilot nor passengers, and carry no explosive materials or fla mmable liquid fuels. As set forth herein and in the CB&I Procedures, they will operate at relati vely low speeds, in a controlled environment, at least five miles from an airport (unless appropr iate approvals have been obtained) and within the line of sight of the PIC and VO. Thus, if gran ted, this exemption will only allow for highly controlled, closely observed operations in limited and defined areas.

Further, application of these same criteria demonst rates that there is no credible threat to national security posed by the sUA due to their siz e, speed of operation, location of operation, lack of explosive materials or flammable liquid fue ls, and inability to carry a substantial external

load.

B. 14 CFR 91.7(a) – Civil Aircraft Airworthiness

14 CFR 91.7(a) provides that “[n]o person may opera te a civil aircraft unless it is in an airworthy

condition.”U.S. Department of Transportation

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Currently, the FAA does not have a regulatory stand ard for determining whether an sUAS is airworthy. However, as noted above, the FAA has pr eviously approved the use of the same model sUAS that CB&I seeks to operate, the DJI Phan tom 3 Professional and the DJI Inspire 1.

CB&I will achieve an equivalent level of safety wit h respect to its sUAS by complying with the CB&I Procedures and the CB&I sUAS Pre-flight Checkl ist. Those documents contain procedures that allow the PIC to determine whether the sUAS is in a condition safe for flight prior to each flight, and an exemption from §91.7(a ) is therefore warranted.

C. 14 CFR 61.101(e)(4)&(5) – Recreational Pilot Privi leges & Limitations; 61.113(a) – Private Pilot Privileges & Limitations: Pilot in Command; 61.315(a),(c)(1),(2)&(3) – What Are the Privileges and Limits of My Sport Pilot Certificate; 14 CFR 61.23(a)&(c) – Medical Ce rtificates: Requirement &

Duration

Section 61.113 (a) limits private pilots to non-com mercial operations. Sections 61.101(e)(4)&(5) similarly limit recreational pilot s to non-commercial operations while 61.315(a),(c)(1),(2)&(3) limit sport pilot certific ate holders to acting as PIC of light-sport aircraf t for non-commercial purposes. Section 61.23(a) requ ires a person exercising the privileges of a private pilot certificate or recreational pilot cer tificate to hold at least a third class medical certificate. 61.23(c) requires a person exercising the privileges of a sport pilot certificate in a light-sport aircraft other than a glider or balloon to hold either a medical certificate or U.S.

driver’s license.

In the grant of Exemption No. 11062 to Astraeus Aer ial, the FAA determined that the unique characteristics of sUAS operations outside of contr olled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot certificate and second class medical certificate. More recently, t he FAA determined in the context of the grant of Exemption No. 11213 to Aeryon Labs Inc. that hol ders of recreational and sport pilot certificates would also have adequate aeronautical knowledge to pilot a sUAS. Because these individuals would also be subject to security scree ning by the Department of Homeland Security, the FAA determined that holders of recrea tional and sport pilot certificates would be qualified to serve as the PIC for sUAS operations.

Like those in Exemption Nos. 11062 and 11213, the s UA that CB&I proposes to operate will not carry a pilot or passengers, nor any explosive mate rial or flammable liquid, and will weigh less than 10 lbs. In addition, all flights will be oper ated in controlled locations within the visual line of sight of the PIC and VO, will be planned and coordi nated in advance, and will not take place within five miles of an airport (unless appropriate approvals have been obtained). Given the foregoing, CB&I submits that its proposed operation s will achieve at least the equivalent level of safety of a single individual holding a commercial pilot certificate operating a conventional aircraft by requiring the PIC to hold a minimum of a valid sport pilot certificate issued by the FAA and a valid state issued driver’s license, as w ell as to have completed the sUAS training requirements set forth in the CB&I Procedures.

Indeed, the risk associated with the operation of C B&I’s sUAS (given their small size, speed, operational capabilities and limitations and lack o f combustible fuel) are so diminished from theU.S. Department of Transportation

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level of risk associated with commercial operations with manned aircraft (and even operations permitted with a private pilot certificate) contemp lated by Part 61 when drafted, that allowing operations of the sUAS as set forth herein will gre atly exceed the present level of safety provided for under 14 CFR Part 61.

D. 14 CFR 91.119(c) – Minimum Safe Altitudes: General

Section 91.119 establishes safe altitudes for opera tion of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than conges ted areas to an altitude of 500 feet above the surface, except over open water or sparsely populat ed areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure.

As set forth in the CB&I Procedures, CB&I will not operate its sUA higher than 400 feet AGL. The sUA will, however, be operated to avoid congest ed or populated areas. Because aerial imagery, inspection, surveying and data collection must be conducted at relatively low altitudes and at altitudes less than 500 feet AGL, an exempti on from Section 91.119(c) is needed.

The equivalent level of safety will be achieved giv en the size, weight, speed and material with which the sUA are built. Also, all flights will be conducted over private and/or controlled access property with the permission of the land owner or t hose who control the land. Moreover, the CB&I Procedures contain provisions to assure that a ll non-participating persons are either 500 feet from the sUA or are protected by barriers or o ther structures.

Compared to operations conducted with aircraft or r otorcraft weighing far more than the sUA and carrying flammable fuel, any risk associated with t hese operations will be significantly less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the sUA will maintai n separation between the sUA and conventional aircraft that must comply with Section 91.119.

E. 14 CFR 91.121 – Altimeter Settings

Section 91.121 requires each person operating an ai rcraft to maintain cruising altitude by

reference to an altimeter that is set to "... the e levation of the departure airport or an appropriate altimeter setting available before departure." Bec ause the sUAS CB&I seeks to operate may rely on GPS altitude, an exemption is required.

Prior to each flight, the sUAS CB&I seeks to operat e automatically establish an altitude initiation point at ground level. Once flight commences, GPS based altitude information will automatically be provided to the PIC from the sUA for active moni toring of the flight path and altitude. This altitude information, combined with the operation o f the sUA below 400 feet AGL and within the visual line of sight of the PIC and VO, will ensure an equivalent level of safety.

F. 14 CFR 91.151 (a)(1) – Fuel Requirements for Fligh t in VFR Conditions

Section 91.151 (a) prohibits an individual from beg inning “a flight in an airplane under VFR conditions unless (considering wind and forecast we ather conditions) there is enough fuel to flyU.S. Department of Transportation

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to the first point of intended landing and, assumin g normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At n ight, to fly after that for at least 45 minutes.”

The DJI Phantom 3 Professional is powered by a remo vable, rechargeable, lithium-polymer battery that provides approximately 23 minutes of p owered flight. The Inspire 1 is also powered by a removable, rechargeable, lithium-polymer batte ry that provides approximately 18 minutes of powered flight. Without an exemption from 14 CF R 91.151, flights by CB&I would not be possible. Given the limitations on the proposed ope rations and their locations, a less burdensome reserve requirement for flight in daylig ht VFR conditions is reasonable. Moreover, both the DJI Phantom 3 Professional and Inspire 1 p rovide low battery warnings that advise the PIC to command the sUA’s return to the launch point or land when low battery capacity voltage is reached. A critical low battery warning is also provided. The sUAS will initiate an automatic descent and landing at the critical low battery war ning.

Given the foregoing, an exemption from 14 CFR 91.15 1(a) is safe and is also within the scope of prior exemptions for sUAS referenced herein. In line with the previous grants of exemption, CB&I requests that the FAA grant relief under the c ondition that the PIC will not begin a flight unless (considering wind and forecast weather condi tions) there is enough power 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.

G. 14 CFR §91.405(a) - Maintenance Required; 91.407(a )(1) – Operation After Maintenance, Preventive Maintenance, Rebuilding or Alteration; 91.409(a)(1)&(2) – Inspections; 91.417(a)&(b) – Mai ntenance Records

Section 91.405(a) requires that an aircraft operato r or owner “[s]hall have that aircraft inspected as prescribed in subpart E of this part and shall b etween required inspections, except as provided in paragraph (c) of this section, have dis crepancies repaired as prescribed in part 43 of this chapter...”. Section 91.407(a)(1) provides tha t “[n]o person may operate any aircraft that has undergone maintenance, preventive maintenance, rebu ilding, or alteration unless – (1) It has been approved for return to service by a person aut horized under §43.7 of this chapter ...”. Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner o r operator to keep records showing certain maintenance work that has been accomplished and rec ords of approval of the aircraft for return

to service.

Given these sections and Part 43 apply only to airc raft with an airworthiness certificate, these sections will not apply to CB&I. Maintenance of th e sUAS will be accomplished in accord with the CB&I Procedures and the manufacturers’ requirem ents, including any manufacturer safety bulletins. Further, CB&I will keep appropriate rec ords of all maintenance performed on its sUAS. An equivalent level of safety will be achiev ed because the sUA CB&I intends to operate are limited in size and will operate only in contro lled areas for limited periods of time from no higher than 400 feet AGL. Given it will not be ope rating higher than 400 feet AGL, the sUA can land immediately if mechanical issues arise. And, as provided in the CB&I Procedures andU.S. Department of Transportation

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CB&I sUAS Pre-flight Checklist, the PIC will ensure that the sUAS is in working order prior to initiating flight.

VII. SUMMARY FOR PUBLICATION

Pursuant to 14 CFR Part 11, the following summary i s provided for publication in the Federal Register, should it be determined that publication is necessary:

Petitioner, Chicago Bridge & Iron (“CB&I”), seeks a n exemption from the following rules in Title 14 of the Code of Federal Regulations:

Part 21, Subpart H; 61.101(e)(4)&(5); 61.113(a); 61 .315(a),(c)(1),(2)&(3); 61.23(a)&(c); 91.7(a); 91.119(c); 91.121; 91.151(a) (1); 91.405(a); 91.407(a)(1); 91.409(a)(1)&(2); 91.417(a)&(b).

Approval of these exemptions will permit CB&I to op erate commercially small Unmanned Aircraft Systems to conduct aerial imagery, inspect ion, surveying and data collection of its projects at various construction sites. The ex emption will enhance safety by significantly reducing the risk and hazards associa ted with performing equivalent work through individual workers and conventional manned aircraft. The exemption will also reduce the environmental impact of such activities by dramatically decreasing the energy that would otherwise be used via helicopter or smal l aircraft.

VIII. CONCLUSION

CB&I’s petition for exemption satisfies the criteri a articulated in Section 333 of the Reform Act, including weight, speed, operating capabilities, pr oximity to airports and populated areas, operation within visual line of sight and national security concerns. The proposed operations in this petition are similar to those in previously is sued grants of exemption, and they would benefit the public as a whole by increasing safety while re ducing the environmental impact arising from

the use of manned aircraft. In consideration of th e foregoing, this petition provides the FAA with all of the necessary justification for issuance of a grant of exemption permitting CB&I to use sUAS to conduct aerial imagery, inspection, surveyi ng and data collection.U.S. Department of Transportation

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We thank you for your prompt consideration of the r equested exemption. Should you have any questions, or if you need additional information to support the requested exemption, please do not hesitate to contact the undersigned.

Very truly yours,

LOCKE LORD LLP

T. Patrick Byrnes

TPB:mc

Encl.