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Austin, TX • Bradenton, FL • Chicago, IL • Horsham, PA • Naperville, IL • Washington, DC • Doha, Qatar

Corporate Office: 5400 Old Orchard Road, Skokie, IL 60077-1030 P: 847-965-7500 F: 847-965-6541 www.CTLGroup.com

CTLGroup is a registered d/b/a of Construction Technology Laboratories, Inc.

Construction Technology Laboratories, Inc.

d/b/a CTLGroup

5400 Old Orchard Road

Skokie, IL 60077-1030

www.CTLGroup.com

January 8, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Submitted Via www.regulations.gov

Re: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from 14 CFR § 61.3; 14 CFR § 61.113(a) & (b); 14 CFR § 61.133;

14 CFR § 91.7(a); 14 CFR § 91.9(b); 14 CFR § 91.119(c); 14 CFR § 91.121; 14 CFR § 91.151(a);

14 CFR § Part 21; Subpart H; 14 CFR § 91.203; 14 CFR § 91.405(a); 14 CFR § 91.407(a)(1); 14 

CFR § 91.409(a)(1) & (a)(2); 14 CFR § 91.417(a) & (b)

Dear Sir or Madam:

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Construction Technology 

Laboratories, Inc., d/b/a CTLGroup (hereafter “CTLGroup”) hereby requests a grant of

exemption from the Federal Aviation Regulations (FARs) noted herein. CTLGroup is seeking a

grant of exemption to operate small Unmanned Aircraft Systems (sUAS) within the National

Airspace System (NAS) for commercial operations.

As directed by Congress through the enactment of Section 333(a) - (c) of the Reform Act, the 

Secretary of Transportation shall determine whether certain unmanned aircraft systems

(UAS) may operate safely in the NAS before completion of the plan and rule-making required

by Section 332. This petition will show that, due to their size, weight, speed, and operational 

capability, the sUAS operated by CTLGroup will not create a hazard to users of the NAS, the

public, or national security.

In addition to considering size, weight,speed, etc, it is important to note that per Section 333(b)

of the Reform Act, "ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS. - In making the

determination under subsection (a), the Secretary shall determine, at a minimum-- (2) whether 

a certificate of waiver, certificate of authorization, or airworthiness certification under section
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www.CTLGroup.com

44704 of Title 49 United States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1)." CTLGroup respectfully submits that the phrase "at a

minimum" used by Congress in Section 333(b) carries the same meaning as the phrase "at

least", which by definition means "lowest in consideration, position, or importance". Therefore,

Section 44704 of Title 49 U.S.C. was intended to be a starting point, for the Secretary, when

considering requested exemptions from regulations prior to the establishment of a sUAS Rule.

Being such, the Secretary has the implied authority to also consider granting relief from other

Title 49 sections as necessary, including Section 44711 - Prohibitions and Exemption, to

accomplish the Congressional goal of safely accelerating the integration of civil UAS into the

NAS.

The sUAS to be employed by CTLGroup are high-quality commercial off-the-shelf models 

made by reputable manufacturers: DJI Developers and 3DRobotics. In addition to the 

investment in quality equipment, CTLGroup has also invested its time, energy, and resources

to ensure a safe sUAS operating environment.

CTLGroup will employ sUAS for aerial data collection for engineering, construction, inspection, 

real estate, risk management, and related industries. Granting this petition will help fulfill the 

goal of Congress to safely accelerate the introduction of sUAS into the NAS.

The information and documentation included within the attached petition has been provided

to support CTLGroup's requested grant of exemption.

We look forward to your favorable response. 

Sincerely,

Timothy D. Tonyan

Chief Operating Officer

CTLGroup

Enclosure: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations
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Petition for Exemption Under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

This Petition is organized as follows:

Section Page_

1. Description of Petitioner ..................................................................................... 3

2. Proposed Uses ..................................................................................................... 4

3. Description and Characteristics of sUAS .............................................................. 4

4. Public Interest and Benefits ................................................................................. 6

5. CTLGroup's sUAS Operations Guidelines............................................................... 6

6. Requested Exemptions from Regulations ............................................................ 9

7. Supporting Documentation .................................................................................. 14

8. Summary for Publication ...................................................................................... 14

1. Description of Petitioner

The name and address of the Petitioner is: 

CTLGroup

Attn: Timothy D. Tonyan

5400 Old Orchard Rd.

Skokie, IL 60077-1030

847-965-7500

Fax: 847-965-6541

TTonyan@CTLGroup.com

www.CTLGroup.com

CTLGroup is an internationally recognized expert consulting engineering and materials science 

firm, providing engineering, architecture, and scientific testing to clients across the globe. Our 

engineering expertise is complemented by one of the largest private materials and structural 

testing laboratories in the world. CTLGroup originated a century ago as the cement and concrete 

technology Research and Development Laboratories of Portland Cement Association (PCA) in 

1916. In the 1960s, we began providing consulting services for applied research projects, 

continuing to expand our engineering consulting services through the 1980s. In 1987, CTLGroup 

was incorporated as Construction Technology Laboratories, Inc., a wholly-owned subsidiary of 

PCA, and in 2005 began doing business as CTLGroup. CTLGroup has been a principal investigator

for owners and agencies, such as FEMA, on some of the most significant infrastructure failures in 
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recent history. These include the Oklahoma City bombing, 9/11 World Trade Center attacks, Sago 

Mine explosion, Big Dig Tunnel collapse, I-35W bridge collapse and Hurricane Katrina, to name a 

few (for more background information, visit CTLGroup.com).

CTLGroup will employ small unmanned aerial systems (sUAS) for aerial data collection for use in 

engineering, construction, inspection, real estate, risk management, and related industries. The 

sUAS program at CTLGroup will be managed by Dr. David Kosnik and Mr. Jaimy Juliano. Dr. 

Kosnik is a consulting engineer with a BS degree in computer engineering and MS and PhD in civil 

engineering, all from Northwestern University. He is a licensed professional engineer in Illinois 

and a member of the Academy of Model Aeronautics. Mr. Juliano is a senior technician with 

over a decade of experience in engineering technology, and also has several years (and hundreds 

of flight hours) of experience as a safe operator of sUAS as a hobbyist.

2. Proposed Uses

CTLGroup will employ sUAS for aerial data collection for use in engineering, construction,

architecture, real estate, inspection, risk management, and related industries. Typical data to be 

collected include still and video imagery needed to generate detailed models of structures, 

public and private infrastructure facilities, real estate, terrain, and related items.

3. Description and Operational Characteristics of sUAS

For the applications listed in Section 2 above, CTLGroup will employ two models of commercial 

off-the-shelf sUAS, both from reputable manufacturers: the DJI Phantom 3 quadcopter and 

3DRobotics X8-M octocopter. Both models will be flown at altitudes below 400 feet above ground 

level (AGL) and speeds below 50 mph / 43 knots. Specifically, it is anticipated that most sUAS 

operations by CTLGroup will take place no higher than 200 feet AGL and no faster than 20 mph. Both

models of sUAS weigh considerably less than 55 pounds: the Phantom 3 and X8-M weigh 

approximately 2.8 lbs. and 8.2 lbs., respectively, with battery and maximum payload. Neither carries 

any fuel. Additional description and operational characteristics of both sUAS follow.

a) Common safety features

All sUAS flights by CTLGroup will be conducted by a Pilot In Command (PIC) and a Visual 

Observer (VO). Both the PIC and VO will maintain visual line-of-sight (VLOS) contact with the 

sUAS at all times during flight. Both sUAS models employ GPS data to determine horizontal 

position and altitude. A barometric altimeter provides redundant altitude information. Using 

the remote control interface, the PIC can monitor the aircraft’s position, altitude, heading, 

speed, and remaining battery life at all times during the flight. GPS satellite reception quality 

and remote control signal strength are also monitored.
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Both sUAS have an automatic Return to Home (RTH) feature to guide the aircraft back to its 

starting location and effect safe landing without human control. The RTH feature engages 

automatically in the event that the remote control signal is lost or the battery becomes critically 

low. In addition, the PIC may manually activate the RTH feature at any time, for example, in the 

event that conditions warrant immediate abort of the flight. When activated, the RTH feature

commands the sUAS to a preset altitude, typically 100 feet AGL, and returns to its home point. In 

situations where direct RTH might pose a hazard (due to obstructions, for example), the sUAS can 

be programmed to land immediately upon activation of RTH, rather than fly back to its starting 

location.

b) DJI Phantom 3 specifics

Below are the standard specifications of the DJI Phantom 3 quadcopter.

DJI Phantom 3 Specifications

Weight (including battery and camera) 2.8 lbs (1.3 kg)

Dimensions Approx. 27 inches diagonal

Maximum Speed 36 mph (16 m/s)

Typical Flight Time Approximately 20 minutes

Remote Control Operating Frequency 2.4 GHz

Remote Control Range 1.2 miles

Flight Battery 4400 mAh LiPo 4s

c) 3DRobotics X8-M specifics

Below are the standard specifications of the 3DRobotics X8-M Octocopter.

3DRobotics X8-M Specifications

Weight (including battery and camera) 8.2 lbs (3.7 kg) max.

Dimensions 13.7 in x 20.1 in x 11.8 in

Maximum Speed 40 mph (18 m/s)

Typical Flight Time Approximately 14 minutes

Remote Control Operating Frequency 2.4 GHz control, 900 MHz telemetry

Remote Control Range 0.6 mile

Flight Battery 10000 mAh 10C LiPo 4S

The 3DRobotics X8-M utilizes a fully redundant propulsion system that provides increased

reliability. That is, each of the four nacelles includes two independent motor/rotor 

combinations.

To obtain very high quality aerial data, CTLGroup will conduct autonomous flights using the X8-

M. Autonomous flights will be programmed into the aircraft's onboard autopilot flight controller

prior to arriving at each site. Adjustments, however, may be made on the ground prior to each
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flight to correct for wind direction and other unanticipated site related variables discovered at

the time of each flight to ensure the safe and efficient operation.

4. Public Interest and Benefits

By employing sUAS for CTLGroup's operations, the potential risk of serious accidents and injuries

associated with suspending workers at height on tethers, or with manned rotary and fixed wing

aircraft weighing thousands of pounds, will be greatly reduced and/or eliminated. In addition to

weight, the type of manned aircraft typically used to capture the high resolution photography and

video described herein are capable of carrying 100 or more gallons of fuel which creates the

potential risk of spillage and fire in the event of an incident or accident, emit emissions harmful to

the environment, and require an onboard pilot and additional crew members to operate the 

photographic and video equipment. The sUAS employed by CTLGroup weigh less than 10 pounds

fully loaded, carry no fuel, and emit no harmful emissions; the pilot and crew are remotely located

from the aircraft, and the sUAS are operated over controlled access sites/properties, so a

significant public benefit is achieved.

Additionally, by employing sUAS at altitudes well below and at speeds far less than manned 

aircraft, CTLGroup will provide the engineering, construction, architecture, real estate,

inspection, risk management, and related industries with data and imagery that possess a

superior level of detail and precision than is impossible to acquire with manned flights or

satellite imagery.

5. CTLGroup's sUAS Operations Guidelines

CTLGroup will review and update the following sUAS guidelines annually, or more frequently if 

necessary, to ensure that the information contained therein is current, relevant to sUAS

operations, and to ensure that it accurately reflects updated best practices and FAA rules for

civil sUAS operations.

a. Safety

In the interest of safety and efficiency, CTLGroup sUAS operations will be conducted in 

accordance with manufacturer recommendations, best practices (e.g., the Academy of 

Model Aeronautics Safety Code), FAA and local rules, and the following CTLGroup 

operations guidelines

Each field deployment of sUAS by CTLGroup will begin with a safety briefing to review 

flight goals, site-specific hazards, restricted airspace, and other operational and safety 

information. A preflight inspection of the sUAS will be conducted before each flight.
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In addition to the Pilot in Command, each flight will include a Visual Observer (VO). The

VO will maintain direct Visual Line of Sight (VLOS) with the aircraft at all times. The VO 

will remain in verbal contact with the PIC at all times during a flight. The duties of the 

VO will include identification of ground-based and aerial obstacles and potential hazards,

including, but not limited to, other UAS and manned aircraft.

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

Flights operations will be conducted only during daylight and under visual meteorological 

conditions. No flights may take place under special visual flight rules. The PIC and VO will

monitor weather conditions prior to and during every flight. If adverse weather conditions 

are predicted or observed, the flight will be aborted.

Phone calls, electronic messaging, and texting will not be permitted at any time during 

flight operations.

No flights will be conducted over crowds or congested areas. Flight operations will avoid 

nonparticipating persons as much as practical. The sUAS will be used for close-in 

inspection of structures or vessels only with permission of the owner, and where

the PIC has determined that risks associated with such close-in operation do not present 

an undue hazard.

Any incidents, accidents, or transgressions of operational area boundaries will be 

documented and reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents will be reported to the National Transportation Safety Board.

b. Flight Planning

During the preflight safety meeting at each sUAS deployment, the PIC and VO will

visually survey the flight area to identify obstacles and potential hazards that may affect

the aircraft during flight. They will also determine the safest location from which to

launch the aircraft as well as the best vantage point from which to maintain a VLOS of 

the aircraft at all times during the flight.

The PIC will be designated prior to each flight, and the PIC designation will not be 

transferred to another individual for the duration of the flight.

Prior to each flight, the PIC, VO, and other necessary participants will review and discuss 

the details and parameters of the flight to insure that all participants have a firm 

understanding of the flight objectives.
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The PIC will identify any pertinent airspace restrictions, including areas of manned 

aircraft operation, prohibited airspace, and temporary flight restrictions (TFRs). The PIC 

will take prudent measures to avoid incursion into restricted airspace.

The PIC will determine the altitude of the launch site and calculate the maximum

allowable flight altitude for the operation such that the aircraft will remain within 400

feet AGL during the flight.

Prior to each flight, the PIC will ensure that the sUAS has been programmed to 

automatically return-to-home if the remaining battery life falls below 25%.

c. Preflight Inspections

The PIC will conduct a preflight visual inspection of the sUAS, batteries, and remote control. 

The PIC will check the charge levels of the sUAS and remote control batteries to ensure

that enough power is available to complete the mission and land safely with at least 25% battery 

remaining. Prior to takeoff, the PIC will verify that the sUAS is receiving an adequate GPS

signal for safe operation.

d. Flight Procedures

A copy of CTLGroup’s sUAS operations guidelines and the manufacturer's user manual

will be in possession of the PIC or other designated operations personnel at all times 

during a flight.

The sUAS will be operated at an altitude of no more than 400 feet AGL and will not 

exceed speeds recommended by the manufacturer.

The sUAS will not be operated within 5 nautical miles of an airport unless a letter of 

agreement from the airport’s management is obtained, or otherwise permitted by 

certificate of airworthiness issued to CTLGroup.

The sUAS will be operated within visual line of site (VLOS) of the PIC and VO at all

times. The PIC and VO must be able to communicate verbally at all times.

The sUAS will not be operated less than 500 feet below or within 2000 feet

horizontally from a cloud.

The PIC will stay clear of and always yield the right-of-way to other sUAS and manned 

aircraft.
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The PIC will manually activate the sUAS's return-to-home feature in the event of

any detected abnormality or emergency.

During flight, the PIC will monitor the UAS's altitude, horizontal speed, distance of the

aircraft from the remote control, and remaining battery life; and the remaining life of the

remote control.

During all programmed autonomous flights, the PIC will maintain Visual Line of Sight of 

the sUAS and monitor the sUAS controls. The PIC will assume manual control of the 

aircraft in the event of any detected abnormality or emergency and activate the returnto-home.

e. Maintenance

Each sUAS will be maintained according to the manufacturer’s recommendations.

Corrective maintenance will be completed according to the manufacturer's

recommendation.

Any sUAS that has undergone maintenance or alterations that affect critical flight 

components will undergo a functional test flight prior to being placed back into service.

The functional flight test will be conducted such that no undue hazard is posed to 

nonparticipating persons.

f. Record Keeping

An aircraft maintenance record will be kept for each sUAS operated by CTLGroup.

Routine and preventive maintenance, as well as any repair or corrective maintenance

will be recorded in the aircraft record for each sUAS

Each flight for commercial purposes will be logged in the pilot’s and the aircraft’s 

logbook.

6. Requested Exemptions from Regulations

14 CFR § 61.3; Requirements for certificates, ratings and authorizations: 14 CFR § 61.113(a) & 

(b); Private Pilot Privileges and Limitations: 14 CFR § 61.133; Commercial pilot privileges and 

limitations

CTLGroup seeks an exemption from 14 CFR § 61.3 which states "No person may serve as a

required pilot flight crewmember of a civil aircraft of the United States, unless that person: (1)

Has in the person's physical possession or readily accessible in the aircraft when exercising the

privileges of that pilot certificate or authorization— (i) A pilot certificate issued under this part 

and in accordance with §61.19;", and
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14 CFR § 61.113(a) & (b) which states "(a) Except as provided in paragraphs (b) through (h) of 

this section, no person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for 

compensation or hire, act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) The 

aircraft does not carry passengers or property for compensation or hire.", and

14 CFR § 61.133 which states "(a) Privileges—(1) General. A person who holds a commercial pilot

certificate may act as pilot in command of an aircraft— (i) Carrying persons or property for 

compensation or hire, provided the person is qualified in accordance with this part and with the 

applicable parts of this chapter that apply to the operation; and (ii) For compensation or hire, 

provided the person is qualified in accordance with this part and with the applicable parts of this

chapter that apply to the operation."

Prior to the grant of exemption issued to Jeffery J. Walsh (11229), FAA required that a PIC of a 

commercially operated sUAS must at least hold a Private Pilot Certificate. Following the grant of 

exemption issued to Jeffery J. Walsh, FAA's stance changed thus permitting a PIC to hold a range

of licenses from a Commercial Pilot Certificate down to a Sport Pilot Certificate.

Most recently, per the release of a Small UAS Notice of Proposed Rulemaking, FAA proposes to 

replace the pilot airman certificate requirement with an Aeronautical Knowledge Test, create a 

sUAS certificate, and establish a TSA security screening process for sUAS Operators, followed by 

recurrent Aeronautical Knowledge Tests every 24 months, all of which CTLGroup feels is

reasonable and necessary.

As of the date of this petition, a number of petitioners have requested complete relief from the 

requirement to hold a pilot airman certificate; however, FAA has held firm to the position that 

Section 333 did not grant the authority to exempt that requirement (e.g. Singer's Creations 

(11191)). Additionally, FAA has also required a pilot certificate for sUAS operations because pilots

holding an FAA issued pilot certificate are subject to the security screenings by the Department of 

Homeland Security that certificated airmen undergo.

Section 333(b) of the Reform Act states, "ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS. - In 

making the determination under subsection (a), the Secretary shall determine, at a minimum-- (1)

which types of unmanned aircraft systems, if any as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line

of sight do not create a hazard to users of the national airspace system or the public or pose a

threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States Code, is required for the

operation of unmanned aircraft systemsidentified under paragraph (1)."
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Based upon the wording of Section 333(b) of the Reform Act, CTLGroup respectfully disagrees

with FAA's opinion/position that the Secretary only has the authority to grant relief from Section

44704 of Title 49 U.S.C. when considering requested exemptions from regulations; and instead

submits that the phrase "at a minimum" used by Congress in the Section 333(b) carries the same

meaning as the phrase "at least", which by definition means "lowest in consideration, position,

or importance". Therefore, Section 44704 of Title 49 U.S.C. was simply intended to be a

minimum starting point, for the Secretary, when considering requested exemptions from

regulations, prior to the establishment of a sUAS Rule. Being such, the Secretary also has the

implied authority to grant relief from other Title 49 sections as necessary, including Section 

44711 - Prohibitions and Exemption, to accomplish the Congressional goal of safely accelerating

the integration of civil UAS into the NAS.

CTLGroup will achieve an equivalent level of safety requiring the pilot to:

1. Complete Sport Pilot ground instruction and pass the FAA Sport Pilot written

examination to substantiate that essential aeronautical knowledge has been

acquired.

2. Possess a valid driver’s license issued by a US state, the District of Columbia, or other US 

territory or possession.

3. Adhere to all sections of the CTLGroup sUAS operations guidelines, the manufacturer's

operating manuals, and FAA sUAS operating rules.

4. Undergo a Transportation Security Administration screening process, once such screenings

become available for sUAS operators.

Granting this requested exemption will facilitate the mandate of the Reform Act to safely 

accelerate the introduction of sUAS into the NAS.

14 CFR § 91.7(a); Civil Aircraft Airworthiness

CTLGroup seeks an exemption from 14 CFR § 91.7(a) which states "No person may operate a

civil aircraft unless it is in an airworthy condition."

Currently FAA does not have a regulatory standard for determining whether any UAS is 

airworthy. CTLGroup will achieve an equivalent level of safety by complying with the

manufacturer’s user manual and CTLGroup's sUAS operations guidelines to insure each sUAS

is airworthy.
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14 CFR § 91.9(b); Civil Aircraft Flight Manual, Marking, and Placard Requirements

CTLGroup seeks an exemption from 14 CFR § 91.9(b) which states "(b) No person may operate a

U.S.-registered civil aircraft—(1) For which an Airplane or Rotorcraft Flight Manual is required by

§21.5 of this chapter unless there is available in the aircraft a current, approved Airplane or

Rotorcraft Flight Manual or the manual provided for in §121.141(b); and (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof."

Due to the small size of the sUAS operated by CTLGroup, it is impractical to store manual

materials, markings, and placards onboard the aircraft. CTLGroup will achieve an equivalent level

of safety by keeping the user, maintenance, and operations manuals is possession of the PIC, VO, 

or other designated operations personnel during each flight.

14 CFR § 91.119(c); Minimum Safe Altitudes

CTLGroup seeks an exemption from 14 CFR § 91.119(c) which states "Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over

other than congested areas. An altitude of 500 feet above the surface, except over open water

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500

feet to any person, vessel, vehicle, or structure."

Since FAA rules, and widely accepted sUAS best practices (e.g., the Academy of Model 

Aeronautics Safety Code), require that sUAS operate no higher than 400 feet AGL, CTLGroup 

cannot comply with the 500-foot minimum altitude requirement in 14 CFR § 91.119(c). In addition, 

the requirement that aircraft approach no closer than 500 feet to any person, vessel, vehicle, or structure 

would preclude CTLGroup’s intended use of sUAS for structural inspection and other engineering 

purposes. We believe it is in the public interest to allow sUAS operation near structures or vessels for 

engineering purposes, provided the PIC has assessed that such operation does not pose undue risk, and 

that the structure or vessel owner has granted permission for the sUAS to approach. In many cases, such 

as investigation following major property losses, it would be both safer and less disruptive to use sUAS, 

rather than manned aircraft, for the necessary aerial data collection. For example, use of sUAS provides a 

quiet, clean, and safe alternative to flying noisy manned aircraft, with human operator and large amounts 

of flammable fuel on board, in the already-busy airspace around a catastrophe site (e.g. hurricane 

damage) to obtain imagery. As it is in the national interest to recover from property losses – and thus 

return to normal life – as quickly and efficiently as possible, relief from 14 CFR § 91.119(c) would seem 

to align strongly with the Congressional mandate to incorporate civil sUAS into the NAS.

An equivalentlevel of safety in the spirit of 14 CFR § 91.119(c)will be achieved by approaching structures/vessels 

only with the permission of the owner/controller and taking reasonable measures to exclude nonparticipating 

persons from the flight operations area,as specified by CTLGroup's operations guidelines.
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14 CFR § 91.121; Altimeter Settings

CTLGroup seeks an exemption from 14 CFR § 91.121 which states, in pertinent part, "Each person

operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case

may be, by reference to an altimeter that is set, when operating—(1) Below 18,000 feet MSL,

to—(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate available station; or (iii) In

the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure;"

CTLGroup will achieve an equivalent level of safety by following its sUAS operations guidelines,

which state that prior to each flight, the PIC will determine and document the altitude of the

launch site and calculate the maximum flight altitude allowable such that the sUAS remains within

400 feet AGL during the flight.

14 CFR § 91.151(a); Fuel Requirements for Flight in VFR Conditions

CTLGroup seeks an exemption from 14 CFR § 91.151(a) which states, " (a) No person may begin a

flight in an airplane under VFR conditions unless (considering wind and forecast weather

conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal

cruising speed— (1) During the day, to fly after that for at least 30 minutes;"

The typical flight time as allowed by battery power is 20 minutes for the DJI Phantom 3 and 15

minutes for the 3DRobotics X8-M, making it impossible to comply with this regulation. CTLGroup

will achieve an equivalent level of safety by following its sUAS operations guidelines which

requires the PIC to monitor the remaining battery life of the UAS and by programming the UAS

to automatically return to home if the remaining battery life reaches 25%.

14 CFR § Part 21; Certification Procedures for Products and Parts: Subpart H; Airworthiness

Certificates: 14 CFR § 91.203; Civil Aircraft, Certifications Required

CTLGroup seeks an exemption from 14 CFR § Part 21 Subpart H which prescribes procedural

requirements for the issuance of airworthiness certificates, and 14 CFR § 91.203 which requires

that no person may operate a civil aircraft unless it has within it an appropriate and current

airworthiness certificate, however, while FAA does not currently have a regulatory standard for

determining whether or not a sUAS is airworthy, Section 333 of the Reform Act has granted the 

Secretary the authority to determine which types of UAS, based upon size, weight, speed,

operational capability, etc, do not create a hazard to users of the NAS, the public, or national

security.
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Due to the size, weight, speed, and operational capabilities of the DJI Phantom 3 and 3DRobotics 

X8-M operated by CTLGroup as compared to manned aircraft normally operated for the same

purpose of obtaining high resolution aerial data, an even greater level of safety is achieved.

14 CFR §§ 91.405(a); Maintenance Required: 91.407(a)(1); Operation After Maintenance, 

Preventive Maintenance, Rebuilding, or Alteration: 91.409(a)(1) & (a)(2); Inspections: and

91.417(a) & (b); Maintenance Records;

CTLGroup seeks an exemption from 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b); which collectively, these regulations specify certain procedural requirements for

the maintenance, repair, and inspection of manned aircraft that are issued airworthiness

certificates.

CTLGroup will achieve an equivalent level of safety by following its sUAS operations guidelines

and the manufacturers’ manuals in regards to the maintenance, repairs and inspections, and 

record keeping for the sUAS being operated.

7. Supporting Documentation

Submitted with this petition, as separate documents, are the manufacturers’ manuals for the DJI 

Phantom 3 and 3DRobotics X8-M sUAS.

8. Summary for Publication

CTLGroup

5400 Old Orchard Rd.

Skokie, IL 60077

847-965-7500

www.ctlgroup.com

Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 14 CFR § 61.3; 14 CFR § 61.113(a) & (b); 14 CFR § 61.133; 14 CFR §

91.7(a); 14 CFR § 91.9(b); 14 CFR § 91.119(c); 14 CFR § 91.121; 14 CFR § 91.151(a); 14 CFR § 

Part 21; Subpart H; 14 CFR § 91.203; 14 CFR § 91.405(a); 14 CFR § 91.407(a)(1); 14 CFR §

91.409(a)(1) & (a)(2); 14 CFR § 91.417(a) & (b)

CTLGroup will utilize the DJI Phantom 3 Quadcopter and 3DRobotics X8-M Octocopter for 

aerial data collection for engineering, construction, architecture, real estate, inspection, risk 

management, and related industries.