www.csmgroup.com

444 W. Michigan Avenue

Suite 100

Kalamazoo, MI 49007

PH: 269.746.5600

FAX: 269.746.5699

600 Monroe Ave. NW

Suite 104

Grand Rapids, MI 49503

PH: 616.458.5600

FAX: 616.458.6099

1111 N. 13th Street

Suite 105

Omaha, NE 68102

PH: 402.342.4593

June 15, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: CSM Group Request for Exemption Under Title 14 CFR, Section 333

To Whom It May Concern:

CSM Group is a construction management firm with national experience managing projects of 

all sizes. Since our inception in 1983, our history, combined with our extensive knowledge of 

today’s ever-changing demands, allows us to deliver the best solutions for our clients.

Our construction management experts provide transparent, collaborative solutions and 

represent our clients’ best interests from project design to completion. Our portfolio of 

construction experience includes managing projects within the regulated and specialized 

environments of our healthcare, food and beverage, industrial/manufacturing, education, 

advanced technologies, and commercial market segments.

Through community involvement, sustainable business practices, proactive safety initiatives, 

and unwavering integrity, we are steadfast advocates for our clients, our employees, and the 

communities in which we work.

As a construction management firm, CSM Group is required to perform many different 

inspections on the outside of existing buildings, as well as monitor active construction sites for 

safety and quality assurance purposes. These inspections validate the construction techniques 

and procedures, and often require our employees to be put in situations that require CSM 

Group to accept risk. We have found that by using a “small Unmanned Aircraft System” (sUAS) 

with a high-resolution camera mounted on it, often times we can accomplish the same 

inspections and alleviate the need to put our employees in danger.

CSM Group shares Congress’ goal of getting sUAS flying commercially in the United States safely 

and soon. In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to 

safely accelerate the integration of civil unmanned aircraft systems in the National Airspace 

System” and, under Section 333 of that law, gave the FAA the power to grant innovators 

“expedited operational authorization” to do so. By this petition, CSM Group is seeking 

authorization to conduct sUAS operations on our own construction sites in order to improve the 

safety of our employees and ensure quality assurance for the projects we are managing.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 CFR 

Part 11, CSM Group (“Petitioner”) requests exemption from several provisions of the Federal 

Aviation Regulations (“FAR”). Specifically, portions of 14 CFR Parts 21, 27, 45, 61, and 91 to 

allow, among other things, the use of the sUAS – DJI Phantom 3 Professional – in the National 
www.csmgroup.com

444 W. Michigan Avenue

Suite 100

Kalamazoo, MI 49007

PH: 269.746.5600

FAX: 269.746.5699

600 Monroe Ave. NW

Suite 104

Grand Rapids, MI 49503

PH: 616.458.5600

FAX: 616.458.6099

1111 N. 13th Street

Suite 105

Omaha, NE 68102

PH: 402.342.4593

Airspace System (“NAS”) by knowledged individuals in all regulations and operations of aircraft 

according to FAA regulations.

Information Supporting this Petition as Specified in 14 CFR §11.81

A. Petitioner information

CSM Group, Inc. – Corporate Headquarters

444 W. Michigan Avenue, Suite 100

Kalamazoo, MI 49007

Phone: 269-746-5600

Fax: 269-746-5699

Contact: Katrina Reed, CIT, LEED® Green Associate

katrina.reed@csmgroup.com

269-929-5462

B. Specific section or sections of 14 CFR from which CSM Group seeks exemption

14 CFR Part 21 Subpart H

14 CFR Part 27

14 CFR 45.23(b)

14 CFR 45.27

14 CFR 61.113(a) and (b)

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) 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)

C. The extent of relief CSM Group seeks, and the reason CSM Group seeks the relief

If granted the above exemptions, CSM Group will operate the sUAS with the property 

owner’s permission. CSM Group intends to use the sUAS for the following activities:

Surveying hard to reach areas of buildings and/or construction sites

Roof inspections

Building exterior envelope inspections

Visual documentation of existing conditions before demolition of key areas

Visual documentation of existing site conditions before, during, and after 

construction

Quality Control / Quality Assurance inspections
www.csmgroup.com

444 W. Michigan Avenue

Suite 100

Kalamazoo, MI 49007

PH: 269.746.5600

FAX: 269.746.5699

600 Monroe Ave. NW

Suite 104

Grand Rapids, MI 49503

PH: 616.458.5600

FAX: 616.458.6099

1111 N. 13th Street

Suite 105

Omaha, NE 68102

PH: 402.342.4593

Aerial photography / videography of construction site and project progress for 

marketing purposes

D. The reasons why granting CSM Group’s request would be in the public interest; that is, how it 

would benefit the public as a whole

Granting CSM Group’s request would benefit the public by giving CSM Group a capable risk 

mitigated inspection platform. The proposed sUAS gives CSM Group an alternative to 

sending our employees and sub-contractors into dangerous situations, or placing large 

construction equipment next to or near occupied building spaces in order to accomplish 

necessary and required construction inspections. This in turn could help prevent on-site 

accidents and/or construction related deaths. At CSM Group, our motto is “lead with 

safety,” and this would have a positive trickledown effect to the families of our employees 

and sub-contractors that work on our sites, which ultimately benefits the public.

E. The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule for 

which CSM Group seeks the exemption

The following operating procedures will apply during the sUAS inspection operations under 

this exemption request:

1. The sUAS that CSM Group has chosen to work with (DJI Phantom 3 Professional) has 

an operational weight of 2.82 pounds and will be powered via a battery source. CSM 

Group will only use a sUAS that is below 4.4 pounds now and in the future if these 

exemptions are granted.

2. CSM Group inspection operations will be conducted:

a. within the visual line of sight of the Pilot in Command (PIC) and one or more 

Visual Observers (VO).

b. at less than 400 feet AGL.

c. within Class G airspace.

3. CSM Group inspection operations will be conducted in a confined area over isolated 

private property located at least 5 miles away from any airport, heliport, seaplane 

base, spaceport, or other location with aviation activities, and any military or U.S. 

government facilities or airfields. If we are within the 5-mile radius of any of the 

above installations, CSM Group will seek written approval from that installation’s 

owner before sUAS inspection operations take place. If said installation owner 

requires stricter guidelines for operations, then CSM Group will comply.

4. All sUAS operations will remain within the lateral and vertical boundaries of the 

operating area, taking into account all factors, including wind, gross weight, and 

glide distances, that may affect the capability of the sUAS to remain within the 

airspace boundary; moreover, the ceiling height will be no more than 400 feet AGL.
www.csmgroup.com

444 W. Michigan Avenue

Suite 100

Kalamazoo, MI 49007

PH: 269.746.5600

FAX: 269.746.5699

600 Monroe Ave. NW

Suite 104

Grand Rapids, MI 49503

PH: 616.458.5600

FAX: 616.458.6099

1111 N. 13th Street

Suite 105

Omaha, NE 68102

PH: 402.342.4593

5. CSM Group sUAS inspection operations under this exemption will be conducted 

under the supervision of the designated PIC who ultimately has final responsibility 

for the operation in accordance with 14 CFR 91.3.

6. The PIC will maintain the sUAS in a condition safe for operation and conduct a preflight inspection prior to each flight to ensure that the sUAS, control station, data 

link equipment, camera, and support equipment are in a condition safe for 

operation and in a configuration appropriate for the purpose of the intended flight.

7. The PIC and VO will maintain two-way communications with each other during all 

operations; if unable to maintain two-way communications, or if any condition

occurs that may otherwise cause the operation to be unsafe, the operator will 

immediately conclude the operation.

8. Each sUAS that CSM Group will employ under this exemption will safely return 

automatically to a home location designated by the PIC if the communication link is 

lost.

9. The aircraft documentation required by 14 CFR §§ 91.9 and 91.203(b), as applicable, 

will be available to the PIC referred to above at any time CSM Group sUAS are 

operating.

CSM Group will effectively operate under our own standard operating procedures that will 

provide additional safeguards that go far beyond the level of safety for public model airplane 

fields.

F. A summary the FAA can publish in the Federal Register, stating: (1) The rule from which you 

seek the exemption; and (2) A brief description of the nature of the exemption you seek.

1. Petitioner: CSM Group, Inc.

2. Sections of 14 CFR Affected: §§ Part 21, Subpart H; 45.23(b); 45.27; 61.113(a) and 

(b); 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 

91.409(a)(1) and (2); and 91.417(a) and (b)

3. Description of Relief Sought: Petitioner seeks relief from the requirements of 14 CFR 

§§ Part 21, Subpart H; 45.23(b); 45.27; 61.113(a) and (b); 91.119; 91.121; 91.151(a); 

91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); and 91.417(a) and 

(b) in order to conduct commercial small unmanned aircraft system operations on 

construction sites with owner approval subject to operating procedures that meet 

or exceed those that FAA requires for similar operations.

G. Any additional information, views, or arguments available to support your request

Please refer to the introduction of this exemption request for specific supporting 

information.
www.csmgroup.com

444 W. Michigan Avenue

Suite 100

Kalamazoo, MI 49007

PH: 269.746.5600

FAX: 269.746.5699

600 Monroe Ave. NW

Suite 104

Grand Rapids, MI 49503

PH: 616.458.5600

FAX: 616.458.6099

1111 N. 13th Street

Suite 105

Omaha, NE 68102

PH: 402.342.4593

H. If you want to exercise the privileges of your exemption outside of the United States, 

the reason why you need to do so

At this time, CSM Group does not wish to exercise the privileges of this exemption 

outside of the United States.

Thank you for your consideration, and I look forward to your response. If you require 

additional information, please do not hesitate to contact me via cell at 269-929-5462.

Respectfully yours,

Katrina Reed, CIT, LEED® Green Associate

Content Strategist

CSM Group

444 W. Michigan Avenue, Suite 100

Kalamazoo, MI 49007

Direct: 269-488-6628

Cell: 269-929-5462

E-mail: katrina.reed@csmgroup.com