1701 Towanda Ave. T 866.COUNTRY 

PO Box 2020 www.countryfinancial.com 

Bloomington. IL 61702-2020 Clillli;*tt 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. 

SE Washington, D.C. 20590 

Re: Petition of CC Services, Inc. for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

Dear Sir or Madam: 

CC Services, Inc. (CC Services) hereby applies for an exemption from the Federal Aviation 

Regulations (F ARs) listed below to enable commercial operations of Small Unmanned Aerial 

Systems (sUAS) pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 

(Reform Act) and 14 C.F.R. Part 11. 

CC Services, Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 91.417(a) & (b), and 

such additional statute or regulation as may be necessary to permit CC Services to commercially 

operate sUAS for the purpose of conducting aerial imaging for use in assessing structures and 

crops for insurance functions including: underwriting, claims assessment, roof inspection, 

catastrophic claims assessment, and testing of new imaging methods. The requested exemption is 

similar to those previously granted to other petitioners seeking to utilize sUAS technology. 

This exemption request is made based on the information in this petition as well as the 

accompanying operations manuals for the sUAS to be utilized by CC Services. 

This petition is organized as follows: 

I. Glossary of Abbreviations 

II. Description of Petitioner 

III. Description of sUAS to be utilized under this exemption 

IV. Types of Operations 

V. Regulations from which Exemption is requested 

VI. Federal Register Summary 

VII. Additional information supporting CC Services' request for exemption 

VIII. Conclusion 

CC Services Inc. Section 333 Exemption Request 1 
I. GLOSSARY OF ABBREVIATIONS 

AGL 

ATC 

CFR 

COA 

FAA 

FAR 

FMRA 

GCS 

GPS 

LOL 

MSL 

NAS 

NOT AM 

PIC 

Section 333 

SOP 

sUAS 

UAS 

VFR 

VLOS 

VMC 

vo 

VTOL 

Above Ground Level 

Air Traffic Control 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

FAA Modernization and Reform Act of2012 

Ground Control Station 

Global Positioning System 

Loss of Link 

Mean Sea Level 

National Airspace System 

Notice to Airmen 

Pilot in Command 

FAA Modernization and Refom1 Act of2012 Section 333 

Standard Operating Procedure 

Small Unmanned Aircraft System 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Sight 

Visual Meteorological Conditions 

Visual Observer 

Vertical Takeoff and Landing 

II. Description of Petitioner 

CC Services is a member of the COUNTRY Financial® group of companies. COUNTRY 

Financial is a group of US insurance and financial services companies headquartered in 

Bloomington, Illinois. CC Services provides services to or on behalf of the member companies 

of the COUNTRY Financial group, including the affiliated property and casualty insurance 

companies COUNTRY Mutual Insurance Company®, COUNTRY Preferred Insurance 

Company®, and COUNTRY Casualty Insurance Company®. COUNTRY Financial was 

founded by a group of Illinois fanners in 1925 as a fire and lightning insurance company and has 

grown over 90 years to encompass a wide array of insurance products including: crop, fire, 

home, commercial, and auto insurance. Today, COUNTRY Financial is a $3 billion insurance 

group comprised of eight operating companies with exclusive and independent representatives in 

39 states. 

CC Services requests an exemption to utilize sUAS to conduct aerial imaging to improve the 

accuracy and speed of underwriting insurance risks and assessing insurance claims. Utilizing 

sUAS for aerial imaging enables risk and losses to be evaluated more rapidly and safely than 

current methods by eliminating the need to place employees and/or contractors at risk on ladders, 

on rooftops, and in light aircraft at low altitudes. Applying sUAS technologies will improve the 

service COUNTRY Financial can provide to its nearly I million customers nationwide. 

CC Services Inc. Section 333 Exemption Request 2 
CC Services looks forward to applying sUAS imaging across its product lines for commercial 

use and for internal testing of new types of innovative services. 

Contact infommtion for CC Services: 

Colin Haley 

Office of General Counsel 

1701 Towanda Avenue 

Bloomington, Illinois 61701 

Tel: (309) 557-3139 

Fax: (309) 557-2211 

Email: chaley@ilfb.org 

COUNTRY Financial 

III. Description of sUAS to be Utilized Under this Exemption 

CC Services will operate the included list of sUAS to enable testing of a wide aiTay of imaging 

scenarios, and to conduct commercial imaging flights for insurance purposes. All sUAS listed by 

COUNTRY on this exemption request have maximum weight of less than 55 pounds including 

payload, maximum speed ofless than 87 knots (I OOmph), and will be operated at an altitude of 

no more than 400 feet above ground level. All operations will be conducted within Visual Line 

of Sight (VLOS) of the Pilot in Command (PIC) at all times and will be conducted per the 

operating manual and maintenance manual for each sUAS utilized under the requested 

exemption. 

sUAS to be utilized under this exemption request include: 

I) DJI Phantom 2 

2) DJI Phantom 3 

3) Crop Copter 

4) Precisioni-Iawk Hawkeye Lancaster 

5) 3D Robotics Solo 

Manufacturer's Operating Manuals and Maintenance Manuals have been filed confidentially in 

conjunction with this exemption filing and will be utilized by the PIC for each sUAS. 

Dimensions and exact systems capabilities for each sUAS are included in said manuals. A list of 

the manuals provided as pat1 of this exemption request is listed below and the documentation is 

provided in the appendices: 

List of Appendices containing sUAS Operating and Maintenance Manuals: 

A. CC Services sUAS Operating Manual 

B. DJI Phantom 2 User Manual V1.4- Serves as both Operating Manual and Maintenance 

Manual for DJI Phantom 2 

CC Services !nc. Section 333 Exemption Request 3 
C. DJI Phantom 3 User Manual Vl.O- Serves as both Operating Manual and Maintenance 

Manual for DJI Phantom 3 

D. Crop Copter User Manual v1 

E. PrecisionHawk Hawkeye Lancaster sUAS Aircraft Flight Manual 

F. 3D Robotics Solo User Manual 

Should any of the sUAS manufacturers update their manuals, CC Services will substitute the 

revised manufacturer's documentation to ensure the most recent information is available to the 

PIC, VO, and other personnel involved in operating sUAS. 

CC Services has also developed a set of its own SOPs and checklists to be utilized along with the 

Manufacturer's Operating Manuals. These checklists are included in CC Services' sUAS 

Operating Manual which is filed confidentially with this exemption filing as Appendix A. 

The Precisionl-lawk Lancaster Aircraft Flight Manual makes reference to the PrecisionHawk 

Flight Operations Manual in multiple places. In these cases, the CC Services UAS Operating 

Manual shall be used as the cross-reference for any operations conducted by CC services under 

the requested exemption. 

The sUAS operated by CC Services will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Prut 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification ru1d Registration Marking. 

IV. Types of Operations 

CC Services is requesting exemptions pursuant to Section 333 to conduct imaging ilights v-,'ith 

sUAS for the purposes of testing new services and providing data for assessing risk and damage 

for insurance purposes. Flights will be performed over private property with prior permission 

from the owner, operator, or occupant of the property. 

Testing will be perfmmed at altitudes of 400 feet AGL or less using the sUAS listed in Section 

III which all weigh 551b or less and will all be flown at speeds not to exceed 87kts (lOOmph). 

V. Regulations from which Exemption is requested, Extent of Relief Requested, and 

Reasons \Yhy granting the request are in the public interest and will not adversely 

affect safety: 

In accordance with 14 C.P.R.§ 11.81, CC Services provides the following infom1ation in 

support of its petition for exemption: 

A. Name And Address Of The Petitioner: 

The name and address of the Petitioner is: 

CC Services, Inc. 

1701 Towanda Avenue, 

Bloomington, Illinois 61701 

CC Services !nc. Section 333 Exemption Request 4 
The point of contact for this Petition and specific contact information is as follows: 

Colin Haley 

Office of General Counsel 

1701 Towanda Avenue 

Bloomington, 1Jiinois 61701 

Tel: (309) 557-3139 

Fax: (309) 557-2211 

Email: chaley@iltb.org 

B. The specific sections of 14 C.F.R. from which CC Services seeks exemption, the extent 

of such requested exemptions, and the reasons for each exemption are as follows: 

I. CC Services seeks exemption from the requirements of Section 61.23 (a) and (c). 

Section 61.23 (a) and (c) entitled Medical Certificates: Requirement and Duration, state 

the following: 

(a) Operations requiring a medical certificate. Except as provided in paragraphs 

(b) and (c) of this section, a person-

(I) Must hold a first-class medical ce1tificate: 

(i) When exercising the pilot-in-command privileges of an airline 

transport pilot certificate; 

(ii) When exercising the second-in-command privileges of an 

airline transport pilot ce1tificate in a flag or supplemental operation 

in part 121 of this chapter that requires three or more pilots; or 

(iii) When serving as a required pilot flightcrew member in an 

operation conducted under part 121 of this chapter if the pilot has 

reached his or her 60th birthday. 

(2) Must hold at least a second class medical certificate when exercising: 

(i) Second-in-command privileges of an airline transport pilot 

certificate in part 121 of this chapter (other than operations 

specified in paragraph (a)(l)(ii) of this section); or 

(ii) Privileges of a commercial pilot cet1ificate; or 

(3) Must hold at least a third-class medical certificate-

(i) When exercising the privileges of a private pilot certificate; 

(ii) When exercising the privileges of a recreational pilot 

ce1tificate; 

(iii) When exercising the privileges of a student pilot certificate; 

(iv) When exercising the privileges of a flight instructor certificate 

and acting as the pilot in command; 

(v) When exercising the privileges of a flight instructor certificate 

CC Services Inc. Section 333 Exemption Request 5 
and serving as a required pilot flight crewmember; 

(vi) When taking a practical test in an aircraft for a recreational 

pilot, private pilot, commercial pilot, or airline transport pilot 

certificate, or for a flight insh·uctor certificate; or 

(vii) When performing the duties as an Examiner in an aircraft 

when administering a practical test or proficiency check for an 

airman certificate, rating, or authorization. 

(c) Operations requiring either a medical certiJicate or U.S. driver's license. 

(1) A person must hold and possess either a medical ce11ificate issued 

under part 67 of this chapter or a U.S. driver's license when-

(i) Exercising the privileges of a student pilot certificate while 

seeking sport pilot privileges in a light-sport aircraft other than a 

glider or balloon; 

(ii) Exercising the privileges of a sport pilot CCI1ificate in a lightsport aircraft other than a glider or balloon; 

(iii) Exercising the privileges of a flight instructor certiJicate with a 

sport pilot rating while acting as pilot in command or serving as a 

required night crewmember of a light-sport aircraft other than a 

glider or balloon; or 

(iv) Serving as an Examiner and administering a practical test for 

the issuance of a sport pilot certificate in a light-sport aircraft other 

than a glider or balloon. 

(2) A person using a U.S. driver's license to meet the requirements of this 

paragraph must-

(i) Comply with each restriction and limitation imposed by that 

person's U.S. driver's license and any judicial or administrative 

order applying to the operation of a motor vehicle; 

(ii) Have been found eligible for the issum1ce of at least a third~ 

class ainnan medical certificate at the time of his or her most 

recent application (if the person has applied for a medical 

certificate); 

(iii) Not have had his or her most recently issued medical 

certificate (if the person has held a medical certificate) suspended 

or revoked or most recent Authorization for a Special Issuance of a 

Medical Certificate withdrawn; and 

(iv) Not know or have reason to know of any medical condition 

that would make that person unable to operate a light-sport aircraft 

in a safe manner. 

CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to 

enable the PIC of an sUAS to satisfY the requirement for current medical certification for 

commercial operation of a sUAS with either: a ctment FAA airman medical certificate; 

or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a 

tenitory, a possession, or the Federal government. 

CC Services Inc. Section 333 Exemption Request 6 
SUAS have unique characteristics that enable the PIC to very rapidly address any in1light 

emergencies involving either the PIC or equipment. These characteristics include: light 

weight, slow speed, short range VLOS operations, and capability of landing safely in a 

wide variety of locations. The requested sUAS operations will offer enhanced safety 

when compared with aerial imaging conducted with manned aircraft. 

2. CC Services seeks exemption from the requirements of Section 61.113 (a) and (b). 

Section 61.113, entitled Private Pilot privileges and !imitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if.-

(l) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

CC Services seeks substantially similar relief to that granted in prior 333 Exemptions, to 

enable the holder of a Private Pilot certificate to operate a sUAS for commercial 

purposes. The reduced risk associated with the operation of a sUAS weighing less than 

551bs and the lack of passengers or crew onboard the sUAS, enable increased levels of 

safety when compared to aerial imaging with manned aircraft. The FAA has the authority 

to waive pilot requirements for commercial operations under 49 U.S.C. 44701(1). 

3. CC Services seeks exemption from the requirements of Section 91.7 (a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

Relief from Section 91.7(a) entitled Civil Aircraft Airworthiness, is requested to the 

extent required to allow CC Services to determine that the sUAS listed in this exemption 

filing is in an airworthy condition prior to every flight by ensuring that: the sUAS is in 

compliance with the manufacturer's recommended maintenance procedures, the sUAS 

undergoes a fw1ctional test flight after maintenance or alterations are performed, and that 

the aircraft is in a condition for safe flight. 

CC Services seeks the requested relief because the sUAS listed in this exemption filing 

does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

CC Services Inc. Section 333 Exemption Request 7 
Subprut H. The combination of the sUAS being unmanned and their tight weight, will 

achieve an equivalent or better level of safety when compared to manned aerial imaging 

aircraft. 

4. CC Services seeks exemption from the requirements of Section 91.119 (c). 

Section 91.119 (c). entitled Minimum Safe Altitudes: General, states the following in 

part: 

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

(a) Anywhel'e. An altitude allowing, if a power unit fails, an emergency 

landing without tmdue hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 

I ,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of500 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. 

CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to 

enable flight closer than 500 feet to nonparticipating persons, vessels, vehicles, and 

structures if the following criteria are satisfied: 

(a) BruTiers or structures are in place that sufficiently protect nonparticipating 

persons from the sUAS in the event of an accident; and/or 

(b) The ov.ner/controller of any vessels, vehicles, or structures has granted 

pem1ission for operating closer to those objects and the PIC assesses that 

operation closer to those objects does not present an undue hazard. 

Due to the light weight ofsUAS and their low speed compared with manned aircraft used 

for aerial imaging, CC Services can achieve an equivalent or better level of safety when 

operating sUAS under the conditions requested. 

5. CC services seeks exemption from the requirements of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in patt: 

(a) Each person operating atl 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--

CC Services Inc. Section 333 Exemption Request 8 
(I) 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)(l)(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 airpmi or an appropriate altimeter setting 

available before depmture. 

Relief from Section 91.121, entitled Altimeter settings, is required to allow flight 

operations of the sUAS listed in this exemption filing, which utilize a combination of 

barometric pressure sensors, GPS equipment, and radio conununications telemetry to 

determine altitude. CC Services seeks the requested relief because the sUAS to be 

operated do not utilize a typical barometric altimeter on board that may be set as 

contemplated by Section 91.121. 

The combination of methods of determining altitude combined with the flight being 

conducted with reference to height AGL and not MSL, enable an equivalent level of 

safety to conventional means of dete1mining altitude with a barometric altimeter. 

6. CC Services seeks exemption from the requirements of Section 91.151 (a) and (b). 

Section 9 L 151, entitled Fuel requirements for flight in VFR conditions, subsections (a) 

and (b), state the following: 

(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-

( I) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

(b) No person may begin a flight in a rotorcraft 1.mder 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, to fly 

after that for at least 20 minutes. 

CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to 

operate sUAS with enough available 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, whichever one is greater. 

CC Services Inc. Section 333 Exemption Request 9 
Given the light weight, small size, and relatively short flight times of sUAS; and in 

consideration of the fact that sUAS can be landed safely in a very small landing area on 

very short notice; an equivalent or greater level of safety is present when operating sUAS 

with the proposed reserve power when compared to a manned aircraft operating with 

VFR minimum fuel requirements. 

7. CC Services seeks exemption from the requirements of Section 9l.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft~ 

(a) Shall have that aircraft inspected as prescribed in subpart E of this pm1 and 

shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter. 

CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to 

follow the maintenance procedures recommended by the mmmfacturer of the sUAS, since 

the sUAS to be operated do not have ai1wm1hiness certificates. The light weight sUAS 

listed in this exemption request pose an equivalent or lower risk to the public than a low~ 

flying mmmed aerial imaging aircraft. 

8. CC Services seeks exemption from the requirements ofSection91.407(a)(1), Section91 .409 

(a) (I) and (2), and Section 91.417 (a) and (b). 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration tmless~-

(1) It has been approved fOr return to service by a person authorized under 

§ 43.7 of this chapter 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has bad--

(1) An annual inspection in accordance with pru1 43 of this chapter and 

has been approved for return to service by a person authorized by § 43.7 

of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

Section 91.417, entitled Maintenm1ce records, subsections (a) ru1d (b), state the following: 

CC Services Inc. Section 333 Exemption Request 10 
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(I) Records of the maintenance. preventive maintenance, and alteration 

and records of the 100-hour, annual, pl"ogressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the 

Administrator) of the work perfonned; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving 

the aircraft for return to service. 

(2) Records containing the following infmn1ation: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified time 

basis. 

(iv) The cunent inspection status ofthe aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The cunent status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. 

If the AD or safety directive involves recurring action, the time and 

date when the next action is required. 

(vi) Copies of the fmms prescribed by§ 43.9(d) of this chapter for 

each major alteration to the airframe and cunently installed 

engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

CC Services lnc. Section 333 Exemption Request 11 
(1) The records specified in paragraph (a)(l) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transfened with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 

43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to 

perform the sUAS manufacturer's maintenance, overhaul, replacement, inspection, and 

life limit requirements on the aircraft and its components without necessitating the 

approvals required in Section91.407 or the annual inspections specified in Part 43. 

The maintenance procedures for the sUAS to be operated under the requested exemption 

are substantially different than the maintenance for manned aircraft and are best 

understood by the manufacturer of the sUAS. Following the manufacturer's 

recommendations; when combined with the light weight, slow speed, and short range 

operations of the sUAS; will deliver an equivalent or increased level of safety when 

compared to conventional manned aircrail used for aerial imaging. 

9. Certificate of Authorization- CC Services also seeks a standing COA for ongoing operations 

in Class G airspace for flight at or below 200 feet AGL and more than 5 miles from the nearest 

charted airport, as has recently been granted to other operators utilizing 333 Exemptions for 

sUAS. Operations in this designated airspace pose a low risk to the general public and other 

rnrumed air traffic. 

10. CC Services welcomes additional guidance from the FAA to prescribe other conditions it 

deems appropriate for safe operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) 

and 14 C.F.R. § 21.16 entitled Special Conditions, CC Services requests that the FAA prescribe 

special conditions for the intended operation of the SUAS listed in this exemption filing, which 

contain such safety stru1dru·ds as the Adminish·ator finds appropriate to establish a level of safety 

equivalent to that established by 14 C.P.R. Parts §§ 61.23 (a) & (c), 6l.ll3(a) & (b), 91.7 (a). 

9l.ll9 (c), 9l.l2l, 91.151 (a) & (b), 9l.405(a), 91.407(a)(l ), 91.409(a)( l) & (a)(2), and 

9l.4l7(a) & (b). 

Such special conditions will enable CC Services's safe operation of the sUAS for the purpose of 

conducting aerial imaging in suppmi of insurance assessment, claims, adjustment, and R&D for 

new services. 

CC Services Inc. Section 333 Exemption Request 12 
B. Summary for publication in the Federal Register, stating: The Rules From Which CC 

Services Seeks Exemption: 

The following summary may be used in the Federal Register to state the rules from which CC 

Services seeks exemption: 

CC Services, Inc. seeks exemption from the requirements of 14 C.F.R. Parts§§ 61.23 (a) 

& (c), 61.113(a) & (b), 91.7 (a), 91.119 (c), 91.121, 91.151 (a) & (b), 9l.405(a), 

91.407(a)(1 ), 9l.409(a)(1) & (a)(2), and 91.417(a) & (b). 

The requested exemption will enable CC Services, Inc. to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial imaging for 

insurance purposes including: accelerating assessment of catastrophic damage, increasing 

efficiency of evaluating crop insurance claims, safely evaluating the condition of 

rooftops, and performing R&D on innovative future insurance products. 

VII. Additional information in support of CC Services, request. 

C01is Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to detem1ine if certain UAS may 

operate safely in the NAS. 

FMRA Section 333 sets forth the requirements for evaluating whether a sUAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

fm1her, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, CC Services will operate the sUAS listed in this exemption filing 

safely within the NAS, without creating a hazard to users of the NAS, or the public; and without 

posing a threat to national security. 

VIIL CONCLUSION 

As set fotih herein, CC Services seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of2012 (FMRA), which will pennit safe 

commercial operation of the sUAS listed in this exemption filing, for purposes including: 

conducting aerial imaging for insurance purposes including: accelerating assessment of 

catastrophic damage, increasing efficiency of evaluating crop insurance claims, safely evaluating 

the condition of property and rooftops, and performing R&D on innovative future insurance 

products. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modemization and Reforn1 Act of 2012, while also advancing the interests of the 

public, by allowing CC Services to safely, efficiently, and economically operate the SUAS listed 

in this exemption filing commercially within the NAS. 

CC Services Inc. Section 333 Exemption Request 13 
CC Services respectfully requests that the Administrator grant this Petition for an exemption 

from the requirements of 14 C.P.R. Parts §§ 61.23 (a) & (c), 61.113(a) & (b), 91.7 (a), 91.119 

(c), 91.121,91.151 (a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), 91.417(a) & (b) and 

such additional statute or regulation as may be necessary to permit CC Services to commercially 

operate sUAS for the purpose of conducting aerial imaging for use in assessing structures and 

crops for insurance functions including: underwriting, claims assessment, roof inspection, 

catastro 1ic claims assessment, and testing of new imaging methods .. 

Sheri Bane, Vice President 

Commercial Lines & Agribusiness Operations 

Dated: 6/25/15 

CC Services Inc. Section 333 Exemption Request 14 
Appendix A- CC Senrices sUAS Operating Manual Revision 0.1 

Appendices B through G: 

B. DJI Phantom 2 User Manual VIA- Serves as both Operating Manual and Maintenance 

Manual for DJI Phantom 2 

C. DJI Phantom 3 User Manual Vl.O- Serves as both Operating Manual and Maintenance 

Manual for DJI Phantom 3 

D. Crop Copter User Manual VI 

E. PrecisionHawk Hawkeye Lancaster sUAS Aircraft Flight Manual 

F. 3D Robotics Solo User Manual 

CC Services Inc. Section 333 Exemption Request 15