UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

PETITION FOR AMENDMENT TO GRANT OF EXEMPTION NO. 11566

BY CDM SMITH, INC.

Submitted on September 10, 2015

GREGORY S. WINTON, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner
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Petitioner, CDM Smith, Inc. (“CDM Smith”), by and through undersigned counsel, 

pursuant to the provisions of the Federal Aviation Regulations and the Federal Aviation 

Administration (“FAA”) Modernization and Reform Act of 2012, Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator for an amendment to the 

conditions and limitations of Grant Of Exemption No. 11566 (Regulatory Docket No. FAA2015-0040), which granted to CDM Smith an exemption from 14 CFR §§ 61.23(a) and (c), 

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent necessary to allow the 

petitioner to operate a DJI Phantom 2 Vision UAS to perform aerial data collection. 

Specifically, CDM Smith seeks an amendment to Exemption No. 11566 to the extent 

necessary to allow CDM Smith to operate the following UAS under Exemption No. 11566:

 3D Robotics Aero-M

 3D Robotics X8

 DJI Phantom 3

 DJI S1000 

 DJI S900

 DJI S800

 DJI Inspire 1 

 DJI Flame Wheel 450

 DJI Flame Wheel 550 

 DJI Matrice 100

 SenseFly eBee

 SteadiDrone Flare

 CDM Smith submits that operation of the aforementioned UAS under the conditions and 

limitations set forth in Exemption No. 11566 will maintain the safety of the National Airspace 

System (“NAS”), as well as the safety of persons or property on the ground.
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In support thereof, CDM Smith states as follows:

Unmanned Aircraft Systems

CDM Smith, Inc. seeks an amendment to operate the additional UAS listed below for 

compensation or hire within the NAS pursuant to Paragraph 1 of the Conditions and Limitations 

section of Exemption No. 11566. All of the proposed UAS have been the subject of previous 

Grants of Exemption and are in all material respects similar to the Phantom 2 Vision UAS. The 

proposed UAS were previously granted exemption as follows:

 3D Robotics Aero-M (Exemption No. 11393A on July 20, 2015)

 3D Robotics X8 (Exemption No. 12366 on August 6, 2015)

 DJI Phantom 3 (Exemption No. 12294 on August 3, 2015)

 DJI S1000 (Exemption No. 12370 on August 6, 2015)

 DJI S900 (Exemption No. 12370 on August 6, 2015)

 DJI S800 (Exemption No. 12370 on August 6, 2015)

 DJI Inspire 1 (Exemption No. 12377 on August 6, 2015)

 DJI Flame Wheel 450 (Exemption No. 11813 on June 16, 2015)

 DJI Flame Wheel 550 (Exemption No. 11813 on June 16, 2015)

 DJI Matrice 100 (Exemption No. 11814 on June 16, 2015)

 SenseFly eBee (Exemption No. 12369 on August 6, 2015)

 SteadiDrone Flare (Exemption No. 11446 on April 29, 2015)

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

CDM Smith, Inc.

50 Hampshire Street

Cambridge, Massachusetts 02139
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The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com

B. CDM Smith Seeks To Amend Condition and Limitation No. 1 Of Grant Of 

Exemption No. 11566.

Condition and Limitation No. 1 of Exemption No. 11566 states the following:

Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

Exemption No. 11566 at page 3, ¶1.

C. Extent Of The Amendment That CDM Smith Seeks And The Reason CDM Smith

Seeks To Amend Condition And Limitation No. 1.

CDM Smith submits that Condition and Limitation No. 1 be amended as follows:

Operations authorized by this grant of exemption are limited to the 3D Robotics 

Aero-M, 3D Robotics X8, DJI Phantom 2 Vision, DJI Phantom 3, DJI S1000, DJI 

S900, DJI S800, DJI Inspire 1, DJI Flame Wheel 450, DJI Flame Wheel 550, DJI 

Matrice 100, SenseFly eBee, and SteadiDrone Flare when weighing less than 55

pounds including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this exemption. 

This relief is requested because CDM Smith’s original Petition For Exemption 

(Regulatory Docket No. FAA-2015-0040) did not request that operation of the UAS proposed in 

this Petition be allowed under the Exemption. However, CDM Smith offers that it may safely 

operate the proposed UAS under the same Conditions and Limitations set forth in Exemption 

No. 11566 for the Phantom 2 Vision UAS.

D. The Reasons Why Granting CDM Smith’s Request For Amendment Would Be In 

The Public Interest; That Is, How It Would Benefit The Public As A Whole.
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Granting the present petition for amendment will further the public interest as set forth by 

the Administrator in Exemption No. 11566. As the Administrator held on page 2 of Exemption

No. 11566, the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) 

with the specifications described by the petitioner and carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this 

exemption is in the public interest. Further, there has been no change in the conditions and 

reasons relative to the public interest and safety that were the basis for granting the original 

exemption.

CDM Smith’s proposed amendment not only furthers the public’s interest as set forth by 

the Administrator in Exemption No. 11566, it also is another step forward in fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, by allowing CDM 

Smith to safely, efficiently, and economically operate the proposed UAS commercially within 

the NAS.

E. The Reasons Why Granting An Amendment To Condition And Limitation No. 1

Would Not Adversely Affect Safety.

CDM Smith proposes that it may safely operate the proposed UAS within the NAS

because they are in all material respects similar to the Phantom 2 Vision UAS and will be 

operated pursuant to the same Conditions and Limitations set forth in Exemption No. 11566.

F. A Summary That Can Be Published In The Federal Register.

CDM Smith submits that good cause exists for not publishing a summary of this petition 

for amendment in the Federal Register because the requested amendment to Exemption No. 

11566 would not set a precedent, and any delay in acting on this petition would be detrimental to 

the petitioner. The Phantom 2 Vision UAS authorized in the original grant of exemption is 
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comparable in type, size, weight, speed and operating capabilities to the proposed UAS and all of 

the proposed UAS have been the subject of previous Grants of Exemption.

G. Any Additional Information, Views, Or Arguments Available To Support CDM 

Smith’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

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

operate safely in the NAS. As such, CDM Smith’s request for amendment may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. The 

respective operating documents for the proposed UAS are attached hereto as the following 

Exhibits: 3D Robotics Aero-M Operating Documents-(A) Aero-M Operations Manual, (B) AeroM Specs; 3D Robotics X8 Operating Documents-(C) X8 Operations Manual, (D) X8 Checklist; 

DJI Phantom 3 Operating Documents-(E) Phantom 3 Professional User Manual, (F) Phantom 3 

Professional Quick Start Guide, (G) Phantom 3 Professional Safety Guidelines Disclaimer; DJI 

S1000 Operating Documents-(H) S1000 User Manual, (I) DJI A2 Flight Controller Manual; DJI 

S900 Operating Documents-(J) S900 User Manual, (I) DJI A2 Flight Controller Manual; DJI 

S800 Operating Documents-(K) S800 User Manual, (I) DJI A2 Flight Controller Manual; DJI 

Inspire 1 Operating Documents-(L) Inspire 1 User Manual, (M) Inspire 1 Maintenance Manual, 

(N) Inspire 1 Quick Start Guide, (O) Inspire 1 Safety Guidelines; DJI Flame Wheel 450

Operating Documents-(P) Flame Wheel 450 User Manual, (I) DJI A2 Flight Controller Manual; 

DJI Flame Wheel 550 Operating Documents-(Q) Flame Wheel 550 User Manual, (I) DJI A2 

Flight Controller Manual; DJI Matrice 100 Operating Documents-(R) Matrice 100 User Manual, 

(I) DJI A2 Flight Controller Manual; SenseFly eBee Operating Documents-(S) eBee Extended

User Manual; and SteadiDrone Flare Operating Documents-(T) Flare Product Sheet, (U) 3D 

Robotics Pixhawk Autopilot Manual.
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CONCLUSION

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, CDM Smith respectfully requests that the 

Administrator grant this Petition for an amendment to Exemption No. 11566 to the extent 

necessary to allow CDM Smith to operate the 3D Robotics Aero-M, 3D Robotics X8, DJI 

Phantom 3, DJI S1000, DJI S900, DJI S800, DJI Inspire 1, DJI Flame Wheel 450, DJI 

Flame Wheel 550, DJI Matrice 100, SenseFly eBee, and SteadiDrone Flare in addition to the 

Phantom 2 Vision UAS under the Conditions and Limitations originally set forth in 

Exemption No. 11566.

Dated: September 10, 2015

Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton 

Gregory S. Winton, Esq.

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner