July 31,2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, D.C. 20590 Reference: CIS Group ofCompanies, LLC. Petition for Section 333 Exemption: Re: Research & Development ofMethods to Use Small Unmanned Aircraft Systems in Property and Casualty Insurance Dear Sir orMadam: Pursuantto Section 333 ofthe FAAModernization and ReformAct of2012 (FMRA) and 14 C.F.R. Part II, CIS Group ofCompanies, LLC (Petitioner orCIS) is petitioning for an exemption from the Federal Aviation Regulations ("FARs") and otherrules/statutes pertainingto small Unmanned Aircraft Systems ("UAS") to conductresidential property inspections with an emphasis on roofconditions. The requested exemption would permittbe operation ofthe UAS to obtain up-close images ofroofs and perform an indepth analysis ofthe images to determine the nature and extent ofdamage to the roofsurface without placing claim adjusters or.inspectors at risk. The CIS representative will be able topromptly share the report and inspection images with our client to reduce claim paymenttime. Section 333 ofthe FMRA addresses special rules for certain UAS and grants the FAA authority to allow for the safe operation of certain UAS within the national airspace. CIS launched as a risk management company in 1997 and has since grownto becomethe largest supplier offield underwriting and inspection supply chain services in the United States. Each day our more than 1,000employees and independently contracted vendors serve the inspection, claim handling and technology needs ofmore than 125 clients in the underwriting, claims and mortgage services sectors. CIS focuses its innovation ondeveloping products and newtechnology to assist its clients from policy inception to fulfilling our service commitment during a claims event. Each ofCIS's clients look to CIS to help their insureds restore and rebuild after a wide range ofnatural and otherdisasters, as well as ensure the quality oftheir underwriting book. CIS is always seeking ways to improve the timing and quality of its responsesto its clients' needs: Property and casualty insurers play a majorrole in funding the restoration ofbusinesses and communities aftermajor incidents, andthe integration ofunmanned aircraft into CIS UAS operations will have immediate, positive effects on the lives ofAmericans and the business community. I. REQUEST FOREXEMPTION TOUSE UAS FORROOF INSPECTIONS A. Overview ofRequest to Use UAS for Rooflnspections CIS proposes to conductroofinspections using small UAS includingthe DJI Phantom 2+ and/orthe 3D Robotics X8-M multi-rotorquad copters. As described more fully below, the requested exemption would permitthe operation ofsmall UAS under controlled conditions in airspace that is I) limited, 2) predetermined, and 3) controlled as to access. Operations will be limited to the customer's property and always occurwithin the line ofsight ofthe UAS operator. The property ownerwill be notified in advance ofthe date and time for inspection. The customer's privacy and their neighbors' privacy will be fully protected. CIS's use ofUAS forroofinspections does not create a hazard to users ofthe national airspace orthe public or pose a threat tonational security.

1Federal Aviation Administration 7/31/15 Page 2 Grant ofthis request is warranted as use ofUAS will improve safety for CIS's claim representatives and inspectors (hereinafter CIS representative orrepresentative). Currently, CIS representatives must physically climb onto a policyholder's roofusing ladders for inspection. Inspectingroofs is dangerous as evidencedby annual industrywide worker compensation claims due to falls while performingthis task. By utilizing UAS, CIS representatives will be able to reduce their exposure tohazards and obtain accurate assessments ofthe roofwhile remaining safely on the ground. Additionally, CIS representatives will be able to capture a full view ofthe roofwhich is currently not feasible in certain instances (multi-level and severe pitch dwellings). 

### II. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST CIS shares Congress's vision ofintegrating small UAS for civil use in to our national airspace and providing economic benefits and growth from this rapidly developing technology. Current law does not provide adequate authority to extendthese research and development activities, and this application seeks interim authority from the FAA to allow CIS to pursuethese activities it began researching in 2014. In addition, the Federal Aviation Act expressly grants the FAAthe authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under§ 40l0I of the Act, that includes UAS, from the requirementthat all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulationprescribed under§§ 4470l(a) or (b) or in§§ 44702-44716 ofthe Act ifthe Administrator finds the exemption in the public interest. Obtaining a Section 333 exemption would allow CIS the authority to do further research and development in a safe and efficient manner withoutburdening the FAA with additional requests for each ofourUAS platforms and operations. Currently, the FAA does not allow civil operations (meaning operations other than public aircraft operations ormodel aircraft I "hobbyist" activities which include research and development); therefore CIS has not been able to fully develop its UAS flight research. Through this petition, CIS seeks an exemption to operate small unmanned aircraft systems to further develop its research and development ofthis emergingtechnology. CIS's small unmanned aircraft systems are aircraft weighing significantly less than 55 lbs. (details are provided within). They operate at slow speeds (under 45kts) and within line ofsight within the areas described in this petition. Such operations will ensure thatthe small unmanned aircraft systems operated byCIS will not create a hazard to otheraircraft operating in the national airspace, to the general public or pose athreat to national security as dictated by the Federal Aviation Regulations. 

### III. NAMES AND ADDRESS OF THE PETITIONER: CIS GROUP ofCompanies Morgan Cassady 8620 Precinct Line Road North Richland Hills, Texas 76182 Phone: 866-816-7445 E-mail: mcassady@cisgroup.net 

### IV. EXEMPTIONS REQUESTED:Federal Aviation Administration 7/31/15 Page 3 The FAA considers unmanned aircraft as "aircraft" flown by a "pilot"regardless ofthe location ofthe pilot. All aircraft and pilots must comply with applicable sections ofTitle 14 ofthe Code ofFederal Regulations (14 CFR)to operate within the National Airspace. Unmanned aircraft are unable to comply with certain sections of 14 CFR as the regulations were written priorto the consideration ofsmall UAS operating within the national airspace. Therefore CIS is requesting an exemption from certain parts of 14 CFR cited below in addition to such further exemptions and reliefas the FAA may determine is necessary to permit the operations described herein. 14 CFR Part 21.191 (H)- Airworthiness Certificates 14 CFRPart 45.23 (b)- Display ofmarks; general 14 CFRPart 45.27- Location ofmarks; non-fixed wing aircraft 14 CFR Part 61.113 (a) and (b) -Privatepilotprivileges and limitations 14 CFR Part 91.119 (c) -Minimum safe altitudes over congested and other areas 14 CFRPart 91.121

- Altimeter settings 14 CFR Part 91.151 (a) -Fuelrequirements for flight in VFR conditions 14 CFRPart 91.405 (a)- Maintenance required 14 CFR Part 91.407 (a)- Operation after maintenance, preventive maintenance, rebuilding oralteration 14 CFRPart 91.409 (a) (I) and (2)- Inspections 14 CFRPart 91.417 (a) and (b)- Maintenance Records The extentofreliefCIS seeks, and the reason CISseeks the relief: CIS seeks reliefpursuanttothis exemption from applicable parts ofthe Federal Aviation Regulations to the extent necessaryto permit civil flight operations within the national airspace and CIS seeks authorization to conduct small UAS flight operations withintheperimeters ofthis exemptionrequest. The reasons why granting CISrequestwould be in the public interest; thatis,how itwould benefit the publicas a whole: Grant ofCIS's request to use UAS for roofinspections is in the public interest. While CIS takes every precaution to keep its representatives safe, roofinspection conductedbyhuman beings carries with it certain risks. Currently, CIS representatives need to physically climb onto the roofusing ladders and other safety gearto conduct inspections. Sometimes, a two story/steepteam is used, requiringtwo representatives and special safety harnesses. The dangers ofinspecting any roofinclude losing one's footing, having a ladder slip, and beingblown offa rooffrom wind shear. Inadditionto safety concerns, inspecting a roofby physically climbing on it has the potential to damage the roof. Using UAS for roof inspections avoids all ofthese risks. By utilizing UAS, CIS representatives will be able to reduce their exposure to hazards and rapidly obtain accurate assessments ofthe roofwhile remaining safety on the ground. Fasterroofdamage assessments will result in faster claims processing and repairs for affected policy holders. Grantingthe exemption for CIS would allowthe organization to safely and efficiently conduct small UAS flight operations to gain valuable information and experience with CIS'sresearch and development in this technology. Gaining this information and experience would enable CIS, in the future, to utilize UAS technology to conduct safe and efficient operations both before and after claim events to assist its membership in preparing for natural disasters and post-disaster recovery and reliefoperations, and reduce the time it takes communities to rebuild afternatural disasters. Withoutthis exemption, CIS would be unable to conducttheproperresearch and developmentto build a successful small UAS operation which would assist its members and their communities. CIS believes such UAS research can leadto safer,Federal Aviation Administration 7/31/15 Page4 quicker, and more economical and effective claims service for its clients' policy holders and their communities. In addition, as described in more detail below, operation will not create a hazard to aviation orthe public. Flights will be conducted under 200 feet AGL-avoiding interference with users ofthe national airspace system. Operation will also not create a hazard to the public as CIS will only operate the UAS over private property with the owner's consent. Finally, operation will not pose a threatto national security. The UAS poses no crediblethreat to national security due to its size, speed, ofoperation, location of operation, lack ofexplosive materials orflammablejetfuels, and inability to carry a substantial external load. The reasons whygrantingthe exemptionwould not adversely affect safety, orhow the exemption would provide a level ofsafety atleastequal tothat provided by the rulefrom which CIS seeks the exemption: CIS requests thatthe exemption be granted with the following limitations and operational conditions. These limitations and conditions will provide an enhanced level ofsafety and will be the guiding principles when CIS is conducting R&D operations under this exemption: A. CIS specifically proposes to conduct UAS operations using small UAS includingthe DJI Phantom 2+. The DJI Phantom 2+ is a multi-rotor aircraft. The Phantom 2+ has a 1284gtake-off weight (battery and propellers included). The Phantom 2+carries a 5200mAh LiPo battery, which facilitates up to 25 minutes offlight time. Itcan be flown with either a radio ortablet and carries a 3-axis Camera Stabilization Gimbal with a 14 Megapixel/1080p integrated camera system. The Phantom 2+ has a maximum cruise speed of15 m/s. It features auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. A remote controller andWi-Fi Communications system; 5.8 GHz remote control receiver, flight control system and a 2.4 GHz Wi-Fi module. B. CIS agrees that any UAS it uses for roofinspections will include, at minimum: geo fencing at a maximum ceiling of200' AGL, flight programming capabilities, a flight termination link available to the operator to prevent a "fly away," l;!nd safe abort procedures. Ifthe UAS loses communications orits GPS signal, the UAS will return to a pre-determined location and land or be recovered in accordance with the Operations Manual. The UAS will have markings identifYing the serial number and identification (N-number) markings as large as practicable. Further, CIS's UAS operation will comply with all manufacturer Safety Bulletins. Any UAS tobe used will weigh less than 55 pounds and would be specifically authorized bythe FAA. UAS operations will occuronly during daytime. C. CIS proposes thatthe exemptionrequested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent oreven higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancement to the already safe operations conducted with conventional aircraft. D. The limitations and conditions to which CIS agrees to be bound when conducting R&D for commercial operations under an FAA issued exemption include:

a. UAS Pilot and ObserverFederal Aviation Administration 

### 7/31/15 Page 5

i. UAS operations will be conducted by, atminimum, pilots holding a private pilot certificate and at least a currentthird-class medical certificate.

n. All UAS operations must utilize a visual observer ("VO"). iii. Thepilot-in-command ("PIC") and VO must be able to communicate verbally at all times.

IV. The PIC will be wearing a safety vest that identifies him orher as the pilot.

v. Priorto operations, the pilot must have accumulated and logged a minimum of 200 flight cycles, or more as required bythe FAA, and 25 hours oftotal time as a UAS rotorcraft pilot. The pilot must also have accumulated and logged priorto operations atleastten hours as a UAS pilot with a similar UAS type (single blade ormulti-rotor). Prior documented flight experiencethat was obtained in compliance with applicable regulations may satisfY this requirement. All pilot in command and ground observers will be trained in detail to eachofthe unmanned aircraft system platform's operations, systems and emergencyprocedures. Every air crewmemberwill obtain an FAA Class 2 medical certificate.
vt. Training, proficiency, and experience-building flights can also be conducted underthe FAA's grant ofexemption to accomplish therequired flight cycles and flight time. vii. During training, proficiency, and experience-buildingflights, all persons not essentialfor flight operations are considered nonparticipants, and the pilot must operatethe UAwith appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

vm. All pilot in command and ground observers will be trained in detail to each ofthe unmanned aircraft system platform's operations, systems and emergency procedures. Every air crew member will obtain an FAA Class 2 medical certificate. 5. The qualification testwill be developed and implementedbya qualified person designated atthe sole discretion ofCIS. 6. A record ofcompletion ofthis qualification process must be documented and made available to the Administrator upon request.

IX. CIS will require all pilots conducting UAS operations toprovideproofofpilot and third-class medical certification as well as proofofcompletion ofthe applicable vendor's training program. 

### b. Operational Parameters i. Aircraft will not carry pilots orpassengers, and aircraft will not carry explosive materials or flammable liquid fuels.Federal Aviation Administration 

### 7/31/15 Page 6

n. UAS must be operated within visual line ofsight ofthe pilot at all times. n1. UAS may not be flown at ground speeds exceeding 50 knots.

IV. Flights will be operated at an altitude ofno more than 200 feet above ground level.

v. Each UAS operation will be completed within 60 minutes flight time orwith 25% battery powerremaining, whicheveroccurs first. At 30% battery the UAS will enter a return and land sequence; at 20% it will land immediately. v1. UAS will not be operated over any person (other than participating CIS personnel) at an altitude that is hazardous to persons orproperty on the surface in the event ofa UAS failure oremergency. 5. Distance from participating persons will be specified in the Operations Manual. 6. Operations will be conducted as far as practicable from nonparticipating persons.

vn. The UAS will abortthe flight in the event ofunpredicted obstacles or emergencies in accordance with the Operations Manual.

vm. Flight operations and safety briefings will be conducted prior to all planned small unmanned aircraft system flights and will be mandatory for all air crew. Briefings will include weatherreviews, take off, landing and aircraft performance data for those real time conditions, and full pre- and post-flight inspections/checklists and briefings for each specific unmanned aircraft system beingoperated.

IX. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of WaiverorAuthorization (COA) priorto conducting any operations underthis grant ofexemption. 5. This COA will also require the operator to request a Notice toAirmen (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

x. Operations will be limited to the property ofconsenting CIS Client's policyholders. xi. Petitioner will display signage notifYing the public ofUAS operations before beginning operations. Signs will be approximately 18" x 24" in size and will be placed in locations that will be visible from adjacent roadways atleast 5 minutes priorto UAS operations. An area will be marked offas the UAS "landing zone."Federal Aviation Administration 

### 7/31/15 Page? Petitioners will also display signage notifYing the public that UAS operation is in progress once operations begin.

XII. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS will comply with the FCC orother appropriate government oversight agency requirements. xiii. The documents required under 14 C.F.R. 

### § 91.9 must be available to the PIC at the Ground Control Station ofthe UAS anytime the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. x1v. The UAS must remain clear and yieldthe right ofway to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

xv. CIS will ensure safety to first responder aircraft and helicoptertraffic. Upon notification from manned aircraft controllers orthrough visual identification of manned aircraft, CIS will immediately suspend the UAS flight until the airspace is cleared. xv1. 17. UAS operations may notbe conducted during night, as defined in 14 C.F.R. 

### § 1.1. All operations must be conducted undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

XVII. The UAS may not be operatedby the PIC from any moving device orvehicle.

xvm. TheUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. x1x. TheUAS may not operate in Class B, C, or D airspace without approval from the FAA. The UAS may not operate within 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on a current FAApublished aeronautical chart unless an agreementwiththat airport's management is obtained, and the operation is conducted in accordance with aNOT AM as required by the Operator's COA. The letter ofagreement with the airport management should be made available to the Administratorupon request.

xx. Altitude information will be provided tothe UAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraftto a ground-based onscreen display. The UAS may have GPS altitude readout. Priorto each flight, a zero altitude initiation pointwill be established and confirmed for accuracy by the PIC. xxi. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation SafetyBoard (NTSB)Federal Aviation Administration 7/31/15 PageS
perinstructions contained on theNTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, ortransgression is reviewed by AFS-80 and authorization to resume operations is provided.



### c. Operations Manual

1. The Operatormust follow the procedures as outlined in its Operations Manual. ii. The Operations Manual must be maintained and made available to the Administrator upon request. iii. Pre-Flight Inspections and Maintenance 5. Priorto each flight, pilot will inspect UAS to ensure it is in condition for safe flight. Ifthe inspection reveals a discrepancy, aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. iv. Operator will develop procedures to document and maintain a record ofthe UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service ofthe UAS. These procedures will be added to the Operations Manual.

v. Operator will develop UAS technician qualification criteria. These criteriawill be added to the Operations Manual.



### V. SPECIFIC SECTIONS OF 

### 14 C.F.R. FROM WHICH PETITIONERS SEEKAN EXEMPTION: Such other reliefas the FAA deems appropriate to enable the requested operations CIS also requests exemption from such otherFARs as the FAA deems appropriate to enable the requested operations. If, during the effective dates ofanyGrant ofExemption issued pursuant to this Petition, the FAA issues interim orfinal rules for small UAS, CIS requests that it be relieved ofthe requirements of any conditions and limitations ofsaid exemption and allowed to comply with any less burdensome applicable regulations thatmay have become effective. 

### VI. SUMMARY TO BE PUBLISHED INFEDERAL REGISTER Petitioner: CIS Group ofCompanies 

### Sections of 14 C.F.R. Affected: Part 21 Subpart 

### H; § 45.23(b); § 45.27; §§ 61.113(a) and (b);§ 91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and (b).

### Federal Aviation Administration 7/31/15 

### Page 9 

### Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F .R. Part 21 Subpart H; 14 C.F.R. 

### § 21.19l(a); 14 C.F.R. 

### §45.23(b); 14 C.F.R. 

### §45.27; 14 C.F.R. 

### §§ 61.113(a) and (b); 14 C.F.R. 

### § 91.119(c); 14 C.F.R. 

### § 91.121; 91.15l(a); 14 C.F.R. 

### § 91.405(a); 14 C.F.R. 

### § 91.407(a)(l); 14 C.F.R. 

### §§ 91.409(a)(l) and (2); 14 C.F.R. 

### §§ 91.417(a) and (b) to conduct small unmanned aircraft systems (UAS) roofinspections subject to operating procedures that meet or exceed those that the FAA requires for similar operations for internal CIS Group Research & Development purposes. Any additional information,views orarguments availableto support CIS's request: Satisfaction ofthe criteriaprovided in Section 333 ofthe FMRA regarding size, weight, speed, operatingcapabilities, proximityto airports and populated areas, operation within visual line ofsight, and national security, provide more than adequatejustification for the grant ofthe requested exemption allowing operation ofPetitioner's UAS for roofinspections pursuant to the Operations Manual Allowing CIS this exemption would give CIS the ability to continue our UAS research and development beyond the limits imposed today. Additional testing would benefitnot only CIS and its clients, butwould serve as a partnership with the FAA and others within the UAS community to advance this new and emergingtechnology in a safe and controlled environment. Requestto exercise the privileges ofthe exemption outside the United States, the reason why the petitionerneeds to do so: CIS does not seek to exercise the privileges ofthis exemption, should it be granted, outside the United States. Our request is strictlyto be granted authority for civil UAS R&D operations at specified locations within the national airspace system. 

# /1k--

# Cu:::J- Morgan Cassady Vice President CIS Group, LL mcassady@cisgroup.net 972-280-8009