July 31,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Reference: CIS Group of Companies, LLC. Petition for Section 333 Exemption: Re: Research & 

Development of Methods to Use Small Unmanned Aircraft Systems in Property and Casualty 

Insurance 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. Part 

II, CIS Group of Companies, LLC (Petitioner or CIS) is petitioning for an exemption from the Federal 

Aviation Regulations ("FARs") and other rules/statutes pertaining to small Unmanned Aircraft Systems 

("UAS") to conduct residential property inspections with an emphasis on roof conditions. The requested 

exemption would permit tbe operation of the UAS to obtain up-close images of roofs and perform an indepth analysis of the images to determine the nature and extent of damage to the roof surface without 

placing claim adjusters or.inspectors at risk. The CIS representative will be able to promptly share the 

report and inspection images with our client to reduce claim payment time. Section 333 of the 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 grown to become the largest supplier 

of field underwriting and inspection supply chain services in the United States. Each day our more than 

1,000 employees and independently contracted vendors serve the inspection, claim handling and 

technology needs of more than 125 clients in the underwriting, claims and mortgage services sectors. CIS 

focuses its innovation on developing products and new technology to assist its clients from policy 

inception to fulfilling our service commitment during a claims event. Each of CIS's clients look to CIS to 

help their insureds restore and rebuild after a wide range of natural and other disasters, as well as ensure 

the quality of their underwriting book. CIS is always seeking ways to improve the timing and quality of 

its responses to its clients' needs: Property and casualty insurers play a major role in funding the 

restoration of businesses and communities after major incidents, and the integration of unmanned aircraft 

into CIS UAS operations will have immediate, positive effects on the lives of Americans and the business 

community. 

I. REQUEST FOR EXEMPTION TO USE UAS FOR ROOF INSPECTIONS 

A. Overview of Request to Use UAS for Rooflnspections 

CIS proposes to conduct roof inspections using small UAS including the DJI Phantom 2+ and/or the 3D 

Robotics X8-M multi-rotor quad copters. As described more fully below, the requested exemption would 

permit the operation of small 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 occur within the line of sight of the UAS operator. The property owner will be notified in advance 

of the date and time for inspection. The customer's privacy and their neighbors' privacy will be fully 

protected. CIS's use ofUAS for roof inspections does not create a hazard to users of the national airspace 

or the public or pose a threat to national security. 

1 
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Grant of this request is warranted as use ofUAS will improve safety for CIS's claim representatives and 

inspectors (hereinafter CIS representative or representative). Currently, CIS representatives must 

physically climb onto a policyholder's roof using ladders for inspection. Inspecting roofs is dangerous as 

evidenced by annual industrywide worker compensation claims due to falls while performing this task. 

By utilizing UAS, CIS representatives will be able to reduce their exposure to hazards and obtain accurate 

assessments of the roof while remaining safely on the ground. Additionally, CIS representatives will be 

able to capture a full view of the roof which 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 of integrating 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 extend these research and development activities, and this application seeks 

interim authority from the FAA to allow CIS to pursue these activities it began researching in 2014. 

In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under§ 40 l 0 I of 

the Act, that includes UAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed 

under§§ 4470l(a) or (b) or in§§ 44702-44716 of the Act if the 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 without burdening the FAA with additional requests for each of our UAS 

platforms and operations. Currently, the FAA does not allow civil operations (meaning operations other 

than public aircraft operations or model 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 of this emerging technology. 

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 of sight within the areas 

described in this petition. Such operations will ensure that the small unmanned aircraft systems operated 

by CIS will not create a hazard to other aircraft operating in the national airspace, to the general public or 

pose a threat to national security as dictated by the Federal Aviation Regulations. 

III. NAMES AND ADDRESS OF THE PETITIONER: 

CIS GROUP of Companies 

Morgan Cassady 

8620 Precinct Line Road 

North Richland Hills, Texas 76182 

Phone: 866-816-7445 

E-mail: mcassady@cisgroup.net 

IV. EXEMPTIONS REQUESTED: 
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The FAA considers unmanned aircraft as "aircraft" flown by a "pilot" regardless of the location of the 

pilot. All aircraft and pilots must comply with applicable sections of Title 14 ofthe Code of Federal 

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 prior to the consideration of small 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 relief as the FAA may determine is necessary 

to permit the operations described herein. 

14 CFR Part 21.191 (H)- Airworthiness Certificates 

14 CFR Part 45.23 (b)- Display of marks; general 

14 CFR Part 45.27- Location of marks; non-fixed wing aircraft 

14 CFR Part 61.113 (a) and (b) -Private pilot privileges and limitations 

14 CFR Part 91.119 (c) -Minimum safe altitudes over congested and other areas 

14 CFR Part 91.121 - Altimeter settings 

14 CFR Part 91.151 (a) -Fuel requirements for flight in VFR conditions 

14 CFR Part 91.405 (a)- Maintenance required 

14 CFR Part 91.407 (a)- Operation after maintenance, preventive maintenance, rebuilding or alteration 

14 CFR Part 91.409 (a) (I) and (2)- Inspections 

14 CFR Part 91.417 (a) and (b)- Maintenance Records 

The extent of relief CIS seeks, and the reason CIS seeks the relief: 

CIS seeks relief pursuant to this exemption from applicable parts of the Federal Aviation Regulations to 

the extent necessary to permit civil flight operations within the national airspace and CIS seeks 

authorization to conduct small UAS flight operations within the perimeters of this exemption request. 

The reasons why granting CIS request would be in the public interest; that is, how it would benefit 

the public as a whole: 

Grant of CIS's request to use UAS for roof inspections is in the public interest. While CIS takes every 

precaution to keep its representatives safe, roof inspection conducted by human beings carries with it 

certain risks. Currently, CIS representatives need to physically climb onto the roof using ladders and other 

safety gear to conduct inspections. Sometimes, a two story/steep team is used, requiring two 

representatives and special safety harnesses. The dangers of inspecting any roof include losing one's 

footing, having a ladder slip, and being blown off a roof from wind shear. In addition to safety concerns, 

inspecting a roof by physically climbing on it has the potential to damage the roof. Using UAS for roof 

inspections avoids all of these risks. By utilizing UAS, CIS representatives will be able to reduce their 

exposure to hazards and rapidly obtain accurate assessments of the roof while remaining safety on the 

ground. Faster roof damage assessments will result in faster claims processing and repairs for affected 

policy holders. 

Granting the exemption for CIS would allow the organization to safely and efficiently conduct small UAS 

flight operations to gain valuable information and experience with CIS's research 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 relief operations, and reduce 

the time it takes communities to rebuild after natural disasters. Without this exemption, CIS would be 

unable to conduct the proper research and development to build a successful small UAS operation which 

would assist its members and their communities. CIS believes such UAS research can lead to safer, 
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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 or the public. 

Flights will be conducted under 200 feet AGL-avoiding interference with users of the 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 threat to national security. 

The UAS poses no credible threat to national security due to its size, speed, of operation, location of 

operation, lack of explosive materials or flammable jet fuels, and inability to carry a substantial external 

load. 

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 from which CIS seeks the 

exemption: 

CIS requests that the exemption be granted with the following limitations and operational conditions. 

These limitations and conditions will provide an enhanced level of safety 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 including the DJI 

Phantom 2+. The DJI Phantom 2+ is a multi-rotor aircraft. The Phantom 2+ has a 1284g take-off 

weight (battery and propellers included). The Phantom 2+ carries a 5200mAh LiPo battery, which 

facilitates up to 25 minutes of flight time. It can be flown with either a radio or tablet and carries 

a 3-axis Camera Stabilization Gimbal with a 14 Megapixel/1080p integrated camera system. The 

Phantom 2+ has a maximum cruise speed of 15 m/s. It features auto-takeoff and landing, auto go 

home and landing, GPS waypoint navigation, direction lock, and GIS mapping. A remote 

controller and Wi-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 roof inspections 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. If the UAS loses 

communications or its 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 to be used will 

weigh less than 55 pounds and would be specifically authorized by the FAA. UAS operations will 

occur only during daytime. 

C. CIS proposes that the exemption requested 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 or even higher level of safety to operations under the 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 Observer 
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i. UAS operations will be conducted by, at minimum, pilots holding a private pilot 

certificate and at least a current third-class medical certificate. 

n. All UAS operations must utilize a visual observer ("VO"). 

iii. The pilot-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 or her as the pilot. 

v. Prior to operations, the pilot must have accumulated and logged a minimum of 

200 flight cycles, or more as required by the FAA, and 25 hours of total time as a 

UAS rotorcraft pilot. The pilot must also have accumulated and logged prior to 

operations at least ten hours as a UAS pilot with a similar UAS type (single blade 

or multi-rotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfY this requirement. All pilot in 

command and ground observers will be trained in detail to each of the unmanned 

aircraft system platform's operations, systems and emergency procedures. Every 

air crew member will obtain an FAA Class 2 medical certificate. 

vt. Training, proficiency, and experience-building flights can also be conducted 

under the FAA's grant of exemption to accomplish the required flight cycles and 

flight time. 

vii. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the pilot must 

operate the UA with 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 of the 

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 test will be developed and implemented by a qualified 

person designated at the sole discretion of CIS. 

6. A record of completion of this qualification process must be documented 

and made available to the Administrator upon request. 

IX. CIS will require all pilots conducting UAS operations to provide proof of pilot 

and third-class medical certification as well as proof of completion of the 

applicable vendor's training program. 

b. Operational Parameters 

i. Aircraft will not carry pilots or passengers, and aircraft will not carry explosive 

materials or flammable liquid fuels. 
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n. UAS must be operated within visual line of sight of the pilot at all times. 

n1. UAS may not be flown at ground speeds exceeding 50 knots. 

IV. Flights will be operated at an altitude of no more than 200 feet above ground 

level. 

v. Each U AS operation will be completed within 60 minutes flight time or with 

25% battery power remaining, whichever occurs 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 or property on the surface in 

the event of a UAS failure or emergency. 

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 abort the 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 weather reviews, 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 

being operated. 

IX. The operator must obtain an Air Traffic Organization (A TO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this 

grant of exemption. 

5. This COA will also require the operator to request a Notice to Airmen 

(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 of consenting 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 at least 5 minutes 

prior to UAS operations. An area will be marked off as the UAS "landing zone." 
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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 of the UAS will comply with the FCC or other 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 of the UAS any time 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 yield the right of way 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 helicopter traffic. Upon 

notification from manned aircraft controllers or through visual identification of 

manned aircraft, CIS will immediately suspend the UAS flight until the airspace 

is cleared. 

xv1. 17. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). Flights under special visual flight rules (SVFR) are not authorized. 

XVII. The UAS may not be operated by the PIC from any moving device or vehicle. 

xvm. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

x1x. The UAS may not operate in Class B, C, or D airspace without approval from the 

FAA. The UAS may not operate within 5 nautical miles of the geographic center 

of a non-towered airport as denoted on a current FAA published aeronautical 

chart unless an agreement with that airport's management is obtained, and the 

operation is conducted in accordance with a NOT AM as required by the 

Operator's COA. The letter of agreement with the airport management should be 

made available to the Administrator upon request. 

xx. Altitude information will be provided to the UAS pilot via a digitally encoded 

telemetric data feed, which downlinks from the aircraft to a ground-based onscreen display. The UAS may have GPS altitude readout. Prior to each flight, a 

zero altitude initiation point will be established and confirmed for accuracy by 

the PIC. 

xxi. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the 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 Safety Board (NTSB) 
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per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight 

operations may not be conducted until the incident, accident, or transgression is 

reviewed by AFS-80 and authorization to resume operations is provided. 

c. Operations Manual 

1. The Operator must 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. Prior to each flight, pilot will inspect UAS to ensure it is in condition for 

safe flight. If the 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 of the UAS 

maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

These procedures will be added to the Operations Manual. 

v. Operator will develop UAS technician qualification criteria. These criteria will 

be added to the Operations Manual. 

V. SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN 

EXEMPTION: 

Such other relief as the FAA deems appropriate to enable the requested operations 

CIS also requests exemption from such other F ARs as the FAA deems appropriate to enable the requested 

operations. If, during the effective dates of any Grant of Exemption issued pursuant to this Petition, the 

FAA issues interim or final rules for small UAS, CIS requests that it be relieved of the requirements of 

any conditions and limitations of said exemption and allowed to comply with any less burdensome 

applicable regulations that may have become effective. 

VI. SUMMARY TO BE PUBLISHED IN FEDERAL REGISTER 

Petitioner: CIS Group of Companies 

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). 
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Description of Relief Sought: Petitioner seeks relief from 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) roof inspections 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 or arguments available to support CIS's request: 

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security, provide more than adequate justification for the grant of the requested 

exemption allowing operation of Petitioner's UAS for roof inspections 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 benefit not only CIS and its 

clients, but would serve as a partnership with the FAA and others with in the U AS community to advance 

this new and emerging technology in a safe and controlled environment. 

Request to exercise the privileges of the exemption outside the United States, the reason why the 

petitioner needs to do so: 

CIS does not seek to exercise the privileges of this exemption, should it be granted, outside the United 

States. Our request is strictly to be granted authority for civil UAS R&D operations at specified locations 

within the national airspace system. 

/1 k--Cu:::J- Morgan Cassady 

Vice President CIS Group, LL 

mcassady@cisgroup.net 

972-280-8009