P a g e | 1 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

CH2m Global Headquarters 

9191 S. Jamaica St

Englewood, Co 80112

O +1 303 286 2000

www.ch2m.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

July 1st, 2015

Re: Petition of CH2M Hill Companies LTD, Inc. ("Petitioner") for an Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012

Dear Madam or Sir,

CH2M Hill Companies LTD, Inc. is petitioning the Federal Aviation Administration (FAA) for an exemption 

to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R Part 11. The 

exemption would allow operation of the DJI Phantom 2, DJI S1000+, and Trimble UX5 unmanned aircraft 

systems (UAS) for the purpose of aerial photography/video acquisition, vertical and horizontal 

construction inspections, precision farming, real estate, land surveying, emergency search and rescue, 

and research relative to data acquisition systems. This document will outline requested relief from 

regulations pertaining to this exemption.

CH2M Hill Companies LTD, Inc. agrees to operate within the boundaries set forth by this exemption. 

Along with rules and regulations that the FAA has in place, CH2M Hill Companies LTD, Inc. plans to use 

additional safety precautions were they see fit to ensure safe sUAS operations. Implementation of 

lightweight small-unmanned aircraft systems (sUAS) is a tool that can greatly improve the safety 

standards of our National Airspace System (NAS). sUAS can fly operations that would traditionally 

require manned aircraft, carrying pilots and gallons of flammable fuel. Please allow CH2M Hill 

Companies LTD, Inc. to offer sUAS operations to promote the safe, efficient and responsible use of sUAS.

Regards,

Blake Scott

Finance Professional

CH2M Hill Companies LTD, Inc.

720-286-3487

Blakes.Scott@ch2m.com
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Table of Contents

Glossary of Abbreviations......................................................................................2

List of Attachments................................................................................................3

Introduction and Interest of Petitioner..................................................................3

Unmanned Aerial Systems.....................................................................................3

Equipment List.......................................................................................................4

Unmanned Aircraft Pilot in Command (PIC)..........................................................6

Operations of sUAS ..............................................................................................6

Requested Exemptions from Regulations ...........................................................10

Public Interest......................................................................................................13 

Conclusion...........................................................................................................13

Glossary of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

MAAP Mid Atlantic Aviation Partnership 

NAS National Airspace System

PIC Pilot in Command

sUAS Small Unmanned Aircraft Systems 

VFR Visual Flight Rules

VMC Visual Meteorological Conditions 

VO Visual Observer

VLS Visual Line of Sight
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List of Appendixes

Appendix: A

DJI S1000+ Operating Manual 

Appendix B:

A2 Flight Control Operating Manual

Appendix C:

Futaba 8FG Operating Manual  

Appendix D:

DJI Phantom 2 Operating Manual

Appendix E:

Naza M flight control Operating Manual

Appendix F:

Trimble UX5 User Guide

Appendix G: 

CH2M Hill Companies LTD, Inc. Standard Operating Procedures and Checklists

Appendix H:

CH2M Hill Companies LTD, Inc. sUAS Preflight Form

The eight attachments listed above are referenced in the request for exemption and contain trade 

secret and commercial proprietary information that CH2M Hill Companies LTD, Inc. has not and will not 

share with others except under appropriate confidentiality agreements. The CH2M Hill Companies LTD, 

Inc. Standard Operating Procedures (SOP) attachment contains operating conditions and procedures 

that have been developed exclusively by CH2M Hill Companies LTD, Inc. and that are not available to the 

public. CH2M Hill Companies LTD, Inc. is requesting that these attachments be treated as proprietary 

information pursuant to 14 C.F.R. Section 11.35, and maintains that they are protected from public 

release under the Freedom of Information Act. See 5 U.S.C. 552 et seq.

Section 1: Introduction and Interest of Petitioner

CH2M Hill Companies LTD, Inc. is a business entity located in Englewood, CO that intends to use two 

current DJI model sUAS platforms, and one Trimble model sUAS platform to engage in aerial 

photography/video acquisition, vertical and horizontal construction inspections, precision farming, real 

estate, land surveying, emergency search and rescue, and research relative to data acquisition systems. 
P a g e | 4 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

CH2M Hill Companies LTD, Inc. is committed to offering safe and responsible sUAS flight operations.

It shall be the intent of every sUAS operator to make a responsible effort to not invade a person's 

reasonable expectation of privacy when operating the UAS while performing safe flight operations. 

When operating the sUAS, CH2M Hill Companies LTD, Inc. operators will abide by all FAA Regulations for 

flight and receive the proper authorization for flight.

Section 2: Unmanned Aerial Systems

Regarding the Unmanned Aircraft System from FAA Documentation

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk 

to the NAS or to persons and property on the ground. Specifically, petitioners should describe the design 

and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft performance 

and performance limitations, operating procedures, and aircraft loading information in as much detail as 

possible. This could be provided in the petition or in an Aircraft Flight Manual or similar document.

NOTE: The FAA will consider all information and data submitted by the petitioner that describes the UAS 

developmental and operational history. This could include statistical data or other documentation for the 

specific design and performance characteristics of the UAS, including the operational history and 

operational failure modes, obtained through previous Research & Development (R&D) and/or flight test 

activities, e.g. operations conducted under a COA, with a civil airworthiness certificate, or under other 

authorized operating conditions.

2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, 

maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in 

the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document.

NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may be separate documents 

or combined in a single document

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and 

associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with 

Federal Communications Commission (FCC) or other appropriate government oversight agency 

requirements. NOTE: Petitioners should be able to provide the FCC approval letter or show compliance 

with FCC requirements upon request.

General Information Pertaining to All Proposed sUAS

CH2M Hill Companies LTD, Inc. will operate less than fifty-five pound sUAS, with the ability to conduct 

precision data collection, inspections, and aerial mapping, with payloads capable of supporting this 

mission.

Prior to each flight the CH2M Hill Companies LTD, Inc. PIC shall inspect the sUAS to ensure it is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, 

the aircraft will be prohibited from operating until the necessary maintenance has been performed and 

the sUAS is found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in aircraft records. 

All discrepancies noted shall be documented as described in the CH2M Hill Companies LTD, Inc. SOP 

(Section 5, Page 14).

Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight 

characteristics, e.g. replacement of a flight critical component, shall undergo a functional test flight in 

accordance with the manufacturer’s manual and CH2M Hill Companies LTD, Inc. SOP (Section 5, Page 

10). The CH2M Hill Companies LTD, Inc. PIC who conducts the functional test flight shall make an entry 
P a g e | 5 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

in the sUAS aircraft logbook of the flight.

CH2M Hill Companies LTD, Inc. shall follow the manufacturer’s sUAS aircraft/component, maintenance, 

overhaul, replacement, inspection and life limit requirements, with particular attention to flight critical 

components that may not be addressed in the manufacturer’s manuals.

CH2M Hill Companies LTD, Inc. CH2M Hill Companies LTD, Inc. shall carry out the maintenance, 

inspections and record keeping requirements, in accordance with the CH2M Hill Companies LTD SOP. 

Maintenance, inspection, and alterations must be noted in the aircraft log book, including total flight 

hours, and description of work accomplished. Only personnel who are authorized shall perform such 

operations. CH2M Hill Companies LTD, Inc. SOP (Section 9, Page 19).

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and 

Safety Bulletins.

CH2M Hill Companies LTD, Inc. technicians will receive and document training referenced in the 

manufacturer’s operations manual.

CH2M Hill Companies LTD, Inc. technicians shall make a record entry in the sUAS logbook or equivalent 

document of the corrective action taken against discrepancies discovered between inspections.

Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS 

shall comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

Equipment List

DJI S1000+

CH2M Hill Companies LTD, Inc. seeks an exemption to operate a DJI-S1000+ sUAS for compensation or 

hire. The DJI-S1000+ is comprised of a multi-rotor unmanned aircraft and two handheld ground control 

stations. The DJI-S1000+ has a maximum gross weight of approximately 24 pounds, diagonal wheelbase 

of 41.4 inches, and height of approximately 18 inches. The DJI-S1000+ is equipped with eight rotors 

driven by eight lithium polymer battery powered electric motors.

Design and operational characteristics are provided in DJI S1000+ Operating Manual (Section 1, Page 2).

CH2M Hill Companies LTD, Inc. flight crews shall conduct pre-flight inspections as documented in DJI 

S1000+ Operating Manual (Section 5, Page 10).

DJI Phantom 2

CH2M Hill Companies LTD, Inc. seeks an exemption to operate a DJI Phantom 2 sUAS, for compensation 

or hire. The DJI Phantom 2 is comprised of a quad-rotor unmanned aircraft and a handheld ground 

control station. The Phantom 2 has a maximum gross weight of approximately 2.8 pounds, diameter 

(rotor span) 23.75 inches, width of 12.5 inches, and height of 8.1 inches. The Phantom 2 is equipped 

with four rotors driven by four lithium polymer battery powered electric motors.

Design and operational characteristics are provided in the DJI Phantom 2 Operating Manual (Page 35). 

CH2M Hill Companies LTD, Inc. flight crews shall conduct pre-flight inspections as documented in DJI 

Phantom 2 Operating Manual (Page 24).

Trimble UX5

CH2M Hill Companies LTD, Inc. seeks an exemption to operate a Trimble UX5 sUAS, for compensation or 
P a g e | 6 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

hire. The Trimble UX5 is comprised of a fixed-wing unmanned aircraft and a handheld ground control 

station. The Trimble UX5 has a maximum gross weight of approximately 5.5 pounds, diameter (wing 

span) 39.36 inches, width of 25.6 inches, and height of 4.1 inches. The Trimble UX5 is equipped with a 

single rotor driven by a lithium polymer battery powered electric motor.

Design and operational characteristics are provided in the Trimble UX5 Datasheet (Page 2). CH2M Hill 

Companies LTD, Inc. flight crews shall conduct pre-flight inspections as documented in the Trimble UX5 

Operating Manual (Page 49-51).

Section 3: Unmanned Aircraft Pilot in Command (PIC)

Regarding the Unmanned Aircraft PIC

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for 

the operation of the UAS, including information such as: the level of airman certificate held; any 

applicable training related to the operation; and any minimum hours of flight experience required by the 

PIC(s), both total flight time and the time with the particular UAS. If the operation would use visual 

observers, petitioners should describe their roles and qualifications.

5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for 

the operation of the UAS.

All CH2M Hill Companies LTD, Inc. Flight Crews, including PIC and Visual Observers (VO), will be qualified 

as directed by CH2M Hill Companies LTD, Inc. SOP (Section 1, Page 1).

All flight crewmembers, including CH2M Hill Companies LTD, Inc. PIC and VO, will have an understanding 

of, and comply with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, 

applicable to the airspace where the sUAS will operate. Specifically all CH2M Hill Companies LTD, Inc.

flight crew members will receive training on the rules and responsibilities described in 14 C.F.R Part 91 

Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot controller 

glossary, including standard ATC phraseology and communication.

The CH2M Hill Companies LTD, Inc. PIC must possess at least a current private, recreational or sport pilot 

certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R Section 61.56 in 

an aircraft in which the PIC is rated on his/her pilot certificate.

Prior to operations conducted for the purpose of aerial imagery and videography (or similar operations), 

the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R Section 61.51(b), a 

minimum of 25 hours of total time as a sUAS pilot and at least ten hours logged as a sUAS pilot with 

similar sUAS type (fixed wing or rotary). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience building flights are requested to be conducted under this grant of exception to accomplish 

the required flight cycles and flight time. During training, proficiency, and experience building flights, all 

persons not essential for flight operations will be considered non-participants and the PIC will operate 

the sUAS with appropriate distance from non-participants in accordance with 14 C.F.R Section 91.119.

Prior to operations conducted for the purpose of precision agriculture (or similar operations), the CH2M 

Hill Companies LTD, Inc. PIC must have accumulated and logged in a manner consistent with 14 C.F.R 

Section 61.51(b), a minimum of five hours as a sUAS PIC operating the make and model of the sUAS to 

be utilized for operations under this requested exemption, and three take-offs and landings in the 

preceding 90 days. Training, proficiency, experience- building, and take-off and landing currency flights 

are requested to be conducted under this grant of exemption to accomplish the required flight time and 

90 day currency. During training, proficiency, experience building, and take-off and landing currency 

flights all personnel not essential for flight operations are considered nonparticipants, and the PIC must 

operate the sUAS with appropriate distance from nonparticipants in accordance with 14 C.F.R Section 
P a g e | 7 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to 

communicate verbally at all times. This condition and limitation is consistent with all FAA approved 

Exemptions.

Section 4: Operations of sUAS

Regarding the Operation of the Unmanned Aircraft

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the 

proposed operation(s) would not adversely affect safety, or how they would provide a level of safety at 

least equivalent to that provided by the rule from which exemption is sought. Petitioners should address 

any plans to implement clearly defined operational borders and procedures to ensure public safety, 

which includes persons and property both in the air and on the ground. This can be described in the 

petition, in an Operations Manual, or similar document.

NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of flight, NAS safety 

considerations, and the safety of the non-participating persons and property during the operational 

period and within the operational area.

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe 

minimum flight visibility and distance from clouds for their intended operation(s). Petitioners should 

describe potential hazards and safety mitigations associated with these proposed conditions. These 

issues can be addressed in the petition, an Operations Manual, or similar document.

The sUAS shall remain clear and yield the right of way to all other manned aviation operations and 

activities at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level (AGL). All 

altitudes reported to ATC will be in feet.

The multi-rotor sUAS shall not be flown at a ground speed exceeding 45 mph.

CH2M Hill Companies LTD, Inc. sUAS Operations will be conducted under visual meteorological 

conditions (VMC). The sUAS will not be operated less than 500 feet below or less than 2000 feet 

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

If the sUAS loses communications or loses its GPS signal, it must return to a pre-determined location 

within the planned operating area and land or be recovered in accordance with CH2M Hill Companies 

LTD, Inc. SOP (Section 5, Page 12.

The sUAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with operating documents.

The sUAS PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land 

the sUAS with 25% battery power remaining.

The sUAS operated in accordance with this proposed exemption shall be identified by serial numbers, 

registered in accordance with 14 C.F.R part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R part 45, Subpart C. Markings will be as large as practicable.
P a g e | 8 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

The sUAS documents required under 14 C.F.R 91.9 and 91.203 shall be available to the PIC at the Ground 

Control Station of the sUAS anytime the aircraft is operating. Those documents shall be available to the 

Administrator or any law enforcement official upon request.

Any sUAS incidents, accidents or flight operations that transgress the lateral or vertical boundaries of 

the operational area as defined by the applicable COA shall be reported to the FAA’s UAS Integration 

Office (AFS-80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

Unless otherwise specified in this petition, the sUAS PIC, and the sUAS operations shall comply with all 

applicable parts of 14 C.F.R including, but not limited to, parts 45, 47, 61 and 91.

8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated 

potential hazards, in accordance with the statutory mandate under Section 333 regarding proximity to 

populated areas. These issues can be addressed in the petition, an Operations Manual, or similar 

document.

The sUAS shall not be operated over congested or densely populated areas. These areas include but are 

not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical 

Charts (Sectionals), or Terminal Area Charts (TAC). Each work site will also be evaluated based on local 

conditions.

Operations of sUAS may be conducted at distances less than 500 feet from participating persons, 

vessels, vehicles or structures that perform an essential function in connection with these special 

purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential 

persons are permitted when operationally necessary; but never so close to present an undue hazard. 

This is consistent with Exemption No. 11138.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles 

or structures owned by the land owner/controller when the land owner/controller grants such 

permission, and the PIC makes a safety assessment of the risk from operations and determines that it 

does not present an undue hazard to persons or property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all nonparticipating persons unless barriers or 

structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in 

the event of an accident. CH2M Hill Companies LTD, Inc. shall ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the sUAS, flight operations will cease immediately. This is consistent with 

Exemption No. 11138.

All operations of sUAS shall be conducted with the permission from the land owner/controller or

authorized representative. Permission from the land owner/controller or authorized representative will 

be obtained for each flight to be conducted.

9. Petitioners should describe if they intend to operate in the proximity of any airports, in accordance 

with the statutory mandate under Section 333 regarding proximity to airports.

The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a current 

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s 

COA. The letter of agreement with the airport management will be made available to the Administrator 

upon request. This is consistent with Exemption No 11159.

10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the statutory 

mandate under Section 333(b)(1). Petitioners should describe how they intend to comply with his 
P a g e | 9 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

mandate.

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC to be able 

to use human vision to see the sUAS unaided by any device other than corrective lenses, as specified on 

the PIC’s FAA issued medical certificate.

All sUAS operations must utilize a VO. The VO may be used to satisfy the VLOS requirement as long as 

the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all 

times. The PIC and VO must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in 

CH2M Hill Companies LTD, Inc. SOP (Section 1, Page 1).

The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will not be 

conducted during night as defined in 14 C.F.R 1.1.

11. Petitioners should describe any procedures they would implement for conducting a preflight safety 

risk assessment to determine that the UAS is in a condition for safe flight (14 C.F.R § 91.7(b)) and that 

the planned operation can be completed safely. These procedures can be addressed in the petition, an 

Aircraft Flight Manual, Operations Manual, or similar document.

CH2M Hill Companies LTD, Inc. will conduct preflight safety risk assessments to determine that the sUAS 

is in a condition for safe flight (14 C.F.R Section 91.7(b)) and that the planned operation can be 

completed safely. Specific procedures are addressed in CH2M Hill Companies LTD, Inc. SOP (Section 5, 

Page 10), and sUAS Operation Manuals.

12. If petitioners intend to conduct operations which have existing requirements to notify Flight 

Standards District Offices (FSDOs) prior to operations – such as motion picture and television filming, or 

pipeline and power line patrol – petitioners should describe their intended coordination in this regard for 

their proposed operation(s).

CH2M Hill Companies LTD, Inc. operations do not require a notification to Flight Standards District 

Offices (FSDOs) at this time.

13. The FAA intends to require entities who obtain an exemption under this process to also obtain a 

Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting 

operation(s) in the NAS.

CH2M Hill Companies LTD, Inc. shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this requested grant of exemption. 

Additionally, CH2M Hill Companies LTD, Inc. will request a Notice to Airmen (NOTAM) not more than 72 

hours, but not less than 48 hours prior to the operation.

Section 5: Requested Exemptions from Regulations

Considered 

Regulation Title Recommended Action

14 C.F.R Part 

21.185

Airworthiness 

Certificate

CH2M Hill Companies LTD, Inc. recommends that in 

consideration of the size, weight, speed and limited operating 

area associated with these aircraft and their operation, the 

Secretary of Transportation determine that these aircraft meet 

the conditions of Section 333. Relief is not necessary.
P a g e | 10 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

14 C.F.R. Part 

45.23(b)

Display of 

marks

CH2M Hill Companies LTD, Inc. sUAS shall be identified by serial 

number, registered in accordance with 14 C.F.R part 47, and 

have identification (N-Number) markings in accordance with 14 

C.F.R part 45, Subpart C. Markings will be as large as practicable. 

Relief is not necessary.

14 C.F.R. Part 

61.113(a)

Private pilot 

privileges and 

limitations

The FAA has found in previous grants of exemption that a PIC 

with a private, recreational or sport pilot certificate operating a 

sUAS would not adversely affect operations in the NAS or 

present a hazard to persons or property on the ground. Request 

relief with limitations and conditions specified in this petition.

14 C.F.R. Part 

61.133(b) Commercial 

pilot privileges 

and limitations

The FAA has found in previous grants of exemption that a PIC 

with a private, recreational or sport pilot certificate operating a 

sUAS would not adversely affect operations in the NAS or 

present a hazard to persons or property on the ground. Request 

relief with limitations and conditions specified in this petition.

14 C.F.R. Part 

91.7(a) Civil Aircraft 

Airworthiness

CH2M Hill Companies LTD, Inc. recommends that in 

consideration of the size, weight, speed and limited operating 

area associated with this aircraft and its operation, the Secretary 

of Transportation determines that these aircraft meet the 

conditions of Section 333. Relief is not necessary.

14 C.F.R. Part 

91.9(b)(2) &(c)

Civil Aircraft 

Flight Manual, 

Marking, and 

Placard 

Requirements

The FAA has previously determined that relief from these 

sections is not necessary. Relevant materials may be kept in a 

location accessible to the PIC in compliance with the regulations. 

Relief is not necessary.

14 C.F.R. Part 

91.103

14 C.F.R. Part 

91.109(a)

Preflight Action

Flight 

Instruction

CH2M Hill Companies LTD, Inc. will perform. Relief is not 

necessary.

CH2M Hill Companies LTD, Inc. will conduct all flight training 

through procedures specified in Training Instruction during 

dedicated training sessions. Based on previous decisions made 

by the FAA for sUAS petitions regarding this regulation, relief is 

not necessary.

14 C.F.R. Part 

91.119(c)

Minimum Safe 

Altitude

Aircraft will be operated below 400 AGL, but not over congested 

areas. Request relief with limitations and conditions specified 

in this petition.

14 C.F.R. Part 

121

Altimeter 

Settings

The proposed aircraft have a barometric altimeter and GPS 

derived altitude capabilities. CH2M Hill Companies LTD, Inc.

recommends that the altimeter be set to zero feet AGL rather 

than local barometric pressure or field altitude before flight. 

Considering the limited altitude of the proposed operations. 

Request relief with limitations and conditions specified in this 

petition.
P a g e | 11 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

14 C.F.R. Part 

91.151(a)

Fuel 

Requirements 

in VFR

Prior relief has been granted for manned and unmanned aircraft 

to operate at less than prescribed minimums. Request relief 

with limitations and conditions specified in this petition.

14 C.F.R. Part 

91.203(a) and 

(b)

Certifications 

Required

Original intent of these regulations was to display an aircraft’s 

airworthiness, certification and registration documents so they 

would be easily available to inspectors and passengers. Based on 

the FAA Memorandum subject, “Interpretation regarding 

whether certain required documents may be kept at an 

unmanned aircraft’s control station,” dated August 8, 2014, 

relief is not necessary.

14 C.F.R. Part 

91.405(a)

Maintenance 

Required

Request relief with limitations and conditions specified in this 

petition.

14 C.F.R. Part 

91.407(a)(1)

Operation after 

Maintenance

Request relief with limitations and conditions specified in this 

petition.

14 C.F.R. Part 

91.409(a)(1) 

and (2)

Inspections Request relief with limitations and conditions specified in this 

petition.

14 C.F.R. Part 

91.417(a) and 

(b)

Maintenance 

Records

Request relief with limitations and conditions specified in this 

petition.

Public Interest

CH2M Hill Companies LTD, Inc.’s operations of sUAS to perform aerial photography/video acquisition, 

vertical and horizontal construction inspections, precision farming, real estate, land surveying, 

emergency search and rescue, and research relative to data acquisition systems, will reduce risk to life 

and property by decreasing the requirements of personnel to operate manned aircraft to perform these 

tasks. CH2M Hill Companies LTD, Inc. will use battery-powered sUAS that serve as safe and efficient

alternatives to the manned aircraft commonly utilized to conduct precision agriculture inspections/data 

collections and aerial mapping. Also, the flight data, inspection results, recorded observations and 

lessons learned from these operations will be compiled to further enhance its current safety program.

The applicant proposes that the exemptions 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 aerial photography/video 

acquisition, precision agriculture inspections/data collections and aerial mapping, which is currently 

being conducted by manned aircraft.
P a g e | 12 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

Conclusion

CH2M Hill Companies LTD, Inc. seeks exemption from the requirements of 14 C.F.R § 61.113(a), 

61.133(b), 121, 91,119(c), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1), and (2) and 91.417(a). 

As set forth above, CH2M Hill Companies LTD, Inc. seeks exemption pursuant to 14 C.F.R § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the 

above-named sUAS commercially for the purpose of conducting aerial photography/video acquisition, 

vertical and horizontal construction inspections, real estate, land surveying, emergency search and 

rescue, and research relative to data acquisition systems in non-congested areas. By granting this 

Petition, the FAA will allow CH2M Hill Companies LTD, Inc. to safely, effectively and efficiently operate 

sUAS commercially. 

Submitted on July 1st, 2015

Regards,

Blake Scott

Finance Professional

CH2M Hill Companies LTD, Inc.

9191 S. Jamaica Street

Englewood, Co 80112

720-286-3487