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

J uly 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 unm anned 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 s ystems. 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 th at 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.comP a g e | 2 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved. 

# 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 SightP a g e | 3 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.



## 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 flig ht 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 pursua nt 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, C O 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, precis ion 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 L TD, 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. a ircraft 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 a ll 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 o perational 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 condi tions.

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: Petition ers 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 inspec t 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 i n 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 entryP 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, in spection 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 m aintenance, inspections and record keeping requirements, in accordance with the C H 2M 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

- S10 00+ 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 C ompanies LTD, Inc. f light 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, dia meter (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 Phant om 2 Operat ing Manual (Page 35). CH2M Hill Companies LTD, Inc. f light 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 orP 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, diame ter (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. f light 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 operati on; 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 shou ld 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 understand ing 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 an d 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 bu ilding 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 cons idered 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 H ill 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 nonpa rticipants in accordance with 14 C.F.R SectionP 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 communica te 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 t o 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 FA A 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

- Numbe r) 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 th e 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 operatio n(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 op erated 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 b e 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. O perations 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 condu cted 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 sufficientl y 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 nonpartici pating 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 wi th 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 hisP a g e | 9 © 2015 CH2M Hill Companies LTD, Inc. All Rights Reserved.

mandate.

The sUAS must be operated wi thin 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 UA S 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.

CH 2M 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

, Pa ge 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 Compan ies 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 (CO A) 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 conductin g 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: Reque sted 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 nece ssary

.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 h azard 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 necess ary

.

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 c ompliance 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 befo re 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 airc raft

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 re duce 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 furthe r 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 equivalen t 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 mapp ing, 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 1 st , 2015

Regards,

Blake Scott

Finance Professional

CH2M Hill Companies LTD, Inc.

9191 S. Jamaica Street

Englewood, Co 80112

720

- 286

- 3487