UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Cochrane Technologies, Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF

THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

3DR X8-M OCTOCOPTER UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333

OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on December 10th, 2015

Rod Reed, Chief Surveyor

Cochrane Technologies, Inc.

3913 Highway 90 East

Broussard La., 70518

Tel: (337) 837-3334

Fax: (337) 837-7134

Email: r.reed@cochranetech.com
TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY 4 

INTRODUCTION AND INTERESTS OF PETITIONER 4 

BACKGROUND 4 

BASIS FOR PETITION 4 

NAME AND ADDRESS OF PETITIONER 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Cochrane Technologies, Inc. SEEKS 

EXEMPTION 7 

THE EXTENT OF RELIEF Cochrane Technologies, Inc. SEEKS AND THE REASON Cochrane 

Technologies, Inc. SEEKS THE RELIEF 10

THE REASONS WHY GRANTING Cochrane Technologies Inc.’s REQUEST WOULD BE IN THE 

PUBLIC INTEREST. 12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 15 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 27

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Cochrane 

Technologies, Inc.’s REQUEST 27

CONCLUSION 28

2 
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

OEM Original Equipment Manufacturer

PIC Pilot In Command

RTH Return-to-Home

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing

3
SUMMARY

Cochrane Technologies, Inc. (hereinafter referred to as “CTI”) seeks exemption from the

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit Cochrane Technologies, Inc. to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial acquisitions within the National

Airspace System (NAS).

INTRODUCTION AND INTERESTS OF THE PETITIONER

CTI is a leading offshore surveying firm offering precise navigation and positioning 

services. Our primary service location is the Gulf of Mexico. We also offer near shore and land 

surveying services for Texas, Louisiana, Mississippi, Alabama and Florida. We are 

headquartered in Broussard Louisiana. 

BACKGROUND

Unmanned Aircraft System: 3DR X8-M Octocopter

CTI seeks an exemption to operate the 3DR X8-M Octocopter UAS for compensation or

hire within the NAS. The 3DR X8-M Octocopter UA is comprised of a vertical takeoff and 

landing (VTOL) and a transportable Ground Control Station (GCS). The 3DR X8-M 

Octocopter UA has a maximum gross weight of approximately 7.7 pounds with battery; 

measures approximately 14 inches in length, 20 inches in width, and 12 inches in height; and 

has a maximum speed of approximately 25 mph. The 3DR X8-M Octocopter UA is equipped 

with four rotors, each being driven by a Lithium Polymer battery powered electric motor. 

The 3DR X8-M Octocopter UAS that will be operated by CTI will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Marking. 

BASIS FOR PETITION

Petitioner, CTI, by and through undersigned representative, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act 

of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

4
Administrator to operate the 3DR X8-M Octocopter UAS within the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, CTI’s operation of the 3DR X8-M Octocopter UAS meets 

the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, CTI requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only 

apply to aircraft with an airworthiness certificate.

CTI submits that the requested relief is proper since an equivalent level of safety will be 

ensured. All maintenance, alterations, or preventive maintenance of the 3DR X8-M Octocopter 

UAS performed by CTI will be in accordance with the methods, techniques, and practices 

prescribed in the operating documents (i.e., the 3DR X8-M Octocopter UAS User Manual, the 

3DR X8-M Octocopter UAS Quick Start Guide, the 3DR X8-M Octocopter UAS Checklists, 

the Smart Flight Battery Safety Guidelines and the 3DR X8-M Octocopter UAS Pilot Training 

Guide). Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OEM 

maintainers will perform higher-level inspections and maintenance per the operating 

documents and OEM standards. CTI will document and maintain all maintenance records for 

the 3DR X8-M Octocopter UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in Command, (PIC), is requested by CTI to the extent 

necessary to allow the proposed UAS flight operations to be conducted by a PIC holding a 

private pilot certificate, as well as an airman medical certificate, and who has demonstrated, by

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate 

the 3DR X8-M Octocopter UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

CTI seeks relief from Section 91.7(a), entitled Civil Aircraft Air Worthiness, because the 

3DR X8-M Octocopter UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, CTI submits that it will ensure that the 3DR X8-M 

Octocopter UAS is in an airworthy condition, prior to every flight, by determining that the UAS 

is in compliance with the operating documents (i.e., the 3DR X8-M Octocopter UA User 

Manual, the 3DR X8-M Octocopter UA Quick Start Guide, the 3DR X8-M Octocopter UA 

Checklists, the Smart Flight Battery Safety Guidelines and the 3DR X8-M Octocopter UA Pilot

Training Guide), and that the aircraft is in a condition for safe flight.

5
CTI also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, because the altitude reporting equipment of the 3DR X8-M Octocopter UAS set to 

zero feet above ground level (AGL), rather than local barometric pressure or field altitude, before 

each flight. The altitude information of the 3DR X8-M Octocopter UAS is provided to the PIC 

via a barometric pressure sensor, Global Positioning System (GPS) equipment, and a radio 

communications telemetry data link, which downlinks from the UAS to the GCS for active 

monitoring of the flight path. A level of safety equivalent to Section 91.121 will be ensured as the 

altitude of the 3DR X8-M Octocopter UAS will be reported to air traffic control (ATC) in feet 

AGL, and to zero feet above ground level (AGL), rather than local barometric pressure or field 

altitude, before each flight. The altitude information of the 3DR X8-M Octocopter UAS is 

provided to the PIC via a barometric pressure sensor, Global Positioning System (GPS) 

equipment, and a radio communications telemetry data link, which downlinks from the UAS to 

the GCS for active monitoring of the flight path. A level of safety equivalent to Section 91.121 

will be ensured as the altitude of the 3DR X8-M Octocopter UAS will be reported to air traffic 

control (ATC) in feet AGL, and CTI will operate the 3DR X8-M Octocopter UAS within 

visual line of sight, at or below 400 feet AGL. 

Additionally, CTI seeks an exemption from requirements of Section 91.151(b), entitled 

Fuel requirements for flight in VFR conditions. CTI submits that safety will not be affected by 

operation of the 3DR X8-M Octocopter UAS during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 12 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least two minutes (i.e., 20 percent battery power remaining). 

In accordance with 14 C.F.R. § 11.81, CTI provides the following information in support 

of its petition for exemption: 

A. Name and Address of the Petitioner.

The name and address of the Petitioner is:

Cochrane Technologies, Inc.

3913 Highway 90 East 

Broussard La., 70518 

The point of contact for this Petition and specific contact information is as follows: 

Rod Reed, Chief Surveyor 

Cochrane Technologies, Inc. 

3913 Highway 90 East

Broussard La., 70518 

Tel: (337) 837-3334 Fax: (337) 837-7134 

Email: r.reed@cochranetech.com

6 
B. The Specific Sections of 14 C.F.R. from which CTI Seeks Exemption.

1. CTI Seeks Exemption from the Requirements of Section 61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or hire;

nor may that person, for compensation or hire, act as PIC of an aircraft.

(a) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if— 

(1) The flight is only incidental to that business or employment; and the 

aircraft does not carry passengers or property for compensation or hire.

2. CTI Seeks Exemption from the Requirements of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. CTI Seeks Exemption from the Requirements of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i)

of this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available

before departure; 

4. CTI Seeks Exemption from the Requirements of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

7 
the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 20 minutes.

5. CTI Seeks Exemption from the Requirement of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. CTI Seeks Exemption from the Requirements of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.]

7. CTI Seeks Exemption from the Requirements of Sections 91.409(a)(1) and

91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of 

this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. CTI Seeks Exemption from the Requirements of Sections 91.417(a) and

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods 

8 
specified in paragraph of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include--

(i) A description (or reference to data acceptable to the Administrator) 

of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the 

AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next 

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after

the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service.

9
C. The Extent of Relief CTI Seeks and the Reason CTI Seeks The Relief.

1. Extent of Relief CTI Seeks and the Reason CTI Seeks Relief f rom Section

61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC

holding a private pilot certificate, as well as an airman medical certificate, and who 

has met certain flight-hour and currency requirements, to conduct the proposed UAS

flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and 

(b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, CTI submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the 3DR X8-M Octocopter 

UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate the 3DR X8-M Octocopter UAS 

in a manner consistent with the operations specifications as set forth herein, including 

evasive and emergency maneuvers, as well as maintaining appropriate distances from

people, vessels, vehicles and structures.

Further, CTI submits that all flights of the 3DR X8-M Octocopter UAS, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 

CTI’s business; and (2) will not carry passengers or property for compensation or 

hire. 

2. Extent of Relief CTI Seeks and the Reason CTI Seeks Relief From Section

91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to 

the extent required to allow CTI to determine that the 3DR X8-M Octocopter UAS is 

in an airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the 3DR X8-M Octocopter User

Manual, the 3DR X8-M Octocopter Quick Start Guide, the 3DR X8-M Octocopter

Checklists, the Smart Flight Battery Safety Guidelines and the Phantom Pilot 

Training Guide). 

10
CTI seeks the requested relief because the 3DR X8-M Octocopter UAS does not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Therefore, CTI will ensure that the 3DR X8-M Octocopter UAS is in an airworthy

condition based upon its compliance with the operating documents prior to every 

flight and further, determine the aircraft is in a condition for safe flight, as stated in 

the conditions and limitations below. 

3. Extent of Relief CTI Seeks and the Reason CTI Seeks Relief f rom Section

91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the 3DR X8-M Octocopter UAS, because the 3DR X8-M 

Octocopter UA’s altitude reporting equipment may be set on the ground to zero feet

AGL, rather than local barometric pressure or field altitude, before each flight. The

3DR X8-M Octocopter UAS utilizes a barometric pressure sensor, GPS equipment,

and a radio communications telemetry data link to downlink altitude information 

from the UAS to the PIC at the ground control station (GCS). 

Considering the limited altitude of the proposed operations, relief from 14 

C.F.R. §91.121 is sought to the extent necessary to comply with the applicable

conditions and limitations stated below. As more fully set forth herein, a level of 

safety equivalent to Section 91.121 will be ensured as the altitude of the 3DR X8-M 

Octocopter UAS will be reported to air traffic control (ATC) in feet above ground 

level (AGL), and CTI will operate the 3DR X8-M Octocopter UAS within visual line 

of sight, at or below 400 feet AGL. 

4. Extent of Relief CTI Seeks and the Reason CTI Seeks Relief From Section

91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions, is requested to the extent required to allow flights of the battery powered 

3DR X8-M Octocopter UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR) for a total duration of 12 minutes 

to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least two minutes (i.e., 20 percent battery power remaining). CTI seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered 3DR X8-M Octocopter UAS will severely 

constrain the practicality of any aerial acquisition and research flight operations that 

CTI proposes 

11 
to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR X8-M 

Octocopter UAS, the 3DR X8-M Octocopter UAS operating documents, and CTI’s

proposed operating limitations, ensure that CTI will safely operate the battery powered

3DR X8-M Octocopter UAS during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 12 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least two minutes (i.e., 20 percent battery power 

remaining).

5. Extent of Relief CTI Seeks and the Reason CTI. Seeks Relief From Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) only apply to aircraft with an airworthiness certificate, CTI requests relief from 

these Sections because the 3DR X8-M Octocopter UAS does not require an

airworthiness certificate. As set forth more fully below, the 3DR X8-M Octocopter

UAS meets the conditions of Section 333 of the FMRA for operation without an

airworthiness certificate.

All maintenance, alterations, or preventive maintenance on the UAS of the 3DR 

X8-M Octocopter UAS performed by CTI will be in accordance with the methods, 

techniques, and practices prescribed in the operating documents (i.e., the 3DR X8-M 

Octocopter User Manual, the 3DR X8-M Octocopter Quick Start Guide, the 3DR X8-

M Octocopter Checklists, the Smart Flight Battery Safety Guidelines and the 3DR 

X8-M Octocopter Pilot Training Guide). Furthermore, only the Original Equipment 

Manufacturer (OEM) or qualified OEM maintainers will perform higher level 

inspections and maintenance per the operating documents and OEM standards. CTI

will document and maintain all maintenance records for the 3DR X8-M Octocopter 

UAS. 

D. The Reasons Why Granting CTI’s Request Would Be in the Public Interest; That Is, 

How It Would Benefit the Public as a Whole.

Granting the present Petition will further the public interest by allowing CTI to

safely, efficiently, and economically perform aerial acquisitions and research within the 

NAS, commercially, in support of government entities, agriculture, scientific studies, 

railroad industry, and the oil and gas industries. Additionally, use of the 3DR X8-M 

Octocopter UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of CTI 's proposed operation of 

the 3DR X8- 12
M Octocopter UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisition And Research Performed.

CTI submits this Petition to commercially operate the 3DR X8-M Octocopter 

UAS and perform aerial acquisitions within the NAS, in support of government 

entities, agriculture, scientific studies, mining, and industry (e.g., railroad, gas, and oil 

industries). The 3DR X8-M Octocopter UAS will provide safe, efficient, and

economical aerial acquisition and research operations to further each of these fields,

all of which are critical to the well-being of the general public. 

The specific operations that CTI will perform with the 3DR X8-M Octocopter 

UAS demonstrate how the requested exemption will directly benefit the abovereferenced industries and the public. In the railroad, oil, and gas industries, the 3DR 

X8-M Octocopter UAS will be used to: aid in facility inspections; survey and plan 

new worksites; survey of damage cause by storms, natural disasters, and accidents; 

and perform right of way analysis. The 3DR X8-M Octocopter UAS may also further 

environmental management by mapping deforestation and surveying point source 

pollution. 

2. The Public Will Benefit from Decreased Congestion of the NAS.

The 3DR X8-M Octocopter UAS is battery powered and serves as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized to 

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform

aerial acquisitions, an exemption allowing the use of a 3DR X8-M Octocopter UAS

would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, and increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced.

The 3DR X8-M Octocopter UAS does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial survey missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations.

3. The Public Will Benefit from the Safety and Efficiency of the 3DR X8-M

Octocopter UAS.

Conducting aerial acquisitions with the 3DR X8-M Octocopter UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of

13 
air and noise pollution generated during traditional aerial survey flight operations. By

using battery power and electric motors, the 3DR X8-M Octocopter UAS produces 

no air pollution, and is the most viable environmentally conscious alternative to the

cabin class, six cylinder internal combustion twin engine aircraft that are typically

utilized for aerial acquisitions, and burn approximately 20-30 gallons per hour of 

leaded aviation fuel. The 3DR X8-M Octocopter UAS, while reducing the carbon 

footprint of aerial acquisitions, also reduces noise pollution, as the UAS is propelled 

by battery powered electric motors, rather than an internal combustion engine. 

By using the 3DR X8-M Octocopter UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually

associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the 3DR X8-M Octocopter UAS (weighing 

approximately 7.7 pounds at its maximum gross weight; measuring approximately 20

inches diagonally; and carrying no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the

manned aircraft that typically conduct aerial acquisitions (weighing approximately

6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a

fuel capacity of 180 gallons).

4. Performing Aerial Acquisition Operations with the 3DR X8-M Octocopter UAS

Will Benefit the Economy.

In addition to being safe and efficient, the 3DR X8-M Octocopter UAS is also 

an economical alternative to using manned aircraft to conduct aerial acquisitions. As

such, operation of the 3DR X8-M Octocopter UAS will allow United States based 

companies, like CTI, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order 

to remain competitive. Operating the battery powered 3DR X8-M Octocopter UAS is 

one such technology that not only allows companies greater operational flexibility

compared to manned aircraft, but provides such flexibility without the high

operational cost of a traditional manned aircraft. By operating the 3DR X8-M 

Octocopter UAS, companies such as CTI, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will

ultimately contribute to growth of the U.S. economy. Improved financial

performance of U.S. companies, through commercial use of the 3DR X8-M 

Octocopter UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in

14 
research and development in order to remain competitive both in the United States

and abroad. 

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, CTI’s proposed operation of the 3DR X8-M Octocopter UAS 

will not implicate any privacy issues. Specifically, the 3DR X8-M Octocopter UAS

will only be operated pursuant to the specific conditions and limitations set forth

herein, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the 3DR 

X8-M Octocopter UAS will not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure, which is not directly involved in the operation. 

E. 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 CTI Seeks Exemption.

1. Reasons Why The 3DR X8-M Octocopter UAS Meets the Conditions of the FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, CTI’s operation of the 3DR X8-M 

Octocopter UAS meets the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section

333 provides authority for a UAS to operate without airworthiness certification and

sets forth requirements for considering whether a UAS will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security. Specifically,

FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, operational capability, proximity to airports and populated

15 
areas, and operation within visual line of sight do not create a hazard to 

users of the national airspace system or the public or pose a threat to 

national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section

that certain unmanned aircraft systems may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.

In seeking this exemption, CTI submits that the 3DR X8-M Octocopter UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the 3DR X8-M Octocopter UAS; (b) the pilot certification

requirement; and (c) the specific operating limitations. 

a. The Specifications Of The 3DR X8-M Octocopter UAS Demonstrate Its

Safe Characteristics.

The 3DR X8-M Octocopter UAS does not create a hazard to users of the NAS or

the public, or otherwise pose a threat to national security considering its size,

weight, speed, and operational capability.

i. Technical Specifications of the 3DR X8-M Octocopter UAS.

The technical specifications of the 3DR X8-M Octocopter UAS are 

attached hereto as Exhibit A - Technical Specifications. Exhibit A 

contains proprietary information and is to be held in a separate file 

pursuant to 14 C.F.R. § 11.35(b).

ii. The 3DR X8-M Octocopter UAS Autonomous Flight And Navigation

Modes Enable The UAS To Remain Within A Defined Operational

Area.

The 3DR X8-M Octocopter UAS may be operated in both semi and fully

autonomous flight modes. The 3DR X8-M Octocopter UAS autonomous

features include the following: a GPS Position and Altitude Hold when

the GCS controls are released to their neutral positions; a Return-to-Home

(RTH) function; and Flight Limits (i.e, pre-set limitations that restrict the

distance and height of the UAS flight operations).

16 
iii. The 3DR X8-M Octocopter UAS Is Designed for Automatic Return t o

Home Point or Auto-Land in the Event of Loss of the Control Link or

Navigation.

A complete description of the Failsafe Functions of the 3DR X8-M

Octocopter UAS is set forth at pages 20 and 21 of the 3DR X8-M

Octocopter User Manual, attached hereto as Exhibit B. Exhibit B 

contains proprietary information and is to be held in a separate file

pursuant to 14 C.F.R. § 11.35(b).

iv. The 3DR X8-M Octocopter GCS and Its Operation.

A complete description of the operation and specifications of the 3DR X8-

M Octocopter GCS is provided on pages 2 through 34 of the 3DR X8-M 

Octocopter Operation Manual attached hereto as Exhibit C. A copy of the 

3DR X8-M Octocopter Operation Manual, which contains proprietary

information, is attached hereto as Exhibit C, and is to be held in a separate

file pursuant to 14 C.F.R. § 11.35(b).

b. Flight Operations of the 3DR X8-M Octocopter UAS Are Limited to the

Line of Sight of a Certificated Pilot in Command with a Safety Observer.

CTI will only utilize certificated pilots who possess a current and valid FAA

issued airman medical certificate to act as a pilot in command (PIC) of the 3DR

X8-M Octocopter UAS. Additionally, a safety observer will assist all pilots

during flight operations.

c. Flights Of The 3DR X8-M Octocopter UAS Will Be Conducted Pursuant

t o Specific Operating Limitations.

In seeking this exemption, CTI proposes to commercially operate the 3DR X8-

M Octocopter UAS for the special purpose of conducting aerial acquisitions 

within the NAS, pursuant to the following specific operating limitations:

Operations authorized by this grant of exemption are limited to the following 

aircraft described in the operating documents, which is a quad-rotor aircraft 

weighing less than 7.6 pounds at maximum gross weight: 3DR X8-M 

17 

1.
Octocopter Unmanned Aircraft System. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial acquisitions.

3. The UAS may not be flown at an indicated airspeed exceeding 30 knots.

4. The UAS must be operated at an altitude of no more than 400 feet above ground

level (AGL), as indicated by the procedures specified in the operating

documents. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued

airman medical certificate.

6. The use of first person view (FPV) by the PIC or visual observer (VO) is not

permitted.

7. All operations must utilize a visual observer (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.

Electronic messaging or texting is not permitted during flight operations. The

PIC 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 the operating documents.

8. The VO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant

of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to the grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

18 
10. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition

for safe flight. If the inspection reveals a condition that affects the safe

operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS 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 the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component,

must undergo a functional test flight. The PIC who conducts the functional test

flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the relevant

sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of replacement/overhaul component parts

must be noted in the aircraft records, including total time in service, description

of work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third- class medical certificate. The PIC must also meet the flight review

requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is

rated on his or her pilot certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). The VO is also required to complete the operator’s training

requirements. A record of training must be documented and made available

19
upon request by the Administrator. Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building), are

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight

operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. 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.

20. The UA may 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 Notice to Airmen ( NOTAM) as required by

the operator’s COA. The letter of agreement with the airport management must

be made available to the Administrator upon request.

21. The UA 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.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

24. The 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 UA with 20% battery power

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate

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

grant of exemption. This COA will also require the operator to request a

NOTAM not more than 72 hours in advance, but not less than 48 hours prior to

the operation. All operations shall be conducted in accordance with airspace

requirements in the ATO issued COA including class of airspace, altitude level

and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must 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,

20
Subpart C. Markings must be as large as practicable. Before conducting 

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

UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

27. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the UAS is

operating. These documents must be made available to the Administrator or any

law enforcement official upon request.

28. The UAS must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

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

30. The UAS may not be operated over congested or densely populated areas.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, VO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UAS and/or debris in the event of an accident. The

operator must 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 UAS, flight operations must

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present an

undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with

permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. 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)

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

21
2. Reasons Why an Exemption from the Requirements of Section 61.113 (a) and (b)

Would Not Adversely Affect Safety.

CTI submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the 3DR X8-M 

Octocopter UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the 3DR X8-M 

Octocopter UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

Considering CTI’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements 

to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the 3DR X8-M Octocopter UAS, CTI

submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for CTI’s

specific proposed flight operations.

CTI will not allow any PIC to operate the 3DR X8-M Octocopter UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the 3DR 

X8-M Octocopter UAS training and currency requirements, that the PIC is able to 

safely operate the 3DR X8-M Octocopter UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at

least 10 hours logged as a UAS pilot with a multi-rotor UAS (with a minimum of 5 

hours of those hours as a UAS pilot operating the same make and model of UAS to be 

used for operations under the exemption). In addition to the hour requirements, the 

PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency

purposes). 

22
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during CTI’s proposed operations. The Administrator has 

held that prior documented flight experience that was obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows: In Exemption 

No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive 

rather than additive; i.e. 5 hours make and model time may be included in the 10 

hours of multi-rotor time and the 10 hours may be included in the total 25 hours of 

UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 

take-offs and landings in the preceding 90 days (for currency purposes). The FAA 

finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely conduct 

the petitioner’s proposed operations. The FAA also finds that prior documented flight 

experience that was obtained in compliance with applicable regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. During 

training, proficiency, and experience-building flights the PIC is required to operate 

the UAS with appropriate distances in accordance with 14 C.F.R 91.119 Exemption 

No. 11138 at page 15. 

Accordingly, CTI will ensure safe operations by not allowing any PIC to operate 

the 3DR X8-M Octocopter UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour and currency requirements, that the PIC is able to safely operate

the 3DR X8-M Octocopter UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

3. Reasons Why an Exemption from the Requirements of Section 91.7(a) Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, CTI will ensure that the 3DR X8-M Octocopter UAS is 

in an airworthy condition based upon the 3DR X8-M Octocopter UAS’s compliance 

with its operating documents (i.e., the 3DR X8-M Octocopter User Manual, the 3DR 

X8-M Octocopter Quick Start Guide, the 3DR X8-M Octocopter Checklists, the 

23
Smart Flight Battery Safety Guidelines and the 3DR X8-M Octocopter Pilot 

Training Guide, and as stated in the conditions and limitations herein. 

The 3DR X8-M Octocopter UAS has been the subject of multiple Grants of 

Exemption from Section 91.7(a). Additionally, the FAA has previously granted relief 

from Section 91.7(a) specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161,11166, 11167, 11170, 11171, 11172). 

4. Reasons Why an Exemption from the Requirements of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be

maintained because the altitude of the 3DR X8-M Octocopter UAS will be 

reported to air traffic control (ATC) in feet above ground level (AGL), and CTI

will operate the 3DR X8-M Octocopter UAS within visual line of sight, at or 

below 400 feet AGL. Furthermore, the altitude information of the 3DR X8-M 

Octocopter UAS will be provided to the PIC via a barometric pressure sensor, 

GPS equipment and a radio communications telemetry data link, which downlinks 

from the UAS to the GCS for active monitoring of the flight path and altitude. 

Prior to each flight, a zero altitude initiation point is automatically established by 

the UAS at ground level. 

The 3DR X8-M Octocopter UAS has been the subject of multiple Grants of 

Exemption from Section 91.121. The FAA has previously granted relief from 

Section 91.121 specific to UAS, in circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161, 11166, 11167, 11170, 

11171). 

5. Reasons Why an Exemption from the Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety

established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical 

specifications of the 3DR X8-M Octocopter UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, CTI will ensure that it will safely operate the battery powered 3DR 

X8-M Octocopter UA during daylight hours in visual metrological conditions 

24 
(VMC) under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 14 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least two minutes (i.e., 20 percent 

battery power remaining). Here, as in Exemption No. 11109, the technical 

specifications of the 3DR X8-M Octocopter UAS; the limitations on the 

proposed flight operations; and the location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the 3DR X8-M Octocopter UAS provides 

audible and visual warnings to the PIC at the GCS when the UAS has low battery 

power remaining.

Significantly, the 3DR X8-M Octocopter UAS has been the subject of 

multiple Grants of Exemption from Section 91.151 and other previous 

exemptions granted by the FAA concerning Section 91.151 establish that safety is 

not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has 

previously granted relief from Section 91.151 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161, 11166, 11167, 11170, 11171, 11172). 

6. Reasons Why An Exemption from the Requirements of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely

Affect Safety.

In seeking this exemption, CTI submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established 

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

will be met because all maintenance, alterations, or preventive maintenance of the 

3DR X8-M Octocopter UAS performed by CTI will be in accordance with the 

methods, techniques, and practices prescribed in the operating documents (i.e., 

the 3DR X8-M Octocopter User Manual, the 3DR X8-M Octocopter Quick Start 

Guide, the 3DR X8-M Octocopter Checklists, the Smart Flight Battery Safety 

Guidelines and the 3DR X8-M Octocopter Pilot Training Guide). Furthermore, 

only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers 

will perform higher level inspections and maintenance per the operating 

documents and OEM standards. CTI will document and maintain all maintenance 

records for the 3DR X8-M Octocopter UAS. 

25 
Since the 3DR X8-M Octocopter UAS will be inspected as prescribed by the 

operating documents, CTI will maintain the equivalent level of safety established 

by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating 

documents are attached hereto, identified as the following Exhibits: (A) the 3DR 

X8-M Octocopter Technical Specifications; (B) the 3DR X8-M Octocopter 

Failsafes; and (C) the 3DR X8-M Octocopter Operating Manual. The foregoing 

exhibits contain proprietary information and are to be held in a separate file 

pursuant to 14 C.F.R. § 11.35(b). 

Likewise, the exemption sought will not adversely affect safety because all

maintenance, alterations, or preventive maintenance of the 3DR X8-M 

Octocopter UAS will be performed by CTI in accordance with the methods, 

techniques, and practices prescribed in the operating documents. Only the 

Original Equipment Manufacturer (OEM) or qualified OEM maintainers will 

perform higher level inspections and maintenance per the operating documents 

and OEM standards. CTI will document and maintain all maintenance records for 

the 3DR X8-M Octocopter UAS. 

Furthermore, an equivalent level of safety established by Sections 91.407, 

91.417(a) and 91.417(b), CTI will document and maintain all of the maintenance 

records for the 3DR X8-M Octocopter UAS. The 3DR X8-M Octocopter UAS

has been the subject of multiple Grants of Exemption from Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b) and other previous 

exemptions granted by the FAA concerning these Sections establish that safety is 

not adversely affected when the technical characteristics and operating limitations 

of the UAS are considered (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 

11172). 

7. The FAA May Prescribe Any Other Conditions for Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act 

of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, CTI requests 

that the FAA prescribe special conditions for the intended operation of the 3DR 

X8-M Octocopter UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). Such special conditions will permit safe operation of the UAS for 

the limited purpose of conducting aerial acquisitions within the NAS for

compensation or hire. FMRA Section 333 sets forth the requirements for 

26 
considering whether a UAS will create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security; and further, provides the authority

for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in 

the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. § 21.16, for operation of the 3DR X8-M Octocopter UAS, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the 

aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

contain adequate or appropriate safety standards for an aircraft, aircraft

engine, or propeller because of a novel or unusual design feature of the

aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards

for the aircraft, aircraft engine or propeller as the FAA finds necessary to

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, 

the FAA may prescribe special conditions for CTI's intended operation of the 

3DR X8-M Octocopter UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

F. A Summary That Can Be Published in the Federal Register, stating: The Rules from

which CTI Seeks Exemption:

CTI seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b).

A Brief Description of the Nature of the Exemption CTI Seeks:

This exemption will permit CTI. to commercially operate an Unmanned Aircraft System

(UAS) for the purpose of conducting aerial acquisitions within the National Airspace

System (NAS).

G. Any Additional Information, Views, Or Arguments Available To Support CTI’s

Request.

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, CTI’s request for exemption may be granted 

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

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness 

certification.

As discussed in detail above, CTI will operate the 3DR X8-M Octocopter UAS safely 

in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose 

a threat to national security.

CONCLUSION

As set forth herein, CTI seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation

of the 3DR X8-M Octocopter UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial acquisitions within the National Airspace System (NAS). 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing CTI to safely, efficiently, and economically operate the 3DR X8-M 

Octocopter UAS commercially within the NAS.

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

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

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit CTI to operate the 3DR X8-M Octocopter UAS commercially for 

the purpose of conducting aerial acquisitions within the NAS. 

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Dated: December 15th, 2015 

Respectfully submitted,

Cochrane Technologies, Inc.

Rod Reed, Chief Surveyor

Cochrane Technologies, Inc. 

3913 Highway 90 East

Broussard La., 70518 

Tel: (337) 837-3334 

Fax: (337) 837-7134 

Email: r.reed@cochranetech.com

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