U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, D.C. 20590

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

Dear Sir/Madam,

Full House Roofing Service hereby petitions for an exemption from the Federal Aviation Regulation 

(FAR) and any other rules necessary to allow the operation of a small unmanned aircraft system 

(UAS) for the purpose of conducting roof inspections to safely produce video and/or photo

documentation and damage assessment for review by the homeowners to aid in decisions regarding

any repairs on their roofs. The operation under the requested exemption will adhere to strict safety

protocols which we will list in this document. The rationale for using an unmanned aircraft system

to perform roofing inspections is to provide a much safer mechanism to all involved parties while

posing no safety or privacy threat to the general public, or any other individuals be they

participating or non-participating parties.

1. Name and mailing address:

Full House Roofing Service

1475 Buford Drive

Lawrenceville, GA 30043 403322

Phone: (770) 338-5499

Email: sales@fullhouseroofing.com

2.The specific section or sections of 14 CFR from which you seek an exemption:

Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Aviation

Regulations, Seeking Exemption from

14 C.F.R. §§ 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command

14 C.F.R. § 61.133(a): Commercial pilot privileges and limitations

14 C.F.R. § 91.119(c) Minimum safe altitudes: General

14 C.F.R. § 91.121 Altimeter settings

14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions

14 C.F.R. § 91.405(a) Maintenance required

14 C.F.R.§ 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or 

alteration

14 C.F.R. §§ 91.409(a)(1) and (2) Inspections

14 C.F.R. §§ 91.417(a) and (b) Maintenance records

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

3. The extent of relief you seek and the reason you seek the relief:
a. 14 C.F.R. §§ 61.113(a) and (b): Private pilot privileges and limitations; 14 C.F.R. § 61.133(a): 

Commercial pilot privileges and limitations

Full House Roofing Service is seeking relief and exemption from the above listed Federal

Aviation Regulation and any other applicable rules to allow the use of a Small Unmanned Aircraft

System (UAS) to conduct roof inspections on structures approximately 25’ to 100’ from the

surface of the ground (AGL). The UAS that Full House Roofing Service will use to conduct the

inspection is a DJI Phantom 3 Professional, an Unmanned Aircraft System widely flown by

recreational flyers, is a personal UAS weighing less than 6lbs, whereas per definition by US

Congress as stipulated in Section 331, PL 112-95, 2014: “6) SMALL UNMANNED AIRCRAFT. – The

term “Small Unmanned Aircraft” means an unmanned aircraft weighing less than 55 pounds.”

The DJI Phantom 3 Professional is small and light weight capable of operating both autonomously 

and manually, with “Return Home” and “Position Stabilization” features. In the event connection 

with the remote controller is lost, the DJI Phantom 3 Professional uses its positioning system

and smart flight technology to return back to the pilot.

Full House Roofing Service respectfully petitions that given the characteristics listed in the

paragraph above, to exempt the operations of the UAS by pilot holding a private pilot’s

certificate or commercial pilot certificate. The risks associated with the operation of these small

UAS are lower than the level of risks associated with commercial operations contemplated by Part

61; allowing operation of the UAS as requested therefore exceeds the level of safety achieved by

14 C.F.R. §§ 61.113(a) and (b).

b. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness

Section 91.7(a) requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Given the characteristics of the UAS such as small size, light weight, low operating 

altitude, short flight time, and the stringent operating restrictions and conditions proposed in this 

petition, an equivalent level of safety will be achieved by compliance with the Standard operating 

Procedure. Full House Roofing Service therefore requests the FAA grant an exemption from

Section 91.7(a) and find that the operator may ensure that the UAS is in an airworthy

condition by complying with the Standard Operating Procedure, the proposed operating 

restrictions and conditions.

c. 4 C.F.R. § 91.119(b) and (c): Minimum safe altitudes

Section 91.119(b) and (c) establish certain minimum altitudes for operation of civil aircraft. 

Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, 

no person may operate an aircraft below the following altitudes: ... (b) Over congested areas. 

Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.”Full House Roofing Service requests

to be exempted from this section since the said UAS will not operate at altitudes higher than

100’ AGL. Taking into account its small size, light weight, low speed and its limited range, also that it

carries no passengers or flammable materials, the UAS may safely fly at a lower altitude that

conventional aircrafts. The buildings that Full House Roofing Service intends to inspect do not rise

higher than 100’ AGL. Relief from this rule is warranted because the operations will be 
conducted with the safeguards and under the operating conditions outlined herein and in the

Standard Operating Procedure.

d. 14 C.F.R. § 91.121: Altimeter settings

It is regulated that 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. 

“(b) The lowest usable flight level is determined by the atmospheric pressure in the area of 

operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

Due to the nature of use of the small UAS to perform roof inspections, the UAS will not fly above 

the altitude of 100’ AGL. Full House Roofing Service respectfully submits to be exempted from 

this section.

e. 14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions

Full House Roofing Service submits to exempt this section taking into consideration the limited 

battery life that in turn limits flight duration of the UAS DJI Phantom 3 Professional and also the

characteristics of the UAS being light weight, low speed, limited range, ability to land very

quickly, operation within visual line of sight, restricted operating area, and the fact that 

they do not carry passengers or any flammable materials. In addition to those characteristics

described in the previous, the DJI Phantom 3 Professional has a safety return feature that

enables it to return home in an event that the battery is running low.

f. 14 C.F.R. § 91.405(a): Maintenance required

14 C.F.R. § 91.407(a)(l): Operation after maintenance, preventive maintenance, rebuilding or 

alteration

14 C.F.R. §§ 91.409(a)(l) and (2): Inspections

14 C.F.R. §§ 91.417(a) and (b): Maintenance records

Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Full House Roofing Service. Maintenance will be accomplished by

the operator pursuant to the manufacturer’s manual and the Standard Operating Procedure.

An equivalent level of safety will be achieved because the UAS are very small in size and weight,

will carry a tiny payload and operate only in restricted areas for short periods of time. If

mechanical issues arise, the UAS can land immediately and will be operating from no higher than

100' AGL. As provided in the Standard Operating Procedure, the operator will ensure that the UAS

is in working order prior to initiating flight, perform required maintenance, and keep a log of any

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and
best suited to maintain the aircraft in an airworthy condition to provide an equivalent level of

safety.

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

Full House Roofing Service also requests exemption from such other FARs as the FAA deems 

appropriate to enable the requested operations. If, during the effective dates of the exemption 

issued pursuant to this petition, the FAA issues interim or final rules for small UAS, Full House 

Roofing Service requests that it be relieved of the requirements of any conditions and limitations

of the exemption and allowed to comply with any less burdensome applicable regulations that

may have become effective.

4. How your request would benefit the public as a whole

The exemption will benefit the general public for the following reasons:

1. By using the UAS to perform roof inspections, an Inspector will not physically climb the

roof, therefore ensuring the Inspector’s safety by minimizing the possibility of a fall as well 

as damage that may occur to the roofing material when a person walks on it.

2. The cost of inspection will be reduced drastically to the general public due to the

minimum time spent on the roof by taking high resolution video and/or photos and 

having a qualified Inspector analyze the content in an office environment.

3. With the UAS as the main tool to perform inspections, no ladder will be required, 

thus removing any safety concerns related to the placement of a ladder, potential damage to 

the home from the ladder and ladder related injury or fall.

4. Most residential roofs are high pitch, therefore not safely navigated by an Inspector. For

this reason, homeowners seldom perform roof inspections to implement preventative

measures until a problem occurs.

5. By inspecting roof conditions, this will ensure the condition and soundness of the 

roof, therefore preventing leaks that cause damages to the property, which eventually can lead

to structural damage to the building, and much later can cause safety liability to the tenants

and the general public.

6. Roof inspections can identify leaks and water intrusion to prevent moisture build up 

inside the building. Moisture build up can stimulate the growth of mildew and bacteria that 

can lead to a health hazard.

5. Reasons why the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to the existing rule;

The exemption would not adversely affect safety, or how the exemption would provide a level of

safety at least equal to the existing rule for the following reasons:

1. The UAS will be operated under a strict Standard Operating Procedure produced by Full 

House Roofing Service. Full House Roofing Service has been in business since 1992 providing 

the highest quality roofing services, establishing a reputation for excellence working with

clients large and small. We are a leading provider of roofing for residential, commercial, and 

multifamily clients throughout the State of Georgia.
2. A geo-fence will be enabled on the UAS that will limit the aircraft from leaving the

airspace above the property to be inspected. A signage barrier will also be constructed around

the property in order to alert the public of the UAS inspection.

3. A flight ceiling limit of 100’ altitude from the adjacent ground level or the height of 

foliage or trees adjacent to the property (lesser of the two) shall be strictly adhered to by the

geo-fence and the operator for all inspections. This ensures that no contact with aircraft in

the NAS will occur with our UAS because manned aircraft cannot fly below the tree line or 

highest nearby obstacle.

4. The property owner shall sign a consent prior to the UAS roof inspection and all nonparticipating persons shall be moved to at least 50’ beyond the perimeter of the geo- fence and

signage barrier prior to the flight.

5. The UAS will not fly near a manned aircraft.

6. The UAS flight and operator will abide by all pre-flight checks and manufacturer

suggested flight protocols. The manufacturer operation manual will be readily available

upon request and the operation manual will be strictly adhered to by the operator.

7. A log of each flight including the duration and location shall be kept with the operator and

available for audit upon request.

8. A take-off and landing zone shall be designated prior to the flight.

9. The radio frequency used for operation and control of the UAS will comply with the FCC or 

other appropriate government agency requirements.

10. The UAS flights will be conducted only during daylight hours under visual

meteorological conditions.

11. The UAS flights will not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud. The UAS flights will not occur when visibility is less than 3 miles

from the operator and visual observer.

12. Full House Roofing Service will maintain a $1,000,000.00 liability insurance policy while

operating the UAS.

13. In accordance with the manufacturer’s operating manual, the UAS operator will

perform extensive pre-flight checks prior to each flight to ensure the UAS is 

functioning properly. In the event that ANY pre-flight inspection item does not pass the

check, the UAS will be permanently grounded until the manufacturer issues a full compliance

certificate stating that the UAS has been repaired, properly maintained, and/or inspected and

deemed safe to fly in accordance with their operating manual.

14. The UAS will have a flight termination option to prevent a “fly away” and the pilot-incommand can safely abort or terminate the flight.

6. A summary we can publish in the Federal Register stating —

a) A brief description of the exemption you seek; a. The rule from which you seek the

exemption; and

b) A brief description of the exemption you seek

a) Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Full House Roofing Service seeks to be exempted from

14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 61.133(a); 14 C.F.R. § 91.119(c); 14

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. §

91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1); 14 C.F.R. §§ 91.417(a) and (b); 14 C.F.R. § 91.7(a)
b) Full House Roofing Service is seeking exemption for:

Most of the rules stipulated in the sections listed above do not apply to the small 

Unmanned Aircraft System because it does not carry any passengers, explosive or

flammable materials that may cause concern to public safety. In addition, the UAS is

light weight, low speed, limited range, ability to land very quickly, operation within visual

line of sight, restricted operating area.

The use of the UAS to perform roof inspections will greatly decrease public safety hazard, as

it eliminates the possibility of falling that may lead to severe injury or death by not requiring

the inspector to climb on to the roof or use a ladder. Full House Roofing Service will put in

place a strict Standard Operating Procedure to be followed by the operator to ensure that

the use of this small, popular unmanned aircraft system will not affect public safety.

With the described use of signage, designated take-off and landing zones, owner consent,

operator maintaining line of site, and all other safety protocols listed above, a safe and

limited operating area can and will be established thereby creating a restricted sterile

environment within which the UAS will operate.

7. Any additional information, views, or arguments available to support your request

A description and specs of the UAS to be used by Full House Roofing Service can be found in 

the attached link to the manufacturers user manual.

8. If you want to exercise the privileges of your exemption outside the U.S., you must state

the reason.

Full House Roofing Service does not wish to exercise the privileges of my exemption outside

the U.S.

Respectfully,

Full House Roofing Service

1475 Buford Drive

Lawrenceville, GA 30043 403322

Phone: (770) 338-5499

Email: sales@fullhouseroofing.com

Link to Manufacturers (DJI) Phantom 3 Professional Advanced User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.4_en_0

915.pdf