U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

RE: Petition for exemption according to Section 333 of the FAA Modernization and Reform Act 

of 2012 (FMRA)

Dear Sir or Madam,

ROOFCORP OF CA, Inc. 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 a photo documentation 

damage assessment for the perusal of the homeowners to decide on any necessary repairs on 

their roofs. The operation under the requested exemption will adhere to strict safety protocols 

which we will list in the following. The reason behind using an unmanned aircraft system to 

perform the 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 it 

participating parties or non-participating parties.

1. Name and mailing address:

ROOFCORP OF CA, Inc.

2130 S Dupont Drive

Anaheim, CA 92806

Phone: (714) 210 5993

Fax: (714) 940 9917

Email: info@roofcorp.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

ROOFCORP OF CA, Inc. 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 

to conduct roof inspections on structures approximately 25’ to 100’ from the surface of the 

ground. The UAS that ROOFCORP OF CA will use to conduct the inspection is a DJI Inspire 1, 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 Inspire 1 is transcendently small and light weight capable to operate both autonomously 

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

with the remote controller is lost, the Inspire 1 uses its positioning system and smart flight 

technology to return back to the pilot.

ROOFCORP respectfully petitions that given the characteristics afore mentioned 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. ROOFCORP OF CA, Inc. therefore requests FAA to grant an exemption from Section 

91.7(a) and find that the operator may ensure that the UAS are in an airworthy condition by 

complying with the Standard Operating Procedure the proposed operating restrictions and 

conditions. FAA has granted similar exemptions in Exemption Nos. 11136 and 11138.

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.”

ROOFCORP OF CA, Inc. request to be exempted from this section since the said UAS will not 

operate on altitudes higher than 100’ above ground level. Putting 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 on a lower altitude that conventional aircrafts. The residential buildings 

that ROOFCORP OF CA, Inc. intend to inspect does not rise more than 100’. 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. The FAA issued an 

exemption from Section 91.119(c) in Exemption Nos. 11136 and 11138.

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’. ROOFCORP OF CA, Inc. respectfully submits to be exempted from the 

section.

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

ROOFCORP OF CA, Inc. submits to exempt this section putting into consideration the limited 

battery life that in turns limits flight duration of the UAS DJI Inspire 1 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 Inspire 1 has a safety return feature that enables it to return home in an event 

that the battery is running low. The FAA issued an exemption to this regulation for UAS 

operations in Exemption Nos. 11062, 10673, 11136 and 11138.

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 ROOFCORP OF CA, Inc. 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’ above 
ground level. 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. The FAA issued an exemption to these regulations in Exemption Nos. 11062, 11136 and

11138.

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

ROOFCORP OF CA, Inc. 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, ROOFCORP OF 

CA, Inc. 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, this will not require an Inspector to physically 

climb the roof, therefore ensuring the Inspector’s safety by minimizing the possibility of 

accidents happening due to falling.

2. Clay tiles are brittle, by inspecting the roof with the UAS, it will avoid stepping on the clay 

tiles and causing them to crack.

3. 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 photos and having a qualified roofer

analyzing the pictures at the office.

4. 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.

5. Most residential roofs have a very high pitch, therefor it is not walkable. Due to this reason, 

the homeowners seldom perform roof inspection for preventive measures until a problem 

occurs.

6. 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. 

7. Roof inspections can identify leak areas 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 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 

ROOFCORP. ROOFCORP has spent more than a quarter of a century providing the 

highest quality roofing services, establishing a reputation for excellence working on 

tough demanding jobs for clients large and small. Founded in 1985, we are a leading 

provider of roofing and solar installation for commercial, industrial and multifamily 

clients throughout Washington, Oregon and California.

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 geofence 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. ROOFCORP OF CA, Inc. 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, ROOFCORP OF CA, Inc. 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) ROOFCORP OF CA, Inc. is seeking exemption for:

Most of the rules stipulated in the sections listed above does 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 to that, 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 inspection 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. 

ROOFCORP OF CA, Inc. will put in place a strict Standard Operating Procedure to 

be followed by the operator to ensure that the use of this small popular and with 

hobbyist 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 ROOFCORP OF CA, Inc. can be 

found in the attached manufacturer user manual.

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

must state the reason.

ROOFCORP OF CA, Inc. does not wish to exercise the privileges of my exemption 

outside the U.S.

Respectfully,
ROOFCORP OF CA

2130 S Dupont Drive

Anaheim, CA 92806

Phone: (714) 210 5993

Fax: (714) 940 9917

Email: info@roofcorp.com