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 m** **ailing 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 petitionsthatgiventhe characteristics afore mentioned inthe paragraph above, to exempt the operations of the UAS by pilot holding a private pilot’s certificate or commercial pilot certificate.The risks associated withthe operation of these small UAS are lower than the level of risks associated with commercial operations contemplated by Part 61; allowing operation ofthe UAS as requestedtherefore exceedsthe 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 flighttime, and the stringent operating restrictions and conditions proposed in this petition, an equivalent level of safety will be achieved by compliance with theStandard 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 500feet 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 higherthan 100’ aboveground 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 iswarranted because the operations will be conducted with the safeguards and under the

operating conditions outlined herein and in theStandard 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

Dueto 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 c** **onditions**

ROOFCORP OF CA, Inc. submits to exempt this section putting into consideration the limited battery lifethat inturns limitsflight duration ofthe UAS DJI Inspire 1 and alsothe 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 becausethe UAS arevery 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 operatingfrom no higherthan 100’ aboveground level.As provided intheStandard Operating Procedure,the operatorwill ensurethatthe

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 ofthe requirements of any conditions and limitations ofthe exemption and allowed to comply with any less burdensome applicable regulations that may have become effective.

**4. How y** **our 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 analyzingthe 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 leaksthat cause damagestothe property, which eventually can leadto 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 exemptionwould not adversely affect safety, or howthe 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 ofthe 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 non
participating persons shall be moved to at least 50’ beyond the perimeter ofthe 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 eachflight includingthe duration and location shall be keptwiththe operator and availablefor 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 theoperatorand 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

-in

command 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**  **s eek**  **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 ofthe 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 befollowed bythe operatorto ensurethatthe use ofthis 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**  **y our**  **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 exercisethe 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