U.S. Department of Transportation

Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12

- 140 Washington, DC 20590

RE: Docket ID: FAA

- 2014

- 1081

Revised Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the Federal Aviation Regulations

February 9, 2016

Petitioner: AdamVaillancourt Roofing & Construction, LLC

Adam Vaillancourt , CEO

45 Emerson Road

Milfo rd, NH 03055

Tel.: 603

- 673

- 0006

Email: stephen@adamvroofing.com

Website: www.adamvroofing.com

Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Ref orm Act of 2012 (the Reform Act) and 14 C.F.R. Part 11.81, Adam Vaillancourt Roofing & Construction, LLC, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small, unmanned aircraft fo r photogrammetry, inspection, and analyses. All operations shall be conducted within and under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached operator’s manuals.

1. S ections from which exemptions are sought: Application is hereby made for exemption

from: a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91: i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought: a. Adam Vaillancourt Roofing & Construction, LLC wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) photogrammetry, indust rial inspections and analyses. This relief issought because commercial use of sUAS is currently prohibited by law unless performed under an exemption. b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pound s including payload and energy sources:

i. DJI Phantom 3 (see http://www.dji.com/product/phantom

- 3

- pro ) ii. Other models to be added by future amendment to this exemption.

3. Public benefit : a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/r igging failures during stack or bridge inspections). ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon

emissions from manned aircraft.

4

. Safety not adversely affected : a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and mainte nance work will be conducted or approved by qualified personnel such as those authorized by Robotic Skies (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft. c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations: i. A Pilot In Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA

2. A Third Class medical certificate issued under 14 CFR 67.

3. A bi

- annual flight review under 14 CFR 61.56 4. Successful completion of a UAS knowledge test in a specified

form. 5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or UAS fixed

- wing in the case of fixed

- wing flight operati ons under this exemption). Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in

accordance with 14 CFR 91.119. 6. At least 5 hours of flight experience and 3 takeoffs and landings

in make and model being flown in the prior 90 days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.

ii. A Visual Observer. iii. A Sensor Operator as necessar y.d. All flight operations will be conducted in accordance with valid

Certificates of Authorization. e. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

i i. Conducted in VMC conditions during daylight hours.

i ii . PIC and VO will maintain VLOS at all times.

i v. Pre

- flight inspections (including ground control station, if any) and safety risk assessments will be conducted prior to each flight.

v . Flight altitudes will remain below 400 feet above ground level.

vi . Flight ground speeds will not exceed 50 knots.

vii . Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical miles of an airport.

viii . Not be made near persons as required in 14 CFR 91.119 and

no t over persons on the ground without their prior permission.

i x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook.

x . Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever occurs first.

xi

. Any incidents will be reported within 24 hours of occurrence.

xii

. Adam Vaillancourt Roofing & Construction, LLC will maintain liability insurance of at least $1,000,000 issued by a major

aviation insurance underwriter.

xiii . Any applicable local FSDO requirements.

x i v. All other applicable regulations concerned with the operation

of aircraft. f. Aircraft will use FCC compliant 2.4 GHz for command & control of the

aircraft with well

- defined and tested lost link procedures.

Please advise us of any additional information or changes that may be required.

Sincerely,

Adam Vaillancourt, CEO, Adam Vaillancourt Roofing & Construction, LLC