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

Milford, 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 Reform 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 for 

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. Sections 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, industrial inspections and analyses. This relief is 
sought 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 pounds 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/rigging 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 maintenance 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 operations 

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 necessary. 
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. 

ii. Conducted in VMC conditions during daylight hours. 

iii. PIC and VO will maintain VLOS at all times. 

iv. 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 

not over persons on the ground without their prior permission. 

ix. 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. 

xiv. 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