Page | 1 

## Uriah Shockley

d.b.a

, 

## Rockwall Home Inspection s 101 Oakridge Drive Rockwall, Texas 75032 www.rockwallhomeinspections.com

(972) 772

- 6050

U.S. Department of Transportation May 19, 2015
Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 1

- 866

- TELL

- FAA (1

- 866

- 835

- 5322)

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

Re: Request for Section 333 exemption and COA Waiver for UAS

Dear Administrator and/or Representative



### About Petitioner and Intentional Use of UAS

Uriah Shockley, a Professional Real Estate Inspector, licensed by , the Texas Real Estate

Commission (TREC), has been performing real estate inspections in the, State of Texas, since 2006.

Uriah Shockley (TREC License # 9413) is seeking Section 333 exem p tion

, for UAS under 55lbs

, along

with

, COA waiver to operate an Unmanned Aircraft System (UAS) for the commercial purpose of

conducting aerial video and photography during inspections of: real e state properties, commercial

properties

, steep roofs, high roofs, draw inspections for lending institutions

, new residential

developments, new infrastructure road developments , phase construction for contractors , and other

commercially legal endeavors in the real estate inspection industry

.Page | 2

The petitione r, Uriah Shockley, ( Owner/Senior Inspector ) of Rockwall Home Inspections, will be

the only designated pilot in control (PIC) of registered UAS. The unmanne d aircraft system will fly during

the day at or below 200 ft, no further than 200ft away and within visual line of sight (VLOS) following all

FAA visual flight rule s (VFR).

Flights at 200 feet would be used to inspect the excavation, surveying, and installation of

infrastructure roads an d new subdivision on large undeveloped acreage

. Using an aerial photo in the

inspection process of large developments projects is necessary. These photos help assure that draw request

by developers from lending institutions are appropriate and correct whil e limiting chance of fraud , errors,

and omissions, since photos can be shared among other knowledgeable fund control specialist s , engineers

,

surveyors, and loan underwriters, for further evaluation. This is simply a cost effective tool (UAS with

camera) to help perform inspections in a rapid and efficient manner, which is important when developers

need payment at time of draw to meet payroll dates for construction companies and their employees in a

timely manner

.

H ome buyers usually have a 3

- 10 day contract option periods to have their home inspected before

finalizing a contract; if roof is too steep or high to inspect they will they would have to get a licensed

roofer with specialized equipment to examine roof; scheduling another inspection cos t s the home buyer

more money and more time which can cause the seller problems. A quick look with a small UAS can

determine if roof is in good shape or if further costly investigation is warranted

. Residential home

inspections make up over 80% of Rockwall home Inspections business. These types of inspections usually

are within 20” feet of subject property for photography and seldom exceed 40 feet in the air for a very

limited time of 3

- 5 minutes , with average speeds 5mph to hovering for photos . It usually takes more time

to complete a preflight test, UAS inspection, calibrate GPS compass and set GPS home point for auto land

for fail safe procedures, than it is to raise UAS within a few feet from structure and take pictures. T his

type of flight does not pose the same risk a helicopter with crew would pose with a heavy, loud, gasPage | 3 combustion engine. The 2 lbs 11oz phantom 2 Vision+ UAS can perform these tasks safely and quietly

without endangering structure or people on ground. Being a licensed real estate insp ector all inspection s

are coordinated through a Centralized Showing Services (CSS) which informs seller and sellers agent of

time and day of inspection to limit any claims of invasion of privacy, Company truck and logo lets all

neighbors now a house is being inspected.

The entire general public benefits from a detailed property inspection report t hat only a small UAS

can perform

. Until rece ntly this type of inspection costs thousands of dollars that only the wealthy could

afford since it involved the cost of a gas combustion aircraft, fuel, pilot on board, flight plans, control

towers and a photographer. Now days, this is available to the en tire general public with better quality,

affordability, and safety. The general public also has quick access to a well documented inspection report

on short notice since coordinating a flight plane with pilot and crew is eliminated.

Please note, due to th e new affordability of small drones more people from the genera l public have their

own drones. It is not uncommon now days that clients show up at an inspection with their own UAS or

ground drone. This has happened three times for the petitioner involving two roofs and one crawl space

that could not be inspected due to safety concerns . The clients brought their own UAS and ground drone

to inspect subject areas of concern.

The general public is surpassing the petitioner (owner/senior inspector) in inspection technology and

inspection capabilities and petitioner is seeking relief from the FAA and DOT to unburden the

cumbersome requirement to be a licensed pilot. It is embarra ssing when a client’s son steps out of the car

and flies his drone over a roof for a detailed inspection.

Also, it is unfair to the entire general public that only their insurance company can fly their drone over

their house for damage inspection, but, th ey cannot have a third party licensed inspector fly over

. Most inspection companies do not have the financial resources to employ a pilot on payroll or resources to

send an inspector to pilot training classes. This is denying the general public of fair, u nbiased third partyPage | 4 inspections. It is also, unfair to most third party inspection companies that can’t afford to hire a licensed

pilot to train unlicensed pilots (home inspectors/claims adjusters) in the proper use of drones that the

general public is usi ng and buying like smart phones.

( Note: Using UAS during inspections far exceeds licensi ng agency , Texas Real Estate Commission

(TREC) , M inimum Standards o f Practice , for , Professional Real Estate Inspectors , and is not

required for a real estate inspection in the, State of Texas

. However, the option for an inspector to

exceed “ M inimum” S tandard s of Practice requirement s , and use state of the art technology would

hopefully be allowed and not impeded, so that, p etiti oner (Senior Inspector) can further protect all

parties involved in the real estate transaction proce ss through the use of cutting edge technolog ie s .

For subdivision development draw inspections this type of photography is found to be priceless

. )



### Regarding the Unmanned Aircraft System

1) The specific UAS the petitioner , Uriah Shockley d.b.a Rockwall Home Inspections

, would like a

section 333 exemption , and COA waiver for is the popular

, Phantom 2 visio n+ by DJI. This is the

same UAS that the FAA is already aware of since this UAS has been granted exemptions in th e

past. The Phantom 2 Vision+ weighs 2lbs

. 11oz (less than 55 lbs)

. This UAS h as built in safety

systems such as; GPS navigated return home

, GPS fail safe system, specialized battery

monitoring for UAS’s electrical power source s, controller, Wi

- Fi range extender , and smart phone

battery

. The UAS also comes packaged with detailed Phantom 2 Vision+ quick start guide,

Phantom 2 Vision + pilot training guide

, Phantom 2 Vision+ user manuals , and Phantom 2

Vision+ video tutorials on DJI web site

. The Phantom 2 Vision+ also has flight limit system

built in for maximum height and distance that prevent the UAS from exceeding preset boundaries.

The Phantom also has a built in flight restriction system that restricts unit from entering restrictedPage | 5

fly zo nes

. While not r equired, the phantom 2 vision+ the petitioner currently uses for training is

equipped with original manufactures equipment rotor guards on all four rotors for additional

safety and to assure the durability, longevity, and proper flight char acter of the Phantom 2 vision+

UAS. The Phantom UAS controller is also FCC compliant according to manual and manufacturer.

( NOTE; the petitioner has included the Phantom 2 Vision+ quick start guide, Phantom 2 Vision+ pilot

training guide

, and Phantom 2 Vision+ user manual at bottom of petition to further describe the subject

UAS performance capabilities and limitations. Receipt and packing slip from DJI factory store is also

included petition as proof of purchase and ownership by petitioner, along with picture of serial number

and model number installed by manufacturer

.

Petitioner is seeking the new stream line guidelines for section 333 exemptions and blanket COA

proposed by FAA website:

“ Under the new policy, the FAA will grant a Certificate of Waiver or Authorization (COA) for flights at or

below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55

pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual l ine of sight

(VLOS) of the pilots, and stay certain distances away from airports or heliports:

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an opera tional tower; or

 2 NM from an airport without a published instrument flight procedure or an operational tower; or

 2 NM from a heliport with a published instrument flight procedure

The “blanket” 200

-

foot COA allows flights anywhere in the country except re stricted airspace and other areas, such as major cities, where the FAA prohibits UAS operations. Previously, an operator had to apply for and receive a COA for a particular block of airspace, a process that can take 60 days. The agency expects the new poli cy will allow companies and individuals who want to use UAS within these limitations to start flying much more quickly than before. ”

Uriah Shockley d.b.a. Rockwall home inspections is seeking this specific new stream line exemption. We find that these guid elines meet our desired objective for inspecting homes and acreage development. Heights at two hundred fe et and below are perfect for the type of inspections

, Rockwall Home Inspections

, performs.Page | 6 Procedures for Preparing and Flying Phantom2 Vision+ UAS

A company flight log

, preflight checklist, post flight checklist maintenance log , and repair log are combined in a single flight checklist to record each flight, Company Flight log , also, includes clients name and contact information, and a ddress of proper ty UAS will be used for inspection

.

Pref light Environment Check List :

 Research area for any restricted fly zones, no fly zones , airports, or helipads before traveling to site

.

 Weather conditions must be clear , daylight hours and wind speed < 17mph

 Check for obstacles such as antennas, water towers and power lines and other obstacles that could affect onboard compass.

 Check skies and listen for any low flying planes or helicopters before and dur ing flight.

UAS Preflight Checklist: Special Note: A luminum (non

- combustible) sticker with

, Preflight Check L ist

, is installed on bottom of Phantom2 Vision+ next to serial number and model number , see attached photo of serial number and check list installed on UAS by manufacturer.

 Remote controller, smart battery, range extender, and smart phone are fully charged.

 Propellers are mounted correctly

 Gimbals’ clamp and lens cover removed

 Landing skid s are in good condition

 Turn on Smartphone Wi

- Fi, Set to Airplane mode (to prevent phone data interruptions)

 Tu rn on controller, range extender , then Smart battery for Phantom

 Motors can start and function normally

 DJI Vision App can connect to Smartphone

 Calibrate compass and home point

 Start motors and let them warm up . Che ck all connectivity lights, and/or warn ing lights

.

 Test flight by raising Phantom 6’

- 7’ and let hover to observe proper flight character.

 Test right and left turn before conducting property inspection for client.

Post Flight Checklist :

 Turn off Smart battery first then controller and range extender.

 Record any hard landing, and examine for any damage.

 Turn off Smartphone Wi

- Fi and turn of f Airplane setting to receive calls normally.Page | 7

Repairs and Maintenance Checklist :

 Record date of any repairs performed by manufacturer

.

 Test fly phantom thoroughly in open field before use if any new repairs were made by manufacturer to assure normal working order.

 Test fail safe and recovery procedures, and return to home function, after any repairs by manufacturer have been conducted.

 Record last date of software and firmware update

.

 Record current version of software and firmware updated.

Note: Radio Frequency is FCC compliant according to manufacturers manual that is included as part of petition.



### Regarding the Unmanned Aircraft PIC

The petitioner Uriah Shockley (owner/senior inspector) , will be the only designated operator of the Phantom2 Vision+ UAS. His experience with the phantom2 Vision+ is his first time experience with any UAS. His education and background with UAS first st arted with massive hours of internet research for the most capable, easiest and affordable UAS that could meet company requir ements, FCC requirements and FAA requirements. This involved hours of several manufacturer videos, reading manufacturer flight

man uals, user manuals, and safety videos for pre flight planning by all manufacturers websites and FAA “know Before You Fly” awareness program and is very knowledgeable of proper use of UAS and safety precautions and regulations. With deep research the p etitioner (designated PIC) has decided on the phantom and ordered it on February 28, 2015. The petitioner (PIC) had read the manual front to back more than 10 times until delivery and was ready to start hands on training when product was received.

The PIC

, f

ollowing manufacturer manual and manufacture pilot training g uide; has been successful in completing close to a 60 + takeoff s and landing s while practicing all skills tests of the DJI Flight training guide without any incidents (phantom remains in excel lent/new condition). During practice flights PIC has practiced advanced fail safe procedures of communication loss and recovery over ten times, set predetermined way points , speed and altitude along with return to home and recovery procedures , PIC conside rs himself proficient in all skills to safely operate the Pantom2 Vision UAS. PIC considers flight time , study, knowledge and training well exceeds 80 hours with actual flight time close to 40 hours.

PIC d oes not have a pilot’s license or a medical certificate and seeks exemption from 14 CFR regulations that requires license and medical certificate since these regulations appear to relate to actual aircraft that carries airmen, pilot, and crew. Also, the phantom2, is le ss than 3 lbs, does not carry combustibles and poses little to no threat to pedestrians should it fall from sky.Page | 8 

### Petitioner Seeks Exemption from Certain 14 CFR Regulations

Part 60

- 67 Pilot certification. Petitioner primary objective is to increase inspection capabilities as a professional, licensed, real estate inspector. Going through the training and certification to be a fully licensed pilot would be cumberso me, time consuming, and counterproductive for a home inspector that is simply looking to add another device to the real estate inspection process. Real

e state inspection is the main focuses and estimate that the use of UAS would be less than 3% of the time, not for extra money , but, as a tool to inspect the hard to reach areas quickly, safely and efficiently. It would be hard to justi fy the cost of becoming a certified pilot when I have a Professional Real Estate Inspector license that I must maintain, along with, with continuing education classes, property inspections, and a business to run. Cost and time wou ld far outweigh the benefit s

. By waiving the pilot certification for petitioner; the petitioner could then offer the general public an inspec tion, that before, only a small portion of the general public could afford.

M edical certification would be unnecessary since phantom2 Vision plus, will land its self should PIC become ill. Phantom 2vision plus weighs less than 3 lbs, carries no pilot, crew, passengers,

ca rgo or combustibles and poses no serious harm to anyone should it fall from sky.

Part 21 subpart H

- UAS is under 55 lbs, does not carry a crew or combustibles. Maximum flight time is less than 25 minutes. Maximum capable speed is 35mph on a calm day. Unit is very small to place identification on the side large enough to see from ground, however, identification can b e placed on UAS. UAS does have a factory aluminum sticker (non

- combustible) on the underbelly with serial and model number (picture included after page 8 of petition) . UAS is registered with DJI (UAS Man ufacturer) for software updates and owner identificat ion. If a required ID is to be submitted, the petitioners’ Texas Real Estate license (TREC 9413) could be another suggested registered number.

Part 91.103 (b)(2) Petitioner does not need an airport or helipad to take off and land since UAS can take off an d land from any location , therefore , does not need a flight plan for flight tower. UAS is flown during day under calm winds, away from airports, at or below 200ft, and no more than 200ft away. UAS will be return ed for landing when battery drop s to 20 %. T his is sufficient time to safely return and down load pictures. UAS avoids all airports, helipads and flight approach areas by 2 to 5 miles or greater. Urban inspections are usually at or below 40 feet while taking off and landing from same location.

Part 91.10 5 Flight crews and stations. UAS is not capable of carrying pilot, crew or passengers

.

Part 91.1 09 Flight Instructions. Use of manufacturers operators manual, completing manufacturers flight training guide along with hands on practice time in an open field following NAS no fly restriction is adequate training. Finding a flight school that is as infor mative as DJI (the manufacturer of Phantom 2) training manuals and tech support website would be difficult and redundant. FAA’s “Know Before You Fly” awareness program and website video has also been studied and previewed several times.

Part 91.151 Fuel r equirements for flights in VFR conditions, UAS takes off and lands in the same location. UAS is returned for landing when battery levels reach 20% , UAS will automatically landPage | 9

if battery drops to 8% . UAS can land anywhere without risk to pedestrians, crew, passengers, pilot

or vehicle on the ground. UAS is not flown over people or vehicles at any time.

Part 91.105 Maintenance required. Little maintenance is required of UAS, except for keeping software current, changing out batteries, or changing out rotors

. Replacing battery is common and does not affect flight character. Any major repairs are performed by manufacturer and product tested by PIC before use. Having it re

- certified for a COA would cost more than the UAS is worth.

Part 91.105 Operation after maintenance . If any repairs are needed the UAS is returned to manufacturer. When returned the PIC will test UAS for normal flight character. If not performing as intended it will be sent back to manufacturer for further evaluation. Getting another COA for the same UA S would seem cumbersome and unnecessary.


### Summary The petitioner

, Uriah Shockley

, is seeking the streamlined exemption 333 and COA waiver for the Phantom2 Vision+, manufactured by DJI inc, for use in the real estate inspection process

. The cumbersome requirement to be a licensed pilot is impeding petitioner from operating on equal ground with large insurance companies and the general public who are now days buying or using their own drone.

Also, it is embarrassing when a claims adjuster can inspect a roof using a drone but a Professional Licensed Real Estate Inspector can’t and its double embarrassing when a clients 14 year old son inspects a roof with equipment I can’t use because I am a licensed for h ire commercial business.

Your help and assistance in obtaining this exemption with COA is deeply appreciated.

Should you have any questions or concerns feel free to call or email me at your convenience.

Best Regards

Uriah Shockley TREC License 9413 Rockwall Home Inspections 101 Oakridge Dr. Rockwall, TX 75032 www.rockwallhomeinspections.com 214

- 236

- 8242 cell 972

- 772

- 6050 office ushockley1@aol.com info@rockwallhomeinspections.comModel Number, Serial Number, FCC ID and Pre Flight Check List.

Phantom2 Vision Plus With Factory Rotor Guards

.Douglas E. Oldmixon Administrator 

# Texas Real Estate Commission P.O. Box 12188 Austin, Texas 78711-2188 

### Professional Inspector License

The person named above is licensed by the Texas Rea l Estate Commission as a professional inspector. **License Expires:** 

### 9413 **URIAH B SHOCKLEY 101 OAKRIDGE DR**  **ROCKWALL, TX 75032**



### 07/31/2015 **Professional Inspector License#: Professional Inspector:**  You may wish to laminate the pocket identification card to preserve it.

**Inquiry as to the status of this license may be made to:**

**Texas Real Estate Commission P.O. Box 12188**  **Austin, Tx 78711-2188 www.trec.texas.gov**  **(512) 936-3000 Fax:(512) 936-3864** 

Douglas E. Oldmixon Administrator **The person named on the reverse is licensed by the Texas**  **Real Estate Commission.**

Texas Real Estate Commission P.O. Box 12188 Austin, Texas 78711-2188 Professional Inspector License

**The person named above is licensed by the Texas Real Estate Commission as a professional inspector.**  **Professional Inspector License #: Professional Inspector:**  **License Expires:** 9413 07/31/2015



### ROCKWALL, TX 75032 101 OAKRIDGE DR URIAH B SHOCKLEY ROCKWALL, TX 75032 101 OAKRIDGE DR URIAH B SHOCKLEY