From: Neil RBruris To: Federal Aviation Administration

Subject: REQUEST FOR ISSUANCE OF EXEMPTION UNDER TITLE 14CFR, SECTION 333 Ref: (a) 

### FAA Notice 8900.268 (b) Title 14CFR End: (1) Explanation of Exemptions from 14C.F.R.

To Whom It May Concern, 10Sept2015

Neil R Bruns here by applles for an exemption from the listed Federal Aviation Regulations and any other rules necessary to allowoperation ofa small hobbysized unmanned aircraft {UAS) 

### in order to conduct roof inspections at a lesser height of75' or surrounding foliage/tree height from the ground surface. The sole purpose of using the UAS is to gatherphotographic documentation ofthe condition ofthe roofing materials in orderto safely aid in the consulting of roofing conditions. By strictlyadhering to selfimposed safety protocols listed belowthe use ofthe UAS will provide much safer roof inspections to all parties involved while posing no safety or privacy threatto the general public, the participating inspection parties, or non-participating parties. 

### 1. Neil 

### RBruns 1565 Cassella Montezuma Rd. Maria Stein, Ohio45860 Phone: (419) 852-5498 Email: nbruns@oiroof!ng.com
2. The specific section or sections of 14CFR from which you seek an exemption: Exemption Request Pursuant to Section 333 ofthe FMRA and Part 11 ofthe Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart 

### H; 14 C.F.R. 45.23{b); 14 C.F.R. 45.27; 14 C.F.R. 61.113(a) and (b); 14C.F.R. 91.119(c); 14 C.F.R. 91.121; 14C.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) and (2); 14 C.F.R. 91.417(a) and 

### (b).
3. The extent of reliefyou seek and the reason you seek relief.

NeH R Bruns is requesting relief and exemption from the listed Federal Aviation Regulations and any other applicable rules in orderto allowthe use ofa Small Unmanned Aircraft System (UAS) as defined 

### bythe US Congress 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." To conduct roof inspections on structures less than 75' in total heightfromthe adjacent ground surface or surrounding foliage/tree heightfrom the ground surface (lesser of the two}. The request would allow inspection of roofs and roofing materials in order to assess and photograph these conditions without placing any personnel at risk offall or injury. Per U.S. Department of Labor News Release Number:**10~1753-NAT-** "Fatalities from falls are the number one cause ofworkplace deaths in the construction industry. We must nottolerateworkers being killed in thefield ofconstruction when effective means are readily availableto prevent those deaths", said Assistant Secretary of Labor and Occupational Safety and Health, Dr. David Michaels. "Almostevery week, we see a worker killedfrom falling off a roof. We can stopthese fatalities, and we must". The use ofan UAS would eliminate any risk ofpersonnel offalling off a roofduring roof inspection and subsequently eliminate injury and or death. 4. How your request would benefitthe public as awhole. The exemption would benefitthe public as awhole in the following ways. a.) Safety ofthe workerwho is part ofthe public as awhole. Because the worker is not physically climbing the roof, no possibility offall or injury is present. b.) Due tothe lack of physical roof inspection, would not be extended to the roof. Several accidents and or damage from ladder displacement would no longer be a safety concern to the public. c.) The timeliness of roof inspections would greatly improve, resulting in property owners and tenants being able to return to a productive state more quickly. This wiH also result in employees returning to a safe workplace. d.) The use ofan UAS for roof inspections would decrease the risk exposure ofproperty owners from a liability suit resulting from a rooffalL e.) A morethorough inspection could take place thereby a more efficient, comprehensive and accurate settlement forthe public. f.) The domino effect of lower cost of roofing forthe public start with more efficient inspection techniques. The use ofthe UAS drastically reduces time and liability ofthis process. Aflight ceiling limit of 75' altitude from the adjacent ground level orthe height of foliage or trees (lesser ofthe two) shall be strictly adhered to bythe geo-fence and pilot-incommand for all inspections. This ensures that no contact with aircraft in the NAS will occur with our UAS because manned aircraft is notallowedto operate at such low altitude. g.) The public as a whole would benefitdue tothe reduced time to process insurance claims, especially in natural disasters or catastrophe situationsthereby allowing affected insureds to return to work faster and rebuild faster after a loss. The public economy as a whole will recover much more quickly after a natural disaster with the use of UAS roof inspections. In accordance with the manufacture's operating manual, UAS pilot-in-commandwill perform an extensive pre-flight check priorto each flightto ensure the UAS is functioning properly. In the eventthatANY pre-flight item does not pass the designated check, the UAS will be permanently grounded untll such atime thatthe UAS is in full compliance with manufactures standards. Acompliance statementfrom the manufacture stating the UAS has been repaired, properly maintained, and/or inspected and deemed safe to fly in accordance with their operating manual.5. Reasons whythe exemption would not adversely affect safety, or howthe exemption would providea level ofsafety at least equal tothe existing rule. The exemption would notadversely affect safety dueto self-imposed safety protocols by Neil 

### RBruns. By executingthe safety protocols listed below, the general public would be much safer thanthe current state and process of inspecting roofs requiring physical climbing.
a. The UAS would be operated only by personnel who possess 

### a Drone/UAV Certificatefrom Unmanned Vehicle University. This certificate is only attainable by successfully completing a 

### 50 hourtraining course in accordance with FAA AC 

### 91-57. Neil 

### RBruns will also require an additional100 hour bfflight experience that includes a minimum of

### 50 take-offs and landings with the UAS priorto any roof inspections. 

### b. All operations will utilize an optical observer in addition tothe pilot-in-command. c. The visual observer and the pilot-in-command will be able toverbally communicate at all times. d. The pilot-in-command will wear a high visibilityvestthereby identifying himself as the pilot. e. A geo-fence will be enabled on the UAS thatwill eliminate the aircraftfrom leavingthe airspace above the property being inspected. A signage barrierwill also be erected around the propertyto alertthe public ofthe UAS inspection. f. Aflight ceiling limit of75' altitude from the adjacent ground level height offoliage or trees adjacentto the property (lesser ofthe two) shall be strictly adhered to bythe geefence and pilot-in-command for all inspections. This ensures that no contactwith aircraft In the NAS will occur with the UAS because manned aircraft cannot fly belowthe tree line orthe highest obstacle. g. The property owner shall sign a consent form priorto the UAS roof inspection. A!! adjacent property owners will be notified ofthe proposed flightto include time, date, estimated length oftime, and flight path. All non-participating persons shall be moved to a minimum of

### 50' beyond the perimeter ofthe geo-fence setting priortothe flight. h. The UAS wlll notfly near or in the vicinity ofa manned aircraft. L The UAS Will always be in a !ine ofsight with the pilot-in-command and thevisual observer. This will enable the pilot-in-commandto avoid any obstacles presentat the inspection site. j. The UAS will be less than 5Sibs. and will not exceed a ground speed of

### 50 knots. k. The UAS will end at 20 minutes offlighttime orwhen flight battery reaches 25% of maximum charge, whichever occurs first. 

### I. The UAS will not carry any flammable liquids. m. The UAS flight pilot-in-command will abide by all pre-flight checks and manufactures suggested flight protocols. The manufacturer operation manual will be readily available upon request and the operation manual will be strictly adhered to by the pilot-incommand. n. A log of each flight including, but not limitedto the duration and location shall be kept with the pilot-in-command and available upon request. o. An appropriate take-offand landing shall be determined and designated priorto flight.p. The radio frequency used for operation and control ofthe UAS will comply with the FCC orother appropriate governmentagency requirements. q. The UAS will have Neil R Bruns's contact information and federal exemption number permanently attached. r. The UAS flights

### will be conducted only during daylight hours under meteorological appropriate conditions. s. The UAS flights will nottake place within 500ft below or within 2000' horizontallyfrom a doud. The UAS flights will not occurwhen vlsibllity is less than 3 miles. t. Neil R Bruns

### will maintain a$1,000,000.00 liability insurance policy while operatingthe UAS. u. fn accordance with the manufacture's operating manual, UAS pilot-in-command will perform an extensive pre-fllght check priorto each flight to ensure the UAS is functioning properly. In the event thatANY pre-flight item does not pass the designated check, the UAS will be permanentlygrounded until such atime thatthe UAS is in full compliance with manufactures standards. A compliance statementfrom the manufacture statingthe UAS has been repaired, properly maintained, and/or inspected and deemed safe to fly in accordance withtheir operating manual. v. The UAS will have a flighttermination option to prevent "fly away" and the pilot-incommand can safelyabort orterminate the flight.
By fulfilling these comprehensive safety protocols, the UAS flights to inspect roofs by Neil RBruns greatly exceeds the FAA safety rules as listed in the Model Aircraft Operations Limits in the FAA Modernization and Reform Act of2012.

6. A summary we can publish in the Federal Register Statinga. The rule from which you seek exemption; and b. A briefdescription ofthe exemption you seek Steven GGood is seeking exemption from: Exemption Request Pursuantto Section 333 ofthe FMRA and Part 11 oftheFederal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. 45.23{b}; 14 C.F.R. 45.27; 14 C.F.R. 61.113(a} and (b); 14 C.F.R. 91.119(c); 14C.F.R. 91.121; 14 C.F.R. 91.151(a); 14C.F.R. 91.405(a}; 14 C.F.R. 91.407(a)(1); 14 C.F,R. 91.409(a)(1) and {2); 14 C.F.R. 91.417(a) and (b). A briefdescription ofthe exemption l seek is as follows: By adhering to much morestringent safety measures than is described by the Model Aircraft Operations Limits according to the FAA Modernization Act of2012, I am seeking exemption ofthe above listed rules. Mostofthe rules do notapplyto small unmanned aircraft as no pilot or passengers can be carried and the UAS to be used weighs less than 7 lbs. and does not carry flammable liquid fuels or explosive materials. The sole purpose ofthe UAS is to gather photographic documentation ofa roof in orderto issue a report on serviceability and sustainability. The photos can be obtained quickly and safely bythe use of UAS thereby eliminatingthe chance ofa fatal or debilitating rooffall bythe inspector andcoUateral damage, both human and material. Safe and responsible operation ofa hobby sized UAS to gather photos of a roof below a height of75' poses nothreatof harm to the public when conducted with the above mentioned protocols in place. Conversely, it eliminates the possibility ofsevere injury and/ordeath to the roofing inspector. With the described use ofsignage, designated take-offand landing zones, owner consent, Pilot-incommand and visual observer maintaining line ofsight, and all othersafety protocols listed above, a safe and limited operating area can and will be established thereby creating a restricted sterile environment within whichthe UAS will operate llke the motion picture exemption {Exemption No. 11062) thatwas granted to Astraeus AeriaL 7. Any additional information,views, or arguments available to supportyour request. a. Attached are copies ofthe UAS specifications. b. Attached are copies ofthe pre-flight check list. 8 Ifyou want to exercise the privileges ofyour exemption outside the U.S. you must statethe reason. I do notwish to exercise the privilege of my exemption outsidethe U.S.

Respectfully Submitted, Neil RBruns 1565 Cassella Montezuma Rd. Maria Stein, Ohio 45860 Phone- (419) 852-5498 Email- nbruns@oiroofing.com

# I I

2015,3

# Attachment (1)

# Attachment {2)

# Appendix

.AirCtl;lft.

Mode! Weight{Baitery Included) Hovering Accuracy {P Mode)

Max Angular Velocity
Max Tilt Angle Max Ascent Speed Max Descent Speed Max Speed Max Flight Altitude Max Wind Speed Resistance Max FlightTime Motor Model Propeller Model Indoor Hovering Operating Temperature Range Diagonal Distance Dimensions 

### Gim!J?!

.. Model Output Power (With Camera) Operating Current AngularVibration Range Mounting
Controflable Range

Mechanical Range

Mai Controllable Speed T600 2935g Vertical: 0.5 m Horizontal: 2.5 

### m Pitch: 300°/S Yaw: 150"/s

5 m/s 4m/s 22 m/s (ATT! mode, nowind) 4500m iOm/s Approximately 18 minutes OJI3510 DJI 1345 Enabled by defautt -10° to 40° C 559to 581 mm 438x451x301 

### mm

ZENMUSE X3 St<1tic: 9 W; ln Motion: 1i W Station: 750 rnA; Motion: 900 rnA ±0.03"' Detachable Pitch: -90°

### to +30° Pan: ±320° Pitch:
-i 25" to +45° Pan: ±330° Pitch: 120° /s Pan: 180°/sINSPIRE 1 User Manual 

### G<tm$ra Name Mode! Total Pixels Effective Pixels Image MaxSize !SO Range Electronic Shutter Speed FOV (Field Of View} CMOS

Lens

Still Photography Modes

Video Recording Modes

Max Bitrate Of Video Storage
Supported file Formats

Supported SO CardTypes OperatingTemperature Range ' : ·.:·

. .. .**Rem4J~€?** Controller•·· Name Operating Frequency Transmitting Distance ElRP Video Output Port Power Supply Charging DuafUser Capability 

## X3 FC350 12.76M 12AM 4000x3000 100-3200 (video)**100~160()** (photo) 8 

### s to 1/8000 

### s 94" Sony EXMOR i/2.3" 20mm (35mm format equivalent) f/2.8 focus at oo) 9 Elements in 9 groups Anti-distortion Single shoot Burst shooting: 3/5!7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Time-lapse UHD {4K): 4096x2i60p24/25, 3840x2160p24/25/30 FHD; i 920x1080p24/25/30/48!50/60 HD: 1280x720p24/25/30/48/50/60 60 Mbps FAT32{exFAT Photo:JPEG, DNG Video: MP4/MOV (MP.EGAAVC/H.264) Micro SO Max capacity: 64GB. Class 10 or UHS-1 rating required. O"to 40" C

Ci**922.7MHz~927.7MHz** (Japan Only)

.5.725,...5.825 GHz;2.400-2.483 GHz 2 km (Outdoor And Unobstructed) 10dBrri@900m,**13dBm@5~8G,** 20d8m@2.4G USB, Mini-HDMl Built-in battery OJ! charger Host-and-Slave connectionMobile Device Holder Output Power Operating Temperature Range Storage

### T erriperature Range Charging Temperature Range Battery Cparger · Model Voltage Rated Power BatterY {Standard) Name Mode! Capacity Voltage BatteryType EnE;rgy Net Weight Operating Temperature Range Storage Temperature Range Charging Temperature Range Max Charging Power 

# Batte}y (Optional) Name Model Capacity Voltage Battery Type Energy Net Weight Operating 

### I emperature Range Storage Temperature Range ChargingTemperature Range Tablet or Smart Phone 9W -10" to 40" C Less than 3 months: -20" to45" G More than 3 months:

## 22" to 28°

## c

A14-100P1A 28.3V 

### IOOW
lnte!Hgent Flight Battery TB47 4500 mAh 22

..2V UPo BS High voltage battery 99.9Wh 570g -10"' to 40" C Less than 3 months: -20" to 45° C More than 3 months: 22° C to 28° C O"to 40"G 180W
Intelligent Flight Battery TB48 5700mAh 22.8V LiPo 68 129.96Wh 670g -10 to 40° C Less than 3 months: -20to45° C More than 3 months: 22° to 28° C 

## oo to 40" C INSPIRE 1 User Manual

)> "0 "0 CD :J Q. XINSPIRE 1 User Manual

Max Charging Power

.

## Visi~~§o~lt~ning Velocity Range Altitude Range Operating Environment Operating Range DJI 

### PflofApp.· i.BOW

Below 8 m/s (2m above ground)**5~500cm** Brightly lit (lux> 15) patterned surfaces 0-2509m

Mobile Device System Requirements iOS version 7.1 or later; Android version 4.1.2 or later
Supported Mobile Devices * 

### iPhone 6 

### Plus, iPhone 6, 

### 1Phdne 58, 

### iPad Air 2, 

### iPad Mini 3, 

### !Pad Air, !Pad Mini 2, 

### iPad 4;" 

### Samsung Note 3, 

### Samsung 85, Sony Z3 EXPERIA;* Note: It is recommended that you use a tablet 

### forthe bestexperience

IOC allows users to lock the orientation of aircraft in different fashions. There are three working modes for IOC and you may select the desired IOC modes from the DJI Pilot app. IOC only works under F mode, and user musttoggle the flight mode switch to 

### "F' mode to activate IOC. Referto the table below:

Course lock(CL)
Home Lock (HL)*
Pointof Interest (POl)* Its forward direction is pointing tothe nose directionwhen recording, Which is fixed until you re-record it or ext!:from 

### CL·· Record a Home Point (HP), and push Pitch stick to control the aircraft farfrom or near to the HP. Point of Interest. Record a point of interest (POl), the aircraft can circle around the POl, and the nose always points to the POl.
:\): *Home lockand Point of Interest feature are coming soon. Prerequisites of 

### lOG Use the 

### !OC feature underthe

### folfowing condition:
ModeslOC GPS 13nabled

Course lock No None Home lock Yes**-~.n;·** 

### PO! Yes**~11171** Using lOG 

# ·**F~ght Di,Stanc:e.ull"la~/**  

## • · None Aircraft < eiom , 

### Home Point Aircraft (5m-5DDm l 

### Point of Interest

Enable the IOC feature bytapping "Enable IOC" in the setting page ofthe OJI Pilot app. Toggle the Flight Mode Switch to "F' 

### mode and followthe on-screen instruction to use 100

### feature.

# DJI I S IRE 1 PRE- IGHT C ECK.LIST

BEFORE DEPARTING FOR SITE CHECK



## · Aircraft (AC) and Remote Controller (RC) batteries fully fully charged Radio for communicating with manned AC fully charged card has and is into the Firmware is updated on AC and Cache location maps into all DJI Pilot app devices Check for frequency (FX) by local manned AC (Skyvector.com) Check if flight location is in No-Fly Zone {Check here: airmap.io) Program local FX into portable radio Check for NOTAMs Temporary Flight Restrictions (TFRs) (FAA.gov/notamSearch) weather Precipitation than 5-1 0% Winds under 20kts Cloud layer above 500 1 

## (152M) 1 statute mile visibility KP index is 5 or less (Check UAVforecast.com) Check Sunrise, Sunset, Moonrise, Moonset 

## shirt thatanswers all questions 11

,. 

## (The T-Shlrts) Comprehensive maintenance after 200 flights or 50 flight hours. (Maintenance Manual)
LOCATION ON-SITE CHECK 

## Check flying area free of overhead obstructions WiresJ !ow flying AC, trees, tall buildings Antennas that may interfere with compass and GPS reception

## Winds under 20 (23 MPH or 10 meters per second) Clouds above (152M) Visibility for 1 statute mile KP index 5 or less Confirm flight plan with camera operator and/or spotter Note: Stillperform by itadds clarity decision making.

PHYSICAL AIRCRAFT CHECK 

## ND filter attached to camera locked in card in camera Motors of Foreign Object Debris (FOD) Note: FOD 

## maycause 

## motorburnoutandcompleteAC

## inversion on ,,......co-•



## Check propellers for any melting, misshapen, or cracks Propellers hand tight Prop locks firmly attached or plastic

RElVIOTE CONTROLLER CHECK 

## Antennas oriented Properly no cracks or fissures.

Note: The broad should face the AC and theyshould not touch other.



## Switch to mode Landing gear switch oriented down Check battery level of minimum 75%

DJI PILOT APP CHECK 

## Maximum Flight altitude set Note: 121 Nleters 

## = 400' 

## Failsafe Mode, Set for 

# 1OM Clearance above lowest obstacle in flight plan Note: 1 Meter= 

## 3.3}

## RC Signal Lost set to Return-to-Home Check Sensors between "-1 +1.0"

· Acceleration between "-1.0to+1.0}'

Compass MOD between 400
- 1599" Check IMU Image Transmission Channel set Note: Watch channels for30 seconds to ensure selectedchannel

## is indeedstable Cells afl 4.28V or greater At least 98% battery Ensure no greater than .2V between battery cells Adjust Roll to make 

## level Ensure enough Satellites are (recommend 16) Camera Orientation mode Recommend "Follow-mode'' forsolo and ufree-mode' 1 

## with camera Turn all devices to airplane mode AC into the wind Note: This allows 

# AC floatback operatorin case 

## ofemergency. heading Aircraft Note: actualaircraft

Start Video recording Start Propellers using a Combined Stick Command (CSC) blue dot representing accurately located on map Ensure home point is accurately set on map Ensure elevation reads 0 (zero) of