From: Neil R Bruris 

To: Federal Aviation Administration 

Subject: REQUEST FOR ISSUANCE OF EXEMPTION UNDER TITLE 14 CFR, SECTION 333 

Ref: (a) FAA Notice 8900.268 

(b) Title 14 CFR 

End: (1) Explanation of Exemptions from 14 C.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 allow operation of a small hobby sized unmanned aircraft {UAS) in order to conduct 

roof inspections at a lesser height of 75' or surrounding foliage/tree height from the ground surface. The 

sole purpose of using the UAS is to gather photographic documentation of the condition of the roofing 

materials in order to safely aid in the consulting of roofing conditions. By strictly adhering to selfimposed safety protocols listed below the use of the UAS will provide much safer roof inspections to all 

parties involved while posing no safety or privacy threat to the general public, the participating 

inspection parties, or non-participating parties. 

1. Neil R Bruns 

1565 Cassella Montezuma Rd. 

Maria Stein, Ohio45860 

Phone: (419) 852-5498 

Email: nbruns@oiroof!ng.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. 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); 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) and (2); 14 C.F.R. 91.417(a) and 

(b). 

3. The extent of relief you 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 order to allow the use of a Small Unmanned Aircraft System (UAS) 

as defined by the 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 height from the 

adjacent ground surface or surrounding foliage/tree height from 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 of fall or injury. Per U.S. 

Department of Labor News Release Number: 10~1753-NAT- "Fatalities from falls are the number 

one cause of workplace deaths in the construction industry. We must not tolerate workers being 

killed in the field of construction when effective means are readily available to prevent those 

deaths", said Assistant Secretary of Labor and Occupational Safety and Health, Dr. David 

Michaels. "Almost every week, we see a worker killed from falling off a roof. We can stop these 

fatalities, and we must". The use of an UAS would eliminate any risk of personnel of falling off a 

roof during roof inspection and subsequently eliminate injury and or death. 

4. How your request would benefit the public as a whole. 

The exemption would benefit the public as a whole in the following ways. 

a.) Safety of the worker who is part of the public as a whole. Because the worker is not 

physically climbing the roof, no possibility of fall or injury is present. 

b.) Due to the 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 of an UAS for roof inspections would decrease the risk exposure of property owners 

from a liability suit resulting from a roof falL 

e.) A more thorough inspection could take place thereby a more efficient, comprehensive and 

accurate settlement for the public. 

f.) The domino effect of lower cost of roofing for the public start with more efficient 

inspection techniques. The use ofthe UAS drastically reduces time and liability of this 

process. A flight ceiling limit of 75' altitude from the adjacent ground level or the height of 

foliage or trees (lesser of the two) shall be strictly adhered to by the 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 not allowed to operate at such low altitude. 

g.) The public as a whole would benefit due to the reduced time to process insurance claims, 

especially in natural disasters or catastrophe situations thereby 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-command will 

perform an extensive pre-flight check prior to each flight to ensure the UAS is functioning 

properly. In the event that ANY pre-flight item does not pass the designated check, the UAS 

will be permanently grounded untll such a time that the UAS is in full compliance with 

manufactures standards. A compliance statement from 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 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 exemption would not adversely affect safety due to self-imposed safety protocols by Neil R Bruns. 

By executing the safety protocols listed below, the general public would be much safer than the current 

state and process of inspecting roofs requiring physical climbing. 

a. The UAS would be operated only by personnel who possess a Drone/UAV Certificate from 

Unmanned Vehicle University. This certificate is only attainable by successfully 

completing a 50 hour training course in accordance with FAA AC 91-57. Neil R Bruns will 

also require an additional100 hour bfflight experience that includes a minimum of 50 

take-offs and landings with the UAS prior to any roof inspections. 

b. All operations will utilize an optical observer in addition to the pilot-in-command. 

c. The visual observer and the pilot-in-command will be able to verbally communicate at all 

times. 

d. The pilot-in-command will wear a high visibility vest thereby identifying himself as the 

pilot. 

e. A geo-fence will be enabled on the UAS that will eliminate the aircraft from leaving the 

airspace above the property being inspected. A signage barrier will also be erected 

around the property to alert the public of the UAS inspection. 

f. A flight ceiling limit of 75' altitude from the adjacent ground level height of foliage or 

trees adjacent to the property (lesser of the two) shall be strictly adhered to by the geefence and pilot-in-command for all inspections. This ensures that no contact with aircraft 

In the NAS will occur with the UAS because manned aircraft cannot fly below the tree line 

or the highest obstacle. 

g. The property owner shall sign a consent form prior to the UAS roof inspection. A!! 

adjacent property owners will be notified of the proposed flight to include time, date, 

estimated length of time, and flight path. All non-participating persons shall be moved to 

a minimum of 50' beyond the perimeter of the geo-fence setting prior to the flight. 

h. The UAS wlll not fly near or in the vicinity of a manned aircraft. 

L The UAS Will always be in a !ine of sight with the pilot-in-command and the visual 

observer. This will enable the pilot-in-command to avoid any obstacles present at 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 of flight time or when 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 limited to the duration and location shall be kept 

with the pilot-in-command and available upon request. 

o. An appropriate take-off and landing shall be determined and designated prior to flight. 
p. The radio frequency used for operation and control of the UAS will comply with the FCC 

or other appropriate government agency 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 not take place within 500ft below or within 2000' horizontally from a 

doud. The UAS flights will not occur when vlsibllity is less than 3 miles. 

t. Neil R Bruns will maintain a $1,000,000.00 liability insurance policy while operating the 

UAS. 

u. fn accordance with the manufacture's operating manual, UAS pilot-in-command will 

perform an extensive pre-fllght check prior to each flight to ensure the UAS is functioning 

properly. In the event that ANY pre-flight item does not pass the designated check, the 

UAS will be permanently grounded until such a time that the UAS is in full compliance 

with manufactures standards. A compliance statement from the manufacture stating the 

UAS has been repaired, properly maintained, and/or inspected and deemed safe to fly in 

accordance with their operating manual. 

v. The UAS will have a flight termination option to prevent "fly away" and the pilot-incommand can safely abort or terminate the flight. 

By fulfilling these comprehensive safety protocols, the UAS flights to inspect roofs by Neil R Bruns 

greatly exceeds the FAA safety rules as listed in the Model Aircraft Operations Limits in the FAA 

Modernization and Reform Act of 2012. 

6. A summary we can publish in the Federal Register Statinga. The rule from which you seek exemption; and 

b. A brief description of the exemption you seek 

Steven G Good is seeking exemption from: 

Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the 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); 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) and {2); 14 C.F.R. 91.417(a) and (b). 

A brief description of the exemption l seek is as follows: 

By adhering to much more stringent safety measures than is described by the Model Aircraft Operations 

Limits according to the FAA Modernization Act of 2012, I am seeking exemption of the above listed 

rules. Most of the rules do not apply to 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 of the UAS is to gather photographic documentation of a roof in order to 

issue a report on serviceability and sustainability. The photos can be obtained quickly and safely by the 

use of UAS thereby eliminating the chance of a fatal or debilitating roof fall by the inspector and 
coUateral damage, both human and material. Safe and responsible operation of a hobby sized UAS to 

gather photos of a roof below a height of 75' poses no threat of harm to the public when conducted 

with the above mentioned protocols in place. Conversely, it eliminates the possibility of severe injury 

and/or death to the roofing inspector. 

With the described use of signage, designated take-off and landing zones, owner consent, Pilot-incommand and visual observer maintaining line of sight, 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 llke the motion picture exemption {Exemption No. 

11062) that was granted to Astraeus AeriaL 

7. Any additional information, views, or arguments available to support your request. 

a. Attached are copies of the UAS specifications. 

b. Attached are copies of the pre-flight check list. 

8 If you want to exercise the privileges of your exemption outside the U.S. you must state the reason. 

I do not wish to exercise the privilege of my exemption outside the U.S. 

Respectfully Submitted, 

Neil R Bruns 

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 Flight Time 

Motor Model 

Propeller Model 

Indoor Hovering 

Operating Temperature Range 

Diagonal Distance 

Dimensions 

Gim!J?! .. 

Model 

Output Power (With Camera) 

Operating Current 

Angular Vibration 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, no wind) 

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: 1 i 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°/s 
INSPIRE 1 User Manual 

G<tm$ra 

Name 

Mode! 

Total Pixels 

Effective Pixels 

Image Max Size 

!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 Card Types 

Operating Temperature Range ' : ·.:· . .. . 

Rem4J~€? Controller •· · 

Name 

Operating Frequency 

Transmitting Distance 

ElRP 

Video Output Port 

Power Supply 

Charging 

Duaf User 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 920x1 080p24/25/30/48!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 connection 
Mobile 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 

Battery Type 

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 em perature Range 

Storage Temperature Range 

Charging Temperature Range 

Tablet or Smart Phone 

9W 

-10" to 40" C 

Less than 3 months: -20" to 45" 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 

129.96 Wh 

670g 

-10 to 40° C 

Less than 3 months: -20 to 45° C 

More than 3 months: 22° to 28° C 

oo to 40" C 

INSPIRE 1 User Manual 

)> 

"0 

"0 

CD 

:J 

Q. 

X 
INSPIRE 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 for the best experience 

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 must toggle the flight mode switch to "F' mode to activate IOC. Refer to the table below: 

Course lock (CL) 

Home Lock (HL)* 

Pointof Interest (POl)* 

Its forward direction is pointing to the nose direction when 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 far from 

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 lock and Point of Interest feature are coming soon. 

Prerequisites of lOG 

Use the !OC feature under the 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 by tapping "Enable IOC" in the setting page of the OJI Pilot app. Toggle the Flight 

Mode Switch to "F' mode and follow the 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 5001 (152M) 

1 statute mile visibility 

KP index is 5 or less (Check UAVforecast.com) 

Check Sunrise, Sunset, Moonrise, Moonset 

shirt that answers 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: Still perform by it adds clarity decision making. 

PHYSICAL AIRCRAFT CHECK 

ND filter attached to camera 

locked in 

card in camera 

Motors of Foreign Object Debris (FOD) 

Note: FOD may cause motor burnout and complete AC 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 they should 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 "-1.0 to+ 1.0}' 

Compass MOD between 400 - 1599" 

Check IMU 

Image Transmission Channel set 

Note: Watch channels for 30 seconds to ensure selected channel is indeed stable 

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'' for solo and ufree-mode'1 with camera 

Turn all devices to airplane mode 

AC into the wind 

Note: This allows AC float back operator in case of emergency. 

heading Aircraft 

Note: 

actual aircraft 

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