Roderick Carroll

1043 Reese Ave

Bryn Mawr, PA 19010

Tel: (215) 990-6138

E-mail: rodcarroll@mac.com

January 10, 2016

U.S. Department of Transportation,

Docket Management Systems,

1200 New Jersey Avenue SE,

Washington, DC 20590

RE: Section 333 Petition for Exemption 14 CFR § 11.81

 Electronic Submittal – Via FDMS Website

Dear Sir/Madam,

This letter serves as a petition for exemption from specific rules contained in Title 

14 of the Code of Federal Regulations (14CFR), with regards to operations of 

small, unmanned aircraft (UAS) so as to allow Roderick Carroll to operate 

commercially in the industries listed below. The petitioner (Roderick Carroll) is a 

Private Pilot (Cert #2737079, single-engine land) and holds a current 3rd class 

medical certificate (copy attached).

The Regulations 14 CFR for which exemption is requested are as follows:

14 CFR part 21

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

and 91.417(a) and (b).

The requested exemption would permit Roderick Carroll to pursue his 

commercial interests in providing services to clients using small advanced UAS’s 

with a focus on aerial data collection including the following areas of interest:

• General Video and Photography assignments

• Sports Videography

• Aerial Surveying

• Search and Rescue Operations
• Industrial Facility Inspections

• Conservation Reviews

• Inspection of Wind and Solar power generation structures

• Inspection of Telecommunication structures

• Oil Spill data to provide accurate information of incident in real time

• Training for recreational users and emergency services entities

In addition to the waiver authority provided in Section 333 of the Modernization 

Act, the FAA may grant an exemption under 49 U.S.C. Section 44701(f) if it has 

determined that such an exemption is in the public interest.

Each commercial interest features inherent risks associated with tasks performed 

by personnel. For example;

Wind power generation – Individuals have to rappel down to each blade to 

visually inspect. This risk of equipment failure is removed with a UAS providing 

the visual inspection.

Oil and Gas Infrastructure – Individuals may have to climb high towers and or 

equipment to do visual inspections. If conducted solo and the individual were to 

fall or have a medical emergency, Emergency Medical Service personnel could 

be limited in their ability to respond in a timely fashion.

With our focus on safety we intend to implement, at a minimum, all of the 

Operational Limitations outlined in Proposed Part 107 of the Notice of Proposed 

Rule-making (NPRM). These limitations will ensure the same level of safety 

offered by the rules for which the exemption is sought. By adhering to the 

Operational Limitations, the proposed UAS operations will minimize risk to the 

NAS, and to persons and property on the ground.

An exemption would allow Roderick Carroll to broadly evaluate assets and 

operations utilizing UAS, resulting in a safer and more efficient inspection and 

monitoring scheme across many industries. The grant of an exemption is 

consistent with Congress’ intent, reflected in Section 333 of the FA Modernization 

and Reform Act of 2012, that safe systems be permitted in the national airspace 

prior to the issuance of final regulations governing general use of these items.
Roderick Carroll shall conduct operations with one of the following UAS’s:

DJI FlameWheel F550 Hexacopter 

DJI Inspire 1

DJI Phantom 3

DJI S-1000

Furthermore, our commitment to safety is foremost in our operations:

• Personnel will act as an Observer for 10 assignments and will have 10 hours of

flight time prior to being given assignments.

• Each assignment will be accompanied by a pre-flight check list (See Attached).

In conclusion, due to their light weight, UAS generally pose a significantly low risk 

to people and the property on the ground. The size, weight, speed, and capability 

of the DJI product line will not create a hazard to the users of the NAS or the 

general public, nor will it pose a threat to national security. Granting this request 

for exemption would not adversely affect safety; rather it would give opportunities 

to reduce risk to the personnel of the industries serviced.

The UAS’s listed in this request will be registered with the FAA. A Registration 

Application for FlameWheel F550 Hexacopter has already been submitted. Upon 

award of exemption, a “blanket” 200-foot Certification of Waiver or Authorization 

will be requested.

Sincerely,

Roderick Carroll

Private Pilot Certificate Number: 2737079