September 25, 2015

Exemption No. 13012

Regulatory Docket No. FAA–2015–2260

Ms. Evida Suntoyo

ROOFCORP OF CA, Inc.

2130 South Dupont Drive

Anaheim, CA 92806

Dear Ms. Suntoyo:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on June 15, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of ROOFCORP OF CA, Inc. (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct roof inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 
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finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, ROOFCORP OF CA, Inc. is granted an exemption 

from 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), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, ROOFCORP OF CA, Inc. is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on October 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

RE: Petition for exemption according to Section 333 of the FAA Modernization and Reform Act 

of 2012 (FMRA)

Dear Sir or Madam,

ROOFCORP OF CA, Inc. hereby petitions for an exemption from the Federal Aviation Regulation 

(FAR) and any other rules necessary to allow the operation of a small unmanned aircraft system 

(UAS) for the purpose of conducting roof inspections to safely produce a photo documentation 

damage assessment for the perusal of the homeowners to decide on any necessary repairs on 

their roofs. The operation under the requested exemption will adhere to strict safety protocols 

which we will list in the following. The reason behind using an unmanned aircraft system to 

perform the roofing inspections is to provide a much safer mechanism to all involved parties 

while posing no safety or privacy threat to the general public, or any other individuals be it 

participating parties or non-participating parties.

1. Name and mailing address:

ROOFCORP OF CA, Inc.

2130 S Dupont Drive

Anaheim, CA 92806

Phone: (714) 210 5993

Fax: (714) 940 9917

Email: info@roofcorp.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. §§ 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command 

14 C.F.R. § 61.133(a): Commercial pilot privileges and limitations 

14 C.F.R. § 91.119(c) Minimum safe altitudes: General

14 C.F.R. § 91.121 Altimeter settings

14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions 

14 C.F.R. § 91.405(a) Maintenance required

14 C.F.R.§ 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or 

alteration

14 C.F.R. §§ 91.409(a)(1) and (2) Inspections

14 C.F.R. §§ 91.417(a) and (b) Maintenance records

14 C.F.R. § 91.7(a): Civil aircraft airworthiness

3. The extent of relief you seek and the reason you seek the relief:
a. 14 C.F.R. §§ 61.113(a) and (b): Private pilot privileges and limitations; 14 C.F.R. § 61.133(a): 

Commercial pilot privileges and limitations

ROOFCORP OF CA, Inc. is seeking relief and exemption from the above listed Federal Aviation 

Regulation and any other applicable rules to allow the use of a Small Unmanned Aircraft System 

to conduct roof inspections on structures approximately 25’ to 100’ from the surface of the 

ground. The UAS that ROOFCORP OF CA will use to conduct the inspection is a DJI Inspire 1, an 

Unmanned Aircraft System widely flown by recreational flyers is a personal UAS weighing less 

than 6lbs, whereas per definition by US Congress as stipulated 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.”

The DJI Inspire 1 is transcendently small and light weight capable to operate both autonomously 

and manually, with “Return Home” and “Position Stabilization” features. In an event connection 

with the remote controller is lost, the Inspire 1 uses its positioning system and smart flight 

technology to return back to the pilot.

ROOFCORP respectfully petitions that given the characteristics afore mentioned in the paragraph 

above, to exempt the operations of the UAS by pilot holding a private pilot’s certificate or 

commercial pilot certificate. The risks associated with the operation of these small UAS are lower 

than the level of risks associated with commercial operations contemplated by Part 61; allowing 

operation of the UAS as requested therefore exceeds the level of safety achieved by 14 C.F.R. §§ 

61.113(a) and (b).

b. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness

Section 91.7(a) requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Given the characteristics of the UAS such as small size, light weight, low operating 

altitude, short flight time, and the stringent operating restrictions and conditions proposed in this 

petition, an equivalent level of safety will be achieved by compliance with the Standard operating 

Procedure. ROOFCORP OF CA, Inc. therefore requests FAA to grant an exemption from Section 

91.7(a) and find that the operator may ensure that the UAS are in an airworthy condition by 

complying with the Standard Operating Procedure the proposed operating restrictions and 

conditions. FAA has granted similar exemptions in Exemption Nos. 11136 and 11138.

c. 4 C.F.R. § 91.119(b) and (c): Minimum safe altitudes

Section 91.119(b) and (c) establish certain minimum altitudes for operation of civil aircraft. 

Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, 

no person may operate an aircraft below the following altitudes: ... (b) Over congested areas. 

Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.”

ROOFCORP OF CA, Inc. request to be exempted from this section since the said UAS will not 

operate on altitudes higher than 100’ above ground level. Putting into account its small size, light 

weight, low speed and its limited range, also that it carries no passengers or flammable materials, 

the UAS may safely fly on a lower altitude that conventional aircrafts. The residential buildings 

that ROOFCORP OF CA, Inc. intend to inspect does not rise more than 100’. Relief from this rule is 
warranted because the operations will be conducted with the safeguards and under the 

operating conditions outlined herein and in the Standard Operating Procedure. The FAA issued an 

exemption from Section 91.119(c) in Exemption Nos. 11136 and 11138.

d. 14 C.F.R. § 91.121: Altimeter settings

It is regulated that each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating. 

“(b) The lowest usable flight level is determined by the atmospheric pressure in the area of 

operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

Due to the nature of use of the small UAS to perform roof inspections, the UAS will not fly above 

the altitude of 100’. ROOFCORP OF CA, Inc. respectfully submits to be exempted from the 

section.

e. 14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions

ROOFCORP OF CA, Inc. submits to exempt this section putting into consideration the limited 

battery life that in turns limits flight duration of the UAS DJI Inspire 1 and also the characteristics 

of the UAS being light weight, low speed, limited range, ability to land very quickly, operation 

within visual line of sight, restricted operating area, and the fact that they do not carry 

passengers or any flammable materials. In addition to those characteristics described in the 

previous, the DJI Inspire 1 has a safety return feature that enables it to return home in an event 

that the battery is running low. The FAA issued an exemption to this regulation for UAS 

operations in Exemption Nos. 11062, 10673, 11136 and 11138.

f. 14 C.F.R. § 91.405(a): Maintenance required

14 C.F.R. § 91.407(a)(l): Operation after maintenance, preventive maintenance, rebuilding or 

alteration

14 C.F.R. §§ 91.409(a)(l) and (2): Inspections

14 C.F.R. §§ 91.417(a) and (b): Maintenance records

Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to ROOFCORP OF CA, Inc. Maintenance will be accomplished by the 

operator pursuant to the manufacturer’s manual and the Standard Operating Procedure. An 

equivalent level of safety will be achieved because the UAS are very small in size and weight, will 

carry a tiny payload and operate only in restricted areas for short periods of time. If mechanical 

issues arise, the UAS can land immediately and will be operating from no higher than 100’ above 
ground level. As provided in the Standard Operating Procedure, the operator will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Moreover, the operator is the person most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition to provide an equivalent level 

of safety. The FAA issued an exemption to these regulations in Exemption Nos. 11062, 11136 and

11138.

g. Such other relief as the FAA deems appropriate to enable the requested operations

ROOFCORP OF CA, Inc. also requests exemption from such other FARs as the FAA deems 

appropriate to enable the requested operations. If, during the effective dates of the exemption 

issued pursuant to this petition, the FAA issues interim or final rules for small UAS, ROOFCORP OF 

CA, Inc. requests that it be relieved of the requirements of any conditions and limitations of the 

exemption and allowed to comply with any less burdensome applicable regulations that may 

have become effective.

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

The exemption will benefit the general public for the following reasons:

1. By using the UAS to perform roof inspections, this will not require an Inspector to physically 

climb the roof, therefore ensuring the Inspector’s safety by minimizing the possibility of 

accidents happening due to falling.

2. Clay tiles are brittle, by inspecting the roof with the UAS, it will avoid stepping on the clay 

tiles and causing them to crack.

3. The cost of inspection will be reduced drastically to the general public due to the minimum 

time spent on the roof by taking high resolution photos and having a qualified roofer

analyzing the pictures at the office.

4. With the UAS as the main tool to perform inspections, no ladder will be required, thus 

removing any safety concerns related to the placement of a ladder.

5. Most residential roofs have a very high pitch, therefor it is not walkable. Due to this reason, 

the homeowners seldom perform roof inspection for preventive measures until a problem 

occurs.

6. By inspecting roof conditions, this will ensure the condition and soundness of the roof, 

therefore preventing leaks that cause damages to the property, which eventually can lead to 

structural damage to the building, and much later can cause safety liability to the tenants and 

the general public. 

7. Roof inspections can identify leak areas and water intrusion to prevent moisture build up 

inside the building. Moisture build up can stimulate the growth of mildew and bacteria that 

can lead to health hazard.

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, or how the exemption would provide a 

level of safety at least equal to the existing rule for the following reasons:
1. The UAS will be operated under a strict Standard Operating Procedure produced by 

ROOFCORP. ROOFCORP has spent more than a quarter of a century providing the 

highest quality roofing services, establishing a reputation for excellence working on 

tough demanding jobs for clients large and small. Founded in 1985, we are a leading 

provider of roofing and solar installation for commercial, industrial and multifamily 

clients throughout Washington, Oregon and California.

2. A geo-fence will be enabled on the UAS that will limit the aircraft from leaving the 

airspace above the property to be inspected. A signage barrier will also be constructed 

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

3. A flight ceiling limit of 100’ altitude from the adjacent ground level or the height of 

foliage or trees adjacent to the property (lesser of the two) shall be strictly adhered to 

by the geo-fence and the operator for all inspections. This ensures that no contact 

with aircraft in the NAS will occur with our UAS because manned aircraft cannot fly 

below the tree line or highest nearby obstacle.

4. The property owner shall sign a consent prior to the UAS roof inspection and all nonparticipating persons shall be moved to at least 50’ beyond the perimeter of the geofence and signage barrier prior to the flight.

5. The UAS will not fly near a manned aircraft.

6. The UAS flight and operator will abide by all pre-flight checks and manufacturer 

suggested flight protocols. The manufacturer operation manual will be readily 

available upon request and the operation manual will be strictly adhered to by the 

operator.

7. A log of each flight including the duration and location shall be kept with the operator

and available for audit upon request.

8. A take-off and landing zone shall be designated prior to the flight.

9. The radio frequency used for operation and control of the UAS will comply with the 

FCC or other appropriate government agency requirements.

10. The UAS flights will be conducted only during daylight hours under visual 

meteorological conditions.

11. The UAS flights will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud. The UAS flights will not occur when visibility is less than 3 

miles from the operator and visual observer.

12. ROOFCORP OF CA, Inc. will maintain a $1,000,000.00 liability insurance policy while 

operating the UAS.

13. In accordance with the manufacturer’s operating manual, the UAS operator will 

perform extensive pre-flight checks prior to each flight to ensure the UAS is 

functioning properly. In the event that ANY pre-flight inspection item does not pass 

the check, the UAS will be permanently grounded until the manufacturer issues a full 

compliance certificate stating that the UAS has been repaired, properly maintained, 

and/or inspected and deemed safe to fly in accordance with their operating manual.

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

6. A summary we can publish in the Federal Register stating —
a) A brief description of the exemption you seek; a. The rule from which you seek 

the exemption; and

b) A brief description of the exemption you seek

a) Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the 

Federal Aviation Regulations, ROOFCORP OF CA, Inc. seeks to be exempted from 

14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 61.133(a); 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); 14 C.F.R. §§ 91.417(a) and (b); 14 C.F.R. § 

91.7(a).

b) ROOFCORP OF CA, Inc. is seeking exemption for:

Most of the rules stipulated in the sections listed above does not apply to the 

small Unmanned Aircraft System because it does not carry any passengers, 

explosive or flammable materials that may cause concern to public safety. In 

addition to that, the UAS is light weight, low speed, limited range, ability to land 

very quickly, operation within visual line of sight, restricted operating area. 

The use of the UAS to perform roof inspection will greatly decrease public safety 

hazard, as it eliminates the possibility of falling that may lead to severe injury or 

death by not requiring the inspector to climb on to the roof or use a ladder. 

ROOFCORP OF CA, Inc. will put in place a strict Standard Operating Procedure to 

be followed by the operator to ensure that the use of this small popular and with 

hobbyist unmanned aircraft system will not affect public safety.

With the described use of signage, designated take-off and landing zones, owner 

consent, operator maintaining line of site, 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.

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

request

A description and specs of the UAS to be used by ROOFCORP OF CA, Inc. can be 

found in the attached manufacturer user manual.

8. If you want to exercise the privileges of your exemption outside the U.S., you

must state the reason.

ROOFCORP OF CA, Inc. does not wish to exercise the privileges of my exemption 

outside the U.S.

Respectfully,
ROOFCORP OF CA

2130 S Dupont Drive

Anaheim, CA 92806

Phone: (714) 210 5993

Fax: (714) 940 9917

Email: info@roofcorp.com