U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE. Washington, DC 20590 December 3, 2015 Re: Petition ofA Classic Roofing, LLC, for an Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11 , A Classic Roofing, LLC ("A Classic") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified below, to allow commercial operation of small unmanned aircraft system ("UAS") for conducting aerial inspections and photography ofstructures and facilities as part of exterior building evaluations and structural reviews. This petition is based on information outlined in this Petition for Exemption, as well as the Phantom 3 Professional User Manual v1.2, Phantom 3 Professional Quick Start Guide vl.O, Phantom 3 Intelligent Flight Battery Safety Guidelines vl

.O, Phantom 3 Safety Guidelines and Disclaimer vl

.O(collectively referred to as "Manufacturers Manuals"), see Appendix B.
A Classic began providing residential and commercial property inspections in 2011. We are a leader in roof system inspections in the Central Texas area. A Classic seeks to utilize the latest UAS technologies to provide a higher level of efficiency and safer services for our clients. Property inspections performed by A Classic typically involve the physical inspection of outdoor structures for the assessment of current condition, damage and defects. These inspections typically involve recording images to document existing conditions

. Depending on the nature ofthe inspection, obtaining images ofcertain physical features, such as roofs, may not be feasible due to dangerous conditions, limited access on the structure, risk of damage to structure, or the excessive height ofthe required viewing angle

. The use of UAS-assisted photography and video will provide a practical means to perform property inspections that would be otherwise unsafe to A Classic inspectors and the general public. The primary benefit ofthis technology would be to assist in the close, detailed aerial inspection and examination of building components. Inspection ofsteep-sloped roofs, multi-story roofs, weathered roofs and tall chimneys for residential and commercial buildings are a few examples ofwhere VASassisted photography would be ofgreat benefit to A Classic inspectors

. Health and safety is the primary concern for our clients and the use of UAS would benefit them, our inspectors and the general public.The secondary benefit ofthis technology would be aerial photography and videography for real property inspections, which is primarily available through manned fixed wing aircraft and helicopters. The expense of such aerial photography and videography for small companies and homeowners is cost prohibitive. Only large companies and luxury homeowners can afford to absorb such expenses, hence depriving small businesses and homeowners of this valuable diagnostic tool. Use of manned aircraft for these surveys also poses a threat to the public through potential catastrophic crashes. UAS pose no such threat since size and lack of combustible fuel alleviated potential threats to the public. Additionally, A Classic requests to be allowed use ofthe UAS to benefit first responders nearby who might require and request assistance, including fire fighters and law enforcement, while remaining subject to all limitations cited in this application.
THE UNMANNED AIRCRAFT (UA): • A lightweight (2.82 lbs. gross weight with all on-board equipment), battery operated 4- motor rotorcraft in the form of a quadcopter that takes off and lands vertically, manufactured by DJI, Phantom 3 Professional which carries: • An on-board flight computer with GPS navigation and location ability that receives signals from flight controls from a ground-based transmitter/controller as well as an iOS or Android mobile device application; • An on-board camera capable of capturing imagery in the form offull color, 12 mega pixel still photos and 4K video; • An on-board telemetry system that delivers flight data from the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site; • A 2.4 Ghz on-board radio transmitter that transmits live video from the on-board camera plus all the flight data from the telemetry system described above;
THE GROUND STATION-BASED SYSTEM: • A Pilot in Command (PIC} in operational control of a flight operation from beginning to end and who controls the UA while in the air; • A 2.4 Ghz radio transmitter/controller operated by the PIC to control the UA while in flight; • A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together onto an iOS or Android device for the PIC to view during flight; • A Visual Observer (VO) who assists the PIC and provides a second pair of eyes to visually track the UA while in flight.
The requested exemption would support an application for a commercial Certificate ofAuthorization to use the above described UAS to support aerial photography and video primarily of real property.

2The UAS will be operated in the field with both a PIC and aVO in acco rdance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following restrictions: a. No flight will be made with a UA gross weight exceeding 55 pound s; b. All operations must occur in FAA Class G airspace at no more than 400 feet AGL, at an airspeed of no more than 25 knots; c. All operations must utilize a visual observer (VO)

. The VO and PIC must be able to communicate by voice at all t imes during a flight operation; d. Operations will be restricted to flights over private property with the perm ission ofthe property owner; e. The UAS w ill not be operated over densely populated areas; f. The UAS will not be operated at air shows; g. The UAS will not be operated over any open-air assembly of people; h. The UAS will not be operated over heavily trafficked roads; i. The UAS will not be operated within 5 NM of an airpo rt or heliport; j. Operations will be restricted to daytime only and weather conditions eq u ivalent to VFR; k. The PIC will briefthe VO and property owner about the operation and risk before the first flight at each new location; I. No flight may be made without a Pre-Flight Inspection by the PIC before each operation to ascertain that the UAS is in a condition safe for flight (see Appendix A)

. We submit that the combination ofthe UA's light weight, flight performance and ability and strict operation underthe guidelines established in 8900

.227, and under all ofthe Restrictions (a) through {I) listed above, the FAA can have full confidence that the operation will have and equivalent or greater level of safety than manned aircraft performing the same mission. The name and contact information ofthe applicant is: A Classic Roofing, LLC Attn: William Webster 998 Deer Run Killeen, TX 76549 Tel: 254-702-7479 Email: aclassicroofing@gmail.com
The regulations from which each exemption is requested are listed below

. Each regulation is outlined in the attached Addendum with our proposed equivalent level of safety for each regulation:
14 C.F.R Part 21, Subpart H 14 C.F

. R. Part 27 14 C.F

. R. § 91.7(a) 14 C.F.R. § 91

.9{b)(2) & 14 C.F.R. § 91.203(a) and (b) 14 C.F

. R. § 91.9{c), 45.23{b) & 45.27{a) 14 C.F.R

. § 91.103 14 C.F

. R. § 91.119 14 C.F.R. § 91.121 314C.F.R. § 91.151(a) 14 C.F.R. § 91.40S(a), 91.407(a)(1), 91.409(a)(1) & (2); 91.4174(a) & (b) 14 C.F.R. Part 61, 14 C.F.R

. § 61.3, 14 C.F.R. § 61.113 We are prepared to modify or amend any part ofthis request to satisfy the need for an equivalent level ofsafety. Please contact us at any time ifyou require additional information or clarification. We look forward to working with your office. Sincerely,

William Webster President/Managing Partner A Classic Roofing, LLC

Addendum- containing Exemption Requests and Equivalent Level of Safety Appendix A- Flight Manual Appendix B- Manufactures Manuals

4ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY CPI requests an exemption from the following regulations as well as any additional regulations thatmaytechnically apply to the operation ofthe UAS: 14 CFR Part 21, Subpart H: Airworthiness Certificates The FAA has stated that no exemption is needed from this section ifa finding is made under the Reform Act thatthe UAS selected provides an equivalentlevel ofsafety when compared to aircraft normally used for the same applicat ion. These criteria are 

### met, and therefore no exemption is needed. See Grant ofExemption to Astraeus Aerial, Docket No. FAA-2014- 0352 at 13-14, 22. If, however, the FAA determines thatthere are some characteristics of the chosen UAS that fail to meetthe requirements ofthe Reform Act, an exemption is requested. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification ofnormal category rotorcraft. To the extent thatCPI's small UASs would otherwise require certification under Part 27, Petitioner seeks an exempt ion from Part 27's airworthiness standards for the same reasons identified in the requestfor exemption from 14 C.F.R. Part 21, Subpart H, supra. 14 C.F.R. § 91.7(a): Civil AircraftAirworthiness CPI seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated thatno exemption is required for 14 C.F.R. § 91.7(a) to the extentthatthe requirements ofPart 21 are waived or found inapplicable. See Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, Petitioner requests that the requirements for§ 91
.7(a) be treated in accordance with Section V(A), supra. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in theAircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certificationand Registration CPI seeks exemption from 14 C.F.R. § 91.9(b)(2). Given the small size and configuration of the UAS, itwould be impossible to keep airworthiness documents and other aircraft manuals on board the UAS because there is simply no room and the UAS has no cabin or cockpit
. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Markingand Identification Requirements CPI seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part45 ofthis chapter
. 14 C.F.R. § 45.23(b), Markings ofthe Aircraft, states: When marks include only the Roman capital lett er "N" andthe registration numberis displayed on limited, restricted or light

### 5 I Pagesport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable. 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display on that rotorcrafthorizontally on both surfaces ofthe cabin, fuselage, boom, or tail the marks required by§ 45.23. In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted provided thatthe aircraft "have identification (N

-Number) markings in accordance with 14 C.F.R Part45, Subpart Cifthe markings are as large as practicable." FAA Docket No. FAA-2014-0352. 14 C.F.R. § 91.103: PreflightAction CPI seeks an exemption from 14 C.F
.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required. 14 C.F.R. § 91.119: Minimum Safe Altitudes CPI seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c)
. Section 91.119(d) allows for a helicopter to operate atless than those minimum altitudes when it can be operated "without hazardto persons or property on the surface," provided that "each person operatingthe helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the proposed UAS operations will occur below 200 feet AGL. Additionally, due the nature ofthe proposed operations, the Pilot andfor Observers(s) may need to be less than 500 feet away from the UAS. 14 C.F.R. § 91.121: Altimeter Settings CPI seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraftto maintain cruising altitude or flight level by reference to an altimeterthat is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extentthatthe UASs do nothave a barometric altimeter, but rather GPS altitude display. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions CPI seeks an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. The technological limitations on UAS batterypower means that no meaningful flight operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements of14 C.F.R. § 91.151(a) is therefore required. Additional information: Individual CPI Flight missions will be limited 22 minutes or less. 6I Page14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections CPI seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a) (l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43
. See, e.g., 14 C.F.R. § 91.40S(a) (statingthat each owner or operator ofan aircraft "[s]hall have the aircraftinspected as prescribed in subpart E ofthis partand shall between required inspections
...have discrepancies repaired as prescribedin part43 ofthis chapter"). An exemption from these regulations is needed because Part43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS to be operated underthis grant ofexemption will not have
. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 61.113: subsections (a) and (b) prescribe the following: a. No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraftthat is carrying passengers or propertyfor compensation orhire; nor may thatperson, for compensation or hire, act as PIC ofan aircraft
. b. Aprivate pilot may, for compensation or hire, act as PIC ofan aircraft in connection with anybusiness or employment if1. The flight is only incidental to thatbusiness or employment; and 2. The aircraft does not carrypassengers or property for compensation or hire. CPI seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraftfor compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure thatthe skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if the private pilot is carryingpassengers or cargo for hire. In this case, while the UASs will be operated as part ofa commercial operation, it carries neither passengers nor cargo. In the Grant ofExemption to Astraeus Aerial17, the FAA determined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrantthe addition cost and restrictions attendantwith requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment ofthe additional requirement s for a private pilotto become qualified as a commercial pilot would not lead to any additional safetybenefits when UAS operations are involved. Furthermore, while helpful, a pilotlicense will not ensure remote control piloting skills
. The risks associated with the operation ofsmall UAS is far less than the risks associated with the commercial activities outlined in 14 CFR § 61.113 (a) & (b).

71 PageAPPENDIX A - FLIGHT MANUAL FLIGHT RESTRICTIONS a. No flight will be made with a UA Gross weight exceeding 55 pounds; b. All operations must occur in FAA Class Gairspace at no more than 400ftAGL, at an airspeed ofno more than 25 knots; c. All operations must utilize a visual observer (VO). The VO and PIC mustbe able to communicate byvoice at all times during a flight operation; d. Operations will be restricted to flights over private propertywith the permission of the property owner; e. The UAS will notbe operated over densely populated areas; f. The UAS System will notbe operated at air shows; g. The UAS will notbe operated over any open-air assembly ofpeople; h. The UAS will notbe operated over heavily trafficked roads; 1. The UAS will notbe operated within 5 NM ofan airport or heliport; j. Operations will be restricted to day only and weather conditions equivalentto VFR; k The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each newlocation; I. No flight may be made without a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UAS is in a condition safe for flight. PRE-FLIGHT CHECKLIST 1. Transmitter and UAS firmware is up to date; 2. Determine that UAS battery is fully charged in order to preventunexpected premature descent; 3
. Check all wiring connections and props are tight and locked; 4. Position transmitter antennae in the up position to maximize signal strength; 5. Check all propellers are undamaged and no cracks exist in any structural members ofthe UA; 6. Turn on radio controller, check for adequate voltage, set itto connectto the UA, move all control switches to forward or down position and throttle control stick full backposition; 7
. Connect UA main battery, check for radio contactwith UA's radio receiver; 8. At a location different from previous flight, re-set GPS and compass to current location; 9. Turn on transmitter, gimbal and camera; 10. Calibrate UA compass according to instructions outlined in user manual; 11. Adjust minimum automated return height for location; 12. Insure that launch area is safe and clear ofpeople; 13.Warn bystanders oftakeoff; 14
. Hover at low al titude for 20 seconds, look and listen for problems; 15. Confirm expected stick operation while hovering; 16
.Always monitor battery power and signal strength; 17. Maintain line ofsight operation with the UA at all times 8I PageAPPENDIX B- MANUFACTURER MANUALS Phantom 3 Professional User Manual v1.2 http://download.dji-innovations.com/downloads/phantom 3/en/Phantom 3 Professional User Manual vl.2 en.pdf Phantom 3 Professional Quick Start Guide vl.O http://download.d ji-innovations
.com/downloads/phantom 3/en/Phantom 3 Professional Quick Start Guide en.pdf Phantom 3 Intelligent Flight Battery Safety Guidelines vl.O http://download.dji-innovations.com/downloads/phantom 3/en/lntelligent Flight Battery Safety Guidelines en.pdf Phantom 3 Safety Guidelines and Disclaimer vl.O http: 1/download
.dji-innovations.com/downloads/phantom 3/en/Safety Guidelines Disclaimer en,pdf

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