Fine Structure Home Inspections, dba Pillar to Post Home Inspectors

2801 Ashby Avenue, Berkeley, CA 94705

Petitioning for Exemption under Section 333

To whom it may concern,

I, Bruce MacDermott, owner of Fine Structure Home Inspections, am writing pursuant to the 

FAA Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333 

and the procedures contained within 14 C.F.R. 11, requesting to be exempt from the Federal 

Aviation Regulations as specified and from the requirements of 14 C.F.R 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), so that I can operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012.

This exemption request will permit me, Bruce MacDermott, as the owner and operator of 

Fine Structure Home Inspections, to operate a UAS vehicle for the commercial purpose of 

conducting home roof and property exterior inspections. I am the sole operator of the named 

UAS vehicle, a Horizon Hobby Blade Chroma quad copter with CG03 4K Camera. 

(http://www.horizonhobby.com/media/chroma/BLH8675.html). I am an experienced UAS pilot 

with the above-mentioned aircraft having flown numerous flights in both open areas and 

housing areas as practice for conducting home roof inspections.

The Horizon Blade Chroma UAS has numerous safety features which will ensure that I can 

provide a safe inspection environment for both people and property. The following are the 

most important safety features of the UAS.

1) The UAS has a SMART MODE, which makes operating of the UAS easier. SMART 

MODE:

a) ensures the UAS moves in the direction the device controller moves, regardless of 

the orientation of the UAS. (i.e., left on the device controller means the UAS moves 

left even if the UAS is facing towards you.)

b) creates a "safe circle," which is a barrier that prevents the aircraft from flying to close 

to the operator and clients, and restricts flight to a maximum altitude of 200 feet.

c) holds the position and altitude when the control stick is released.

2) Adjustable Flight Boundaries to make it easier to: Stay legal; Stay safe; Fly responsibly.

a) Keeps the drone within altitude and distance limits you define.

b) Easily adjusted using the Chroma programmer.

c) Helps you avoid sensitive airspace ...and neighbors.

3) The operations manual provides a startup procedure for the operator that I will follow for 

each flight. 

a) The UAS and associated ST-10 controller inform the operator when they are in sync 

and the GPS is locked via lights on the UAS and screen information on the device 

controller.

b) Maintenance and repair of the UAS will be my responsibility and I will conduct a preflight inspection will occur before every flight.

The UAS (Horizon Chroma) specifications and camera information are listed below.

Approx. Flying Time: 30 minutes per battery

Battery:11.1V 3S 6300mAh Li-Po

Motor to Motor Distance: 15.7 in. (400mm)

Height: 9.50 in. (242mm)

Weight: 45.9 oz. (1.3kg)

Motors: 4 x 780Kv Brushless Outrunner

Prop Diameter: 10.0 in. (253mm)
Flight Control Link: 2.4GHz

Video Link: 5.8GHz

Approx. Video Link Range: 1,970ft (600m)

Satellite Navigation: GPS Receiver, GLONASS

Length: 12.8 in. (325mm)

Width: 12.8 in. (325mm)

UAS Camera Information:

 4K/60 fps Video

 16MP RAM

 Photo Distance No Distortion Lens

 Integrated, 3 axis, brushless stabilization gimbal

 Adjustable Resolution and Frame Rate

 Streams live video to the ST-10 controller from as far as 600 meters

The San Francisco Bay Area, where I operate my business, has two international airports 

(OAK & SFO) and several local municipal airports. I will follow the requirements stated by the 

FAA regarding proximity to airports and helipads at all times. Those distances are listed 

below, which I took from the FAA site.

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an 

operational tower; or

 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or

 2 NM from a heliport with a published instrument flight procedure

I request the exemption because incorporating the UAS into my inspection procedures will 

allow members of the public seeking a home inspection to receive a high-quality roof 

inspection without spending extra money for a roofer. It will also negate the use of long 

ladders, which can create an unsafe condition and creates an opportunity to potentially 

damage property. Currently, most home inspectors use binoculars from the ground to 

perform a roofing inspection, which provides a lower quality inspection. This creates an 

opportunity for missed roof and roof covering information, creating a litigation concern for the 

home inspector. Providing this higher quality roofing information within the inspection report 

is beneficial to clients, agents, and sellers, because it gives them with the information 

needed to make informed decisions during the home sale process.

Thank you.

Sincerely,

Bruce MacDermott, CCI

CREIA Certified Inspector