June 23, 2016 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. , 

Washington, DC 20590 

RE: Amendment to Exemption 12248A -Trevor Battieste 

Dear Sir I Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the 

.. Reform Act .. ), Trevor Battieste (the .. applicant .. ), operator of an Unmanned Aircraft 

Systems ("UAS") seeks an amendment to current Exemption No. 12248A from the 

Federal Aviation Regulations ("FARs .. ). This amendment will allow for night flight 

operations for the purposes of infrared aerial scans of damaged flat-roof commercial 

properties in the Dallas, Ft. Worth (DFW) area. 

Applicant: 

Trevor Battieste 

(North Texas Property Inspections LLC) 

11700 Luna Rd. Suite 1 0205 

Farmers Branch, Texas 75234 

Regulations from which this exemption is requested: 

14 C.F.R. § 1.1 (Night Operations) -for performing Commercial Flat-Roof Infrared 

Scans 

Extent of relief I seek, and why: 

I seek to perform UAS night operations between the end of evening civil twilight and the 

beginning of morning civil twilight. The exemption is defined in 14 C. F. R. § 1.1. 

The reason for this petition is to seek the ability to conduct UAS night operations using a 

mounted infrared camera for aerial roof inspections, which in some applications is 

superior to ground-based roof inspections. Aerial infrared roof moisture inspections 

can be used to find and quantify the area of moisture (water) contamination in an 

insulated flat or low-slope roof. At night, areas of subsurface roof moisture are warmer 

(because the stored heat from daylight sunshine in the trapped water mass) as 

compared to the dry, functioning insulation or roof substrate. After sunset, when the 

roof's structure cools down, wet areas of roof insulation and other materials stay warm 

longer, allowing infrared cameras to detect the sources of heat and record them for later 

analysis. 
Safety Case 

• Applicant has worked in the aerostructures industry for over 1 0 years. (Vought) 

• Applicant has performed aerial & ground night infrared roof inspections safely for 

5.5 years. 

• Applicant has partnered and employed small engine planes/pilots to perform 

night aerial roof inspections for over 50+ clients. 

• Applicant is an authorized On-Roof moisture survey authorized contractor. 

Safety Mitigations: 

1. All flight operations will occur within 1 00 feet of the boundaries of a permanent 

structure and no higher than 400 feet above ground level. 

2. The drone is equipped with anti-collision lighting visible for at least 5,000 feet. 

3. The pilot in command ("PIC") holds a private pilot certificate, and a current FAA 

airman medical certificate. 

4. PIC will comply with 14 CFR § 61.53 

s. All PIC certificates and operating documents will be accessible during UAS 

operations and made available to an Administrator upon request. 

6. The drone is equipped to inform the PIC of accurate position, altitude, attitude, 

speed, and heading of the aircraft throughout the flight operation. 

7. The petitioner will conduct a daytime site assessment to note hazards and 

obstacles that may be difficult to see in low light conditions. 

a. The PIC and visual observer must be in place 30 minutes prior to night 

operations to ensure dark adaptation. 

9. The 'take-off' and landing areas will be lighted to allow the PIC to see the 

distance between the aircraft and surface during takeoff and landing and 

enabling the observer to monitor that non-participants remain at a safe distance. 

10. All operations will be conducted under visual meteorological conditions (VMC). 

Additional Safety Measures: 

• I do not operate within 5 miles of an airport. 

• I land my UAS prior to manufacturer recommended minimum level of battery 

power 

• I pilot my UAS through remote control by line of sight 

• My UAS uses GPS and a flight safety feature whereby it returns to a 

preprogrammed position and then slowly lands if communication with the remote 

control pilot is lost. 

• I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocol. 

• I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance. 

• I always obtain all necessary permissions prior to operation; and, 

• I have procedures in place to abort flights in the event of safety breaches or 

potential danger. 
• UA will be less than 55 lbs. in total weight (including attached infrared imager) 

• UAS will only be flown within the parameters of the roof-top being inspected. 

Public Interest: 

Infrared imaging is a proven method for identifying and defining moisture leak problems 

in commercial flat and low-slope roofs. During the day, the sun radiates energy onto a 

flat roof and into the roof substrate, and then at night, the roof radiates the heat back 

into outer space. Infrared imagers can detect the heat radiated back to .. see .. the 

warmer wet areas. The vertical vantage point of an infrared imager (attached to a 

drone) allow these wet areas to be detected more extensively and accurately versus 

walking the roof. Also, the capturing of infrared images by the UAS will limit or negate 

the need for a Roof Inspector to walk the roof in unstable roof to retrieve images. 

Thank you for your consideration. 

Trevor Battieste 

~6~ 

Please mail all correspondence to: 

11700 Luna Rd #1 0205 

Farmers Branch, Tx 75234 

Illustrations: 
Thermal Image Capturing Process Description: 

Durning the day, heat At night the roof radiates 

from the sun heats up the roof the collected heat back to the sky 

Dry Insulation ry Insulation 

Wet Insulation Wet Insulation 
PHOTOGRAPH THERMOGRAPH 

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B 

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g 

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.. 1. 

CAD DRAWING CAD OVERLAY