June 23, 2016 U

. S. Department ofTransportation Docket Management System 1200 NewJerseyAve. , Washington, DC 20590 RE: Amendment to Exemption 12248A-Trevor Battieste Dear Sir

### I Madam: Pursuant to the Section 333 ofthe 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. 12248Afrom 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 10205 Farmers Branch,Texas 75234 

### Regulationsfrom 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 forthis petition is to seek the abilityto conduct UAS night operations using a mounted infrared camera for aerial roof inspections,which in some applications is superiorto ground-based roof inspections. Aerial infrared roof moisture inspections can be used to find and quantifythe 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 heatfrom 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 detectthe sources of heat and record them for later analysis

.Safety Case
• Applicant has worked in the aerostructures industryforover 10 years. (Vought) • Applicant has performed aerial & ground night infrared roof inspections safelyfor 5.5 years. • Applicant has partnered and employed small engine planes/pilotsto perform night aerial roof inspectionsfor over50+ clients. • Applicant is an authorized On-Roof moisture survey authorized contractor. Safety Mitigations: 1. All flight operations will occurwithin 100 feet of the boundaries of a permanent structure and no higherthan 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 documentswill 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 petitionerwill conduct a daytime site assessmentto 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 priorto night operations to ensure dark adaptation. 9. The 'take-off' and landing areas will be lighted to allowthe PIC to see the distance between the aircraft and surface duringtakeoff and landing and enabling the observerto monitorthat non-participants remain at a safe distance. 10. All operations will be conducted undervisual meteorological conditions (VMC). Additional Safety Measures: • I do not operate within 5 miles of an airport. • I land my UAS priorto 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 othersources 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 priorto 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 backto
..see.. the warmer wet areas. The vertical vantage point of an infrared imager (attached to a drone) allowthese 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 Inspectorto walk the roof in unstable roof to retrieve images.

Thankyou for your consideration

. Trevor Battieste



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Please mail all correspondence to: 11700 Luna Rd #1 0205 Farmers Branch, Tx 75234

Illustrations:Thermal Image Capturing Process Description:
Durningthe day, heat At nightthe roof radiates from the sun heats upthe roof the collected heat backtothesky

Dry Insulation ry Insulation
Wet Insulation Wet Insulation

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