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,

JLS Associated Services, Inc. dba WIN Home Inspection Dublin 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:

JLS Associated Services, Inc.

PO Box 1356

Westerville, OH 43086

Phone: (614) 890.2800

Fax: (614) 890.8904

Email: Lstumph@insight.rr.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

JLS Associated Services, 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 JLS Associated Services will use to conduct the inspection

is a DJI Phantom 3, 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 Phantom 3 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 Phantom 3 uses its positioning

system and smart flight technology to return back to the pilot.

JLS Associated Services 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. JLS Associated Services, 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.”

JLS Associated Services, 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 JLS Associated Services, 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’. JLS Associated Services, Inc. respectfully submits to be exempted from the

section.

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

JLS Associated Services, Inc. submits to exempt this section putting into consideration the

limited battery life that in turns limits flight duration of the UAS Phantom 3 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 Phantom 3 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 JLS Associated Services, 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

JLS Associated Services, 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, JLS Associated

Services, 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. Various roof coverings are brittle, by inspecting the roof with the UAS, it will avoid stepping

on them and causing damage.

3. 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.

4. Most residential roofs have a very high pitch, therefore it is not walkable. Due to this

reason, the homeowners seldom perform roof inspection for preventive measures until a

problem occurs.

5. 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.

6. 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 JLS

Associated Services. JLS Assocaited S e r v i c e s has spent more than fifteen years

providing the highest quality roofing inspections, establishing a reputation for excellence

working on tough demanding jobs for clients large and small. Founded in 1998, we are a

leading provider of roofing and home inspections throughout Central Ohio.

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.

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 UAS will not fly near a manned aircraft.

5. 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.

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

available for audit upon request.

7. A take‐off and landing zone shall be designated prior to the flight.

8. The radio frequency used for operation and control of the UAS will comply with the FCC or

other appropriate government agency requirements.

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

conditions.

10. 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.

11. JLS Associated Services, Inc. will maintain a $350,000.00 liability insurance policy while

operating the UAS.

12. 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.

13. The UAS will have a flight termination option to prevent a “fly away” and the pilot‐in‐ 

command can safely abort or terminate the flight.

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

exemption; and

a) 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, JLS Associated Services, 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) JLS Associated Services, 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.

JLS Associated Services, 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 designated take‐off and landing zones, 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 JLS Associated Services, 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.

JLS Associated Services, Inc. does not wish to exercise the privileges of my exemption

outside the U.S.

Respectfully,

JLS Associated Services, Inc

PO Box 1356  

Westerville, OH 43086

Phone: (614) 890.2800

Fax: (614) 890‐8904

Email: Lstumph@insight.rr.com