Petition for Exemption 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 1200 

New Jersey Avenue, SE., Washington, DC 20590 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

September 15th, 2015

RE: Petitioning for Exemption under Section 333

Collins Construction Inc., DBA Collins Inspection Services and Collins Real Estate Services, (hereafter 

referred to as CCI) respectfully request to submit our Petition for Exemption for Unmanned Aircraft 

System (UAS) operations. We are a well-established, licensed and insured business. We have currently 

logged over 1000 hours of flight time with Multi Rotor UAS and model helicopters. We are looking to 

operate our UAS for use in commercial applications for the real estate, construction and inspection 

industries. We would further like to extend our scope to photography and videography. We are 

requesting exemption of the sections identified below. Approving this request will serve the public, its 

economic interest and will contribute to the public safety. We are knowledgeable of the FAA rulings and 

restricted operational airspace. We put safety of the public, operators and personal property as our top 

priority. By allowing us this exemption, we will be able to further our research and development of new 

marketing and inspection methods to best benefit the general public and our specific industries as a 

whole. 

Sections of the Code of Federal Regulations that we are seeking exemption from;

14 C.F.R: part 21 Subpart - Airworthiness Certificates

14 C.F.R. §45.23(b) - Display of marks; general

14 C.F.R. § 45.27- Location of marks; nonfixed-wing aircraft.

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. § 91.7 (a) - Civil aircraft airworthiness.

14 C.F.R. § 91.9(b) (2) - Civil aircraft flight manual, marking, and placard requirements.

14 C.F.R. § 91.119 (b) and (c) - Minimum safe altitudes: General.

14 C.F.R. § 91.121- Altimeter settings

14 C.F.R. § 91.151(a) and (b) - 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.

Please also include any other sections from previously granted exemptions that you feel would be 

helpful in our operations. 
Airworthiness Certification

CCI proposes to utilize the following professional grade Unmanned Aircraft Systems; DJI S900; DJI S800 

EVO, and DJI F550. All units are equipped with DJI Wookong Control Systems with GPS. This control 

system significantly exceeds the precision and stability of the control systems of previously approved DJI 

Phantom units. 

The extent of relief we are seeking and the reason we are seeking the relief:

We are requesting relief and exemption from the listed Federal Aviation Regulations and any other 

applicable rules in order to allow the use of a Small Unmanned Aircraft System (UAS). We are looking to 

provide aerial marketing of real estate and building, bridge, dam and roof inspections. In addition, to 

survey construction sites and potential development sites. We would also like to utilize the excellent 

photography and videography capabilities of these units for photography and filming as requested by 

clients, not limited to closed-set motion picture and television filming. 

How our request would benefit the public as a whole:

1. Eliminate the need for aerial photography by a manned aircraft, increasing safety.

2. Eliminate use of ladders, scaffolding and other means of access that put construction and 

inspection personnel at risk of falls.

3. Provide faster results to the public for services.

Reasons why the exemption would not adversely affect safety;

The exemption will not adversely affect safety due to the following safety protocols; 

1. A visual observer (VO) in addition to the Pilot-in-Command (PIC) will be mandatory at all times.

2. Communication will be maintained between the VO and PIC at all times. 

3. The UAS will never be flown near manned aircraft or airports. 

4. A consent form will be required to be signed by private property owners during operations. 

5. All non-participating persons will be asked to move to a safe area beyond the perimeter of 

operations. 

6. During operations maximum of 400 feet above ground level (AGL) will be maintained 

7. A barrier with signage will be set up at every flight location to alert the public of an UAS 

operations in progress. 

8. A GPS controlled perimeter range from point of takeoff will be enabled on the UAS so the 

aircraft will be limited to the airspace above the property where operations are being 

conducted. 

9. The UAS will always be in the line of sight of the PIC and VO at all times.

10. UAS will never carry any dangerous materials or flammable liquids.

11. The UAS flight will end at 29 minutes of flight time or when the battery level reaches a point of 

25%. 

12. All UAS controls will be equipped with a return to home switch to help prevent loss of control 

due to malfunction or loss of orientation. 
13. The UAS has integrated GPS pilot system and on screen display system provides distance from 

point of takeoff, height AGL, speed, battery voltage, and can be programmed for no-fly zones.

14. The PIC will have access the manufacturer operation manual and will be available upon request. 

15. The PIC and UAS flight will abide all pre-flight checks and suggested flight protocols from 

manufacturer. 

16. A log will be kept of all flights and locations. 

17. Take-off, landing and emergency landing zones will be designated before the beginning of the 

flight.

18. All radio frequency used for the operation and controls of the UAS will comply with the FCC and 

any other agencies. 

19. Operations will not occur under IFR conditions. 

20. CCI will maintain a $1,000,000 insurance liability policy at all times during the operation of the 

UAS.

21. The UAS will have all the proper contact information and the federal exemption number 

attached to it permanently. 

22. In the event that that UAS fails any pre-flight inspections, the UAS will be grounded permanently 

until the manufacturer issues a compliance certificate stating that the UAS has been fixed and 

has been inspected and deemed safe to fly again.

Summary; 

a) Rules we are seeking exemption from;

CCI is seeking exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 

C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 61.133(a); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R.§ 

91.119 (b) and (c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a) and (b); 14 C.F.R. § 91.405(a); 14 C.F.R. § 

91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b)

b) A brief description of the exemptions we are seeking;

CCI is seeking exemption for the above listed sections of the Code of Federal Regulations so that we may 

legally provide better and safer services to the general public and our industries. By the use of a UAS to 

perform work that would require ladders, scaffolding or low flying manned aircraft we are improving the 

overall safety of the general public and workers. Furthermore we are able to provide a much quicker 

turn around for services to the public.

We do not wish to use the rights of our exemption outside of the United States. 

Thank You,

Scott A. Collins

Collins Construction Inc., DBA Collins Inspection Services and Collins Real Estate Services

1135 Terminal Way #209

Reno, NV 89502

916-705-5542

CollinsConstructionInc@Gmail.com