1 P.L. 112-95, 126 Stat 11, February 14, 2012.

2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas,

and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national security. March 6, 2016

Mr. James Williams Manager, Flight Standards Service Unmanned Aircraft Systems Integration Office

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

U.S. Department of Transportation, Docket Operation West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the use of small unmanned aerial systems on land cont rolled by clients of Centurion Home Inspections to assist in the safe evaluati on of tall and steep roofs for our clients.

Dear Mr. Williams:

Centurion Home Inspections respectfull y requests an exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial systems (sUAS) to assi st in the inspections and evaluations of buildings, typically roofs and other tall obj ects normally found in re sidential and small commercial properties, for our clients. This request is motivated primarily by the desire to maximize safety in said inspections by minimizing the need to use ladders and traverse tall or steep structures. While an exemption would not totally eliminate the need climb and traverse on some lower roofs, it would allow Centurion Home Inspections to evaluate structures that would otherwise be inaccessible with sUAS, resulting in a safer and more efficient roof inspections. Accordingly, the grant of an exemption is consistent with Congress’ in tent, reflected in Section 333 of the FAA

Modernization and Reform Ac t of 2012 (Modernization Act), 1 that safe systems be permitted in the national airspa ce prior to the issuance of final regulations governing general use of these systems. 2 A summary of this request suitable for publication in the Federal Register is provided as Appendix A.

Appendix B provides the manufacturers information regarding the design,

aircraft performance, and fail-safe featur es. We have provided manufacturer

information related to operating limitations, normal and emergency procedures,

and maintenance and inspection procedures. As we add aircraft designs, we will update this appendix appropriately.

Appendix C provides the Centurion Home Inspections Operations Manual for flights covered under this Exemption Request. Victor G. Faggella, P.E., President Centurion Home Inspections, Inc. 78 Pond Valley Road Woodbury, CT 06798 (203) 263-0178 sUAS Registration #FA3HF79H4Y vgf@centurion-inspections.com http://www.centurion-inspections.comBackground Information

Centurion Home Inspections is in the business of performing home inspections for our clients. With homes becoming larger and taller in recent times, the use sUAS for our clients is becoming expected, as not being to evaluate a component is becoming no longer acceptable. Centurion Home Inspections clients look to us for Safe Operations of sUAS and to this end, we have deve loped specific Centurion Home Inspections Safe UAV Operational Procedures.

Home Inspecti on Operations

1. Roof Inspections

2. Property Overview

3. Pre-Listing Videos for Real Estate Transactions Expert Witness Testimony

4. Any other inspection required for a real estate transaction that requires an aerial perspective

As part of this Centurion Home Inspections is requesting FAA Exemption for sUAS operations for safety, inspection and video capture usage.

Regulatory Basis for Exemption Request In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the public interest. The FAA has imposed a sepa rate requirement in its procedural regulations, providing that the petitioner shall explain why granting the exemption would not adversely affect safety or how the exemption would provide at least an equivalent level of safety as compliance with the underlying regulation. In this case, approval of this exemption would advance the public in terest by significantly enhancing the safety and efficiency of home insp ection operations and by providing the FAA with valuable user experience on sUAS in a context wi th appreciable economic and societal benefits. As described more fully below, the requested exempt ion would permit the operation of sUAS under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety. To the contrary, as explained below, Centurion Home Inspections anticipates that use of sUAS will enhance safety in home inspection operations. Granting an Exem ption is in the Public Interest. The safety and efficiency of home inspection operations is heavily dependent upon visual analysis of systems and components of a home, the roof and exterior bein g major components. There are a wide variety of factors that can affect conditions and cause pr oblems for home inspection. One slip can lead to accidents or other incidents causing personal in jury and downtime of the home inspector.

As a result, pursuant to state regulations governing home inspections and company policy, the safety of the home inspector comes before the need to gather information for the client. At present, inspections of roofs and tall structures is done with the use of ladders if the home inspector deems it safe enough to climb and/or walk upon the roof. In many cases, the roof is not reachable in any practical manner with equipment normally carried by home inspectors (ladders typically 17-22’ in length). Setting up and climbing a ladder, and walking on a roof, is likely the single most hazardous part of performing a home inspection.

This also is often a labor-inten sive and sometimes arduous, if not dangerous job. While the use of sUAS for supplemental or primary roof inspectio ns/evaluations would not eliminate these risks entirely (as it is an additive safety measure), it would reduce the risks to inspectors by allowing forremote aerial review.

By using sUAS for primary or supplemental roof in spections, Centurion Home Inspections will be able to substantially upgrade its capacity to detect defects in the roofing of areas that are otherwise inaccessible to the home inspector. Thus, the use of sUAS has the potential to improve efficiency and safety, resulting in a safer and more complete inspection for the client.

For aerial property surveys (pre-listing inspections), there is no other way to practically capture video or still photos without the use of full sized fixed or rota ry wing aircraft. The us e of such aircraft would normally be cost prohibitive to the client and would prose a much greater risk to the generally population, as the fixed or rotary wing aircraft would have to fly to the property in question and would have to loiter over said property for some time to cap ture the required video or still photos. The use of sUAS would provide a much safer (and less expensiv e) alternative to the client and would normally only have to loiter for a short time over the target property. Any failure of sUAS would have a much smaller impact, if any, to the property and persons present.Granting an Exemption will not Adversely Affect Safety Centurion Home Inspections notes that there is no a pplicable standard for an equivalency determination. Some have argued that the appropriate standard is that for model aircraft, noting that their operations, if conducted for recreational purposes, would fall comple tely within the allowable operations for model aircraft. We believe it is difficult to argue that there is sufficient correlation between model operations controlled by the Academy of Model Aeronautics and the ones contemplated by Centurion Home Inspections. At the same time, it is clear that equivalency cannot be es tablished for traditional, manned civil aircraft because the design and use profiles be tween traditional aircraft and sUAS are simply too different. As such, we believe it makes more sense to focus on why the contemplated operations would not adversely affect safety, whic h is all that §11.81(e) requires.

Granting an exemption will not adversely affect public safety. Centurion Home Inspections contemplates conducting sUAS ope rations over client owned or controlled land, or properties involved in real estate transactions for the buyer, solely during daylight hour s, at altitudes well below that which would pose a risk to other aircraft. In general, sUAS operations are intended to be conducted in areas distant from both congested ar eas and airports. The nature of operations anticipated by Centurion Home Inspections requires that the sUAS be flown at relatively low altitudes (<400 feet) and relatively low speeds (<40mph). Centurion Home Inspections expects that in most instances, the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS. Accordingly, the risk of interference with another aircraft is minimal. Centurion Home Inspections also plans to conduct sUAS operations at least three miles from any public airports (including heliports). In the event an operation need s to be conducted closer to an airport, Centurion Home Inspections will inform the airport operator and airport air traffic control tower of the contemplated operation and will comply with any directions issued by air traffic control at that airport.

Approval of exemptions allowing commercial operations of sUASs in the infrastructure aerial inspection industry will enhance safety by reducing risk. Conventional operati ons, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from th e inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass

and lack of combustible fuel carried on board. The sUAS is carried to the inspection site. The sUAS will carry no passengers or crew and, therefore, w ill not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the gran t of the exemptions requested herein, including 333 Aircraft Exem ption Status exempting the appli cant from conventional aircraft requirements and allowing commercia l operations. These lightweight airc raft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

The safety of those on the ground is protected by th e fact that no one will be allowed into the area without the permission of the company. Security will be established for the flight area as part of thepre-flight control. Each individual within the secure area will be briefed prior to flight and will consent to being in the area. All others will be excluded from the area. Each individual in the secure area will sign a consent/release form.

Centurion Home Inspections initially intends to use a dedicated staff for sUAS operations. All operations will be within visual line-of-sight (i.e., no more than appr oximately 0.25 miles from the manipulator of the controls, or pilot in command (PIC)). Each PIC will conduct at least three take-offs and landings with the sUAS on which he or she is trained every 90 days. PIC’s will establish their qualifications thru a combination of aeronautical knowledge, UAS airmanship skills, and verification through testing of flight ability before home inspections have commenced. Depending on the type of operation, additiona l ground-based visual observers may be employed as well. These observers will be within constant visual line of sight and in constant contact with the PIC. The visual observers will assist the PIC in avoiding objects near the sUAS.

There are no standards for either Private or Commercial sUAS pilot certificates. The safe operation and

control of the UAS as described in this application does not depend on the type of FAA license held by the PIC. Given the restricted and controlled airspace within which operations will take place, the key factors needed by the PIC are knowledge of the airs pace within which the ope ration will take place and how that airspace fits into the National Airspace System (NAS). That knowledge can be and is gained primarily through ground school and not through flight training in fixed wing or rotor aircraft, nor is it dependent on the acquisition of a commercial or private pilot’s certificate. Those certificates demonstrate knowledge of the factors and skills needed for the safe operation of those types of aircraft (fixed wing or rotorcraft). It cannot be assume d that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial vehicle, operating at 400 AGL or lower, within st rictly controlled pre-appr oved airspace. Besides knowledge of airspace regulations, dexterity in the control and ope ration of the sUAS acquired from actual operation of the aircraft is the most important f actor in establishing an e quivalent leve l of safety.

If the PIC has acquired the necessary knowledge of ai rspace requirements, the relevant issues are (1) where the aircraft will be flown, (2) the size of the aircraft relative to w hat i s being used today to accomplish the same mission, and (3) what precautions w ill be taken to ensure the safety of those in the area of operation. We propose that the PIC ha s to be familiar with the sUAS to be flown (as detailed on page 6) ; the aircraft be operated within a relativel y secure environment (private property);

and that no one be allowed to ente r the environment unless they have been fully briefed of the risks prior t o operati on of the sUAS, and have consented to the ri sks associated with being in the operating area. Should there be a mishap, th e sUAS being flown pose significan tly less of a threat than the helicopters and fixed wing aircraft now being employ ed because they are a fraction of the size, carry no flammable fuel, do not carry crew or passengers, and pose an infinitesimal risk to others. This is in

stark contrast to conventi onal aircraft that are flown to the site , carry explosive fuel, carry passengers and crew, and operate in a much larger area.

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who are also qualified to fly the type of sUAS that are utilized for image-capture operations. There are even fewer commercial pilots that can fly these sUAS – to the point that to do both is considered rare. Assuming that it is unlikely for a company to find a pilot that has both qualifications, that company would either have to source a qualified sUAS pilot to train and obtain a commercial certificate, or find a commercialcertificated pilot who would be willing to learn to fly a sUAS to the competency level required for professional use.

Minimum requirements for the PIC include:

1) A minimum of 25 flight cycles and 5 hours of to tal time as a sUAS rotorcraft pilot and at least 5 hours logged as a sUAS pilot with a si milar sUAS type (single blade or multirotor). 2) A minimum of 5 hours as sUAS pilot with the make and model of s UAS to be utilized for operations under the exemption and 3 take offs and landings in the preceding 90 days. 3) Have undergone a qualification process as specifi ed in the Flight Operations & Procedures Manual consisting of a knowledge & skill test of the aircraft to be used. 4) Have obtained a Small UAS Ce rtificate of Registration from the FAA and keep this registration current.

Centurion Home Inspections intends to use commer cially available sUAS. The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passe nger, and operates exclusively within a relatively secured area (private property). We have a rou tine maintenance schedule to verify that the sUAS will remain in safe and op erational condition. Please see Appendix B , for Specific Types of sUAS.

Notes Regarding: 14 C.F.R. Part 21, Subpart H In accordance with the statutory criteria provided in Section 3 33 of PL 112

--- 95 in reference to 49 USC 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, we request that this aircraft exemption meets the conditions of Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise

certification and testing requirements of part 36, is not necessary.

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft Given the size of the sUAV, two-inch lettering will be impossible. s UAS will be identified by serial number, registered in accordance with Small UAS Certificate of Registration number and will be as large as practicable. The number will be displayed on the sUAS and the controller, as well.

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness Centurion Home Inspections’s request is based on the fact that no airworthiness certificate will be issued for the UAS. Centurion Home Inspections’s UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary.

Notes Regarding: 14 CFR § 91.9(b)(2) Civil ai rcraft flight manual, marking & placard Certifications required, the original intent of these regulations was to display an aircraft’s airworthiness, certification, and registration documents so they would be easil y available to inspector s and passengers. Based on the FAA Memorandum subject “Inter pretation regarding whether cert ain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2) a nd 91.203(a) and (b) is not necessary.Notes Regarding: §91.109 Flight instruction; Si mulated instrument & certain flight tests Small UASs, by their design, do not have full y functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. Aircraft being considered for us e by Centurion Home Inspections DO NOT allow for any sUAS instruction. The aircraft under cons ideration do have a simulator mode that allows the PIC to “fly” the sUAS without it ever leaving the ground. There will also be a “Beginner Mode” that allows the limitation of height and distance from the PIC to be set to no more than 30M (100 ft.) and limits the speed of the sUAS (ascent/decent and hori zontally). The simulator and beginner modes will be used as the primary training tool for any PIC.

Centurion Home Inspections does not describe training scenarios in wh ich a dual set of controls would be utilized or required, i.e. dual fl ight instruction, provided by a flig ht instructor or other companydesignated individual, that woul d require that individual to have fully functioning dual controls. Rather, Centurion Home Inspections evaluates the qualification of its PICs based on their experience with the sUAS to be operated and verifies through testing, in lieu of formalized training. As such, Centurion Home Inspections does not seek relief from 14 CFR § 91.109.

Notes Regarding § 14 CFR 91.119(b) Relief from § 14 CFR 91.119(b), operation over conges ted areas, is not applicable, because the operations of Centurion Home Inspections will only be conducted within the secured area described

herein.Centurion Home Inspections Safety Operations & Procedures Overview:

Technology Considerations: Best-in-class, tried and proven technologies that are in advanced iterations. Software from highlyreputable industry partners will include features

- 1. Auto descent (landing) if communication signal were to be severed. If the sUAS loses communications, the sUAS will have capability to return to a pre-determined location within the Security Perimeter and land. 2. Auto descent (landing) if battery were to drop lower than nominal level. 3. Flights will be terminated at 25% battery power reserve. 4. Live video for operator gives real-time positioning feedback. In other words, we can monitor the scene from the vehicle's perspective for collision avoidance, and to maintain spatial

orientation. 5. The sUAS will have the limit altitude and distance from the PIC via a programmable option. This will ensure the sUAS stays within the limits of the area under consideration

. 6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all times: speed, altitude, number of GPS satellites (when available), heading and voltage. 7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link failures occur (highly improbable), vehicle returns automatically to the point of launch. 8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.

Mechanical/Physical: 1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus eliminating the concern of signal severance (flying behind objects/walls). 2. The sUAS will weigh less than 55 lbs and travel at less than 40 mph. 3. Batteries should far exceed the capacity required for actual flight time. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site if deemed appropriate for the environment. The sUAS and th e associated equipment will normally be stored and transported in a waterproof, impact resistant case made specifically for the transport of the

sUAS model.

6. UA operated under this exemption will be marked in accordance w ith 14 CFR part 45 or as otherwise authorized by the FAA.

Personnel: 1. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, gimbal op, director) if required based on the size of the property under consideration. This will be at the sole discretion of the PIC and is not anticipated to be required in the majority of

the cases. 2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication. This typically is provided by the sUAS control system. 3. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties within theboundaries of the safety perimeter be present for this briefing. This will only be required if a spotter is to be used, as it is anticipated that the vast majority of the jobs will require only

the PIC. 4. The operator will obtain the consent of all persons involved in the sUAS operations and ensure that only consenting persons will be allowed within 100 feet of the flight operations. 5. Spotter and pilot will at all times be able to communicate by voice. This will be by personal communication devices that will not interfere with the operation of the sUAS and will only be required of a spotter is utilized. 6. Written and/or oral permission from the relevant property holders will be obtained. 7. Pilot and spotter will have been trained in operation of sUAS generally and received upto-date information on the particular sUAS to be operated.

Operations:

1. The unmanned aircraft (sUAS) must weigh less than 55 pounds (25 Kg), including energy source(s) and equipment. Operations authorized by this petition of exemption are limited to the following aircraft described in Appendix B . Proposed operations of any other aircraft will require a new petition or a petition amendment to this request.

2. The sUAS may not be flown at a ground speed exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operator’s manual. All altitudes reported to Air

Traffic Controllers when near ai rports must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

5. Some operations must utilize a visual observer (VO) (AKA “Spotter”). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The use of personal

communication devices that do not interfere with the operation of the sUAS are allowable.

6. The operator’s manual included as Appendix C and this petition of exemption must be

maintained and made available to the Adminis trator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s

manual.

The operator may update or revise its operator’s manual. It is the operator’s responsibility to track such revisions and present updated a nd revised documents to the Administrator upon request. The operator must also present upda ted and revised documents if it petitions for extension or amendment. If the operator deter mines that any update or revision would affect the basis for which the FAA grants this petiti on for exemption, then the operator must petition for amendment to their exemption. The FAA’ s UAS Integration Office (AFS-80) may be contacted if questions arise regarding update s or revisions to the operator’s manual.7. Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. Th e Ground Control Station, if utilized, must be included in the preflight inspection. All main tenance and alterations must be properly

documented in the aircraft records.

8. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a f light critical component, must undergo a functional test flight in accordance with the operator’s manual. The PIC who condu cts the functional test flight must make an entry in the UAS aircra ft records of the flight. The requirements and procedures for a functional test f light and aircraft record entry must be added to the operator’s

manual.

9. The operator must follow the manufacturer’s sUAS aircraft/com ponent, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator’s manual. At a minimum, requirements for the following must be included in the operator’s manual: a) Actuators / Servos; b) Powerplant (motors); c) Propellers; d) Electronic speed controller; e) Batteries; f) Remote command and control; g) Ground control station (if used); and h) Any other components as determined by the operator;

10. The Pilot In Command (PIC) must possess at least an FAA Small UAS Certificate of Registration.

11. Prior to operations conducted for the pur pose of infrastructure inspections, the PIC must have accumulated and logged, in a manner consistent with the minimum requirements as detailed on page 6. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this require ment. Training, proficiency, and experiencebuilding flights can also be conducted under this petition of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight oper ations are considered nonparticipants, and the PIC must operate the UA with appropria te distance from nonparticipants.

12. Prior to operations conducted for the purpose of inspections as deta iled herein in Home Inspection Operations , page 2, the PIC must have a ccumulated and logged, in a manner consistent with minimum requirements for the PIC, page 6, a minimum of five hours as sUAS pilot operating the make and model of sUAS to be utilized for operations under the exemption and three take-offs and three landings in th e preceding 90 days. Training, proficiency, experience- building, and take-off and landing currency flights can be conducted under this petition of exemption to accomplish the required flight time and 90 day currency. Duringtraining, proficiency, experience -building, and take-off and landing currency flights all persons not essential for flight operations are consider ed nonparticipants, and th e PIC must operate the UA with appropriate dist ance from nonparticipants.

13. Prior to any flight operations authorized by this petition of exemption, the PIC and VO (AKA “Spotter”) must have successfully complete d a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualif ication process must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of a “home inspection”, a flight demonstration will be documented via video recording and stored on the company server and website. This documentation video will readily available for review upon request by the

Administrator.

15. The sUAS may not be operated directly over any person, except authorized and consenting personnel, below an altitude th at is hazardous to persons or property on the

surface in the event of a sUAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and c onsenting personnel. At all times, those persons must

be essential to the operations.

17. Regarding distance from nonparticipating persons, the operator must ensure that no persons are allowed within 50 feet of the area except those consenting to be involved and necessary for the infrastructure inspection operations. This provision may be reduced to no less than 25 feet if it would not adversely affect safety. This will be at the discretion of the PIC. The level of safety may be determined by an evaluation of the inspection area.

18. If the sUAS loses communications or loses its GPS signal, the sUAS must return to the

“home” location set before initial take-off.

19. The sUAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual.

20. Each UAS operation must be completed with 25% battery power remaining.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this petition of exemption that fall within the prescribed minimum distance from an airport. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance w ith this exemption must be identified by the Small UAS Certificate of Registration number as obtained by the FAA.23. The operator must develop procedures to document and maintain a record of the s UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the s UAS. These procedures must be added to the operator’s manual.

24. Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

25. The operator must develop sUAS technician qualification criteria. These criteria must be added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official

upon request.

29. The sUAS must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

30. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorolog ical conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

31. The sUAS may not be operated by the PIC from any moving device or vehicle.

32. The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

33. The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The sUAS may not operate within 3 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.34. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume operations is provided.Support for Petition for Exemption In accordance with the procedural requirements of 14 C.F.R. §11.81, Centurion Home Inspections provides the following information:

Contact Information: Victor G. Faggella, P.E.

President/Owner Centurion Home Inspections, Inc. 78 Pond Valley Road Woodbury, CT 06798 (203)263-0178 vgf@centurion-inspections.com

Regulatory Provisions from which Centurion Home Inspections seeks an Exemption Centurion Home Inspections belie ves it may need an exemption from the following provisions to conduct the contemplated operations. In some instances, relief is needed because relief from another provision renders compliance with th e regulation at hand infeasible. 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)(1)&(2) 14 C.F.R. §91.417(a)&(b)

Centurion Home Inspections believes an exemption is only needed from the above-listed regulatory provisions. To the extent that the FAA believes that additional relief is requ ired for Centurion Home Inspections to conduct the operati ons described here, we request an exemption from any such regulatory provisions as well. 3

3 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as applicable”. Since none of the underlying requirements (e.g., inspection intervals) can be met and will require an exemption, Centurion Home Inspections believes a separate exemption should not be required for §91.417(a).The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status: Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular sUAS, as well as its proximity to airports and populated areas. An analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate in the areas and under the conditions contemplated by Centurion Home Inspections will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the conditions proposed in this request.

The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area of operation as is now done with conventional home inspections/evaluations. Application of these

same criteria demonstrates that there is no credib le threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materials and inability to carry a substantial external load.

Given the size and limited operating area associated w ith the aircraft to be utilized by the Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S. C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt airc raft from the requirement for an airworthiness certificate, upon consideration of the size, w eight , s pee d, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these crite ria demonstrates that the sUAS operated without an airworth iness certificate, in the rest ricted environment and under the conditions proposed will be at least as safe, or sa fer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certific ate without the restricti ons and conditions proposed.14 C.F.R. §61.113(a) and (b) §61.113 Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) throug h (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hi re; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any busin ess or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or

hire.

***** Centurion Home Inspections anticipates initially using limited, specially trained staff to conduct the sUAS operations. While these individuals will not hold commercial pilot licenses, the sUAS will not carry property for compensation or hire since they will be used solely to assist in home inspections and the evaluation of the property involved in real estate transactions in furtherance of Centurion Home Inspections’s primary business, th e inspection of real property.

Without an exemption, the pilot would be requi red to hold a commercial pilot certificate under §61.133. However, the risk associated with the contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole control of Centurion Home Inspections. Accordingly, the risk would be limited to Centurion Home Inspections personnel, who will be a ppropriately outfitted and the property on the ground. Requiring a commercial pilot certificate would provide no appreciable safety be nefit and would needle ssly impose additional cost on Centurion Home Inspections. Because the contemplated operations would not comply with §61.113(b)(1) and none of the other exceptions to pa ragraph (a) apply, relief is needed from both paragraphs (a) and (b).14 C.F.R. 91.119(c) §91.119 Minimum safe altitudes: General. Except when necessary for takeoff or la nding, no person may operate an aircraft below the following altitudes:

*** (c) Over other than congested areas. An altit ude of 500 feet above the surface, except over open water or sparsely populated areas. In t hose cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

***** Centurion Home Inspections submits that the only relief it requires from §91.119 is from the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations

because asset evaluation conducted at 500 feet or higher is insufficien tly distinct to be meaningful. Since operations at this altitude also pose a heightened risk of collision with another aircraft, safety can only be assured through the grant of an exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additi onally, relief should not be needed from paragraph (a) beca us e a n emergency landing of the aircraft due to a power failure will not create an undue hazard to persons or property on the surface. As noted in the explanation of why an exemption will not adversely affect safety, Centurion Home Inspections has been granted access to the land over which the sUAS will be operated, and public access is restricted. Centurion Home Inspections tightly control access to land and have the ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk of injury is minimal. Centurion Home Inspections

doe s not contemplate conducting operations over conges ted areas, so relief is not requested from paragraph (b).

14 C.F.R. 91.121 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person opera ting an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.”

***** As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded

barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.14 C.F.R. 91.151 §91.151 Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an airp lane under VFR conditi ons unless (considering wind and forecast weather conditions) there is en ough fuel to fly to the first point of intended landing and, assuming norma l cruising speed – (1) During the day, to fly after that

for at least 30 minutes. (b) No person may begin a flight in a rotorc raft under VFR conditions unless (considering wind and forecast weather conditions) there is en ough fuel to fly to the first point of intended landing and, assuming nor mal cruising speed, to fly after that for at least 20

minutes.

***** Operating the sUAS in a pre-defined area with less than 30 minutes of reserve fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft coul d run out of fuel in the event it has to be flown to an alternate airport or circle the planne d airport in the event of unanticipated conditions. Centurion Home Inspections does not intend to use the sUAS for point-to-point flights and will not operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport in order to land. Rather, Centurion Home Inspections will operate the sUAS using pre-planned flight paths (taking into account weather conditions) designed to allow the sUAS to fly to the point of intended landing. As such, there is no need for a time-based excess fuel requireme nt. Rather it should be sufficient to require only as much additional excess flight capacity as necessa ry to safely land the sUAS. We believe that a 25% battery reserve is more than sufficient to meet this objective.14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) §91.405 Maintenance required. Each owner or operator of an aircraft – (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provi ded in paragraph (c) of this section, have discrepancies repaired as prescrib ed in part 43 of this chapter;

***** §91.407 Operation after maintenan ce, preventive maintenance, rebuilding, or alteration. (a) No person may operate any aircraft that has undergone maintenance, rebuilding, or alteration unless – (1) It has been approved for return to service by a person authorized under §43.7 of this chapter;

***** §91.409 Inspections. (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

***** §91.417 (a) & (b)

***** Centurion Home Inspections believes that an ex emption from these three maintenance requirements i s appropriate because the FAA has not developed maintenanc e standards that would allow an operator to meet the part 91 maintenance requirements. In pa rticular, there are no individuals authorized by the FAA to approve a sUAS for return to service und er §91.407(a) or to conduct the initial airworthiness and annual return to service inspections requi red by §91.409(a). Centurion Home Inspections will

maintain the aircraft as instructed in the owne r’s manual and ASTM F2909, wh ere applicable, and will not operate the aircraft until it has reasonably determined that any needed repairs have been made. However, because of the technical impossibilit y of meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exem ption from these provisions is appropriate.

Please do not hesitate to contact me at the phone number or via the e-mail address provided above should you have any questions or concerns.

Respectfully submitted,

Victor G. Faggella, P.E. President, Centurion Home Inspections, Inc.Appendix A Summary for Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA determine that publication is needed.

Petitioner: Centurion Home Inspections, Inc. (Centurion Home Inspections)

Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) Description of

Relief Sought:

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS opera tions over Centurion Home Insp ections Client’s owned or controlled land, solely during daylight hours, to assist in the safe evaluation and analysis of infrastructure and operations. In general, sUAS operations are intended to be conducte d i n areas remote from both congested areas and airports. The nature of operations an ticipated by Centurion Home Inspections requires that the sUAS be flown at relatively low altitudes. Centurion Home Inspections expects that in most instances, the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk of interference with other aircraft is minimal.Appendix B

Spec i f i c t yp e ( s )

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## #1 --- DJI Phantom 3 Advanced

See Attached Flight M a n u a l s: DJI Phantom 3 User M a n u a lAppendix C

Please see the attached Confidential & Proprietary: Centurion Home Inspections, Inc. Flight Operation & Procedures Manual (FOPM)