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 controlled by clients of Centurion Home 

Inspections to assist in the safe evaluation of tall and steep roofs for our clients. 

Dear Mr. Williams: 

Centurion Home Inspections respectfully 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 assist in the inspections and evaluations of 

buildings, typically roofs and other tall objects normally found in residential 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’ intent, reflected in Section 333 of the FAA 

Modernization and Reform Act of 2012 (Modernization Act),1 that safe systems be 

permitted in the national airspace 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 features. 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.com
Background 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 developed specific Centurion 

Home Inspections Safe UAV Operational Procedures. 

Home Inspection 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 separate 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 interest by significantly 

enhancing the safety and efficiency of home inspection operations and by providing the FAA with 

valuable user experience on sUAS in a context with appreciable economic and societal benefits. As 

described more fully below, the requested exemption 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 Exemption 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 being major components. There are a wide variety of 

factors that can affect conditions and cause problems for home inspection. One slip can lead to 

accidents or other incidents causing personal injury 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-intensive and sometimes arduous, if not dangerous job. While the use of 

sUAS for supplemental or primary roof inspections/evaluations would not eliminate these risks 

entirely (as it is an additive safety measure), it would reduce the risks to inspectors by allowing for 
remote aerial review. 

By using sUAS for primary or supplemental roof inspections, 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 rotary wing aircraft. The use 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 capture the required video or still photos. The use of 

sUAS would provide a much safer (and less expensive) 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 applicable 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 completely 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 established for traditional, manned 

civil aircraft because the design and use profiles between 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, which is all that §11.81(e) requires. 

Granting an exemption will not adversely affect public safety. Centurion Home Inspections 

contemplates conducting sUAS operations over client owned or controlled land, or properties 

involved in real estate transactions for the buyer, solely during daylight hours, 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 areas 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 needs 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 operations, 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 the 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, will 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 grant of the exemptions requested 

herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft 

requirements and allowing commercial operations. These lightweight aircraft 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 the 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 the 
pre-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 approximately 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, additional 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 airspace within which the operation 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 assumed 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 strictly controlled pre-approved airspace. Besides 

knowledge of airspace regulations, dexterity in the control and operation of the sUAS acquired from 

actual operation of the aircraft is the most important factor in establishing an equivalent level of safety. 

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues are (1) 

where the aircraft will be flown, (2) the size of the aircraft relative to what is being used today to 

accomplish the same mission, and (3) what precautions will be taken to ensure the safety of those in 

the area of operation. We propose that the PIC has to be familiar with the sUAS to be flown (as 

detailed on page 6); the aircraft be operated within a relatively secure environment (private property); 

and that no one be allowed to enter the environment unless they have been fully briefed of the risks 

prior to operation of the sUAS, and have consented to the risks associated with being in the operating 

area. Should there be a mishap, the sUAS being flown pose significantly less of a threat than the 

helicopters and fixed wing aircraft now being employed 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 conventional 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 commercial 
certificated 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 total time as a sUAS rotorcraft pilot and at 

least 5 hours logged as a sUAS pilot with a similar sUAS type (single blade or multirotor). 

2) A minimum of 5 hours as sUAS pilot with the make and model of sUAS 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 specified in the Flight Operations & Procedures 

Manual consisting of a knowledge & skill test of the aircraft to be used. 

4) Have obtained a Small UAS Certificate of Registration from the FAA and keep this 

registration current. 

Centurion Home Inspections intends to use commercially available sUAS. The sUAS is less than 55 

lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a relatively 

secured area (private property). We have a routine maintenance schedule to verify that the sUAS 

will remain in safe and operational 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 333 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. sUAS 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 aircraft 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 easily available to inspectors and passengers. Based on 

the FAA Memorandum subject “Interpretation regarding whether certain 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) and 91.203(a) and (b) is not necessary. 
Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests 

Small UASs, by their design, do not have fully 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 use by Centurion Home Inspections DO NOT allow 

for any sUAS instruction. The aircraft under consideration 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 horizontally). 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 which a dual set of controls would 

be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other companydesignated individual, that would 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 congested 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 the 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 with 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 the 
boundaries 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 airports 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 Administrator 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 and revised documents to the Administrator upon 

request. The operator must also present updated and revised documents if it petitions for 

extension or amendment. If the operator determines that any update or revision would affect 

the basis for which the FAA grants this petition 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 updates 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. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance 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 flight critical component, must undergo a functional 

test flight in accordance with the operator’s manual. The PIC who conducts the functional test 

flight must make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry must be added to the operator’s 

manual. 

9. The operator must follow the manufacturer’s sUAS aircraft/component, 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 purpose 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 requirement. 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 operations are considered nonparticipants, and the PIC 

must operate the UA with appropriate distance from nonparticipants. 

12. Prior to operations conducted for the purpose of inspections as detailed herein in Home 

Inspection Operations, page 2, the PIC must have accumulated 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 the 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. During 
training, proficiency, experience-building, and take-off and landing currency flights all persons 

not essential for flight operations are considered nonparticipants, and the PIC must operate the 

UA with appropriate distance from nonparticipants. 

13. Prior to any flight operations authorized by this petition of exemption, the PIC and VO 

(AKA “Spotter”) must have successfully completed 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 qualification 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 that 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 consenting 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 with 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 sUAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the sUAS. 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 meteorological 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 believes 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 the 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 required for Centurion Home 

Inspections to conduct the operations 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 credible 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 with 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 aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the 

sUAS operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions 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) through (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 hire; 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 business 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, the inspection of real property. 

Without an exemption, the pilot would be required 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 appropriately outfitted and the property on the ground. Requiring a commercial 

pilot certificate would provide no appreciable safety benefit and would needlessly 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 paragraph (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 landing, no person may operate an aircraft 

below the following altitudes: 

*** 

(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. 

***** 

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 insufficiently 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). Additionally, relief should not be needed from paragraph 

(a) because an 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 

does not contemplate conducting operations over congested 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 operating 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 airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed – (1) During the day, to fly after that 

for at least 30 minutes. 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal 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 could run out of fuel in the event it has to be 

flown to an alternate airport or circle the planned 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 requirement. Rather it should be sufficient to require only 

as much additional excess flight capacity as necessary 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 provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter; 

***** 

§91.407 Operation after maintenance, 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 exemption from these three maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow an operator 

to meet the part 91 maintenance requirements. In particular, there are no individuals authorized by the 

FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness 

and annual return to service inspections required by §91.409(a). Centurion Home Inspections will 

maintain the aircraft as instructed in the owner’s manual and ASTM F2909, where applicable, and will 

not operate the aircraft until it has reasonably determined that any needed repairs have been made. 

However, because of the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 

409(a) and 417(a)&(b), we believe an exemption 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 operations over Centurion Home Inspections 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 conducted in areas 

remote from both congested areas and airports. The nature of operations anticipated 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

Specific type(s), make, and model

#1 --- DJI Phantom 3 Advanced

See Attached Flight Manuals:

DJI Phantom 3 User Manual
Appendix C

Please see the attached Confidential & Proprietary: Centurion Home 

Inspections, Inc. Flight Operation & Procedures Manual 

(FOPM)