Petitioning for Exemption under Section 333

October 5th, 2015 

To whom it may concern, 

I, Michael Millspaugh, owner of Cover Your Assets Home Inspections LLC, am writing pursuant to the FAA Modernization 

and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333 and the procedures contained within 14 C.F.R. 

11, requesting to be exempt from the Federal Aviation Regulations as specified and from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), so that I 

can operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012.

This exemption request will permit me, Michael Millspaugh, as the owner and operator of Cover Your Assets Home 

Inspections LLC to operate a UAS vehicle for the commercial purpose of conducting home roof and property exterior 

inspections. I am the sole operator of the named UAS vehicle, a Horizon Hobby Blade Chroma quad copter. 

(http://www.horizonhobby.com/media/chroma/BLH8665.html). I am an experienced UAS pilot with the above-mentioned 

aircraft having flown numerous flights in both open areas and housing areas (free roof inspections for neighbors) as a 

hobby and as practice for conducting home roof inspections under my LLC. 

The Horizon Blade Chroma UAS has numerous safety features which will ensure that I can provide a safe inspection 

environment for both people and property. The following are the most important safety features of the UAS. 

a. The UAS has a SMART MODE, which makes operating of the UAS easier. SMART MODE ensures the UAS

moves in the direction the device controller moves, regardless of the orientation of the UAS. IE, Left on the device 

controller means the UAS moves left even if the UAS is facing towards you.

b. SMART MODE creates a "safe circle," which is a barrier that prevents the aircraft from flying to close to the 

operator and clients, and restricts flight to and maximum altitude of 200 feet.

c. SMART MODE holds the position and altitude when the control stick is released. 

The operations manual (See Attached) provides a start up procedure for the operator that I will follow for each flight. The 

UAS and associated ST-10 controller inform the operator when they are in sync and the GPS is locked via lights on the 

UAS and screen information on the device controller. Maintenance and repair of the UAS will be my responsibility and I 

will conduct a pre-flight inspection will occur before every flight. 

The UAS (Horizon Chroma) specifications and camera information are listed below. 

Approx. Flying Time 30 minutes per battery

Battery 11.1V 3S 6300mAh Li-Po

Motor to Motor Distance 400mm

Height 9.50in (242mm)

Weight 45.9oz (1.3kg)

Motors 780Kv Brushless Outrunner

Prop Diameter 260mm

Flight Control Link 2.4GHz

Video Link 5.8GHz

Approx. Video Link Range 1,970ft (600m)

GPS Receiver GLONASS and U.S.

Completion Level Ready-To-Fly

Recommended Environment Outdoor
UAS Camera Information

1080p/60 fps Video

Battery16MP Photo

Distance No Distortion Lens

Integrated, 3 axis brushless stabilization gimbal

Adjustable Resolution and Frame Rate

Streams live video to the ST-10 controller from as far as 600 meters 

The Northern Virginia area, where I operate my business, has two international airports (IAD & DCA) and one local airport

(Manassas). I will follow the requirements stated by the FAA regarding proximity to airports and helipads at all times. 

Those distances are listed below, which I took from the FAA site. 

5 nautical miles (NM) from an airport having an operational control tower; or

3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

2 NM from an airport without a published instrument flight procedure or an operational tower; or

2 NM from a heliport with a published instrument flight procedure

I request the exemption because incorporating the UAS into my inspection procedures will allow members of the public

seeking a home inspection to receive a high-quality roof inspection without spending extra money for a roofer. It will also 

negate the use of long ladders, which can create an unsafe condition and creates an opportunity to potentially damage 

property. Currently, most home inspectors use binoculars from the ground to perform a roofing inspection, which provides 

a lower quality inspection. This creates an opportunity for missed roof and roof covering information, creating a litigation 

concern for the home inspector. Providing this higher quality roofing information within the inspection report is beneficial to

clients, agents, and sellers, because it gives them with the information needed to make informed decisions during the 

home sale process. 

Thank you.

Sincerely, 

Michael Millspaugh

Cover Your Assets Home Inspections

Mike@CoverYourAssetsInspections.com

www.CoverYourAssetsInspections.com

703-395-2753