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Carroll Property Inspection, Inc. 

1301 Crenshaw Blvd 

Torrance, CA 90501 

Tel: 310-375-4703 

June 15, 2015 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Re: Petition of Carroll Property Inspection, Inc., for an Exemption Pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") 

and 14 C.F.R. Part 11, Carroll Property Inspection, Inc. ("CPI") hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs") identified below, to allow 

commercial operation of small unmanned aircraft or ("UAS") for conducting aerial 

inspections and photography of structures and facilities as part of exterior building 

evaluations and real estate transactions. 

This petition is based on information outlined in this Petition for Exemption, as well as the 

Phantom 3 Professional User Manual v1.2, Phantom 3 Professional Quick Start Guide v1.0, 

Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0, Phantom 3 Safety Guidelines 

and Disclaimer v1.0 (collectively "Manufacturer Manuals"), see Appendix B. 

CPI began providing residential and commercial property inspections in 2001. In the 

greater Los Angeles market, CPI is a leading inspection firm with expertise in property 

inspection and litigation support. Our inspectors consists of highly credentialed 

professionals who are certified member of the California Real Estate Inspection Association 

(CREIA) and the American Society of Home Inspectors (ASHI). 

CPI seeks to utilize the latest UAS technologies to provide higher level of efficiency and 

safer services for our clients. Property inspections performed by CPI typically involve the 

physical inspection of outdoor structures for the assessment of current condition, damage 

and defects. These inspections typically involve recording images to document existing 

conditions. Depending on the nature of the inspection, obtaining images of certain physical 
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features, such as roofs, may not be feasible due to dangerous conditions, limited access on 

the structure, risk of damage to structures, or the excessive height of the required viewing 

angle. 

The use of UAS-assisted photography and video will provide a practical means to perform 

property inspections that would be otherwise unsafe to CPI inspectors and the general 

public. 

The primary benefit of this technology would be to assist in the close, detailed aerial 

inspection and examination of building components. Inspection of steep-sloped roofs, 

multi-story roofs, weathered roofs and tall chimneys for residential and commercial 

buildings are a few examples of where UAS-assisted photography would be of great benefit 

to CPI inspectors. 

On 5/27/2015 while conducting a residential team inspection, a CPI inspector fell off a one 

story roof due to ladder malfunction. While miraculously the inspector landed on his feet 

and only sustained minor injuries, this illustrates the inherent dangers associated with 

inspecting building components which the use of UAS would mitigate. The three witnesses 

(lead inspector, Realtor, contractor) were in close proximity to the incident and were 

fortunately unharmed by the falling inspector and ladder. Health and safety is the primary 

concern for our clients and the use of UAS would benefit them, our inspectors and the 

general public. 

The secondary benefit of this technology would be aerial photography and videography for 

real estate marketing, which is primarily available through manned fixed wing aircraft and 

helicopters. For small budget real estate companies and average homeowners the expense 

of such aerial photography and videography is cost prohibitive. Only large companies and 

high end Realtors or luxury homeowners can afford to absorb such expenses. Hence 

depriving non-luxury homeowners and lower budget Realtors from a valuable marketing 

tool. Manned aircraft pose a threat to the public through potential catastrophic crashes. 

UAS pose no such threat since size and lack of combustible fuel alleviates potential threats 

to the public. 

Additionally, CPI request to be allowed use of the UAS to benefit first responders nearby 

who might require and request assistance, including fire fighters and law enforcement, 

while remaining subject to all limitations cited in this application. 

THE UNMANNED AIRCRAFTS (UA): 

• A lightweight (2.82 lbs. gross weight with all on-board equipment), battery operated 

4-motor rotorcraft in the form of a quadcopter that takes off and lands vertically, 

manufactured by DJI, Phantom 3 Professional which carries: 

• An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/controller as well as an 

iOS or Android mobile device application; 
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• An on-board camera capable of capturing imagery in the form of full color, 12 

megapixel still photos and 4K video; 

• An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site; 

• A 2.4 Ghz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above; 

THE GROUND STATION-BASED PART OF THE SYSTEM: 

• A Pilot in Command (PIC) in operational control of a flight operation from beginning 

to end and who controls the UA while in the air; 

• A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while 

in flight; 

• A radio receiver receiving live video and flight data from the on-board camera and 

computer projects it all together onto an iOS or Android device for the PIC to view 

during flight; 

• A Visual Observer (VO) is a person who provides a second pair of eyes to visually 

track the UA while in flight. 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above described UAS to support aerial photography and video 

primarily of real property. 

The UAS will be operated in the field with both a PIC and a VO in accordance with FAA 

Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following 

Restrictions: 

a. No flight will be made with a UA Gross weight exceeding 55 pounds; 

b. All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an 

airspeed of no more than 25 knots; 

c. All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 

d. Operations will be restricted to flights over private property with the permission of 

the property owner; 

e. The UAS will not be operated over densely populated areas; 

f. The UAS System will not be operated at air shows; 

g. The UAS will not be operated over any open-air assembly of people; 

h. The UAS will not be operated over heavily trafficked roads; 

i. The UAS will not be operated within 5 NM of an airport or heliport; 

j. Operations will be restricted to day only and weather conditions equivalent to VFR; 

k. The PIC will brief the VO and property owner about the operation and risk before 

the first flight at each new location; 

l. No flight may be made without a Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UAS is in a condition safe for flight (see Appendix A). 
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We submit that the combination of the UA's light weight, flight performance and ability and 

strict operation under the guidelines established in 8900.227, and under all of the 

Restrictions (a) through (l) listed above, the FAA can have full confidence that the 

operation will have an equivalent or greater level of safety than manned aircraft 

performing the same mission. 

The name and contact information of the applicant are: 

Carroll Property Inspections, Inc. 

Attn: Steve Carroll 

1301 Crenshaw Blvd. 

Torrance, CA 90501 

Tel: 310-375-4703 

Email: steve@carrollpropertyinspections.com 

 

The regulations from which each exemption is requested are listed below. Each regulation 

is outlined in the attached Addendum with our proposed equivalent level of safety for each 

regulation: 

14 CFR Part 21, Subpart H 

14 C.F.R. Part 27 

14 C.F.R. § 91.7(a) 

14 C.F.R. § 91.9(b)(2) & 14 C.F.R. § 91.203(a) and (b) 

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.119 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151(a) 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b) 

14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113 

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional 

information or clarification. We look forward to working with your office. 

Sincerely, 

Steve Carroll, President 

Carroll Property Inspections, Inc. 

Addendum – containing Exemption Requests and Equivalent Level of Safety 

Appendix A – Flight Manual 

Appendix B – Manufactures Manuals 
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ADDENDUM 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

CPI requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the UAS: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the UAS selected provides an equivalent level of safety when compared 

to aircraft normally used for the same application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014- 

0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of 

the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is 

requested. 

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. To the extent that CPI’s small UASs would 

otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's 

airworthiness standards for the same reasons identified in the request for exemption from 

14 C.F.R. Part 21, Subpart H, supra. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

CPI seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required for 

14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found 

inapplicable. See Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, Petitioner requests 

that the requirements for § 91.7(a) be treated in accordance with Section V(A), supra. 

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

CPI seeks exemption from 14 C.F.R. § 91.9(b)(2). Given the small size and configuration of 

the UAS, it would be impossible to keep airworthiness documents and other aircraft 

manuals on board the UAS because there is simply no room and the UAS has no cabin or 

cockpit. 

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements 

CPI seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter. 

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include only the Roman 

capital letter "N" and the registration number is displayed on limited, restricted or light-
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sport category aircraft or experimental or provisionally certificated aircraft, the operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable. 

14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that 

rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by § 45.23. 

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) 

markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as 

practicable." FAA Docket No. FAA-2014-0352. 

14 C.F.R. § 91.103: Preflight Action 

CPI seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent 

that an FAA-approved Flight Manual is required. 

14 C.F.R. § 91.119: Minimum Safe Altitudes 

CPI seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. 

§ 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may 

not operate, including 500 feet above the surface and away from any person, vessel, 

vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) 

allows for a helicopter to operate at less than those minimum altitudes when it can be 

operated "without hazard to persons or property on the surface," provided that "each 

person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA." 

An exemption is required because the proposed UAS operations will occur below 200 feet 

AGL. Additionally, due the nature of the proposed operations, the Pilot and/or Observers(s) 

may need to be less than 500 feet away from the UAS. 

14 C.F.R. § 91.121: Altimeter Settings 

CPI seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to 

the elevation of the departure airport or barometric pressure. An exemption is required to 

the extent that the UASs do not have a barometric altimeter, but rather GPS altitude 

display. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

CPI seeks an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. The technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30-minute battery reserve. An 

exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. 

Additional information: Individual CPI Flight missions will be limited 22 minutes or less. 
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14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections 

CPI seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations 

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 

C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An 

exemption from these regulations is needed because Part 43 and these sections only apply 

to aircraft with an airworthiness certificate, which the UAS to be operated under this grant 

of exemption will not have. 

14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and 

Limitations 

61.113: subsections (a) and (b) prescribe the following: 

a. No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as PIC of an aircraft. 

b. A private pilot may, for compensation or hire, act as PIC 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. 

CPI seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical 

certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if 

the private pilot is carrying passengers or cargo for hire. In this case, while the UASs will be 

operated as part of a commercial operation, it carries neither passengers nor cargo. In the 

Grant of Exemption to Astraeus Aerial17, the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the addition 

cost and restrictions attendant with requiring a the PIC to have a Commercial Pilot 

Certificate and Class II Medical Certificate. The fulfillment of the additional requirements 

for a private pilot to become qualified as a commercial pilot would not lead to any 

additional safety benefits when UAS operations are involved. Furthermore, while helpful, a 

pilot license will not ensure remote control piloting skills. The risks associated with the 

operation of small UAS is far less than the risks associated with the commercial activities 

outlined in 14 CFR § 61.113 (a) & (b). 

 
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APPENDIX A – FLIGHT MANUAL 

FLIGHT RESTRICTIONS 

a. No flight will be made with a UA Gross weight exceeding 55 pounds; 

b. All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an 

airspeed of no more than 25 knots; 

c. All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 

d. Operations will be restricted to flights over private property with the permission of 

the property owner; 

e. The UAS will not be operated over densely populated areas; 

f. The UAS System will not be operated at air shows; 

g. The UAS will not be operated over any open-air assembly of people; 

h. The UAS will not be operated over heavily trafficked roads; 

i. The UAS will not be operated within 5 NM of an airport or heliport; 

j. Operations will be restricted to day only and weather conditions equivalent to VFR; 

k. The PIC will brief the VO and property owner about the operation and risk before 

the first flight at each new location; 

l. No flight may be made without a Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UAS is in a condition safe for flight. 

PRE-FLIGHT CHECKLIST 

1. Transmitter and UAS firmware is up to date; 

2. Determine that UAS battery is fully charged in order to prevent unexpected 

premature descent; 

3. Check all wiring connections and props are tight and locked; 

4. Position transmitter antennae in the up position to maximize signal strength; 

5. Check all propellers are undamaged and no cracks exist in any structural members 

of the UA; 

6. Turn on radio controller, check for adequate voltage, set it to connect to the UA, 

move all control switches to forward or down position and throttle control stick full 

back position; 

7. Connect UA main battery, check for radio contact with UA’s radio receiver; 

8. At a location different from previous flight, re-set GPS and compass to current 

location; 

9. Turn on transmitter, gimbal and camera; 

10. Calibrate UA compass according to instructions outlined in user manual; 

11. Adjust minimum automated return height for location; 

12. Insure that launch area is safe and clear of people; 

13. Warn bystanders of takeoff; 

14. Hover at low altitude for 20 seconds, look and listen for problems; 

15. Confirm expected stick operation while hovering; 

16. Always monitor battery power and signal strength; 

17. Maintain line of sight operation with the UA at all times 
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APPENDIX B – MANUFACTURER MANUALS 

Phantom 3 Professional User Manual v1.2 

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf 

Phantom 3 Professional Quick Start Guide v1.0 

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf 

Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 

http://download.dji-innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf 

Phantom 3 Safety Guidelines and Disclaimer v1.0 

http://download.dji-innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf