1 | P a g e 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 an d 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 ("F ARs") identified below, to allow commercial operation of small unmanned aircraft or ("UAS") for conducting aerial inspections and photography of structures and facil ities as part of exterior building

evaluations and real estate transactions.

This petition is based on information outlined in t his 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 Guideli nes v1.0, Phantom 3 Safety Guidelines and Disclaimer v1.0 (collectively "Manufacturer Man uals"), see Appendix B.

CPI began providing residential and commercial prop erty inspections in 2001. In the greater Los Angeles market, CPI is a leading inspec tion firm with expertise in property inspection and litigation support. Our inspectors c onsists of highly credentialed professionals who are certified member of the Calif ornia 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 inspection s performed by CPI typically involve the physical inspection of outdoor structures for the a ssessment of current condition, damage and defects. These inspections typically involve re cording images to document existing conditions. Depending on the nature of the inspecti on, obtaining images of certain physical2 | P a g e

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 chimney s 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 in spection, a CPI inspector fell off a one story roof due to ladder malfunction. While miracul ously 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 l adder. Health and safety is the primary

concern for our clients and the use of UAS would be nefit them, our inspectors and the general public.

The secondary benefit of this technology would be a erial 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 t o absorb such expenses. Hence depriving non-luxury homeowners and lower budget Re altors from a valuable marketing tool. Manned aircraft pose a threat to the public t hrough potential catastrophic crashes. UAS pose no such threat since size and lack of comb ustible 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-b oard 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 c arries:

• An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based tra nsmitter/controller as well as an iOS or Android mobile device application;3 | P a g e

• 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 d ata from the on-board flight computer to the on-board radio transmitter includin g altitude AGL, horizontal and vertical speed, compass direction of flight and dir ection 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 t he PIC to control the UA while in flight;

• A radio receiver receiving live video and flight da ta from the on-board camera and computer projects it all together onto an iOS or An droid device for the PIC to view during flight;

• A Visual Observer (VO) is a person who provides a s econd pair of eyes to visually track the UA while in flight.

The requested exemption would support an applicatio n for a commercial Certificate of Authorization to use the above described UAS to sup port aerial photography and video primarily of real property.

The UAS will be operated in the field with both a P IC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requireme nts for UAS" and with the following

Restrictions:

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

b. All operations must occur in FAA Class G airspace a t 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 o peration;

d. Operations will be restricted to flights over priva te 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 asse mbly of people;

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

i. The UAS will not be operated within 5 NM of an airp ort or heliport;
j. Operations will be restricted to day only and weath er 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 Inspecti on by the PIC before each operation to ascertain that the UAS is in a conditi on safe for flight (see Appendix A).4 | P a g e

We submit that the combination of the UA's light we ight, flight performance and ability and strict operation under the guidelines established i n 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 a re:

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 reques ted are listed below. Each regulation is outlined in the attached Addendum with our propo sed 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) a nd (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 an y time if you require additional

information or clarification. We look forward to wo rking with your office.

Sincerely,

Steve Carroll, President Carroll Property Inspections, Inc.

Addendum – containing Exemption Requests and Equiva lent Level of Safety

Appendix A – Flight Manual

Appendix B – Manufactures Manuals5 | P a g e ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

CPI requests an exemption from the following regula tions as well as any additional regulations that may technically apply to the opera tion of the UAS:

14 CFR Part 21, Subpart H: Airworthiness Certificat es 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 eq uivalent 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 Astr aeus 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 o f the Reform Act, an exemption is requested.

14 C.F.R. Part 27 Airworthiness Standards: Normal C ategory Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural r equirements for airworthiness certification of normal category rotorcraft. To the extent that CPI’s small UASs would otherwise require certification under Part 27, Peti tioner seeks an exemption from Part 27's

airworthiness standards for the same reasons identi fied 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), wh ich requires that a civil aircraft be in airworthy condition to be operated. The FAA has sta ted that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirem ents 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 a ccordance with Section V(A), supra.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manua l in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certific ation and Registration CPI seeks exemption from 14 C.F.R. § 91.9(b)(2). Gi ven the small size and configuration of the UAS, it would be impossible to keep airworthine ss 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): Aircra ft Marking and Identification Requirements CPI seeks an exemption from the aircraft marking an d 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.-registe red civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapt er. 14 C.F.R. § 45.23(b), Markings of the Aircraft, sta tes: When marks include only the Roman capital letter "N" and the registration number is d isplayed on limited, restricted or light-6 | P a g e

sport category aircraft or experimental or provisio nally certificated aircraft, the operator must also display on that aircraft near each entran ce to the cabin, cockpit, or pilot station,

in letters not less than 2 inches nor more than 6 i nches high, the words "limited," "restricted," "light-sport, "experimental," or "pro visional," as applicable. 14 C.F.R. § 45.27(a), Rotorcraft, states: Each oper ator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cab in, fuselage, boom, or tail the marks required by § 45.23. In a previous Grant of Exemption, the FAA determine d that exemption from these requirements was warranted provided that the aircra ft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpa rt 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, whi ch requires a PIC to become familiar with specific information before each flight, inclu ding 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 altitu de requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum saf e altitudes under which aircraft may not operate, including 500 feet above the surface a nd away from any person, vessel, vehicle, or structure in non-congested areas. See 1 4 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than tho se 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 r outes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the proposed UAS o perations will occur below 200 feet AGL. Additionally, due the nature of the proposed o perations, 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, whi ch requires a person operating an aircraft to maintain cruising altitude or flight le vel by reference to an altimeter that is set to the elevation of the departure airport or barometri c pressure. An exemption is required to

the extent that the UASs do not have a barometric a ltimeter, 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 ba ttery power means that no meaningful flight operations can be conducted while still main taining 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 missi ons will be limited 22 minutes or less.7 | P a g e

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) a nd (2); 91.417(a) and (b): Maintenance Inspections CPI seeks an exemption from the maintenance inspect ion 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 ref erence to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or oper ator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of th is part and shall between required inspections ...have discrepancies repaired as prescri bed 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, whic h 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 follo wing:

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 prope rty for compensation or hire; nor may that person, for compensation or hire, act as P IC 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 e mployment; and

2. The aircraft does not carry passengers or property for compensation or hire. CPI seeks exemption from 14 CFR § 61.113, which res tricts 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 th at the skill and competency of any PIC matches the airspace in which the PIC will be opera ting, as well as requiring certifications if the private pilot is carrying passengers or cargo f or hire. In this case, while the UASs will be operated as part of a commercial operation, it carr ies neither passengers nor cargo. In the Grant of Exemption to Astraeus Aerial17, the FAA de termined that the unique characteristics of UAS operation outside of control led airspace did not warrant the addition cost and restrictions attendant with requiring a th e PIC to have a Commercial Pilot

Certificate and Class II Medical Certificate. The f ulfillment of the additional requirements for a private pilot to become qualified as a commer cial 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 piloti ng skills. The risks associated with the operation of small UAS is far less than the risks a ssociated with the commercial activities outlined in 14 CFR § 61.113 (a) & (b).8 | P a g e APPENDIX A – FLIGHT MANUAL

FLIGHT RESTRICTIONS

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

b. All operations must occur in FAA Class G airspace a t 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 o peration;

d. Operations will be restricted to flights over priva te 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 asse mbly of people;

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

i. The UAS will not be operated within 5 NM of an airp ort or heliport;
j. Operations will be restricted to day only and weath er 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 Inspecti on by the PIC before each operation to ascertain that the UAS is in a conditi on safe for flight.

PRE-FLIGHT CHECKLIST

1. Transmitter and UAS firmware is up to date;

2. Determine that UAS battery is fully charged in orde r to prevent unexpected premature descent;

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

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

5. Check all propellers are undamaged and no cracks ex ist in any structural members of the UA;

6. Turn on radio controller, check for adequate voltag e, set it to connect to the UA, move all control switches to forward or down positi on and throttle control stick full back position;

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

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

9. Turn on transmitter, gimbal and camera;

10. Calibrate UA compass according to instructions outl ined 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 list en 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 times9 | P a g e APPENDIX B – MANUFACTURER MANUALS

Phantom 3 Professional User Manual v1.2

http://download.dji-innovations.com/downloads/phant om_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/phant om_3/en/Phantom_3_Professional_Quick_Start_Guide_en .pdf

Phantom 3 Intelligent Flight Battery Safety Guideli nes v1.0
http://download.dji-innovations.com/downloads/phant om_3/en/Intelligent_Flight_Battery_Safety_Guideline s_en.pdf

Phantom 3 Safety Guidelines and Disclaimer v1.0

http://download.dji-innovations.com/downloads/phant om_3/en/Safety_Guidelines_Disclaimer_en.pdf