C:\PROGRA~2\Documentum\CTS\docbases\ProDocbase\config\temp_sessions\2606369177301692253\0900006481b75804.doc

San Antonio

Galveston

Austin

Dallas

Zero/Six Consulting, LLC

1027 Tremont

Galveston, TX 77551

409-740-0090 (voice)

409-740-0554 (fax)

866-551-0090 (toll free)

ATTN: Department of Transportation

Federal Aviation Administration

Washington, DC

FROM: Bill Coltzer, Zero/Six Consulting, LLC

1027 Tremont

Galveston, TX 77550

Fax: 409-740-0554

Phone: 409-740-0090

Email: bcoltzer@z6consulting.com

RE: First Exemption Request for Zero/Six Consulting Under Section 333 of the FAA 

Modernization and Reform Act; FAA-2007-0001

Dear Sir or Madam:

Zero/Six Consulting, LLC (ZSC) opened for business in April of 2003 in response to an 

industry wide need for firms with building envelope expertise. ZSC services include third 

party pier reviews, quality control programs, preparation of construction documents, 

construction contract administration, forensic Architecture, and “in house” testing. ZSC 

increases the design and construction quality in multiple phases of a project. This includes, 

but is not limited to, prevention, identification, and remediation in ensuring air and water 

tight facilities across Texas and Louisiana. ZSC’s services allow us to maintain better quality 

control of the testing process. We are dedicated to providing clients with excellent 

performance testing through our dedicated focus on building envelope commissioning. 

The objective for ZSC, as it pertains to this exemption we are seeking, is to use a small 

unmanned aircraft system (sUAS) for commercial purposes in order to ensure the safety of 

our employees and the public by assuring quality control inspection. The purpose of the 

sUAS is to increase the quality of the inspections being done while also increasing the safety 

of both the public and those employed at ZSC.

In the attached document you will find:

 Zero/Six Consulting’s formal request for exemption

 Sections pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 of Title 14 C.F.R. form which we request exemption

 The extent of relief sought

 How granting said relief would be in the public’s best interest

 The reason(s) granting the exemption would not adversely affect safety

 A summary the FAA can publish in the Federal Register

 Additional information to support ZSC’s request

 A diagram/photos of the small unmanned aircraft system (sUAS) to be used by ZSC

Thank you for the opportunity to present this petition for exemption and for your time

and consideration. ZSC looks forward to your response. For any further questions or 

information necessary, ZSC can be contacted directly via email or phone number listed.
www.z6consulting.com

Sincerely,

Bill Coltzer
www.z6consulting.com

This petition is to serve as Zero/Six Consulting’s official request for issuance of exemption 

under Title 14 C.F.R., Section 333. The specific sections of 14 C.F.R. from which we are 

seeking exemption are as follows:

 Part 21, Subpart H: Airworthiness Certificates 

 §45.23 Display of Marks; General

 §45.27 Location of Marks; Nonfixed-Wing Aircraft

 §91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft

 §91.109 Flight Instruction

 §91.119 (c): Minimum Safe Flight Altitudes; General

 §91.121 Altimeter Settings

 §91.151 Fuel Requirements for Flight in VFR Conditions

 §91.203 (a) (b): Civil Aircraft Certifications Required

 §91.409 Inspections

The extent of relief ZSC seeks, and the reason ZSC seeks that relief:

ZSC is seeking relief and exemption from the above listed Federal Aviation Regulations and 

any other applicable rules based on the decision to use a sUAS commercially in order to 

supply our clients, as well as the public, with thorough and complete building envelope 

inspection and analysis. Commercial use of sUAS is currently prohibited unless an 

exemption is granted. This request for exemption is based primarily on ZSC’s desire to 

maximize safety and efficiency in all of our inspection operations.

The reason why granting ZSC’s request would be in the public interest; that is, how it 

would benefit the public as a whole:

It is ZSC’s mission to operate our sUAS in such a way that not only complies with the FAA 

regulations set forth by Title 14 of the Code of Federal Regulations (14 C.F.R.) but also to 

ensure our own standards of safety that both comply with and exceed those that are required. 

We will employ and ensure methods of safe operations within the national airspace system. 

Our sUAS, should the exemption be granted, will be used by ZSC’s operator only for quality 

control inspections as well as detailed reporting and deficiency tracking. Our sUAS 

operations will be conducted in a controlled environment during daylight hours with specific

regard to inclement weather conditions as well as heightened awareness of our surroundings. 

The sUAS will be flown at or below the required altitude so as not to pose as a threat to 

other aircraft. This will give way to an increase in the general safety of those involved in the 

development and construction of the buildings in question while also increasing the safety of 

the public. 

Use of a drone will allow ZSC to do a multitude of things that pertain to the exterior of 

buildings and roof tops. ZSC performs building envelope inspections in order to assure the 

structure of a building is safe and water tight. This helps to guarantee quality assurance 

during construction as well as air quality by reducing the risk of structural debris and the 

possibility of mold. With the use of a drone we will be able to efficiently collect real time 

data on the progress of a buildings development whether it be repairs, testing, or general 

construction by inspecting roofs, windows, and outside walls of buildings. The drone will 

also allow ZSC to be able to identify potential hazards or quality issues in a safe and cost 

effective way. 

This is beneficial to the public in that is helps protect them from hazardous conditions 

involved when construction is being completed on any large structure that is exposed to 

outlying properties. It will also give us the ability to further protect those that will be inside 

the building by being able to eliminate risks associates with water infiltration. The use of a 

drone will allow safety measures to be implemented for our employees while further
www.z6consulting.com

reducing the risk associated with repelling and climbing on high and sometimes unstable 

surfaces. These are risks that currently need to be taken in order to get a full scope of the 

building’s envelope structure. By eliminating the need for these actions to take place and 

replacing them with the use of a drone we are greatly reducing the risk of falling. This not 

only increases the safety of our employees but those within a general proximity of said 

building. Exemption approval would be in the public’s best interest because it will allow 

ZSC to enhance the efficiency and safety of their operations both economically and within 

society. It will allow for almost immediate detection of potential problems and issues within 

a building’s envelope before they become hazardous to the safety of the public. 

The reason why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule 

from which ZSC seeks the exemption:

ZSC will implement strict safety protocols that adhere to the safety requirements put in place 

by the FAA. These protocols will be distributed via Zero/Six Consulting Flight and Safety 

Manual to those who are to operate the sUAS. The manual will not be present on the aircraft 

as per §91.9 (b) (2) limitations request due to the sUAS’s small size, but it will be available 

and present at ground level with the operator and PIC for safety reasons. Any and all 

operations to be performed by the sUAS will be done under controlled conditions to help 

ensure there will be no adverse impact on safety.

 ZSC drone operations will be conducted as follows:

1. Only within the visual line of sight of the operator and have one or more 

visual observer (VO)

2. With clear verbal communication between the operator and VO

3. With all those involved in flight operations within 100 feet of said 

operation

4. At less than 400 ft. flight ceiling limit

5. Within the designated class G airspace

6. Not within 5 feet of an airport without proper notification to the 

necessary authorities beforehand 

7. Flight may not exceed 40 mph 

 ZSC flight operations will be conducted as follows:

1. Operator and VO will inspect the sUAS before and after each flight.

2. Flight operations will take place in controlled and supervised areas with 

clear communication between the operator and VO.

3. No flight will be allowed to commence unless the weather and 

surrounding factors are conducive to a safe flight.

 The DJI Phantom 2 Vision UAV is comprised of a VTOL unmanned aircraft and a 

transportable ground station. The DJI Phantom 2 UAV has a maximum gross weight 

of approximately 2.5 pounds ( and the following technical and operational 

specifications: 

1. Max Flight Speed- 40 mph (The flights being conducted for observation/inspection 

of the exterior envelope will rarely exceed 10 mph)

2. Dimensions- 29x29x18

3. 5.8 GHz remote controller

4. Includes a “no fly zone” feature; exceeding control range of remote will trigger 

“return home” and the drone will automatically fly back to takeoff point and land 

safely

5. Battery- LiPo Smart Flight Battery

6. Flight time- 25 minutes

7. Serial Number: BI262049413018
www.z6consulting.com

 The DJI Phantom 2 unmanned aircraft is equipped with four (4) propellers driven by 

four (4) Lithium Polymer battery powered electric motors.

Note: See attached for sUAS photos

As you can see from the above listed drone description, ZSC’s drone fits the criteria and 

limitations set forth by the FAA. Due to the weight, size, speed, operating capabilities, and 

general proximity to airports our sUAS (Phantom 2 Vision) will not pose as a threat or 

hazard to users of the national airspace system nor will it disrupt the general public in 

violations of privacy or sound. For the sake of privacy, if the area in which the sUAS 

inspection is to take place is heavily populated or in close proximity to private property the 

necessary steps will be taken in order to receive the proper permission to conduct said flight.

In the event of a privacy issue in accordance with the Privacy Act Law for the state of Texas, 

ZSC will receive the proper permission and report it to the FAA before beginning flight 

operations. 

If there is a situation where the sUAS will be within 5 miles of an airport, our operator will 

provide the airport/air traffic control tower with prior notice of any flight operation that is to 

take place. The reliefs being requested four ZSC will allow for safe and managed flights that 

help ensure a secure building envelope thus ensuring the safety of the public as well as those 

involved in said construction/development.

A summary the FAA can publish in the Federal Register, sitting: (1) The rule from 

which you seek exemption; and (2) A brief description of the nature of the exemption 

you seek:

1. Petitioner: Zero/Sic Consulting, LLC

2. Sections of 14 C.F.R. Affected: Part 21, Subpart H; §45.23; §45.27; §91.9 (b) (2); 

§91.109; §91.119 (c): §91.121; §91.151; §91.203 (a) (b); §91.409

3. Description of relief sought: Petitioner (ZSC) seeks relief from the requirements of 

14 C.F.R. Part 21, Subpart H; §45.23; §45.27; §91.9 (b) (2); §91.109; §91.119 (c): 

§91.121; §91.151; §91.203 (a) (b); §91.409 in order to be able to conduct 

commercial small unmanned aircraft system (sUAS) operations on site; subject to 

operating procedures that either meet or exceed those put in place by both the FAA

and Zero/Six. The sole purpose of the sUAS is to gather photo documentation in 

order to provide our clients with adequate building envelope inspections. Due to the 

size, weight, and intended use of the Phantom 2 Vision our operations pose no threat 

to the public and greatly reduces the risk of injury to our employees. 

Any additional information, views, or arguments available to support your request:

 As this is a small unmanned aircraft system weighing less than 3 pounds, no pilot or 

passengers can be carried and it does not contain flammable liquids or explosive 

materials. 

 ZSC is currently in the process of receiving a drone liability insurance policy that 

will cover bodily injury and property damage. Proof of insurance can be submitted 

for documentation as soon as it is received if necessary and drone operations will not 

begin until the policy is in place. 

 ZSC is also in the process of registering our aircraft through the Aircraft 

Registration Branch and can submit proof upon request.
www.z6consulting.com

 The drone flight procedure and safety manual to be used by the operator and VO can 

also be submitted upon request.

 The information provided in this petition serves as adequate justification for an 

exemption approval to allow Zero/Six Consulting, LLC to operate a sUAS 

commercially in order to provide accurate and safe building envelopes for the use 

and wellbeing of the public. 

If you want to exercise the privileges outside of the United States, the reason why you 

need to do so:

Zero/Six Consulting does not wish to exercise these privileges outside of the Unites States at 

this time. 
www.z6consulting.com

DJI Phantom 2 Vision
www.z6consulting.com