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5039 West Avenue • P. 0. Box 13380 • San Antonio, Texas 78213 (210) 341-3100 • (800) 688-1663 • Fax (210) 341-2959 www.beldon.com 

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June 17, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington, D.C. 20950

Re: Petition of Beldon Roofing & Remodeling Co. doing business as Beldon Roofing Company for Exemption Pursuant to Section 333 of the FAA Reform Act Department of Transportation: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Beldon Roofing Company ("Petitioner"), a roofing company that performs roof repairs and roofing services, hereby applies for an exemption from Federal Aviation Regulations ("FARs") identified below, to allow commercial operation of small unmanned aerial vehicles (i.e., small unmanned aircraft systems or small "UAS"). This exemption is in accordance with the UAS manufacturer's operations and/or instructions manual ("Aircraft Operations Manual"), and any other requirements established by the FAA pursuant to Section 333 of the Reform Act. For your convenience, this petition is organized as follows:
I. Petitioner's Description Il. Relevant Statutory Authority III. Qualification for Approval Under Section 333 of the Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested A. 14 C.F.R. Part 21, Subpart H— Airworthiness Certificates & 14 C.F.R. § 91.203(a)(1) B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§91.9(c), 45.23 (b) and 45.27(a)

licensed in the states of Florida CC-0O57757, Nevada M111, and other states. Please see www.beldon.com/states for a complete list of licenses.D. 14 C.F.R. §91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft E. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness F. 14 C.F.R. 91.103: Preflight Action G. 14. C.F.R. §91.109(a) Flight Instruction H. 14 C.F.R. §91.119: Minimum Safe Altitudes I. 14 C.F.R. §91.121: Altimeter Settings J. 14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions K. 14 C.F.R. §91.203(a) &(b) Carrying Civil Aircraft Certification and Registration L. 14 C.F.R. §§91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) &(b): Maintenance Inspections VI. Public Interest VII. Privacy VIII. Federal Register Summary IX. Conclusion
I. PETITIONER'S DESCRIPTION Petitioner is a roofing company based in San Antonio, Texas. Consistent with the requirements of 14 C.F.R. §11.81(a), Petitioner provides the following information in support of its petition for exemption:
The name and address of the Petitioner is: Beldon Roofing & Remodeling Co. d/b/a Beldon Roofing Company Attn: Curtis P. Cote General Counsel 5039 West Avenue San Antonio, Texas 78213 Phone (210) 366-6938 Email: curt.cote(

~ >,beldon.com Fax: (210) 340-5512

11. IZELEVANT STATUTORY AUTHORITY This petition for exemption is submitted to fulfil Congress' goal in passing Section 333(a) through (c) of the Reform Act. In the Reform Act, Congress directed the FAA to "safely accelerate the integration of civil unmanned aircraft systems into the national airspace system" and, under Section 333 of that law, directed the Secretary of Transportation ("FAA Administrator") to

~

~consider whether certain unmanned aircraft systems may operate safely in the National Airspace

System ("NAS") before completion of the rulemaking required under Section 332 of the Reform Act. l In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS, the public or pose a threat to national security in light of the following: • The UAS's size, weight, speed and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. 2 If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System." 3 In addition, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49. U.S.C. § 4470(f) (authorizing the grant of exemptions from a requirement of regulations prescribed pursuant to section 44701(a) —(b) and sections 44702 — 44716). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and; (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. §11.81; FAA, Petition for Exemptions.
1)[)(. QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the Statutory criteria and other potentially relevant factors are satisfied. The proposed operations would permit the use of small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access; and (4) would provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. Petitioner intends to use small UASs that are rotorcraft, weighing 55 or fewer pounds including payload. They operate, under normal conditions, at a speed of no more than 27 knots, have the capability to hover and move in the vertical and horizontal plane simultaneously. The small UASs will operate in line-of-sight and will operate only within airspace over properties where buildings at which roof work has been requested, at the request of and with advance authority and/or permission from the property owners and/or the property owner's
' Reform Act § 333(a). 2 Id. at § 333(b) (1).
3 1d. at § 333(c). 

## i 

## AF] ~~authorized agent. Such operations will ensure that the small UASs will not create a hazard to users

of the National Airspace System or the public. Petitioner's intend of use of the small UASs is in the interest of safety for its employees. Specifically, there are portions of a roof that its sales representatives/estimator cannot safely access. The small UASs will be used to take photographs/video of those portions of the roof that present a safety hazard to its employees.
Given the small size of the UASs involved and the restricted environment within which they will operate, this petition for exemption falls within that zone of safety (i.e., an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of small UASs to commence immediately. Also, due to the size of the UASs and the restricted areas in which the sUASs will operate, approval of the application presents no national security issue. Considering the direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing sUASs for the proposed operations, the grant of the requested exemptions is also in the public interest. Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption without delay.

IV. DESCRIPTION OF PROPOSED OPERATIONS To assist the FAA in its safety assessment of Petitioner's proposed small UAS operations, below is a summary of the operational limitations and conditions which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:
1. The small UAS will weigh less than 55 pounds. 2. Flights will be operated within line-of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute limit. 4. Flights will be operated at an altitude of no more than 400 feet above ground level ("AGL"). 5. Minimum crew for each operation will consist of the small UAS Pilot and an Observer. 6. The small UAS Pilot will operate the aircraft in accordance with the manufacturer's directions of operation, and within the parameters established by any and all local, state or federal laws, rules, guidelines, and ordinances. 7. The small UAS will operate only in the immediate area above buildings where roofing work has been requested and advance authorization/permission is obtained from the property owner or the property owner's authorized agent.



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### i i8. A briefing will be conducted regarding the planned small UAS operations prior to each such operation. It is mandatory for each person performing duties within the boundaries of the safety perimeter be present for this briefing. 9. Pilot and Observer will have been trained in the operation of UAS generally and will have received up-to-date information on the particular UAS to be operated. 10. Observer and Pilot will at all times be able to communicate by voice and/or text. 11. Written and/or oral permission from the relevant property owners will be obtained in advance of any and all small UAS operations. 12. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 13. If the small UAS loses communication of loses its GPS signal, the small UAS is equipped with advanced safety features that will allow the small UAS to automatically return to a pre-determined location. 14. The small UAS will have the capability to abort a flight in case of unpredicted obstacles of emergencies.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. By its terms, the statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including small UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. 4 Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 or the purposes of conducting aerial surveys and inspections using small UASs. Listed below are: (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has established to ensure a level of safety equal to or better than the rules from which exemption is sought. s A. 14.C.F.R. Part 21 Subpart H— Airworthiness Certificates & 14 C.F.R. § 91.203(a)(1). This petition seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1). Given the size and limited operating area associated with the use of small UASs to be utilized by the Petitioner, an exemption from Part 21 Subpart H 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. §7701(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 UAS.

4 See 49 U.S.C. §44701(f)(authorizing the grant of exemptions from the requirements of regulations prescribed pursuant to section 44701(a) —(b) and sections 44702 — 44716).
1 14 C.F.R. §11.81(e) 

# 9In all cases, an analysis of these criteria demonstrates that the small UASs 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 rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed sUAS operations.
EQUIVALENT LEVEL OF SAFETY The small UASs to be operated hereunder are less than 55 pounds, fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out above. Unlike other civil aircraft, the proposed operations in this petition for exemption will be controlled and monitored by the Operator and Pilot in concert, only above buildings where roofing services, inspection or repairs have been requested, and only with authority and/or permission of the property owner and/or the property owner's authorized agent. Moreover, the FAA will have advance notice of all operations conducted under this exemption. These safety enhancements, which already apply to civil aircraft operated in connection with existing inspection operations, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 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 or flammable liquid fuels, and inability to carry a substantial external load.
B. 14 C F R Part 27: Airworthiness Standards: Normal Category Rotorcraft 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the Petitioner's small UASs would otherwise require certification under Part 27, as a rotorcraft, Petitioner requests an exemption from Part 27's airworthiness standards for the same reasons identified in the exemption request from 14 C.F.R. Part 21, Subpart H.
C. Aircraft Marking and Identification requirements: 14 C.F.R. §&91.9(c), 45.23(b) and 45.27(a). This petition seeks an exemption from the aircraft marking and identification requirements of 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 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 Aircraft, states: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or 

### i iprovisionally certified aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than two (2) inches nor more than six (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. Exemption from §45.23(b) is warranted because the sUAS has no entrance to the cabin, cockpit or pilot station on which the word "experimental" can be placed. Moreover, given the size of the sUAS, two (2) inch lettering would be impossible. The word "Experimental" will be placed in the fuselage in compliance with §45.29(f) Given the nature of the specific relief sought by this exemption request, Petitioner requires relief from the associated marking and identification requirements of §45.27(a) and §91.9(c, which would require compliance with §45.23(b).
EQUIVALENTLEVEL OFSAFETY An equivalent level of safety for exemptions to the aircraft marking requirements of §§91.9(c), 45.23(b) and 45.27(a), will be provided by having the sUAS marked on its fuselage as required by §45.29(f) where the pilot, observer and others working with the sUAS will see the identification of the UAS as "Experimental." Additionally, Petitioner will ensure compliance with any requests of sUAS marking by the FAA. The FAA has issued the following exemptions to the aircraft marking requirements of §45.23(b): Exemptions Nos.: 10700, 8738, 10167 and 10167A.
D. 14 C.F.R. 01.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. This petition seeks an exemption from the flight manual requirements of 14 C.F.R. §91.9(b) 

### (2), which states: (b) No person may operate a U.S. registered civil aircraft — (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given its size, configuration and load capacity, the sUAS has no ability to carry such a manual on the aircraft, not only because there is no pilot on board, but because there is simply no room or capacity to carry such an item on the aircraft.



# ~ 1, i



# ~ `EQUIVALENT LEVEL OF SAFETY

The safety related purpose of the manual requirements can be equally satisfied by maintaining the sUAS flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. Accordingly, Petitioner requests an exemption from §91.9(b) (2)'s flight manual requirements, on the condition the sUAS flight manual be available at the control point during each operation. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.
E. 14 C.F.R. 01.7(a): Civil Aircraft Airworthiness. This petition seeks exemption from 14 C.F.R. §91.7(a), which requires that a civil aircraft be in an airworthy condition to be operates. Inasmuch as there will be no airworthiness certificate issued for the sUAS, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

EOUIVALENTLEVEL OFSAFETY Petitioner's small UAS Operators who will be flying the small UAS are fully trained in the small UASs maintenance and operations and have an incident-free safety record. Given the guidance of the Flight Manual for the small UAS for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827 and 10700.
F. 14 C.F.R. §91.103: Preflight Action. This petition seeks exemption from §91.103, which requires a Pilot In Command ("PIC") to become familiar with specific information before each flight, including information contained in the FAA-approved flight manual on board the aircraft. Inasmuch as a FAA approved flight manual will not be provided for the small UAS, an exemption will be needed.

EOUIVALENT LEVEL OF SAFETY An equivalent level of safety will be provided by following the Aircraft Operations Manual comprehensive preflight checklist. The PIC, in this case it is Petitioner's small UASs Operator, will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
G. 14 C.F.R. 01.109(a) Flight Instruction. This petition seeks an exemption from 14 C.F.R. §91.109(a), which provides that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

# r 

# I J IAII Fk ~instruction unless that aircraft has fully functioning dual controls." Small UAS and remotely

piloted aircraft, by their design do not have fully functional dual controls. Instead, flight control is accomplished through the use of a control box that communicates with the small UAS via radio communications.
EQUIVALENT LEVEL OFSAFETY Given the size and speed of the small UAS, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the small UAS, and all persons will be a safe distance away should the small UAS experience any difficulties during flight instruction. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft (See Exemption Nos. 5778K & 9862A).
H. 14 C.F.R. §91.119: Minimum Safe Altitudes. This petition 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 an 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)(1) 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." To provide the intended inspections, the small UAS will normally need to be operated within a range of approximately 50 feet from the buildings being inspected. Accordingly, due to the nature of the proposed operations, the PIC and the designated spotter may at times be less than 500 feet away from structures during the operation, and an exemption is therefore required.

EOUIVALENT LEVEL OFSAFETY Compared to flight operations with rotorcraft weighing far more than the maximum 55 pounds proposed herein, and the lack of flammable fuel, any risk associated with these operations is far less than those currently presented with conventional aircraft. An equivalent level of safety will be achieved given the size, weight and speed of the small UAS, as well as the location where it is operated. As previously stated, the small UAS will be operated in a restricted area, where buildings and people will not be exposed to operations without their pre-obtained consent. No flight will be taken without the permission of the property owner and/or local officials. Because of the advance notice to the property owner and participants, all affected individuals will be aware of the planned flight operations. Furthermore, by operating at such lower altitudes, the small UAS will not interfere with other aircraft that are subject to the minimum safe altitude regulations.



### i i14 C.F.R §91.121 Altimeter Settings.

This petition 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 an elevation of the departure airport or barometric pressure. An exemption is requires because the sUAS does not have a barometric pressure altimeter, but rather a GPS altitude read out.
EQUIVALENT LEVEL OF SAFETY An equivalent level of safety will be achieved by following the procedures set forth in the Aircraft Operation Manual. As prescribed in the Manual, the operator will confirm the altitude of the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the small UAS elevation above ground level, thus ensuring operation at safe altitudes.
J. 14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions. This petition seeks an exemption from 14 C.F.R. §91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (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 for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. The battery powering the small UAS provides approximately 20 minutes of powered flight. An exemption from the 30 minute reserve requirement in 14 C.F.R. §91.191 is therefore required.
EQUIVALENT LEVEL OF SAFETY An equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power, whichever happens first. The restriction would be more than adequate to return the small UAS to its planned landing zone from anywhere within its limited operating area. Operation of the small UAS with less than 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed. This request for exemption falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with §91.151(a)); see also Exemptions Nos. 2689F, 5745, 10673 and 10808.



### i iK. 14 C.F.R. §91.203 (a) &(b): Carrying Civil Aircraft Certification and Registration. This petition seeks an exemption from civil aircraft certification and registration requirements of 14 C.F.R. §91.203 (a) and (b). The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: an appropriate and current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. In addition to the fact that Petitioner is seeking an exemption from airworthiness certificate requirements, an exemption to this regulation is necessary because: (1) the small UAS's load capacity and size does not allow it to carry certification and registration documents; (2) the small UAS does not have a cabin or cockpit entrance at which the documents could be displayed; and (3) there are no passengers or crew for whom the certificates need be displayed.

EOUIVALENT LEVEL OF SAFETY To the extent these regulations are applicable to the proposed small UAS operations, an equivalent level of safety will be achieved by keeping these documents at the ground point where the pilot flying the small UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemptions Nos. 9565, 9789, 9789A, 9797, 9797A, 9816A and 10700.
L. 14 C.F.R.

~ §91.405(a); 91.407(a) (l); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections. This petition seeks an exemption from the maintenance inspection requirements of 14 C.F.R. §§99.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) &(b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43 See 14 C.F.R. §91.405(a)(stating that each owner or operator of an aircraft "[s]hall have that 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 to these regulations is needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the small UAS will not have.

EOUIVALENT LEVEL OF SAFETY An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Aircraft Operations Manual. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with the aircraft and



### p®r ibest suited to maintain the aircraft in an airworthy condition to provide the equivalent level of

safety. If a mechanical issue arises, the small UAS can land immediately and will be operating from no higher than 400 feet AGL. Moreover, the UAS's small size, carrying capacity, and the fact that its flight operations will only take place in restricted areas for limited periods of time, create less risk than the same factors associated with conventional fixed-wing and rotorcraft performing the same operation.

VI. PUBLIC INTEREST Consistent with the requirements of 14 C.F.R. 11.81(d), Petitioner offers the following reasons why granting this petition for exemption is in the public interest, i.e., how granting it would benefit the public as a whole. Approval of the exemptions allowing commercial operations of a small and lightweight small UAS in the roofing industry benefits the public as a whole in the following ways: • It helps fulfil Congress' goal in passing Section 333(a) through (c) of the Reform Act, namely, the FAA Administrator's assessment of whether certain UAS may operate safely in the National Airspace System before completion of the rulemaking required under Section 332 of the Reform Act. • The operation significantly improves safety and reduces risk by alleviating human exposure to danger associated with current aerial survey and inspection methods, namely, full-size helicopters. Manned helicopters performing roofing inspections and patrols can experience accidents and fatalities. The public's interest is furthered by reducing human exposure to death or serious injury associated with manned aircraft performing such roofing inspections and patrols. • Petitioner's small UASs are battery powered and create no emissions. If Petitioner's sUAS crashes, there is no fuel to ignite and/or explode. Any impact of Petitioner's lightweight sUASs is, obviously, far less than a full size helicopter. The public's interest is furthered by minimizing ecological impact of an accident and by reducing human exposure to potentially harmful emissions associated with manned aircraft. • Aerial surveys are valuable tools for roofing inspections. However, problems with safety, cost, statistical integrity, and logistics continue to impede aerial surveys and inspections from conventional manned aircraft. The use of small UAS addresses these problems and is a powerful tool for performing a wide range of roofing inspection applications. The public as a whole will benefit from the safer and more cost effective roofing aerial inspection services that small UAS operations provide.
VII. PltivaCV. All flights will occur over Petitioner's property or the Petitioner's Customer's property with the Customer's prior consent and knowledge.



# ~ 1, i iVIII. FEDERAL REGISTER SUMMARY.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules: 14 C.F.R. Part 21, Subpart H; 14 C.F.R. Part 27; 14 C.F.R 45.23(b); 14 C.F.R. 45.27(a); 14 C.F.R. 91.9(b)(2) &(c); 14 C.F.R. 91.103; 14.C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203 (a) &(b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) &(b) and 14 C.F.R. 91.7(a). Approval of exemptions allowing commercial operations of small and lightweight uninanned aircraft ("UAS") in the roofing industry will enhance safety by reducing risk. Conventional operations in this industry using rotorcraft or fixed-wing aircraft presents the risks associated with vehicles that weigh in the neighborhood of several thousand pounds and carrying large amounts of fuel. Such aircraft must fly to and from the survey or inspection location and operate at low altitudes. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates virtually all of that risk, given the reduced mass and lack of combustible fuel carried on board. The small UAS is transported, not flown, to the designated survey area and set up. The small UAS carries no passengers or crew and, therefore, does not expose them to the risks associated with manned aircraft flights. The operation of small UASs, weighing less than 55 pounds provides an equivalent level of safety and thus supports the grant of exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight small UASs operate at slow speeds, close to the ground and in a sterile environment. As a result,they are far safer than conventional aerial survey and inspections operations conducted with fixedwing aircraft or helicopters.
IX. CONCLUSION Satisfaction of the criteria provided in Section 333 of the Reform Act on 2013 — size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation within visual line of sight and national security — provides more than adequate justification for the grant of the requested exemptions allowing commercial operation of Beldon Roofing Company's roofing aerial inspection services. If additional information is required, or if you have any questions regarding this Petition, please contact the undersigned at (210) 366-6938. 

### Sincerely, 

# C uIr ( i;u ✓

~ i` is P. Cote 

## ~ General Counsel Beldon Roofing Company



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