BElDO ~ 

Roofing 

CO m pang A Ndm eYouCan Tru5t 

5039 West Avenue • P. 0. Box 13380 • San Antonio, Texas 78213 

(210) 341-3100 • (800) 688-1663 • Fax (210) 341-2959 

www.beldon.com 

+ 

~ ~ 

Founded ~ 

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). 

2Id. 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. 

~~ i 

i 
8. 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) 9 
In 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 

i 
provisionally 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 

IJIAII 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 

i 
14 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 

i 
K. 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 

i 
best 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 

i 
VIII. 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, 

CuIr 

(

i;u✓~i`

is P. Cote ~ 

General Counsel 

Beldon Roofing Company 

~

1, 

i 

i