1727 N STATE ROAD 7, MARGATE, FL 33063

954.975.7979 FAX: 954.975.7509

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E.

West Building Ground Floor, Room W12-140

Washington, DC 20590

Petition for Exemption under Section 333 of FAA Modernization and Reform Act and Part 11.81 

of Federal Aviation Regulations

September 30, 2015

Petitioner: Willcott Engineering Inc.

Phillip Quinn, EI

1727 North State Road 7

Margate, FL 33063

Tel: 954-975-7979

Email: PQuinn@WillcottEngineering.com

Web: www.WillcottEngineering.com

Dear Sir or Madam,

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

14 C.F.R. Part 11.81, Willcott Engineering Inc. hereby applies for an exemption from the listed 

Federal Aviation Regulations ("FARs") to allow commercial operation of its small, unmanned 

aircraft for building inspections and analyses. All operations shall be conducted within and under 

the conditions and limitations outlined previously by the FAA as required by Section 333 and 

conducted in compliance with the UAS operator's manuals.

1. Sections from which exemptions are sought: 

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 45:

i. 45.23

ii. 45.27

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFR Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417
2. Relief Sought 

a. Willcott Engineering Inc. wishes to operate a small Unmanned Aircraft System for 

commercial purposes to include building inspections and analyses.

b. The relief is sought due to commercial use of UASs being currently prohibited by 

law unless performed under an exemption.

c. This exemption will cover use of the following airframes, which will weigh less 

than 55 pounds including payload and energy sources:

i. DJI Inspire 1 – www.dji.com/product/inspire-1/spec

ii. Other models to be added by future exemption.

3. How this Request Would Benefit the Public As a Whole

a. UASs Reduce risk to human life due to dangerous activities such as performing 

inspections from scaffolding, swing stages and rooftops.

b. UASs allow for more thorough inspection and evaluation of buildings and 

structures, allowing detection of potential hazards to the public to be found more 

quickly.

c. UASs reduce the cost of inspections, which benefits property owners. This will 

help owners financially and make more frequent inspections possible, improving 

public safety.

4. How this request for exemption will not adversely affect safety:

a. This request will not adversely affect public safety due to strictly followed safety 

protocols including but not limited to those listed below:

i. A Visual Observer (VO) in addition to the Pilot in Command (PIC) will be 

mandatory at all times.

ii. The Pilot in Command and Visual Observer will have thorough 

knowledge of manufacturer’s user manuals and safety procedures.

iii. Communication between visual observer and pilot in command will be 

maintained at all times.

iv. All residents of the building under inspection will be notified in advance of 

UAS operation. Barriers with signage will be set up around perimeter of 

flight zone to restrict access to area.

v. A geo-fence will be set up to restrict the UAS from leaving the flight zone.

vi. In the event that the UAS fails any pre-flight inspections, the UAS will be 

grounded until it has been repaired by manufacturer and deemed safe to 

fly again.

vii. Flight operations will occur during daylight hours. No flight operations will 

be conducted during windy, foggy or inclement weather.

viii. The UAS will never operate above an altitude of 400 feet above ground 

surface.

ix. The UAS will never operate within 5 miles of any airport.

x. The UAS will never be flown in the same area that a manned aircraft is 

operating.

xi. The UAS will at all times be in the visual line of sight of the PIC and VO.

xii. The UAS will fly for a maximum of 30 minutes or when 25% battery 

capacity is reached, whichever happens first.

xiii. The UAS will utilize a failsafe that will return the UAS to the takeoff area 

in the event that communication is lost.

xiv. The UAS will use FCC compliant 2.4 GHz for control of aircraft.

xv. A log will be kept of all flights conducted and maintenance of aircraft.
xvi. The UAS will have all company contact information and federal 

exemption number displayed at all times.

xvii. Willcott Engineering Inc. will maintain liability insurance of at least 

$1,000,000 at all times.

Please advise if you need any additional information or if changes need to be made.

Best Regards,

June Willcott, PE

Owner/President

Willcott Engineering Inc.