Owens Corning Roofing & Asphalt, LLC 

1 Owens Corning Parkway 

Toledo, OH 43659 

(419) 248-5846 

Dan.Mills@owenscorning.com 

March 2, 2016 

U.S. Depatiment ofTransp01iation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey A venue, SE 

Washington, DC 20590 

Re: Request for Exemption under Section 333 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("FMRA"), Owens 

Corning Roofing & Asphalt, LLC ("OC") hereby requests a determination by the Secretary of 

Transp01iation authorizing conduct of commercial operations of its Small Unmanned Aircraft 

System ("UAS") for the purposes of aerial inspection, photography, and videography. Operations 

will be conducted within and under the safeguards outlined herein and as may be established by 

the FAA under FMRA Section 333(c). 

In accordance with Section 333 of the FMRA and 14 C.F.R. Pmi 11, OC hereby requests an 

exemption from the listed Federal Aviation Regulations to allow commercial use of its UAS. 

• 14 C.F.R. Part 21 Subpmi H: Airw01ihiness Cetiificates 

• 14 C.F.R. § 61.113(a) & (b) and 61.133(a)(1)(ii): Private and Commercial Pilot Privilege 

and Limitation 

• 14 C.F.R. § 91.119: Minimum Safe Altitudes (General) 

• 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

• 14 C.F.R. § 91.203(a) & (b): Civil Aircraft- Cetiifications Required 

• 14 C.F.R. § 91.205(b): Required Instruments 

• 14 C.F.R. Subpmi E §§ 91.401 - 91.407: Maintenance, Preventative Maintenance, 

Alterations, and Inspections 

• 14 C.F.R. § 91.7: Civil Aircraft Airw01ihiness 

• 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements 

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The exemption is requested because (1) existing regulations will burden OC; (2) OC can provide 

a level of safety that is equal to those provided by existing rules; and (3) the request is in the 

public interest. The hereafter documentation includes detailed exemption requests that 

demonstrate how these exemptions are in the public interest and will maintain at least an 

equivalent level of safety to existing regulations. 

Authorizing OC to conduct commercial UAS operation would enhance community education 

and awareness of UAS. Further, operation of UAS vehicles in these commercial operations are 

less disruptive, safer, and more cost effective than manned aviation equivalents due to the low 

altitude environment, given the size, speed, and inherent risk of traditional commercial helicopter 

operations. The low expense of operation compared to cost prohibitive manned aviation 

alternatives allows a greater economic and educational benefit to local businesses and 

individuals, as the photos and videos will be used to educate contractors and homeowners on 

how to properly install a roof and product features and benefits. 

OC seeks an exemption to operate the Phantom 3 Professional, manufactured by DJI. The 

aircraft is battery-powered, weighs less than 3 pounds, and will operate during daylight within 

visual line of sight (VLOS) in tightly controlled and limited airspace subject to strict operating 

safeguards. The Phantom is capable of operating at speeds up to 35 miles per hour, but will be 

routinely operated at much lower speeds. The Phantom will routinely be operated below 200 feet 

above ground level (AGL), but never above 400 feet AGL. 

OC's exemption request would permit its commercial operation of UAS for aerial photography 

and videography in tightly controlled and limited airspace. Aerial photography and videography 

conducted by OC will be offered to contractors and homeowners to educate product users on 

how to properly install a roof and the features and benefits of OC's products. All operations will 

be conducted on private property with the written and/or oral permission of the property 

owner(s). 

I. About Owens Corning Roofing & Asphalt, LLC 

OC is the second largest producer of asphalt roofing shingles in the United States. OC sells 

shingles and roofing accessories primarily through home centers, lumberyards, retailers, 

distributors and contractors in the United States and sells other asphalt products internally to 

manufacture residential roofing products and externally to other roofing manufacturers. Demand 

for such products is generally driven by both residential repair and remodeling activity and by 

new residential construction. 

The drone is an exciting addition to OC as it will allow the company to utilize flight capabilities 

for the purposes of aerial inspection, photography, and videography. The information collected 

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will then be used to educate contractors and homeowners on how to properly install a roof, as 

well as product features and benefits. 

II. Aircraft 

OC operates a DJI Phantom 3 Professional. This phantom quadcopter includes an attached 

camera, gimbal, controller, and on board flight control system. The Phantom is monitored by a 

smart phone or tablet connected to the remote. Pilots can control the Phantom's movements in 

many directions including pitch, roll, elevation, and yaw. The control system provides the pilot 

with information on battery level, cunent heading's, direction, and distance from home. The on 

screen radar shows the position of the drone as well and it's orientation. On board GPS helps to 

stabilize the aircraft and also acts as a safety feature for if the controller and aircraft loose 

communication. Internal sensors can measure its altitude, and external sensors measure its 

distance to what's below. GPS assisted hover allows the aircraft to keep its altitude and distance 

from the ground. The aircraft is equipped with LED lights to indicate flight status and aleti the 

pilot of any possible issues. 1 

III. Regulations -Exemptions Requested 

Pursuant to 14 C.F.R. § 11.81(e), OC seeks exemption from the below listed regulations and 

provides reason as to why the exemption should be approved based on the level of safety at least 

equal to that of which the rule requires. 

14 C.F.R. Part 21 Subpart H: Airworthiness Certificates 

Subpmi H establishes the procedural requirements for the issuance of airwotihiness cetiificates 

as required by 14 C.F.R. § 91.203(a)(1). 

Equivalent Level ofSafety 

The Federal Aviation Act and Section 3 3 3 of the FMRA both authorize the FAA to exempt an 

aircraft from the airworthiness cetiificate requirements upon consideration of the size, weight, 

speed, operational capability, and proximity to airpotis and populated areas of the patiicular 

UAS. The UAS to be operated hereunder is approximately 3 pounds, catTies neither a pilot nor 

passenger, canies no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area. Operations under this exemption will be tightly controlled and monitored 

by the operator under OC's safeguards and in compliance with local public and facility safety 

requirements. Receipt of the prior petmission of the landowner, the size of the aircraft, the lack 

of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all 

establish the equivalent level of safety. 

1 See attached 11DJI_Phantom_3_Professionai_Quick_Start_Guide_en" and 11DJI_Safety_Guidelines_Disclaimer_en" 

documents. 

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14 C.F.R. § 61.113(a) & (b) and 61.133(a)(1)(ii): Private and Commercial Pilot Privilege 

and Limitation 

14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no 

person who holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, 

act as pilot in command of an aircraft in connection with any business or employment. 

14 C.F.R. § 61.133: (a) Privileges - (1) General. A person who holds a commercial pilot 

certificate may act as pilot in command of an aircraft- (ii) For compensation or hire, provided 

the person is qualified in accordance with this part and with the applicable pmis of this chapter 

that apply to the operation. 

Equivalent Level of Safety 

These regulations limit private pilots to non-commercial operations. Currently, there are no 

applicable areas identified for UAS in either the private or commercial sector and therefore an 

exemption is required to conduct commercial operations. Because the UAS will not caiTy a crew 

or passengers; due to the UAS's size, weight, speed, and operational capabilities; and since 

operations will occur in tightly controlled and limited airspace, the proposed operations achieve 

an equivalent level of safety of current operations that require a commercial pilot's license. OC's 

operations will be conducted by a pilot who holds, a minimum, a private certificate of any 

category or class. 

14 C.F.R. § 91.119: Minimum Safe Altitudes (General) 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Additionally establishes safe altitudes 

for operations of civil aircrafts. 

Equivalent Level of Safety 

Since the typical mission of the UAS would be aerial inspection, photography, and videography 

at a close range, it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been obtained and 

careful pre-planning has been performed. The aircraft will be operated at a low altitude, allowing 

an emergency landing without undue hazard to persons or property on the surface. Therefore, OC 

maintains that due to the small size of the UAS and low speed of operation, the hazard to 

persons, vehicles, and structures is minimal and provides an equivalent level of safety. In 

addition, the low altitude operations of the UAS will ensure separation between these UAS 

operations and the operations of conventional aircrafts that must comply with § 91.119 

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14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation provides that no person may begin a flight in an airplane under day 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, to fly after that for at 

least 30 minutes. 

Equivalent Level ofSafety 

This regulation was written based on the capabilities of a traditional aircraft, which have flight 

times of several hours or greater. The battery powering the Phantom provides approximately 20 

minutes of powered flight, making it impossible to meet the 30 minute reserve requirement. This 

regulation would effectively deny the ability of the air vehicle to operate. An equivalent level of 

safety can be achieved by limiting flights to 17 minutes or 30% of battery power (whichever 

occurs first). The UAS will emit an audible or visual low battery aleti at 30% and the UAS will 

automatically engage the landing sequence at 10%.2 Based upon that safeguard and the small, 

controlled operational area, the operation will meet an equivalent level of safety. 

14 C.F.R. § 91.203(a) & (b): Civil Aircraft- Certifications Required 

This regulation provides that no person may operate a civil aircraft unless it has an appropriate 

and cuiTent airworthiness certificate. Additionally, no personal may operate a civil aircraft unless 

the airwmihiness cetiificate 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. 

Equivalent Level ofSafety 

At approximately 3 pounds, the UAS is too small to catTy documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of 

safety and meet the intent of§ 91.203, OC proposes the documents deemed appropriate for this 

aircraft by the FAA will be co-located with the crew at the ground control station and available 

for inspection upon request. 

14 C.F.R. § 91.205(b): Required Instruments 

This regulation provides for a minimum set of operational instruments for all powered aircraft 

operating VFR. 

Equivalent Level ofSafety 

The command and control station for the UAS fulfills the operational equivalent level of safety. 

2 See attached 11Phantom_3_Professionai_User_Manual_v1.0_en" and 11DJI_Intelligent_Fiight_Battery_Safety_Guidelines_en" documents. 

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14 C.F.R. Subpart E §§ 91.401 - 91.407: Maintenance, Preventative Maintenance, 

Alterations, and Inspections 

This regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airwmihy condition, including compliance with Part 39 and 43. Section 91.407 and 91.409 

require that the aircraft be approved for return to service by a person authorized under 43.7, after 

maintenance and inspection. 

Equivalent Level ofSafety 

Given that these sections and Pmi 43 only apply to an aircraft with an airwmihiness certificate, 

these sections will not apply. It is OC's intention that the pilot in command (PIC) performs basic 

maintenance and routine inspection of the aircraft and be authorized to approve the aircraft for 

return to service. The PIC will ensure that the aircraft is in an airwmihy condition prior to every 

flight and in addition conduct detailed inspections after every 2 hours of flight. Maintenance 

performed by the PIC will be accomplished pursuant to the user manual and guide. All other 

maintenance will be perfmmed by the manufacturer or other designated repair facility. The PIC 

will document work performed in accordance with § 91.417. 

An equivalent level of safety will be achieved the UAS is limited in size, carries a small payload, 

and operates in restricted areas for limited periods of time. If mechanical issues arise, the PIC 

can land the UAS immediately, which will be operating from no higher than 400 feet AGL. The 

operator will ensure the UAS is in working order prior to initiating flight and perform 

maintenance as required. Given the size, construction, and simplicity of the aircraft, the PIC can 

ensure an equivalent level of safety. 

14 C.F.R. § 91.7: Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in an airworthy 

condition. 

Equivalent Level of Safety 

Currently there is no airwmihiness cetiificate for UAS. Daily pre- and post-flight inspections 

will be accomplished in accordance with the manufacture's maintenance manual(s) and 

guidance. During flight, the pilot-in-command (PIC) will adhere to § 91.7(b) and abmi air 

operations immediately upon identification of an in-flight emergency or other unsafe condition. 

By complying with procedures outlined, by the manufacture, an equivalent level of safety will be 

achieved. 

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements 

This regulation prohibits operation ofU.S.-registered civil aircraft unless there is available in the 

aircraft a cunent approved Airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. 

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Equivalent Level ofSafety 

Given the size and configuration of the UAS, there is no room or capacity to cany a flight 

manual. By keeping all operating documents, manuals, authorizations and exemptions in a binder 

at the ground control station, OC can meet the intent of the regulations and therefore achieve an 

equivalent level of safety. 

IV. Public Interest 

Given the above stated evidence, procedures, and precautions, operation of OC's UAS for the 

purposes of aerial inspection, photography, and videography is ultimately in the public's interest. 

Authorizing OC to conduct commercial UAS operation would enhance community education 

and awareness of UAS. UAS offer a strong equivalent level of safety and a reduction in 

environmental impacts. Operations will be conducted with less risk of collateral damage to 

persons and property while limiting dismptive noise and harmful emissions associated with low 

altitude aviation operations. Further, operation of UAS vehicles in these commercial operations 

are less dismptive, safer, and more cost effective than manned aviation equivalents due to the 

low altitude environment, given the size, speed, and inherent risk of traditional commercial 

helicopter operations. The low expense of operation compared to cost prohibitive manned 

aviation alternatives allows a greater economic and educational benefit to local businesses and 

individuals, as the photos and videos will be used to educate contractors and buyers on how to 

properly install a roof and product features and benefits. 

V. Federal Register Summary 

In accordance with 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register: 

Pursuant to Section 333 of the FAA Modernization and Refmm Act of 2012, 

Owens Corning hereby requests a determination by the Secretary of 

Transpmiation authorizing conduct of commercial operations of its Small 

Unmanned Aircraft System for the purposes of aerial inspection, photography, 

and videography. 

In accordance with Section 333 of the FMRA and 14 C.F.R. Part 11, Owens 

Corning hereby requests an exemption from the listed Federal Aviation 

Regulations to allow commercial use of its Unmanned Aircraft System. 

• 14 C.F.R. Pati 21 Subpart H: Airwmihiness Certificates 

• 14 C.F.R. § 61.113(a) & (b) and 61.133(a)(1)(ii): Private and Commercial Pilot 

Privilege and Limitation 

• 14 C.F.R. § 91.119: Minimum Safe Altitudes (General) 

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• 14 C.P.R.§ 91.151(a): Fuel Requirements for Flight in VFR Conditions 

• 14 C.P.R. § 91.203(a) & (b): Civil Aircraft- Certifications Required 

• 14 C.P.R. § 91.205(b): Required Instruments 

• 14 C.P.R. Subpart E §§ 91.401-91.407: Maintenance, Preventative Maintenance, 

Alterations, and Inspections 

• 14 C.P.R. § 91.7: Civil Aircraft Airworthiness 

• 14 C.P.R. § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard 

Requirements 

VI. Conclusion 

In conclusion, the operation of the UAS conducted in the strict conditions outlined above, will 

provide an equivalent level of safety and further the public interest; thus supporting the grant of 

the exemptions requested herein, including exempting OC from the requirements of Part 21 and 

allowing commercial operations. Given the small size ofthe UAS involved, its operation at slow 

speeds in low altitude and restricted environments demonstrates that it can be operated at an 

equivalent level of safety and poses no threat to national security. Additionally, the UAS offers 

significant public benefit, including enhanced safety, reduction in environmental impacts and 

emissions, decreased noise disturbance, and public education. Satisfaction of the criteria 

provided in Section 333 of the FMRA- size, weight, speed, operating capability, operation 

within the visual line of sight, public safety, and national security- provide more than adequate 

justification to grant OC's requested exemption and allowing commercial operations as 

described herewith. Accordingly, OC respectfully requests that the FAA grant the requested 

exemption without delay. 

Dan Mills 

Digital Communication Specialist - Roofing Components 

Owens Corning Roofing & Asphalt, LLC 

Enclosures (4) 

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