Owens CorningRoofing & Asphalt, LLC 1Owens CorningParkway Toledo, OH 43659 (419) 248-5846 Dan.Mills@owenscorning.com

March2, 2016

U.S. Depatiment ofTransp01iation, Docket Operations WestBuilding Ground Floor, RoomW12-140 1200NewJersey Avenue, SE Washington, DC 20590 Re: Requestfor Exemptionunder Section 333 Dear Sir orMadam: 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") forthe purposes ofaerialinspection, photography, andvideography. Operations will be conducted within and under the safeguards outlined herein and as may be established by the FAAunderFMRA Section 333(c). In accordance with Section 333 ofthe FMRA and 14 C.F.R. Pmi 11, OC hereby requests an exemptionfromthe listedFederalAviationRegulations to allowcommercialuse ofits UAS.

• 14 C.F.R. Part 21 SubpmiH: 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 SafeAltitudes (General) • 14 C.F.R. § 91.151(a): Fuel Requirements for FlightinVFRConditions • 14 C.F.R. §91.203(a) & (b): Civil Aircraft- Cetiifications Required • 14 C.F.R. §91.205(b): RequiredInstruments • 14 C.F.R. Subpmi E §§ 91.401

- 91.407: Maintenance, Preventative Maintenance, Alterations, and Inspections • 14 C.F.R. §91.7: CivilAircraftAirw01ihiness • 14 C.F.R. §91.9(b)(2): CivilAircraftFlightManual, Marking, and PlacardRequirements
1The exemptionis requested because (1) existing regulations will burden OC; (2) OC can provide a level ofsafety 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 equivalentlevel ofsafetyto existingregulations. Authorizing OC to conduct commercial UAS operation would enhance community education and awareness ofUAS. Further, operation ofUAS vehicles in these commercial operations are less disruptive, safer, and more cost effective than manned aviation equivalents due to the low altitude environment, giventhe size, speed, and inherentrisk oftraditional commercialhelicopter 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 howto properly install aroofandproductfeatures andbenefits. 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 ofsight (VLOS) in tightly controlled and limited airspace subject to strict operating safeguards. The Phantom is capable ofoperating 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), butnever above 400 feet AGL. OC's exemption request would permit its commercial operation ofUAS 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 howto properly install a roofand the features and benefits ofOC'sproducts. All operations will be conducted on private property with the written and/or oral permission of the property owner(s). I. About Owens CorningRoofing & 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 newresidential construction. The drone is an exciting additionto OC as itwill allowthe companyto utilize flight capabilities for the purposes ofaerial inspection, photography, and videography. The information collected

2will then be used to educate contractors and homeowners on how to properly install a roof, as well as productfeatures andbenefits. 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, cunentheading's, direction, and distance from home. The on screenradar shows the position ofthe drone as well and it's orientation. Onboard 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 ofanypossible 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 onthe level ofsafety at least equalto that ofwhichthe rule requires. 14 C.F.R. Part21 SubpartH: Airworthiness Certificates Subpmi H establishes the procedural requirements for the issuance ofairwotihiness cetiificates as requiredby 14 C.F.R. § 91.203(a)(1). EquivalentLevelofSafety The Federal Aviation Act and Section 3 3 3 ofthe FMRA both authorize the FAA to exempt an aircraft from the airworthiness cetiificate requirements upon consideration ofthe 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 ofthe prior petmission ofthe landowner, the size ofthe aircraft, the lack offlammable fuel, and the fact that the aircraft is carried to the location and not flown there all establishthe equivalentlevel ofsafety.

1 See attached 11DJI_Phantom_3_Professionai_Quick_Start_Guide_en" and 11DJI_Safety_Guidelines_Disclaimer_en" documents. 314 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) ofthis section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carryingpassengers orproperty for compensation orhire; nor may thatperson, for compensation or hire, act as pilotin command ofan aircraft. (b) A privatepilot may, for compensation orhire, act as pilotin command ofan aircraft in connectionwithany 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 ofan aircraft- (ii) For compensation or hire, provided the person is qualified in accordance with this part and with the applicable pmis ofthis chapter that apply to the operation. EquivalentLevel 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 exemptionis requiredto 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 ofsafety ofcurrent 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 orclass. 14 C.F.R. §91.119: Minimum SafeAltitudes (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 ofcivil aircrafts. EquivalentLevel of Safety Since the typical mission ofthe 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 onlybe flown over property orpersons where permission has been obtained and carefulpre-planninghas beenperformed. The aircraft will be operated at a low altitude, allowing an emergency landing withoutundue hazardto persons orproperty onthe 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 andthe operations ofconventional aircrafts thatmust comply with §91.119

414 C.F.R. §91.151(a): FuelRequirementsfor FlightinVFRConditions 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 ofintended landing and, assuming normal cruising speed, to fly after that for at least 30 minutes. EquivalentLevelofSafety This regulation was written based on the capabilities ofa traditional aircraft, which have flight times ofseveral hours or greater. The batterypowering the Phantom provides approximately 20 minutes ofpowered flight, making it impossible to meetthe 30 minute reserve requirement. This regulation would effectively deny the ability ofthe air vehicle to operate. An equivalent level of safety can be achieved by limiting flights to 17 minutes or 30% ofbattery power (whichever occurs first). The UAS will emit an audible or visual lowbattery 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 operationwill meet an equivalentlevel ofsafety. 14 C.F.R. § 91.203(a) & (b): CivilAircraft- CertificationsRequired 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 legibleto passengers or crew. EquivalentLevelofSafety 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 inspectionuponrequest. 14 C.F.R. § 91.205(b): RequiredInstruments This regulation provides for a minimum set ofoperational instruments for all powered aircraft operatingVFR. EquivalentLevel ofSafety The command and control stationfor the UAS fulfills the operational equivalentlevel ofsafety.

2 See attached 11Phantom_3_Professionai_User_Manual_v1.0_en" and 11DJI_Intelligent_Fiight_Battery_Safety_Guidelines_en" documents. 514 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 aircraftbe approved for return to service byaperson authorized under 43.7, after maintenance and inspection. EquivalentLevel ofSafety Given that these sections and Pmi 43 only apply to an aircraft with an airwmihiness certificate, these sections will not apply. Itis OC'sintentionthatthe pilotin command (PIC) performs basic maintenance and routine inspection ofthe 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 workperformed in accordance with § 91.417. An equivalent level ofsafety willbe achieved the UAS is limited in size, carries a small payload, and operates in restricted areas for limited periods oftime. Ifmechanical 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. Giventhe size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalentlevel ofsafety. 14 C.F.R. § 91.7: CivilAircraftAirworthiness The regulation requires that no person may operate a civil aircraft unless it is in an airworthy condition. EquivalentLevelof 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 ofan in-flight emergency or other unsafe condition. Bycomplying withprocedures outlined, by the manufacture, anequivalent level ofsafety will be achieved. 14 C.F.R. §91.9(b)(2): CivilAircraftFlightManual,Marking, and Placard Requirements This regulationprohibits operation ofU.S.-registered civil aircraftunless there is available inthe aircraft a cunent approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, andplacards, or any combinationthereof.

6EquivalentLevelofSafety Given the size and configuration of the UAS, there is no room or capacity to cany a flight manual. Bykeeping all operating documents, manuals, authorizations and exemptions inabinder at the ground control station, OC can meet the intent ofthe regulations and therefore achieve an equivalentlevel ofsafety. 

### IV. PublicInterest Given the above stated evidence, procedures, and precautions, operation ofOC's UAS for the purposes ofaerial inspection, photography, and videography is ultimately inthe 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 ofUAS 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 properlyinstall aroofandproductfeatures and benefits. V. FederalRegister 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 Regulationsto allowcommercialuse ofits UnmannedAircraft System.

• 14 C.F.R. Pati21 SubpartH: 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 SafeAltitudes (General)

7• 14 C.P.R.§ 91.151(a): Fuel Requirements for FlightinVFRConditions • 14 C.P.R. §91.203(a) & (b): CivilAircraft- Certifications Required • 14 C.P.R. §91.205(b): Required Instruments • 14 C.P.R. SubpartE §§ 91.401-91.407: Maintenance, Preventative Maintenance, Alterations, and Inspections • 14 C.P.R. §91.7: CivilAircraftAirworthiness • 14 C.P.R. § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements VI. Conclusion In conclusion, the operation ofthe UAS conducted in the strict conditions outlined above, will provide an equivalent level ofsafety and further the public interest; thus supporting the grant of the exemptions requested herein, including exempting OC from the requirements ofPart 21 and allowing commercial operations. Given the small size oftheUAS involved, its operation at slow speeds in low altitude and restricted environments demonstrates that it can be operated at an equivalent level ofsafety 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 ofsight, 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 exemptionwithout delay.

DanMills Digital Communication Specialist

- Roofing Components Owens Corning Roofing & Asphalt, LLC

Enclosures (4)

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