Petition for Exemption 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140 1200

New Jersey Avenue, SE., Washington, DC 20590

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, D.C. 20590

April 14th, 2015

Dear Exemption Manager;

We wish to submit our Petition for Exemption for Unmanned Aircraft System operations. We currently 

have well over 900 flight hours in UAS flying. 

Our request is to receive a waiver of the sections identified below. We are looking to operate a UAS in 

use of commercial applications for the roofing industry and insurance claims. 

Approving this request will serve the public, its economic interest and will contribute to the safety of 

people. We have great knowledge of FAA ruling and have great awareness of restricted and operational

airspace. Our number one goal is always safety when it comes to flight operations.

By allowing us this exemption for real world experience, we will be able to develop the best use of the 

UAS in the public. Operational utilization, training of the UAS, etc. has yet to be fully developed in the 

general public area, thus by allowing us to play a role in the development we will require more 

operational flight experience, and therefore need to get your approval for this petition. 

Michael Rouyre dba Point of View

5936 Travertine Ln #327 

Fort Worth, TX 76137

Phone: 817-903-1571

Email: povtours@gmail.com
-We are seeking to get exemption of:

Section of 14 CFR: parts 21 Subpart H14 C.F.R. §45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and 

(b); 14 C.F.R.§ 91.119(c); 14C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 

91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

If there was any omitted relevant sections for what we are looking to do, please feel free to suggest the 

section(s) that are missing.

-The extent of relief you seek and the reason you seek the relief:

Michael Rouyre dba Point of View is requesting relief and exemption from the listed Federal Aviation 

Regulations and any other applicable rules in order to allow the use of a Small Unmanned Aircraft 

System (UAS).

We are looking to help roof inspectors with their roof inspections on structures less than 75’ in total 

height from the adjacent ground. The requested exemption would allow us to help a state licensed 

independent claim adjuster to perform roof inspections of roofs and roof materials in order to assess 

and photograph damages without placing the claim adjuster at risk of fall. The request for this 

exemption will also allow us to help insurance claim adjuster gather data in a much faster and efficient 

way as well as making it safer for them. 

Per the U.S. Department of Labor News Release Number: 10-1753-NAT – “Fatalities from falls are the 

number one cause of workplace deaths in construction. We cannot tolerate workers getting killed in 

residential construction when effective means are readily available to prevent those deaths,” said 

Assistant Secretary of Labor of Occupational Safety and Health Dr. David Michaels. “Almost every week, 

we see a worker killed from falling off a residential roof. We can stop these fatalities, and we must.”” 

Even though this article is referring to construction workers, the matching risks are involved in regards 

to independent adjusters who performs the roof inspections. By using an UAS, the risk of an adjuster 

falling off a roof or a structure during an insurance claim inspection causing serious injury and/or death 

would be eliminated. 

-How your request would benefit the public as a whole:

1. More thorough inspection can be made in the roofing industry and insurance claims. A

comprehensive and accurate report will be available to them.

2. By decreasing the risk of injury and death, the insurance premium should start changing due to 

less claims and better employee worker’s compensation. This should then also affect the 

general public whether they are directly affected by a claim or not.

3. The use of dangerous equipment such as ladders, scaffolds, electronic and gas powered tools 

would not be needed anymore, therefore reducing the risk of injuries.

4. The general public would also benefit due to the amount of claims that can be completed during 

a natural disaster or catastrophic event. By providing such a fast turnaround, the public can 

recover much quicker. 

5. Due to time cutting for inspections in roofs and insurance claims, the named property 

owner/insured will be able to settle much faster on the claims, therefore providing a much 

better customer service experience.
6. Safety of the adjusters whom are part of the public as a whole: adjusters are not physically 

climbing the roof, no possibility of a fall will be present. 

-Reason why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule.

The exemption will not adversely affect safety due to the safety protocols put in place by Michael 

Rouyre dba Point of View. The general public would be much safer than the current state it is in by 

eliminating the risks previously stated.

1. A visual observer in addition to the Pilot-in-Command (PIC) will be mandatory at all times.

2. Communication will be established between the visual observer and PIC at all times.

3. The UAS will never be flown near manned aircrafts.

4. A consent form will be required to be signed by the property owner during roof inspections and 

insurance claims. All non-participating persons will be asked to move 50’ beyond the perimeter 

set.

5. During roof inspections a flight ceiling limit of 100’ altitude from adjacent ground level shall be 

strictly adhered to by the geo-fence and PIC for all inspections. Insurance claims will have a flight 

ceiling limit of 150’ from adjacent ground level. 

6. A signage barrier will be set up at every flight location to alert the public of an UAS inspection in 

progress. A geo-fence will also be enabled on the UAS so the aircraft will be limited to the 

airspace above the property or area to be inspected.

7. The UAS will always be in the line of sight of the PIC and visual observer at all times. 

8. Never will the UAS carry any dangerous materials or flammable liquids.

9. The UAS flight will end at 15 minute of flight time during roof inspections or 30 minutes of flight 

time during search and rescue or when the battery level has 25% power remaining.

10. A flight termination option will be on the UAS, which will prevent a “fly away” which will let the 

PIC safely terminate the flight.

11. The UAS operates electrically, has integrated GPS pilot system, provides location information as 

well as height AGL, speed, battery life, and can be programmed for no-fly zones. The craft can 

also provide direction of travel and distance from the pilot. 

12. The PIC will have access the manufacturer operation manual and be available upon request. The 

PIC and UAS flight will abide all pre-flight checks and suggested flight protocols. 

13. A log will be kept of all flights and locations.

14. A take-off and landing zones will be designated before the beginning of the flight. An emergency 

landing zone will be chosen as well.

15. All radio frequency used for the operation and controls of the UAS will comply with the FCC and 

any other agencies.

16. Operations will not occur under IFR conditions.

17. Michael Rouyre dba Point of View will maintain a $1,000,000 insurance liability policy at all 

times during the operation of the UAS.

18. The UAS will have all the proper contact information and the federal exemption number 

attached to it permanently. 

19. In the event that that UAS fails any pre-flight inspections, the UAS will be grounded permanently 

until the manufacturer issues a compliance certificate stating that the UAS has been fixed and 

has been inspected and deemed safe to fly again.
-A summary we can publish in the Federal Register stating –

a) The rule from which you seek the exemption; and

b) A brief description of the exemption you seek

(a) Point of View is seeking exemption from:

Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Aviation 

Regulations, Seeking Exemption from 14 C.F.R. Part 21 Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 

14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R.§ 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 

91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

(b) A brief description of what Michael Rouyre dba Point of View is seeking is as follows:

By obeying to much more stringent safety measures than is described by the Model Aircraft Operations 

Limits according to the FAA Modernization and Reform Act of 2012, Point of View is seeking exemption 

of the above listed rules. The sole purpose for the use of the UAS is to gather photo documentation of a 

roof or property in order to document an insurance claim made by the property owner. The photos can 

be obtained safely and quickly by the use of a UAS, thus decreasing the chance of a roof fall or any other 

threats during a claim inspection, by the adjuster, and subsequent collateral damage. The UAS roof 

inspection will also eliminate any damage caused by a physical roof inspection to a previously 

undamaged roof (breakage of clay tiles, or bending of metal roofing material by foot traffic, etc.). Safe 

and responsible use of a hobby sized UAS to gather photos of a roof below a height of 100’ poses no 

threat of harm to the public if conducted with the above mentioned protocols in place. Based on the 

size of the craft, experience of the pilot, and the operational goals, this request appears to be well suited 

for approval.

-If you want to exercise the privileges of my exemption outside the U.S.

I do not wish to use the rights of my exemption outside of the United States.

Sincerely,

Michael Rouyre dba Point of View

5936 Travertine Ln #327 

Fort Worth, TX 76137

Phone: 817-903-1571

Email: povtours@gmail.com