February 8, 2016



### Petitioning for Exemption under Section 333 For Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC.
Unmanned Aircraft Systems Integration Office

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 U.S. Department of Transportation, Docket Operation West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the use of small unmanned aerial systems on land controlled by Allen Roofing and Construction Inc. & Allen

Real Estate Co LLC both herein referred to as ARC I NC. to assist in the safe evaluation, inspection of roo f and construction projects and aerial photography and video operations for our clients. Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. respectfully requests an exemption from several provisions of Title 14 of th e Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial systems (UA S) to assist in the safe evaluation, inspection of properties and aerial photography and video operations for our clients. This request is motivated primarily by the desire t o maximize safety in infrastructure and operations. While an exemption would not elimin ate the current need for in-person visual inspection required by various federal regulatory d epartments, it would allow Allen Roofing

and Construction Inc. & Allen Real Estate Co LLC. to broadly evaluate assets and operations with UA, resulting in a safer and more efficient in frastructure network. Accordingly, the grant of an exemption is consistent with Congress’ intent , reflected in Section 333 of the FAA Modernization and Reform Act of 2012 (Modernization Act), 1 that safe systems be permitted in the national airspace prior to the issuance of f inal regulations governing general use of these

systems. 1 P.L. 112-95, 126 Stat 11, February 14, 2012. 2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its size, weight, speed, ope rational capacity, proximity to airports and populated areas, andoperations within visual line of sight do not creat e a hazard to users of the NAS or the public or

pose a threat to national security.

Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. Nathan Trappe, President/Owner

241 ARC Lane PO Box 311

Monona Iowa 52159

Ph. 563.593.4135

Fax 563.539.4137
arcnathan@hotmail.com www.allenroofinginc.com

Background Information Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. is a fully licensed and insured roofing contractor company, and fully licen sed and insured real estate company serving Iowa, Southern Minnesota and Southwest Wisc onsin. We use Safe Operations of UA for inspections, Aero- Photography and Video of our Roofing and Construction projects. We understand that regulations and procedures must be strictly followed always for safety of people in ground and to no affect the safety of aer ospace system.

Operations : Roof Inspection, photography and video capture usag e. Construction Site Inspection. Photography and video capture usage. Real Estate inspection, photography and video captu re usage.

Regulatory Basis for Exemption Request In addition to the waiver authority provided in §33 3 of the Modernization Act, the FAA may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the public interest. The FAA has im posed a separate requirement in its procedural regulations, providing that the petition er shall explain why granting the exemption would not adversely affect safety or how the exemption would provide at least an equivalent level of safety as compliance with th e underlying regulation. In this case, approval of this exemption would advance the public interest by significantly enhancing the safety and efficiency of operations and by prov iding the FAA with valuable user experience on UA in a context with appreciable economic and so cietal benefits. As described more fully below, the requested exemption would permit the ope ration of UA under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety. Additionally, the sheer amount of assets and the wi dely dispersed locations – in many instances far from sizeable population centers – me ans that visual inspection in allinstances by company personnel can be inefficient. Aerial analysis by traditional fixed

wing aircraft is impractical because the required a ltitudes for safe flight reduce visibility below meaningful levels – it is simply not possible to see all asset anomalies from such heights. Helicopters present better vantage points; however manned helicopters are much more costly, subject to human safety and carry high ly explosive jet fuel making them impractical for deployment. By using UA for supplem ental asset evaluation, I Allen Roofing and

Construction Inc. & Allen Real Estate Co LLC. will be able to substantially upgrade its capacity to detect and address issues with the right-of-way and other assets before they become a problem for safe operations. Thus, the use of UA has the po tential to improve efficiency, resulting in faster and safer delivery of goods, energy & natural resou rces vital to the U.S. economy.

Granting an Exemption will not Adversely Affect Saf ety Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. note that there is no applicable standard for an equivalency determination. Somehave argued that the appropriate standard is that for model aircraft, noting that their operatio ns, if conducted for recreational purposes, would fall completely within the allowable operatio ns for model aircraft. We believe it is difficult to argue that there is sufficient correla tion between model operations controlled by the Academy of Model Aeronautics and the ones conte mplated by Me. At the same time, it is clear that equivalency cannot be established for tr aditional, manned civil aircraft because the design and use profiles between traditional aircraf t and UA are simply too different. As such, we believe it makes more sense to focus on why the contemplated operations would not adversely affect safety, which is all that §11.81(e ) requires. Granting an exemption will not adversely affect saf ety. Allen Roofing and Construction Inc. & Allen Real Estate Co LLC. contemplate conducting UA operations over client owned or controlled land, solely during daylight hours, at a ltitudes well below that which would pose a risk to other aircraft. In general, UA operations a re intended to be conducted in areas distant from both congested areas and airports. Moreover, because of the inherent risks presented b y standard infrastructure operations, our clients have already taken steps to secure property against unauthorized public access. For example, substantial stretches o f pipeline, utilities, railroad track and other sites are fenced, elevated, or otherwise secu red to prevent access. Other long stretches of infrastructure are, as noted abov e, in very remote wilderness areas. The nature of operations anticipated by Allen Roofing a nd Construction Inc. & Allen Real Estate Co LLC. requires that the UA be flown at relatively lo w altitudes and relatively low speeds. Allen Roofing and Construction Inc. & Allen Real Estate C o LLC. expect that in most instances, the UA will be flown less than 75 feet from the highest st ructure along the path of the UA. Accordingly, the risk of interference with another aircraft is minimal. Allen Roofing and

Construction Inc. & Allen Real Estate Co LLC. also plans to conduct UA operations at least three miles from any public airports (including heliports ). In the event an operation needs to be conducted closer to an airport, ARC INC. will infor m the airport operator and airport air traffic control tower of the contemplated operation and wil l comply with any directions issued by air traffic control at that airport. Approval of exempt ions allowing commercial operations of UA in the infrastructure aerial inspection industry will enhance safety by reducing risk. Conventional operations, using jet or piston power aircraft, ope rate at extremely low altitudes just feet from the subject being inspected and in extreme proximit y to people and structures; and present the risks associated with vehicles that weigh in th e neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons f or jet helicopters). Such aircraft must fly to and from the inspection site. In contrast, a UA weighing fewer than 55 lbs. andpowered by batteries eliminates virtually all of th at risk given the reduced mass and lack

of combustible fuel carried on board. The UA is car ried to the inspection site. The UA will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small UAs, weighing less than 55 l bs., conducted in the strict conditions outlined above, will provide an equivale nt level of safety supporting the grant of the exemptions requested herein, including 333 A ircraft Exemption Status exempting the applicant from conventional aircraft requiremen ts and allowing commercial operations. These lightweight aircraft operate at s low speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in clo se proximity to the ground and people. The safety of those on the ground is protected by t he fact that no one will be allowed into the area without the permission of the company. Sec urity will be established for the flight area as part of the pre-flight control. Each indivi dual within the secure area will be briefed prior to flight and will consent to being i n the area. All others will be excluded

from the area. Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC

. will operate the UA within visual line-of-sight (i.e., no more than approximat ely 1 mile from the manipulator of the controls, or pilot in command (PIC)). PIC will cond uct at least three take-offs and landings with the UA on which he or she is trained every 90 days. PIC’s will establish their qualifications thru a combination of aeronautical knowledge, UAS airman ship skills, and verification through testing of flight ability before any operations hav e commenced. Depending on the type of operation, additional ground-based visual observers may be employed as well.

These observers will be within constant visual line of sight and in constant contact with the PIC.

The visual observers will assist the PIC in avoidin g objects near the UA There are no standards for either Private or Commercial UA pilot certifica tes. The safe operation and control of the UA as described in this application does not depend on the type of FAA license held by the PIC. Given the restricted and controlled airspace within which operations will take place, the key factors needed by the PIC are knowledge of the airs pace within which the operation will take place and how that airspace fits into the National Airspace System (NAS). That knowledge can be and is gained primarily through ground school an d not through flight training in fixed wing or rotor aircraft, nor is it dependent on the acqui sition of a commercial or private pilot’s

certificate. Those certificates demonstrate knowled ge of the factors and skills needed for the safe operation of those types of aircraft (fixed wi ng or rotorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial v ehicle, operating at 400 AGL or lower, within strictly controlled pre-approved airspace. B esides knowledge of airspace regulations, dexterity in the control and operation of the UA acquired from actual operation of the aircraft is the most important fac tor in establishing an equivalent level of safety. If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues are (1) where the aircraft will be flown, (2 ) the size of the aircraft relative to what is being used today to accomplish the same mission, and (3) what precautions will be taken to ensure the safety of those in the area of operation Should there be a mishap, the UA being flown pose significantly less of a threat tha n the helicopters and fixed wing aircraft now being employed because they are a fraction of the s ize, carry no flammable fuel, do not carry crew or passengers, and pose an infinitesimal risk to others. This is in stark contrast toconventional aircraft that are flown to the site, c arry explosive fuel, carry passengers and crew,

and operate in a much larger area. From a practical standpoint, there are relatively f ew licensed full-scale aircraft pilots who are also qualified to fly the type of UA that are u tilized for infrastructure image-capture operations. There are even fewer commercial pilots that can fly these UA – to the point that to do both is considered rare. Assuming that i t is unlikely for a company to find a pilot that has both qualifications, that company wo uld either have to source a qualified UA pilot to train and obtain a commercial certifica te, or find a commercial certificated pilot who would be willing to learn to fly a UA to the competency level required for professional use.

Minimum requirements for the PIC include: 1) Valid State Issued Drivers License; 2) A minimum of 5 take off and landings with specif ic make and model of UAS to be utilized for operations under the exemption 3) A minimum of 2 hours as UA pilot with the make a nd model of UAS to be utilized for operations under the exemption in the preceding 90 days; 4) Have read and understood the operators manual co nsisting of a knowledge & skill of the

aircraft to be used.

Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. intends to use commercially available UA Components for UA. These UA systems will be tested for quality & safety by t he manufacturer before being deployed to the field. The UA is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a se cured area. Routine maintenance of the UA will be checked prior to each flight to verify that the UA will remain in safe and operational condition.

Please see Appendix A , for Specific Type of UA.

Notes Regarding: 14 C.F.R. Part 21, Subpart H In accordance with the statutory criteria provided in

Section 333 of PL 112---95 in reference to 49 USC 4 4704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, we request that this aircraft exemption meets the conditions of Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise Certification and testing requirements of part 36, is not necessary. Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft Given the size of the UAV, two-inch lettering will be impossible. UA Will be identified by serial number, registered in accordance with 14 CFR part 47, And have identification (N---Number) markings in ac cordance with 14 CFR Part 45, Subpart C. Markings will be as large as practicable.

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Ai rworthiness our request is based on the fact that no airworthin ess certificate will be issued for the UA. our UA will not require an airworthiness ce rtificate in accordance with14 CFR part 21, Subpart H. Based on the fact that a n airworthiness certificate will not be

issued, exemption from § 91.7(a) is not necessary.

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard Certifications required, the original intent of the se regulations was to display an aircraft’s airworthiness, certification, and registration docu ments so they would be easily available to inspectors and passengers. Based on the FAA Memo randum subject “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, the request ed relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary. Notes Regarding: §91.109 Flight instruction; Simula ted instrument & certain flight tests Small UA, by their design, do not have fully functi onal dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. Aircraft being considered for use b y Allen Roofing and Construction Inc. &

Allen Real Estate Co LLC. allow the UA Allen Roofing and Construction Inc. & Allen Real Estate Co LLC. does not describe training scenarios in whi ch a dual set of controls would be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other company-designated individual, that would require t hat individual to have fully functioning dual controls. Rather, Allen Roofing and Construction Inc. & Allen Real Es tate

Co LLC. evaluates the qualification of its PICs based on th eir experience with the UA to be operated and verifies through evaluation, in lieu o f formalized training. As such, Allen Roofing

and Construction Inc. & Allen Real Estate Co LLC . does not seek relief from 14 CFR § 91.109.

Notes Regarding § 14 CFR 91.119(b) Relief from § 14 CFR 91.119(b), operation over cong ested areas, is not applicable,

because the Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC . operations will only be conducted within the secured area described herein.

Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. Safety Operations &

Procedures Overview:

Technology Considerations: Best-in-class, tried and proven technologies that a re in advanced iterations. Software from highly-reputable industry partners will include fea tures: 1. Auto descent (landing) if communication signal w ere to be severed. If the UA loses communications, the sUAS will have capability to return to a pre-determined location within the Security Perimeter and land. 2. Auto descent (landing) if battery were to drop l ower than nominal level. 3. Flights will be terminated at 15% battery power reserve. 4. Live video for operator gives real-time position ing feedback. In other words, we can monitor the scene from the vehicle's perspectiv e for collision avoidance, and to maintain spatial orientation. 5. The UA will have the capability to abort a fligh t in case of unpredicted obstacles or emergencies. 6. On-Screen-Display (OSD) contains operating infor mation to ascertain vehicle health at all times: speed, altitude, number of GPS satellites (when available), heading and voltage. 7. GPS lock supplies for return-to-home (RTH). Shou ld Command and Control (C2)link failures occur (highly improbable), vehicle re turns automatically to the point of

launch. 8. Altitude information will be provided to the UA pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground -based on-screen display. This altitude information will be generate d by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.

Mechanical/Physical: 1. We will fly line-of-sight (LOS) only. The vehicl e will always remain in direct LOS to the pilot, thus eliminating the concern of signa l severance (flying behind objects/walls). 2. The UA will weigh less than 55 lbs and travel at less than 50 knots. 3. Batteries should far exceed the capacity require d for actual flight time. 4. Flights will be operated at an altitude of no mo re than 400 feet AGL. 5. UA Operated under this exemption will be marked in accordance with 14 CFR part 45 Or as otherwise authorized by the FAA.

Personnel: 1. Spotters ensure safe operation and act as a redu ndant set of eyes for operators (pilot, gimbal op, director) 2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication. 3. A briefing will be conducted in regard to the pl anned UAS operations prior to each day’s activities. It will be mandatory that al l personnel who will be performing duties within the boundaries of the safety perimete r be present for this briefing. 4. The operator will obtain the consent of all pers ons involved in the UA operations and ensure that only consenting persons will be all owed within 50 feet of the flight operations. 5. Observer and pilot will at all times be able to communicate by voice. 6. Written and/or oral permission from the relevant property holders will be obtained. 7. Pilot and observer will have been trained in ope ration of UAS generally and received up-to-date information on the particular U AS to be operated.

Operations: 1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy source(s) and equipment. Operation s authorized by this petition of exemption are limited to the following aircraft described in Appendix A. Proposed operations of any other aircraft will requ ire a new petition or a petition amendment to this request. 2. The UA may not be flown at a ground speed exceed ing 50 knots. 3. Flights must be operated at an altitude of no mo re than 400 feet above ground level (AGL), as indicated by the procedures specifi ed in the operator’s manual. All altitudes reported to ATC must be in feet AGL. 4. The UA must be operated within visual line of si ght (VLOS) of the PIC at all times. This requires the PIC to be able to use huma n vision unaided by any device other than corrective lenses, as specified on the P IC’s state issued drivers license. 5. Operations may utilize a visual observer (VO) wh en practical. The VO may be used tosatisfy the VLOS requirement as long as the PIC alw ays maintains VLOS

capability. The VO and PIC must be able to communic ate verbally at all times. 6. The operator’s manual and this petition of exemp tion

must be maintained and made available to the Admini strator upon request. If a discrepancy exists between the conditions and limit ations in this exemption and the procedures outlined in the operator’s manual, t he conditions and limitations herein take precedence and must be followed. Otherw ise, the operator must follow the procedures as outlined in its operator’s manual. The operator may update or revise its operator’s ma nual. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator mus t also present updated and revised documents if it petitions for extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA grants this petition for exemption, then the operat or must petition for amendment to their exemption. The FAA’s UAS Integration Offic e (AFS-80) may be contacted if questions arise regarding updates or r evisions to the operator’s

manual. 7. Prior to each flight the PIC must inspect the UA to ensure it is in a condition for safe flight. If the inspection reveals a condit ion that affects the safe operation of the UA, the aircraft is prohibited from operatin g until the necessary maintenance has been performed and the UA is found to be in a condition for safe flight. The Ground Control Station, if utilize d, must be included in the preflight inspection. All maintenance and alteratio ns must be properly

documented in the aircraft records. 8. Any UA that has undergone maintenance or alterat ions that affect the UA operation or flight characteristics, e.g. replaceme nt of a flight critical component, must undergo a functional test flight in accordance with the operator’s manual. 9. The operator must follow the manufacturer’s UA a ircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/ov erhaul, replacement, and inspection/maintenance requirements must be establi shed and identified in the operator’s manual. At a minimum, requirements for the following must b e included in the operator’s manual: a. Actuators / Servos; b. Transmission (single rotor); c. Powerplant (motors); d. Propellers; e. Electronic speed controller; f. Batteries; g. Mechanical dynamic components (single rotor); h. Remote command and control;i. Ground control station (if used); and

j. Any other components as determined by the operat or; The PIC must also meet the flight review requiremen ts specified in 14 CFR § 61.56

in an aircraft in which the PIC is rated on his or her pilot certificate. 10. Prior to operations conducted, the PIC must have accumulated and logged, in a manner c onsistent with 14 CFR § 61.51(b), a minimum of take offs and landings and 2 hours of total time as a UAS Pilot. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flig hts can also be conducted under this petition of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience- building flights, all persons not essential for flight operations are considered nonp articipants, and the PIC must operate the UA with appropriate distance from nonpa rticipants in accordance with 14 CFR § 91.119. 11. Prior to operations conducted for the purpose o f infrastructure inspection, the PIC must have accumulated and logged, in a manner c onsistent with 14 CFR § 61.51(b), a minimum of two hours as UAS pilot opera ting the make and model of UAS to be utilized for operations under the exempti on and five take-offs and five landings in the preceding 90 days. Training, p roficiency, experience building, and take-off and landing currency flights can be co nducted under this petition of exemption to accomplish the required fl ight time and 90 day currency. During training, proficiency, experience-building, and take-off and landing currency flights all persons not essential for flig ht operations are considered nonparticipants, and the PIC must operate the UA wi th appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 12. Prior to any flight operations authorized by th is petition of exemption, the PIC and VO must have successfully completed a qualifica tion process, as outlined in the operator’s manual. As this is a requirement sti pulated by the operator, the test must be developed and implemented by a qualified pe rson designated at the sole discretion of the operator. A record of completion of this qualification process

must be documented and made available to the Admini strator upon request. 13. Prior to operations conducted for the purpose o f infrastructure inspection, a flight demonstration, administered by an operator-approved and -qualified pilot must be successfully completed and documented. This documen tation must be available for review upon request by the Administrator. Because t he knowledge and airmanship test qualifications have been developed by the oper ator, and there are no established practical test standards that support a jurisdictio nal FAA FSDO evaluation and approval of company designated examiners, the petit ioner will conduct these tests in accordance with the operator’s manual. 14. The UA may not be operated directly over any pe rson, except authorized and consenting personnel, below an altitude that is haz ardous to persons or property on the surface in the event of a UAS failure or emerge ncy. 15. Regarding the distance from participating perso ns, the operator’s manual hassafety mitigations for authorized and consenting pe rsonnel. At all times, those

persons must be essential to the operations. 16. Regarding distance from nonparticipating person s, the operator must ensure that no persons are allowed within 50 feet of the area e xcept those consenting to be involved and necessary for the infrastructure inspe ction operations. This provision may be reduced to no less than 20 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equi valent level of safety may be determined by an aviation safety inspector’s evalua tion of the infrastructure inspection area to note terrain features, obstructi ons, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an acciden t.
17. If the UA loses communications or loses its GPS signal, the UA must return to a pre-determined location within the security perimet er and land or be recovered in accordance with the operator’s manual. 18. The UA must abort the flight in the event of un predicted obstacles or emergencies in accordance with the operator’s manua l. 19. Each UA operation must be completed with 15% ba ttery power remaining. 20. All aircraft operated in accordance with this e xemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 21. The operator must develop procedures to documen t and maintain a record of the UA maintenance, preventative maintenance, alteratio ns, status of replacement/overhaul component parts, and the total time in service of the UA. These procedures must be added to the operator’s ma nual. 22. Each UA operated under this exemption must comp ly with all manufacturer Safety Bulletins. 23. The operator must develop UA technician qualifi cation criteria. These criteria must be added to the operator’s manual. 24. The preflight inspection section in the operato r’s manual must be amended to include the following requirement: The preflight in spection must account for all discrepancies, i.e. inoperable components, items, o r equipment, not covered in the relevant preflight inspection sections of the opera tor’s manual. 25. Before conducting operations, the radio frequen cy spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight age ncy requirements. 26. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS an y time the aircraft is operating.

These documents must be made available to the Admin istrator or any law enforcement official upon request. 27. The UA must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 28. UA operations may not be conducted during night , as defined in 14 CFR § 1.1. All operations must be conducted under visual meteo rological conditions (VMC). Flights under special visual flight rules (SVFR) ar e not authorized. 29. The UA may not be operated by the PIC from any moving device or vehicle. 30. The UA may not be operated less than 500 feet b elow or less than 2,000 feethorizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.

31. The UA may not operate in Class B, C, or D airs pace without written approval from the FAA. The UA may not operate within 5 nauti cal miles of the geographic center of a non-towered airport as denoted on a cur rent FAA-published aeronautical chart unless a letter of agreement with that airpor t’s management is obtained, and the operation is conducted in accordance with a NOTAM a s required by the operator’s COA. The letter of agreement with the airport manag ement must be made available to the Administrator upon request. 32. Any incident, accident, or flight operation tha t transgresses the lateral or vertical boundaries of the operational area as defined by th e applicable COA must be reported to the FAA’s UAs Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Boar d (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Furth er flight operations may not be conducted until the incident, accident, or trans gression is reviewed by AFS-80 and authorization to resume operations is provided.

Support for Petition for Exemption In accordance with the procedural requirements of 1 4 C.F.R. §11.81, Allen Roofing and

Construction Inc. & Allen Real Estate Co LLC. provides the following information: Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. Nathan Trappe, President/Owner

241 ARC Lane PO Box 311

Monona Iowa 52159

Ph. 563.593.4135

Fax 563.539.4137
arcnathan@hotmail.com www.allenroofinginc.com

Regulatory Provisions from which Allen Roofing and Construction Inc. & Allen Real

Estate Co LLC. seeks an Exemption Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. believes it may need an exemption from the following provisions to conduct the contemplated operations. In some instances, relief is needed because relief from another provision renders compl iance with the regulation at hand

infeasible. 333 Aircraft Exemption Status 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 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)(1)&(2) 14 C.F.R. §91.417(a)&(b)Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. believes an exemption is

only needed from the above-listed regulatory provisions.

To the extent that the FAA believes that additional relief is required for Allen Roofing and

Construction Inc. & Allen Real Estate Co LLC. to conduct the operations described here, we reques t an exemption from any such regulatory provisions as well. 14 C.F.R. §91.417(a) imposes certain maintenance re cord keeping requirements “as applicable”. Since none of the underlying requirements (e.g., in spection intervals) can be met and will require an exemption, Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. believes a separate exemption should not be required for §91.417(a). The Extent of Requested Relief and the Reasons Reli ef is Needed Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular UA, as well as its proximity to airports and populated areas. An analysis of these criteria demo nstrates that the UA operated without an

airworthiness certificate in the areas and under th e conditions contemplated by Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airwor thiness certificate without the conditions proposed in this request. The UA is less than 55 lbs. fully loaded, carries n either a pilot nor passenger, and operates exclusively within a secured area. Unlike other civ il aircraft, operations under this exemption will be tightly controlled and monitored by the ope rator and observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area of operation as is now done w ith conventional equipment, infrastructure, bridge and out building evaluation. These safety en hancements provide an expanded degree of safety to the inspectors over conventional opera tions. Lastly, application of these same

criteria demonstrates that there is no credible thr eat to national security posed by the UA, due to its size, speed of operation, location of op eration, lack of explosive materials and inability to carry a substantial external load. Given the size and limited operating area associate d with the aircraft to be utilized by the Applicant, this meets the requirements of an equiva lent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FA A to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to air ports and populated areas of the particular UA. In all cases, an analysis of these c riteria demonstrates that the UAS operated without an airworthiness certificate, in t he restricted environment and under the conditions proposed will be at least as safe, or sa fer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 14 C.F.R. §61.113(a) and (b) §61.113 Private pilot privileges and limitations: P ilot in command. (a) Except as provided in paragraphs (b) through (h ) of this section, no personwho holds a private pilot certificate may act as pi lot in command of an aircraft

that is carrying passengers or property for compens ation or hire; nor may that person, for compensation or hire, act as pilot in c ommand 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 empl oyment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or prope rty for compensation or hire. Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. will conduct the UA operations. The UA will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft. §91.119 Minimum safe altitudes: General. Except when necessary for takeoff or landing, no pe rson may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any per son, vessel, vehicle, or

structure. Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. submits that the only relief it requires from §91.119 is from the minimum altitu des listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operatio ns because asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at this altitude also pose a heightened risk of collision with anoth er aircraft, safety can only be assured through the grant of an exemption.

14 C.F.R. 91.121 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an a ircraft to maintain cruising altitude by reference to an altimeter that is set “ ...to the elevation of the departure airport or an appropriate altimeter setting availab le before departure.” As the UA may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent leve l of safety will be achieved by the operator, pursuant to the Manual and Safety Check l ist, confirming the altitude of the

launch site shown on the GPS altitude indicator bef ore flight. Altitude information will be provided to the UA pil ot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a g round-based on-screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero a ltitude initiation point will be established and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 §91.151 Fuel requirements for flight in VFR conditi ons. (a) No person may begin a flight in an airplane und er VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed –(1) During the day, to fly after that for at least 30 minutes.

(b) No person may begin a flight in a rotorcraft un der VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at least 20 minutes. Operating the UA in a pre-defined area with less th an 30 minutes of reserve fuel does not raise the type of risk contemplated b y §91.151, i.e., that an aircraft could

run out of fuel in the event it has to be flown to an alternate airport or circle the planned airport in the event of unanticipated conditions. We believe that a 15% battery reserve is more than sufficient to meet this objective 14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.40 9(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) §91.405 Maintenance required. Each owner or operator of an aircraft – (a) Shall have that aircraft inspected as prescribe d in subpart E of this part and shall between required inspections, except as provi ded in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter; §91.407 Operation after maintenance, preventive mai ntenance, rebuilding, or alteration. (a) No person may operate any aircraft that has und ergone maintenance, rebuilding, or alteration unless – (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; §91.409 Inspections. (a) Except as provided in paragraph (c) of this sec tion, no person may operate an aircraft unless, within the preceding 12 calenda r months, it has had __ (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person aut horized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthin ess certificate in accordance with part 21 of this chapter. §91.417 (a) & (b) Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. believes that an exemption from these three maintenance requirements is approp riate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no individua ls authorized by the FAA to approve a UA for return to service under §91.407(a) or to conduct th e initial airworthiness and annual return to service inspections required by §91.409(a). Allen Roofing and Construction Inc. & Allen

Real Estate Co LLC. will maintain the aircraft as instructed in the own er’s manual and ASTM F2909, where applicable, and will not operate the a ircraft until it has reasonably determined that any needed repairs have been made. However, be cause of the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 40 9(a) and 417(a)&(b), we believe an exemption from these prov isions is appropriate. Please do not hesitate to contact me at the phone n umber or via the e-mail address provided above should you have any questions or con cerns.Respectfully submitted,

Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC. Nathan Trappe, President/Owner

241 ARC Lane PO Box 311

Monona Iowa 52159

Ph. 563.593.4135

Fax 563.539.4137
arcnathan@hotmail.com www.allenroofinginc.com

Summary for Federal Register Publication Pursuant to 14 C.F.R. Part 11, the following summar y is provided for publication in the Federal Register should the FAA determine that publ ication is needed.

Petitioner: Allen Roofing and Construction Inc. & Allen Real Es tate Co LLC.

Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 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 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) Description of Relief Sought: Petitioner seeks relief from the requirements of 33 3 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to conduct UA operations over our Cli ent’s owned or controlled land, solely during daylight hours. UA operations a re intended to be conducted in areas remote from both congested areas and airpo rts. The nature of operations anticipated by Allen Roofing and Construction Inc. & Allen Real Estate Co LLC. requires that the UA be flown at relatively low altitudes.GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control ATO Air Traffic Organization

AV Aerial Vehicle CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration FAR Federal Aviation Regulation

GCS Ground Control Station GPS Global Positioning System

LOL Loss Of Link NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 201 2 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures

UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules

VLOS Visual Line Of Site VMC Visual Meteorological Conditions VTOL Vertical Take-Off and Landing

Specific type(s), make, and model DJI Phantom 3 Professional See Attached Picture of our DJI Phantom 3 Professio nal and a PDF document with Manual and specs for DJI Phantom 3 Professional