NRCA issues comments about FAA's Proposed Rulemaking Regarding the Operation and Certification of Small Unmanned Aircraft Systems
April 23, 2015
Federal Aviation Administration
U.S. Department of Transportation
1200 New Jersey Avenue, SE
West Building Ground Floor
Washington, DC 20590-0001
Docket No.: FAA-2015-0150; Notice No. 15-01
[By Fax to 202-493-2251 and electronic submission]
Comments of the National Roofing Contractors Association on FAA Proposed Rulemaking Regarding the Operation and
Certification of Small Unmanned Aircraft Systems
The National Roofing Contractors Association (NRCA) appreciates this opportunity to comment on the Notice of Proposed
Rulemaking (NPR) issued by the Federal Aviation Administration concerning the operation and certification of small
unmanned aircraft systems (UAS).
NRCA is a 129-year old trade association with approximately 3,500 member companies operating in all 50 states. NRCA's
members include roofing contractors, roofing material manufacturers, wholesale distributors and others with an interest
in matters pertaining to roof design, installation and assessment.
NRCA applauds the FAA for taking the important step of broadening the opportunities for the commercial use of UAS while
establishing rules for ensuring their safe and secure operation. We believe the framework outlined in the NPRM makes
great sense for the construction industry in general and the roofing industry in particular. We do, however, have
several recommendations for the final rule that we believe are necessary in order to effectively integrate the use of
UAS into the roofing industry.
In many ways, we think the commercial use of UAS, done properly, has the potential to be transformational for the
roofing industry. Among other things, UAS use will:
Enhanceand even replacethe current imaging technology in use today, which involves capturing literally
millions of roof images through the use of airplane-originated photography.
Allow for more accurate assessments of a roof's condition, better enabling home and building owners to make
informed decisions about roof repair and replacement.
Enable insurance claims adjusters to better assess damage to a roof after a weather-related incident such as a
Allow roofing professionals to conduct thermal assessments of roofs, leading the way to finding better solutions
for energy conservation in homes and buildings.
Have a dramaticand positiveeffect on safety in the roofing industry.
Currently, images of roof surfaces are captured, for commercial purposes, by companies using aerial photography. While
these images are generally quite good, approaching 99 percent measurement accuracy in many cases, the use of UAS will
improve accuracy, allow for real-time assessments and likely reduce the need for the constant and continuing use of
manned aircraft to capture those images. The UAS will be closer to the roof surface and show much finer detail, further
minimizing the need for workers to access the roof.
UAS-based images will be better able to identify problem areas on the roof, identify potential safety hazards and allow
for more accurate measurements to be made, in many instances, without the need for roof professionals or others to be
on the rooftop. By greatly reducing the frequency of exposures to falls and other hazards, UAS will provide substantial
safety benefits to the public.
In addition, the use of UAS technology will have clear economic benefits. Assessments of roofs will be performed more
quickly and efficiently; problems will be identified more quicklypreventing damage to the building's interior; and
workers will be less likely to be hurt, resulting in less lost time and lower workers compensation costs.
Allowing for More Accurate Assessments of a Roof's Condition
One of the great advantages of UAS use will be the ability to identify roof-related problems before they reach the
stage where they either contribute to the loss of energy from the home or building, or worse, result in a roof
The life expectancy of roof systems varies, of course, by the type of roof system, the use and location of the building
and the extent to which the roof system has been properly maintained.
Still, a UAS will be able to identify roof systems that are so badly deteriorated that they need immediate repair. They
will also be able to identify roof systems that were originally designed to be highly reflectivethereby reflecting
solar energyand have lost reflective value over time.
Today, aerial imagery is commonly used to conduct an initial assessment of the roof, but in most cases roofers must
still access the roof for a final and more accurate assessment. Use of the UAS mitigates this need.
The issue of lost reflectivity is an important one, and one where the use of a UAS can be of crucial importance. A UAS
could, conceivably, be outfitted to accurately measure the reflectivity value of a roof system; roofs that have lost a
significant amount of reflectivity over time could be repaired, re-coated or replacedin all cases contributing
significantly to energy conservation. In fact, the sensors onboard the UAS can see beyond the spectrum of the naked eyeagain reducing the need for people to access the roof.
Enabling Insurance Claims Adjusters to Better Assess Roof Damage
After a significant weather event, such as a hailstorm, there is commonly substantial damage to roof systems in the
affected area. (As just one example, a recent hailstorm in the Dallas-Ft. Worth metroplex was estimated to have damaged
about 300,000 homes and buildings.) The typical response of insurance companies in those circumstances is to hire
independent claims adjusters to conduct damage assessments and help their insureds get their roofs repaired. Needless
to say, the task is daunting, especially because many independent claims adjusters don't have training in assessing the
damage to a roof. (They also aren't trained about proper roof safety; see below.) The use of UAS would not only
expedite the entire claims adjustment process, it would also allow for more accurate damage assessments and would
obviate the need for those adjusters to access rooftops.
Allowing for Thermal Assessments of Roof Systems
Currently, roofing professionalsprimarily roofing contractors and roof consultantsare able to conduct thermal
assessments of existing roof systems with the use of infrared technology. Infrared measuring devices are used to show
how quickly different areas of a roof's surface cool, indicating the likely presence of moisture. And moisture in a
roof system can affect both the energy-saving properties of the roof and its long-term performance.
Further, these infrared surveys must be conducted after sundown to be done accurately, since the roof surface cools at
Using existing infrared technology, a UAS could conduct infrared thermal assessments of a roof system, the result of
which would be to make it much easier to provide home and building owners with the ability to make informed decisions
about whetheror whento repair or replace a roof.
However, because these infrared assessments must be done in the few hours after sundown, we request the FAA adopt an
exception in the final rule to its proposed prohibition on the nighttime use of UAS for these specific
In addition, it's important to note the additional safety hazard involved with working on rooftops at night. Workers
might not be able to see roof edges, skylights or a multitude of tripping hazards. Much better, for all the obvious
reasons, to be able to conduct thermal infrared assessments from the ground via the use of UAS.
Having a Dramatic Effect on Safety
According to the Bureau of Labor Statistics, fatalities from falls are the leading cause of death for workers in the
construction industry, so any engineering or technological advances that help reduce the incidence of falls are
In 2013, the most recent year for which data are available, there were 302 fatal falls in the construction industry; 66
of those involved workers employed by roofing contractors.
Industry studies have also concluded that falls from ladders represent a significant percentage of total falls in the
construction industryin 2013, 76 of the fatal falls in the construction industry occurred from ladders. So, for all
of the obvious reasons, technology improvements that can keep people off of laddersand roofscan undoubtedly help
reduce the incidence of fall-related accidents and injuries.
In addition, it's worth pointing out that not all people who have reason to access a roofby ladder or otherwise
are properly trained in rooftop safety. Climbing ladders and walking around on roof surfaces is especially dangerous
for such people as insurance claims adjusters, roof consultants and infrared thermography techniciansexactly the
same people who would be able to use UAS from the ground.
While NRCA supports the NPRM in concept, and welcomes the opportunity for the commercial use of UAS in our industry,
there are two matters of specific interest to address:
First, NRCA supports the idea of having a knowledge test for operators rather than detailing training requirements.
NRCA also supports the idea of having FAA-designated test centers for the examinations contemplated in the NPRM. NRCA
believes it is important for affected industries, such as the roofing industry, to be able to develop the training that
is necessary for an operator to prepare for the knowledge test, and we would recommend that the final rule encourage
affected industries to develop and conduct such training, working in cooperation with the FAA.
Second, we understand the intent of having a UAS remain in visual line-of-sight contact with the UAS operator. We would
simply point out that this requirement will make UAS use very difficult in some relatively routine operations, such as
inspecting the condition of a roof on a typical single-family home. We would encourage the FAA to consider language in
the final rule that would allow for exceptions from the line-of-sight requirement when a UAS is being used solely for
the purpose of assessing a home or building, provided that proper safeguards are in place to ensure the UAS is unable
to be operated anywhere than in the vicinity of the home or building being evaluated. For example, we suggest that an
operator be allowed to use First Person View in conjunction with one or more field observers who maintain direct
communication with the Operator, as defined in the NPRM. In most instances, this configuration will provide an added
safety factor as the device gets smaller in the field of view as it travels away from the Operator.
These comments are intended merely to highlight the primary advantages of UAS use for the roofing industry.
Undoubtedly, UAS use will contribute to more efficient management of roofing projects, will eliminate waste and will
allow for the assessment of such rooftop equipment as HVAC, solar or other elements critical to home and building
operation. Most importantly, NRCA believes the use of UAS will greatly enhance safety within the roofing industry for
all the reasons outlined above.
Further, NRCA fully expects that there are many advantages of UAS use still to be discovered. NRCA welcomes the
opportunity to work with the FAA on the issues related to the operation of UAS and encourages the FAA to adopt a final
rule as quickly as is possible.
William A. Good
Executive Vice President
National Roofing Contractors Association