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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
Room W12-140
West Building Ground Floor
Washington, DC 20590-0001

Docket No.: FAA-2015-0150; Notice No. 15-01
RIN 2120-AJ60
[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:
  • Enhance—and even replace—the 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 hailstorm.
  • 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 dramatic—and positive—effect on safety in the roofing industry.
Advancing Technology

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 quickly—preventing 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 leak.

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 reflective—thereby reflecting solar energy—and 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 replaced—in all cases contributing significantly to energy conservation. In fact, the sensors onboard the UAS can see beyond the spectrum of the naked eye—again 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 professionals—primarily roofing contractors and roof consultants—are 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 night.

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 whether—or when—to 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 operations.

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 especially valuable.

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 industry—in 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 ladders—and roofs—can 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 roof—by 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 technicians—exactly the same people who would be able to use UAS from the ground.

Specific Comments

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.

In Conclusion

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.

Respectfully submitted,

William A. Good
Executive Vice President
National Roofing Contractors Association

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