A ugust 7, 2015

U. S. Department of Transportation West Building, Ground Floor, Room w12-140 1200 New Jersey Avenue, SE Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modern ization and Reform Act of 2012

Dear Sir or Madam:

Pursuant to Section 333 of the F AA Modernization and Reform Ac t of 2012 (the “Reform Act”), Walsh & Kelly, Inc., an operator of Unmanned Air craft Systems (UAS) for Volumetric Measurements for Inventory Management, hereby applie s for an exemption from the Federal Aviation Regulations to allow commercial operation of i ts UAS.

Walsh & Kelly, Inc.’s requested exemption would permit the ope ration of its UAS under controlled and secure conditions that are limited, predetermine d, and provides safety in connection with the aircraft operation.

The name and address of the applicant is:

Walsh & Kelly, Inc.

Jeremy A. Fenolio 1700 E. Main Street Griffith, IN 46319

(219) 924-5900 JFenolio@walshkelly.com

Regulations from which the exemption is requested are:

14 CFR 61.113(a) and (b) 14 CFR 91.103 14 CFR 91.119 14 CFR 91.121August 7, 2015 Page 2

14 CFR 91.151(a) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) and (b)

The applicant intends to operate a UAV Model DJI Phantom 2 Vis ion+ UAS for the purpose of safely conducting Volumetric Measurements for Invent ory Management at applicant’s five (5) plants which are located in Griffith, Indi ana and Valparaiso, Indiana. Walsh & Kelly provides asphalt products , excavating, grading, concret e, and paving services in northern Indiana. As a large contractor, Walsh & Kelly has sig nificant stockpiles of inventory at its five (5) locations. Currently, inventory management requir es individuals to climb on these stockpiles, which creates a concern for their safety. The use of a UAS eliminates the safety concern and provides significantly more accurate measurements a s well.

In addition, applicant would use the UAS for pre- and post-pro ject videos. These videos would alleviate the necessity of employees walking the project routes where there are significant safety concerns because of traffic.

The applicant believes that this application should fall under the Federal Aviation Administration Interim Policy for commercial unmanned aircraft operations. The UAS to be operated by applicant and the opera tion itself meets the follow ing criteria:

1. The UAS weighs less than 55 pounds, actually weighing 2.75 p ounds;

2. Flights will be opera ted within visual line of sight of the pilot;

3. All flights are ope rated below 200 feet; and

4. All flights will be operated dur ing daytime Visual Flight Ru les conditions.

Additionally, the applicant has spoken with the management at b oth the GriffithMerrillville Airport (05C) and Porter County Regional Airport ( VPZ) in order to determine if the operation of the UAS over applicant’s plants will have any safe ty impact on the operation of either airport. The management of both airports has indicated that there is no safety concern whatsoever, but the applicant will notify the management of bo th airports prior to operation of the UAS as an additional safety precaution.

It is applicant’s belief that the operation of the UAS for Inve ntory Management will increase the safety for its employees who have been involved in Inventory Management, and the plant operation will be safer. In addition, the applicant perf orms services for numerous municipalities in northern Indi ana, and the pre- and post- proj ect videos will eliminate placingAugust 7, 2015 Page 2

applicant’s employees on the ground in dangerous traffic condit ions. Also, the need to restrict traffic while employees take measurements and examine roadwork will be reduced significantly by these videos.

Summary for Publication :
Pursuant to 14 CFR, Part 11, the following summary is provided for publication in the Federal Register, should it be dete rmined that publication is n eeded:

Walsh & Kelly, Inc. seeks an exemption from 14 CFR 61.113(a) an d (b), 14 CFR 91.103, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a ), 14 CFR 407(a)(1), 14 CFR 409(a)(2), and 14 CFR 417(a) and (b) to operate commerciall y a small Unmanned Aircraft System (under 55 pounds) in order to provide Volumetric Measure ments for Inventory Management and pre- and post-proj ect videos. As established by the exemptions already granted by the FAA for small unmanned aircraft systems in certain comme rcial operations, this will enhance safety by reducing risk. Conventional Volumetric Measu rements require personnel to be exposed to shifting materials in order to adequately measure inventory of materials. In contrast, a UAS eliminates all risk of ground personnel and is significantly more accurate in its measurement capabilities. In th is regard, the UAS eliminates a ny exposure by the applicant’s personnel.

The operation of the UAS conducted in the strict conditions out lined provides a superior level of safety supporting the gr ant of the exemption requested herein.

All manufacturer procedures will be followed for pre and post f lights. An app called “DroneLogbook” will be used to trac k each flight, maintenance a nd locations flown.

Public Benefit:

The Federal Aviation Administration has established an interim policy for certain commercial unmanned aircraft operators to obtain exemptions und er Section 333 of the FAA Modernization and Reform Act of 2012. By allowing the commerci al operation of a UAS a significant risk will be reduced. Previously the only methods for accurately performing inventory management involved the use of an aircraft, helicopte r, or personnel on the ground which carries some risk with it. The use of a UAS operated onl y over the land that contains the inventory will reduce all risks significantly. The operation o f the UAS conducted in the conditions outlined in this request for exemption will provide a level of safety supporting the grant of the exemption requested herein.

Enclosed with this petition are pictures that will provide a vi ew of the size of the inventory of materials that applicant will be measuring through the UAS.Au g ust 7, 2 Page 2

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