To whom it may concern, 

Kajima USA Group (KUSA) offers a wide array of architectural, engineering, construction and 

real estate development services through our national network of specialized companies. 

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Name and Mailing Address 

Kajima USA Inc. 

sUAS Operations % Chris Baze HDCC 

3475 Piedmond Rd NE Suite 1600 

Atlanta, GA 30305 

Phone: 404-564-3900 

Fax: 404-564-3901 

Email: info@kajimausa.com 

The specific sections of 14 CFR from which KUSA seeks an exemption 

1. 14 CFR Part 21 

2. 14 CFR 91.203 (a) & (b) 

3. 14 CFR 45.23 

4. 14 CFR 91 .9 

5. 14CFR91.119 

6. 14 CFR 91.121 

7. 14 CFR 91 .151 

8. 14 CFR Subpart E (91.401-91.417) 

9. 14 CFR 61 .113 (a) & (b) 

10. 14 CFR 91.7 (a) 

11. 14 CFR 91.103 

12. 14 CFR 91 .109 

The extent of relief KUSA seeks, and the reason KUSA seeks the relief 

KUSA seeks exemption from provisions of 14 CFR as needed to operate sUAS commercially. 

KUSA seeks this relief to inspect the built environment using digital photographs, 

photogrammetry, lidar, thermal imaging, and/or other outputs from the sensors on sUAS. 

How KUSA's request for exemption would benefit the public as a whole 

According to OSHA, falls are the leading cause of worker deaths on construction sites. By 

utilizing sUAS, KUSA hopes to reduce or eliminate the exposure of our employees to this 

hazard. Additionally, by utilizing sUAS for remote sensing in lieu of full-sized passenger aircraft, 

the potential for injury and damage to property is greatly reduced. By gaining more information 

on the built environment, KUSA would be able to more immediately identify existing safety concerns that impact our employees and the public as a whole. 
procedures will be followed to ensure the safety of KUSA employees and the public: 

1. KUSA will be working with sUAS with an operational weight of 10 lbs or less 

2. sUAS will always stay within visual line of sight of the Pilot in Command (PIC) 

3. Flights will be limited to 500 feet altitude and no faster than 100 mph 

4. Operations will only occur in daylight under good visibility conditions 

5. The PIC will conduct a pre-flight inspection of the sUAS before each flight 

6. The PIC will possess a valid airman certificate and be at least 17 years old 

7. sUAS will remain under the operational control of the PIC at all times 

Brief description of exemption that KUSA seeks for publication in the Federal Register 

Petitioner seeks relief from above provisions of 14 CFR as needed to utilize sUAS for purposes 

of inspecting the built environment including in-progress construction, the property of clients of 

the petitioner, and the property of prospective clients of the petitioner. 

Any additional information, views, or arguments available to support your request 

Kajima USA considers the safety of our employees and the general public to be of utmost 

importance. 

If you want to exercise the privileges of your exemption outside of the United States, you 

must state the reason 

Kajima USA does not wish to exercise the privileges of this exemption outside of the United 

States. 

Point of contact for petition 

Christopher Baze, AlA 

Hawaiian Dredging Construction Company 

cbaze@hdcc.com 

(808) 330-0282 

Kajima U.S.A. Inc. 

Assistant Secretary