August 10, 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 Modernization and Reform Act of 2012 Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), Walsh & Kelly, Inc., an operator of Unmanned Aircraft Systems (UAS) for Volumetric Measurements for Inventory M anagement, hereb y applies for an exemption from the Federal Aviation Regulations to allow commercial operation of its UAS. Walsh & Kelly, Inc.’s requested exemption would permit the operation of its UAS under controlled and secure conditions that are limited, predetermined, 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 10, 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 M odel DJI Phantom 2 Vision+ UAS for the purpose of safel y conducting Volumetric Measurements for Inventory M anagement at applicant’s five (5 ) plants which are located in Griffith, Indiana and Valparaiso, Indiana. W alsh & Kell y provides asphalt products, ex cavating, grading, concrete, and paving services in northern Indiana. A s a large contractor, Walsh & Kelly has significant stockpiles of inventory at its five (5 ) locations. Currentl y, inventory management requires individuals to climb on these stockpile s , which creates a concern for their safety

. The use of a UAS eliminates the safety concern and provides significantly more accurate measurements as well. In addition, applicant would use the UAS for pre - and post
-project videos. These videos would all eviate 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 f or commercial unmanned aircraft operations. The UAS to be operated b y applicant and the operation itself meets the following criteria: 1. The UAS weigh s less than 55 pounds, actually weighing 2

. 7 5 pounds; 2. Flights will be operated within visual line of sight of the pilot; 3. All flights are operated below 200 feet; and 4. All flights will be operated during day time Visual F light R

ules conditions

. Additionally, the applicant has spoken with the management at both the Griffith

Merrillville Airport ( 0 5C) and Porter County Regional Airport (VPZ) in order to determine if the operation of the UAS over applicant’s plant s will have any s afety impact on the operation of either airport. The management of both airports has indicated that there is no safety concer n whatsoever, but the applicant will notify the management of both airports prior to operation of the UAS as an additional safety precaution. It is applicant’s belief that the operation of the UAS for Inventory M anagement will increase the safety for its employees who have been involved in Inventory M anagement, and the plant operation will be safer. In addition, the applicant performs services for numerous municipalities in northern Indiana, and the pre - and post
- project videos will eliminate placingAugust 10, 2015

Page 2 applicant’s employees on the ground in dangerous traffic conditions. 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 i s provided for publication in the Federal Register, should it be determined that publication is needed: Walsh & Kelly, Inc. seeks an exemption from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 9 1.151(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 commercially a small Unmanned Aircraft System (under 55 pounds) in order to provide Volumetric Measurements 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 commercial operations, this will enhance safety by

reducing risk. C onventional Volumetric Measurements require personnel to be exposed to shifting materials in order to adequately measure inventory o f materials. In contrast, a UAS eliminates all risk of ground personnel and is significantly more accurate in its measurement capabilities. In this regard, the UAS eliminates any exposure by the applicant’s personnel. The operation of the UAS conducted in the strict conditions outlined provides a superior level of safety

supporting the grant of the exemption requested herein. All manufacturer procedures will be followed for pre and post fl ights. An app called “DroneLogbook” will be used to track each flight, maintenance and locations flown. **Public Benefit:** The Federal Aviation Administration has established an interim policy f or certain commercial unmanned aircraft operators to obtain ex emptions under Section 333 of the FAA Modernization and Reform Act of 2012. B y allowing the commercial operation of a UAS a significant risk will be reduced. Previously the only

m ethods for accurately performing inventory management involved the use of an aircraft, helicopter, 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 of the UAS conducted in the conditions outline d 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 view of the size of the inventory of materials that applicant will be measuring through the UAS.August 10, 2015

Page 2 By

providing pre - and post
-project videos instead of having employees on the ground working around significant traffic conditions, the applicant will lessen the need to restrict traffic and make the roadways safer for normal traf fic conditions. Walsh & Kell y, Inc. will satisfy the criteria provided in Section 333 of the Modernization and Reform Act of 2012 as it pertains to the Federal Aviation Administration Interim Policy f or Commercial Unmanned Aircraft Operators, allowing for the requested exemption so that Walsh & Kell y, Inc. may

operate its UAS pursuant to its petition. If there is any additional information that is required please contact the undersigned by phone at (219) 924

- 5900 or email at JFenolio @walshkelly .com. Sincerel y, WAL SH & KELLY, INC.

Jeremy A. Fenolio Director of IT and Communications JAF :jt Enclosure s