June 05 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations for Kroger Television, the internal media division of The Kroger Co.

, under 200ft AGL

.

Dear Sir or Madam:

Pursuant to §333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14
C.F.R. Part 11, The Kroger Co., hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUASs under 200ft AGL by its internal media group, Kroger Television , for purposes of aerial filming and photogr aphy of its

facilities and hosted events , so long as such oper ations are conducted within and under the conditions outlined herein or as may be esta blished by the Federal Aviation Administration (FAA) as required by §333.

As described more fully below, t he requested exemption would permit the operation of small,

unmanned and multi

- rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on

- site safety personnel controlling access, and 4) would provide increased

s afety and enhancements to clients' business operations.

Operations under the exemption will be subject to strict requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarificat ion.

The name and address of the applicant is:

The Kroger Co.

– Kroger Television

Attn: Sayer Crompton Phone: ( 513 ) 7 62

- 1392

Email: sayer.crompton@kroger.com

1014 Vine Street Cincinnati, OH 45202

1The regulations from which the exemption is requested are as follows:

• 14 C.F.R. Part 21 • 14 C.F.R. 45.23(b) • 14 C.F.R. 61.113(a) & (b) • 14 C.F.R. 61.133(a) • 14 C.F.R. 91.7(b) • 14 C.F.R. 91.9(b)(2) • 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203(a) & (b)

• 14 C.F.R. 91.405(a) • 14 C.F.R. 91.407(a)(1) • 14 C.F.R. 91.409(a)(2) • 14 C.F.R. 91.417(a)

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT

The exemption request will permit The Kroger Co.’s Kroger Television division to operate small

unmanned a ircraft system s (sUAS) commercially for the purpose of aerial filming and photograp hy of its facilities and hosted events. The Kroger Co. seeks to benefit the public by using this platform to provide more in

- depth training and communications to its associates

regar ding their facilities resulting in safer work environments and a better customer experience.

The Kroger Co.’s sUASs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aer ial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a sUAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of l ife and property in the air and on the ground.

Conducting aerial acquisitions with The Kroger Co.’s sUASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during tradition al aerial survey flight operations.

PUBLIC SAFETY

The Kroger Co. respectfully submits that because this sUAS will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have co nfidence that the operations will achieve at least an equivalent, if not greater, level of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Sectio n

2333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”

Utilizing The Kroger Co.’s sUAS for aerial acquisitions will not have detrimental effects to the environment caused by operating a combustible fuel based, large scale manned aircraft.

Whether helping to protect the public, inspecting infrastructure or acquiring aerial imagery,

sUASs provide real

- time situational awareness, enabling better decision

- making. Better decision

making saves lives and protects property

.

PRIVACY All flights will occur over private or controlled access property with the property owner’s or controlling authority’s prior consent and knowledge. Aerial photography/filming will be of people who have also consented to being photographed or otherwise have agreed to be in the area where filming will take place.



### Airworthiness of the Inspire

Th e DJI Inspire 1 is small, light weight, and will operate at slow speeds, close to the ground, far

from a irports and in a low risk, low population environments. Approval of this exemption would thereby enhance safety and also fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establi sh requirements for the safe operation of such aircraft systems in the national airspace system.”

A critical element of the exemption application involves evidence of the airworthiness of the Inspire. The Kroger Co. believes that it is in compliance with the requirements of Order 8130.34C, Airworthiness Certification of Unmanned Aircraft Systems and Optionally Piloted Aircraft, in its use of system developed by DJI. The Inspire has a high degree of redundancy and numerous safety features, including:

• Return

- to

- home failsafe in the event of a loss of communications or low battery

• Configurable Geo

- fenced limitations for area of operation and altitude

• Configurable limitations for vertical and horizontal speed

• High visibility lighting system

• Interactive on screen display for streaming real time systems data.



### Mandatory Operating Conditions

Grant of the exemption to The Kroger Co. ’s internal media division Kroger Television will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of Authorization, with

additional restrictions:

• Operations to be conducted over private or controlled

- access property.
• Permission from land owner/controller required before commencing any flight. • Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain withi n Visual Line of Sight (VLOS). o VLOS guaranteed with a cylinder of operation around operator of 1⁄ 2 nautical miles (NM).

3o Cylinder walls may be expanded by observer with ability to control aircraft. • Operations to occur during daylight hours. • Above Ground Level (AGL) altitude to be restricted to 500 feet and below

. • All operations conducted in vicinity of a irport to remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds. Unless otherwise approved by local airport authority and NOTAM’d as such • Operator will file a NOTAM for each flight, as required.

• All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appr opriate governmental agencies.



### Operator Requirements
The Kroger Co. respectfully proposes that ope rator requirements should take into account the

characteristics of the particular UA S. Certain UASs, such as the DJI Inspire 1 , are characterized by a high degree of pre

- programmed control and various built

- in technical capabilities that limit the potential for operation outside of the operating conditions set forth above.

The Inspire has a semi

- autonomous navigation and control system comprised of a Ground

Control Station (GCS) and auto pilot system. Flights can be pre

- programmed and operate with GPS guid ance and may not require human intervention. Additional automated safety functions and safety enhancing features of the Inspire include the following:

• Auto

- pilot detection of lost GPS or of insufficient satellites initiates an immediate

vertical landin g, unless overridden by pilot in command. • Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.

• If the auto

- pilot detects a lost

- link to the GCS for longer than 30 seconds, return

- to

home sequence initiates.

• Aircraft has an on

- board failsafe that limits vertical speed to approximately 6 m/s (configurable). • The aircraft, weighing less than 7 lbs., fully loaded, is constructed of composite material intended to absorb impact energy. • The motors are driven by pulse width modulated signals, not analog signals.

Given these safety features, The Kroger Co. proposes that the operator and Inspire 1 together are more than qualified to operate commercial flights while maintaining the highest level of safety

standards.

Additi onally, no national security issue is raised by the g rant of the requested exemption . Given

the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the Inspire poses no threat t o national security.

LIST OF ATTACHMENTS

1. UAS Operational Limitations and Conditions

2. Pre Flight/Post Flight Checklist

3. DJI Inspire1, Operating Manual

4. DJI Inspire1, Maintenance Manual

5. DJI Inspire1, Safety Guidelines

6. DJI Inspire1 Quickstart Guide

7. DJI Inspi re1 Intelligent Flight Battery Safety Guidelines

48. DJI Disclaimer and Warning document for Inspire1

APPENDIX A



### EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

The Kroger Co. requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the Inspire:



### 14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:

When marks include only the Roman capital letter “N” and t he registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

The Inspire has no entrance to the cabin, cockpit, or pilot station on which the word “Experi mental” can be placed. Given the size of the UAV, two

- inch lettering will be impossible.

The word “Experimental” will be placed on the forward fuselage in compliance with § 45.29(f).

The equivalent level of safety will be achieved by having the Inspire ma rked as required by § 45.29(f) where the pilot, observer, and others working with the UAV will see the identification

of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation, Exemption Nos. 10700, 8738, 10167 and 10167 A.



### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (under 7lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of a irworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved.

In th is case, an analysis of these criteria demonstrates that the Inspire operated without an

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer,

than a conventional aircraft (fixed wing or rotorcraft) with an ai rworthiness certificate. The Inspire weighs less than 7 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre

- disclosed and in compliance with

5conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and by local public safety requirements. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The Inspire construction with absorbent material provides at least an equivalent level of safety to tha t of such operations being conducted with

conventional aircraft that would be orders

- of

- magnitude larger and would be carrying passengers, cargo, and flammable fuel.



### 14 C.F.R. § 61.113(a) & (b); 61.133(a) : Private Pilot Privileges and Limitations; Pilot i n Command; Commercial Pilot Privileges and Limitations.
Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s li cense to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and

coordi nated in advance . The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilo t or higher rating as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b)



### 14 C.F.R. § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy

co ndition. Should the exemption be granted allowing commercial operation of the Inspire

without an airworthiness certificate, no standard will exist for airworthiness of the Inspire. Given

the size of the aircraft and the requirements that have presumably al ready been met in the SAC approval process for the Inspire (for instance, the Inspire’s Maintenance & Inspection Manual and Safety Checklist), an equivalent level of safety will be achieved by insuring compliance with

the appropriate manuals prior to each flight.



### 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No person may operate a U.S.

- registered civil aircraft ... (2)...For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Given the size and configuration of the Inspire, it has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User Guide, Exhibit 2) at the ground control point where the pilot flying the UAS will have immediate

access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos.
8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167 , 10167A, 10602, 32827, and 10700.



### 14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction These regulations provide that no person may operate a civil aircraft (except a manned free

6balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. The Inspire is a remotely piloted aircraft and by design, does not have fully functional

dual controls. Flight control is accomplished through the use of a control box that communicates

with the aircraft via radio comm unications. The flight plan is pre

- programmed into the auto pilot before flight and only in unusual circumstances will the pilot input control functions to alter the

pre

- programmed flight. If instruction is accomplished through a training program, as set f orth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 57 78K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the Inspire 1

.



### 14 CFR § 91.119: Minimum Saf e Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely pop ulated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Inspire will never operat e at higher than 2 00 feet AGL. Because aerial filming and photography of facilities must be captured at low altitudes to be beneficial in a training and communications environment , an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with

whi ch the Inspire is built. Also, no flight will be taken wit hout the permission of the land owner

, if other than The Kroger Co., or those who control the land. Compared to aerial filming and photography operations conducted with aircraft or rotorcraft weighi ng far more than 7 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 2 00 feet AGL. Indeed, the

low

- altitude operations of the UAS will maintain separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.



### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The Inspire batteries provide approxim ately 2 0 minutes of powered flight. Without an exemption

from § 14 CFR 91.151, the UAS’s flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable. The Kroger Co. believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve

fuel does not engender the type of risks tha t Section 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. In the unlikely event that the Inspire 1 should run out of fuel, it would simply l and. Given its weight and construction material, the risks are less than contemplated by the current regulation. The Kroger Co. believes that an equivalent level of safety c an be achieved by maintaining 25% battery reserve , which would be more than adequat e to return the UAS to its

7planned landing zone from a nywhere in its operating area.



### 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a)...no person may operate a civil aircraft unl ess it has...an appropriate and current

airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight author ization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The Inspire 1 fully loaded weighs no more than 7 lbs. As such, there is no ability or place to carry

certification and registration documents or to display them on the UAS. In addition, there is no pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued

numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.



### 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this s ection, have discrepancies repaired as prescribed in part 43 of this chapter...” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspec tion for the issuance of an air worthiness certificate.

Secti on 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Maintenance of the Inspire will be accomplished by the owner/operator pursuant to the manuals, such provided by The Kroger Co . An equivalent level of safety will be achieved because the

UAS is small in size, will operate only in restricted predetermined areas, and is not a complex

mechanical device. As provided in the attached User Manual and the Safety Checklist, the operator of Inspire 1 will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any mainte nance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.

APPENDIX B



### SUMMARY OF EA SECTION 333 EXEMPTION REQUEST

E xemption n umbers 11606, 11607, and 11558 are examples of the past granted exemptions using the Inspire1 for similar

- purposed uses and as such, they should be taken into consideration . The Kroger Co. hereby provides pursuant to Part 11 a summary of its exemption application to allow

commercial operation of the Inspire unmanned aircraft for the purpose of aerial filming and photography of its facilities and events . An exemption is requested from the following

8regulations:

• 14 C.F.R. Part 21 • 14 C.F.R. 45.23(b) • 14 C.F.R. 61.113(a) & (b) • 14 C.F.R. 61.133(a) • 14 C.F.R. 91.7(b) • 14 C.F.R. 91.9(b)(2) • 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203(a) & (b) • 14 C.F.R. 91.405(a) • 14 C.F.R. 91.407(a)(1) • 14 C.F.R. 91.409(a)(2) • 14 C.F.R. 91.417(a)

THE APPLICABLE LEGAL STANDA RD UNDER SECTION 333

The Kroger Co. submits that grant of this exemption application advances the Congressional mandate in Section 333 of the Reform Act to accelerate the introduc tion of

sUASs into the NAS if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard

to users of the NAS, the public, or pose a threat to national security in light of the following:

● The UAS’s size, weight, speed, and operatio nal capability; ● Operation of the UAS in close proximity to airports and populated areas; and ● Operation of the UAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such

aircraft in the n ational airspace system.” Id.§ 333(c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, from the requirement that all civil aircraft must have current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption fro m a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 4470244716 of this title if the Administrator finds the exemp tion is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level o f safety surrounding the proposed operations; and the significant

9public benefit, including enhanced safety and cost savings associated with use of s UASs for aerial videography/photography, the reduction or elimination of unregulated operators, and the

saf e i ntegration of UASs. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Conclusion

As set forth herein, The Kroger Co. seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA M odernization and Reform Act of 2012 from the requirements of 14 CFR § 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 (a); 91.203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b), which will permit safe operation of the sUASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial filming and photography over small, defined operational areas of the United States.

Approval of the exemption allowing commer cial operations of The Kroger Co.’s sUASs by Kroger Television will increase safety by permitting an operator to conduct a service safely by adhering to the prescribed guidelines. The exemption will also encourage the education of sUAS operators and the adoption of FAA guidelines and approval for commercial sUAS operations as pertains to The Kroger Co.’s employees

. It will allow The Kroger Co. to provide a service that benefits the public and its associates

. It benefits the public thr ough a higher level of safety of

sUAS operations and through a smooth integration of sUASs into the NAS

. This assists the FAA with its mission of promoting aviation while preserving safety of aviators, the public, and

property. The sUASs operated by The Kr oger Co.’s internal media department, Kroger Television, satisfiy the criteria set forth in §333 of the Reform Act

– size, weight, speed, operating capabilities, operation within visual line of sight, and national security

– and showing an equivalent level of safety to manned aircraft flights through appropriate pilot certification and safety focused standards of operation, providing more than adequate justification for the grant of the requested exemptions allowing commercial operations. By granting this Peti tion, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing The Kroger

Co. to safely, efficiently, and economically operate the sUAS s commercially within the NAS.

Thank you for your review of this matter

.

Respectfully,

Sayer Crompton

The Kroger Co.

1011