Date: November 12, 2015

Wesley R. Segawa and Associates, Inc. 

Address# 101 Silva St.

Suite 201, Hilo, HI 96720

Phone# 808-536-4495

Email: hilo@wrsasolutions.com

Wesley R. Segawa, CEO

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Seeking Exemption from:

14 C.F.R. Part 21 Subpart H

14 C.F.R. § 21.191(a)

14 C.F.R. § 45.23(b)

14 C.F.R. § 45.27

14 C.F.R. §§ 61.113(a) and (b)

14 C.F.R. § 91.l 19(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a) (l)

14 C.F.R. §§ 91.409(a) (l) and (2)

14 C.F.R. §§ 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14

C.F.R. Part 11, Wesley R. Segawa and Associates, Inc. hereby applies for an exemption from the 

listed Federal Aviation Regulations (" FARs") and any other necessary to allow operation of its 

small Unmanned Aircraft Systems ("sUAS") for commercial photography, video, GIS and topo 

mapping. WRSA plans on using the sUAS to provide quality, accurate photos of ongoing projects, 

including airfield improvements, construction sites, and public facility improvements. Further, airfield 

photos are required for our Part 139 certification services to Hawaii airports as well as our planning 

services for an Airport-Wide Safety Management System (SMS) Implementation throughout the state of 

Hawaii.

Description of Petitioner

The founder/ CEO of our company is Wesley R. Segawa.

Wesley R. Segawa & Associates, Inc. (WRSA) was established in 1981 as a professional 

engineering organization providing civil engineering, structural engineering and construction 

management services to private and governmental clients in the State of Hawaii. 
WRSA is composed of about thirty licensed engineers, technicians, inspectors, project managers 

and administrative support staff who fit within our corporate culture that is unique to our island 

lifestyle and are driven by our Company's Mission of Commitment to Quality Performance 

and Value. As the prime consultant on most of our projects, we are able to assist our clients 

through the various stages of project delivery. Our projects have included airport infrastructure 

and facilities; master planning; highways, bridges, harbor and waterfront developments; 

wastewater treatment plans; water systems; industrial processing plants; land development 

infrastructure; schools; astronomy facilities; athletic facilities and residential, commercial 

and industrial buildings; regulatory permitting and a host of other challenging projects.

WRSA sUAS Pilot in control and safety observers are applying good safety practices with 

knowledge of AMA and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. Part 11 in which they seek exemption from.

WRSA as a company is pursuing this new avenue on behalf of employee safety. Construction 

sites are Dangerous, Dirt, Dull places and sometime very large areas. A small team of inspectors 

can be more efficient with the use of UAV under this exemption we seek.

WRSA foundation of safety starts with sUAS Operators are members of Academy of Model 

Aeronautics World's largest model aviation association, representing a membership of more than 

175,000 from every walk of life, income level and age group. A self-supporting, non-profit 

organization whose purpose is to promote development of model aviation as a recognized sport 

and worthwhile recreational activity, Organization open to anyone interested in model aviation.

An official national body for model aviation in the United States, to learn about safety practices.

AMA sanctions more than 2,000 model competitions throughout the country each year, and 

certifies official model flying records on a national and international level .Organizer of the 

annual National Aero modeling Championships, the world's largest model airplane 

competition. Chartering organization for more than 2,500 model airplane clubs across the 

country. AMA offers its chartered clubs official contest sanction, insurance, and assistance in 

getting and keeping flying sites. The voice of its membership, providing liaison with the Federal 

Aviation Administration, the Federal Communications Commission, and other government 

agencies through our national headquarters in Muncie, Indiana. AMA also works with local 

governments, zoning boards, and parks departments to promote the interests of local chartered 

clubs. WRSA is using the AMA as the starting point for its sUAS program here in Hawaii and 

will meet all FAA requirements.

Aircraft:

WRSA will operate the DJI Inspire 1, Model T600, with a total weight of 2935g or 6.47lbs. The 

dimensions are 438mm x 451mm x 301mm or 17.24inch x 17.75inch x 11.85 inches. Under still 

air the maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 

25mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane 

simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6-cell 

4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 

1345, in use. The DJI Inspire 1 will be controlled with the C1 remote controller with an 
operating frequency of 2.400GHz – 2.483GHz. The live video feed will have an operating 

frequency of 5.728GHz – 5.850GHz. http://www.dji.com/product/inspire-1/spec

This petition for exemption is submitted in accordance with the Section 333(a) through

(c) of the FAA Modernization and Reform Act of 2012. Congress has directed the FAA "to 

safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit 

unmanned aircraft systems to operate in the National Airspace System ("NAS") where it is safe 

to do so base on the following considerations:

• The sUAS's size, weight, speed, and operational capability.

• Operation of the sUAS in close proximity to airports and populated areas.

• Operation of the sUAS within the visual line of sight of the operator. 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety

regulations and minimum standards when the Administrator decides a requested exemption is in 

the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 

U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716, et seq.). A 

party requesting an exemption must explain the reasons why the exemption: (1) would benefit 

the public as a whole, and (2) would not adversely affect safety (or how it would provide a level 

of safety at least equal to the existing rules).

Wesley R. Segawa and Associates Inc.

PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF 

THE REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within the visual line of Sight (VLOS).

3. Flights will be operated by Pilot in Command (PIC) and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be 22 minutes. Flights will be 

terminated at 25% battery power reserve or 18 minutes of flight time whichever occurs 

first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and remain in the line of sight.

6. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer 

(VO) and may include but not limited to a Camera Operator.

7. The UAS pilot will be a designated Pilot in Command (PIC). Responsible for preflight 

check.

8. A briefing will be performed regarding the planned UAS operations prior to each day’s 

flight.
9. The flights will occur no closer than a 5 mile radius of the geographic center/Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport. (WRSA may have 

short flights for projects at airports with proper NOTAM’s in place submitted by airport 

operator ahead of time for scheduled inspection and weather permitting a safe operation 

and air traffic conditions.) If operations will be within a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the 

respective airports will be contacted advising them of the estimated flight time, flight 

duration, elevation of flight and other pertinent information.

10. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated.

11. The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

12. If the sUAS loses communications with the remote controller or loses GPS signal, the 

sUAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously.

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies. sUAS has in its program to limit height and distance from PIC.

This extra level of safety will be used to meet safety requirements.

14. Flights will be operated at a lateral distance of least 300 FT from any inhabited structures, 

buildings, vehicles or vessels, or from people not associated with the operation who have 

not given permission in advance of the operation.

15. Local Authorization will be obtained prior to flight.

16. The operator will coordinate all flights with the appropriate Flight Standards District 

Office.

17. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer.

Abort sUAS Flight

Any of the above mentioned flight rules are just causes to cancel flight of sUAS.

I The Extent of Exemption from which WRSA Seeks and the Reason It Seeks Such Relief: 

The Application is being submitted by WRSA in accordance with the Reform Act, 112 P.L. 95 

§§331- 334, seeking relief from any currently applicable federal aviation regulations PARs 

pertaining to sUAS (small unmanned aircraft systems) and operating to prevent WRSA plans on 

using the sUAS to provide quality, accurate photos and 3D mapping of ongoing projects, including 

airfield improvements, construction sites, and public facility improvements. Further, airfield photos are 

required for our Part 139 certification services to Hawaii airports as well as our planning services for an 

Airport-Wide Safety Management System (SMS) Implementation throughout the state of Hawaii.

The Reform Act in §332 provides for such integration of civil sUASs into our national airspace 

system as it is in the public's interest to do so. WRSA lightweight sUASs meet the definition of 

"small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in 

similar industries, WRSA light duty sUASs are ideal recipients of exemption by the intent of the 

Reform Act. 
Considerations for relief include a combination of sUAS physical characteristics, safety features, 

and safe practices identified in §333: 

• sUAS weight, 

• sUAS overall size, 

• sUAS speed over ground, 

• sUAS flight zone characteristics, - Non-operation near airports (civilian or military), - Tightly 

controlled operation in populated areas.

II Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

• Operation of the sUAS by VLOS. (Visual Line Of Sight)

• Coordination by a minimum of 2 persons, 2 staff members of WRSA and one safety official 

from job location. WRSA may assign a safety observer if one is not provide or qualified under 

this document.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 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 and limited 

operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements

of an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal Aviation 

Act (49 U.S.C.§4470 1 (f)) and §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 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated by WRSA is less than 55 lb. with maximal payload consisting of 

remote sensing instrumentation, Cameras and carries neither person, carries no explosive or 

flammable materials including combustible fuels, and operates exclusively within a secured area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the pilot (PIC), 'spotter' role designated to act as both the remote sensing 

controller and secondary monitor for safety issues, and a technician, which assists in matters 

related to maintaining the sUAS and also monitors for safety concerns and liaisons to the on-site 

safety officials. These enhancements to current safety practices and regulations, which already 

apply to civil aircraft, provide a greater degree of safety to the public and property owners than 

conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

intrinsic credible threat to national security posed by the sUAS, due to its size, speed of 

operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load. 

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks include only 

the Roman capital letter "N" and the 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;' "lightsport;' "experimental;' or "provisional;' as applicable. Even though the sUAS will have no 
airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the 

cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of 

the sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the 

frame in compliance with §45.29 (f) at a size suitable for the available space.

14 C.F.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

§61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring a ground crew member to have a private pilot's license rather 

than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries

the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated 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 as requested with a private pilot in the ground crew exceeds the present level of safety 

achieved by 14 C.F.R. §61.1 13 (a) & (b). The equivalent level of safety provided by the fact,

that neither a pilot nor passengers will be carried in the aircraft by the size and speed of the 

aircraft. Enhancing this safety is the technology inherent in the remote controls utilizing digital 

communications which is paired to the sUAS making it nearly impossible to unintentionally or 

intentionally have the control communications interrupted.

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may

operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft 

and the requirements contained in the Manual for maintenance and use of safety check lists prior 

to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent 

level of safety will be provided. 

14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. §91.9 (b) (2) 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. The sUAS, given its size and configuration has no ability

to carry a physical flight manual on the aircraft. The equivalent level of safety will be maintained 

by keeping the flight manual at the ground control point where the pilot flying the sUAS will 

have immediate access to it. The FAA has issued the following exemptions to this regulation: 

Exemption Nos. 8607,8737,8738,9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 

10700.

14 C.F.R. §91.103: Preflight action this regulation requires each PIC to take certain actions 

before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. Further, we have proprietary manuals created with 
the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding 

insurer and continue to work with these organizations to ensure best safe practices are adhered 

to.

14 C.F.R. §91.109: Flight instruction §91.103 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. UASs and remotely piloted aircraft, by their design do not have 

fully functional dual controls. Flight control is accomplished through the use of a control box 

that communicates with the aircraft via radio communications. 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.5778K & 9862A. 

14 C.F.R. §91.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation of 

civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that closely mimics the behavior of a 

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an 

exemption may be needed to allow such operations. As set forth herein, the sUAS will never 

operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is closer. It 

will however be operated in a restricted area with security officials tasked with ensuring public 

safety, and where buildings and people will not be exposed to operations without their preobtained consent and training. The equivalent level of safety will be achieved given the size, 

weight, speed of the sUAS as well as the location where it is operated. No flight operation will 

be taken without the permission of the property owner in the case of private property or local 

officials in the case of public property or private property with public interests. Because of the 

advance notice to the property owner and participants in the remote sensing activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55lb of WRSA sUASs proposed 

herein and the lack of flammable fuel, any risk associated with these operations is far less than 

those presently presented with conventional aircraft operating at or below 500 AGL. In addition, 

the low-altitude operations of the sUAS will ensure separation between these small- UAS 

operations and the operations of conventional aircraft that must comply with §91.119.

14 C.F.R. §91. 121 Altimeter Settings §91.121 requires each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the 

departure airport or an appropriate altimeter setting available before departure." As the sUAS

may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. The PIC and Technician will 

also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height.

.

14 C.F.R. §9 1.15l (a): Fuel Requirements for Flight in VFR Conditions §91.151 (a) 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 battery powering the sUAS 
provides approximately 15 minutes of powered flight in hover mode without payload. WRSA

sUAS will not be able to meet the 30 minute reserve requirement in 14 CPR §91.151. Operating 

the small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

power, does not engender the type of risks that Section 9l.l51(a) was intended to alleviate given 

the size and speed of the small UAS. WRSA believes that an equivalent level of safety can be 

achieved by limiting flights to » 10 minutes or 25% of battery power whichever happens first. 

This restriction would be more than adequate to return the sUAS toils planned landing zone from 

anywhere in its limited operating area. Similar exemptions have been granted to other operations, 

including Exemptions 2689F, 5745, 10673.

14 C.F.R. §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration the regulation 

provides in pertinent part: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following: (1) 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 authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The sUAS fully loaded weighs no more than 55lb and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display

them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at 

the ground control point where the pilot flying the sUAS will have immediate access to them to 

the extent they are applicable to the sUAS. 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) & (b): Maintenance Inspections These 

regulations require 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 section, have discrepancies repaired as prescribed in part 43 of this 

chapter...;' and others shall inspect or maintain the aircraft in compliance with Part 43. Given that 

these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the 

flight manual. An equivalent level of safety will be achieved because these small UASs are very

limited in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

An exemption granted to WRSA would permit its operation of lightweight, unmanned, remotely 

controlled, sUASs in a tightly controlled environment with limited airspace. WRSA utilizes local 

business' safety officers in specifically determined areas (designed flight zone) to mitigate injury

and property damage while fulfilling clients' goals. Technical enhancements to current safety 

controls will allow WRSA to operate exceeding current safety specifications, and stay ahead of, 

or meet, new ones being implemented by the FAA and Department of Transportation. Further, 
WRSA conducts its operations in compliance with protocols described herein or as otherwise 

established by the FAA.

Summary

Wesley R. Segawa and Associates, Inc. seeks an exemption from the following Regulations: 14 

C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7

(a); 14 C.F.R. § 91.9 (b) (2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §

91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b);

14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.P.R. § 91.409 (a)(2); 14

C.P.R. § 91.409 (a) (2); and, 14 C.P.R.§§ 91.417 (a) & (b) to operate DJI Inspire 1, sUAS’s for

commercial photograph/video, GIS and 3D mapping. WRSA plans on using the UAV to provide 

quality, accurate photos of ongoing projects, including airfield improvements, construction sites, and 

public facility improvements. Further, airfield photos are required for our Part 139 certification services to 

Hawaii airports as well as our planning services for an Airport-Wide Safety Management System (SMS) 

Implementation throughout the state of Hawaii. WRSA will offer community education to change 

the present and change the future. If WRSA is granted exemption, WRSA has an opportunity to 

educate our state to be respectful and responsible operators as hobbyist and future professionals 

of UAS. Granting WRSA request for exemption will reduce current risk levels and thereby 

enhance safety. Further, WRSA operates at lower altitudes and in controlled airspace. WRSA 

owner have strong ties to its community to affect change if exemption is granted. sUAS's and 

therefore the likelihood of death or serious bodily injury are significantly limited. 

In closing Drone Services Hawaii LLC Exemption #12675 helped educate and developed 

Petition for exemption for WRSA the end document user. This step was initiated after Alaska

UAS interest group annual meeting 2015. This action is a new way forward to ensure a higher 

level of Safety. Sharing data across exemption holders will be the way to move forward in 

solving sUAS integration into the NAS.

WRSA respectfully requests that the FAA grants its exemption request without delay. The FAA 

has the authority to issue the exemption sought by WRSA pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act").

Wesley R. Segawa

CEO