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. hereb y applies for an exemption from the listed Federal Aviation Regulations (" FARs") and any other necessary

to allow operation of its small Unmanned Aircraft Sy stems (" s UAS") for commercial photograph y, video, GI S 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**

Th e 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 Comp an y'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; highway s, bridges, harbor and waterfront developments; wastewater treatment plans; water sy stems; 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 safet y observers are appl yi ng good safety practices with knowledge of AMA and Section 333 of the FAA Modernization and Ref orm 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 employ ee safet y. Construction sites are Dangerous, Dirt, Dull places and sometime very large areas. A small team of i nspectors 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 Academ y of Model Aerona utics World's largest model aviation association, representing a membership of mor e 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 recreation al activity
, Organization open to anyone interested in model aviation. An o fficial national body for model aviation in the United States , to learn about safet y practices

. AMA sanctions more than 2,000 model competitions throughout the country each ye ar, and certifies official model flyingrecords on a national and international level .Organizer of the annual National Aero modeling Championships, the world's largest model airplane competition. Chartering org anization 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 fl yi ng sites. The voice of its membership, providing liaison with the Federal Aviation Administration, the Federal Communications Commission, and other government agenc ies 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 i n 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 m aximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The DJ I Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously . The DJ I Inspire 1 has four motors, Motor Model DJ I 3510, powered b y a 6

- cell 4500mAh or 5700mAh Lithium Poly mer battery

. There are four propellers, Propeller Model DJ I 1345, in use. The DJ I Inspire 1 will be controlled with the C1 remote controller with anoperating 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 M odernization and Reform Act of 2012. Congress has directed the FAA "to safel y accelerate the integration of civil unmanned aircraft s ys tems into the national airspace sy stem." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit

unmanned aircraft s ys tems to operate in the National Airspace Sy stem ("NAS") where it is safe to do so base on the following considerations: • The s UAS's size, weight, speed, and operational capability

. • Operation of the s UAS in close proximity to airports and populated areas. • Operation of the s UAS 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 o f 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 adver sely affect safety

(or how it would provide a level of safet y 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 s UAS will weigh less than 55 lbs. 2. Flights will be operated within the visual line of Sight (VLOS)

. 3. Flights will be oper ated by Pilot in Command (PI C) and/or Visual Observer (VO). 4. Maximum flight time for e ach operational flight will be 22 minutes. Flights will be terminated at 25% battery power rese rve or 18 minutes of flight time whichever occurs first. 5. Flights will be operated at an altitude of no more than 4 00 feet Above Ground L evel (AGL) and remain in the line of sight. 6. Minimum crew for each operation will consist of the s UAS 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 (PI C). Responsible for preflight check. 8. A briefing will be performed regarding the planned UAS operations prior to ea ch 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 control led 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 PI C 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 PI C and VO will be able to communicate by voice, radio, and/or text at all times. 12. If the s UAS loses communications with the remote controller or loses GPS signal, the

s UAS will have the capabi lity to return to a pre

- determined location within a designated location and land a

utonomously

. 13. The s UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. s UAS has in its program to limit height and distance from PIC. This extra level of safet y will be used to meet safety requirements. 14. Flights will be operated at a lateral distance of least 300 FT from an y inhabited structures, buildings, vehicles or vessels, or from people not associated with the operatio n 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 safel y terminate flight if there is a loss of communication between the pilot and the observer.

**Abort s**  **UAS Flight** Any of the above mentioned flight rules are just causes to cancel flight of s UAS.

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 an y currentl y applicable federal aviation regulations PARs pertaining to s UAS ( small unmanned aircraft s y stems) 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, airfiel d 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 s UASs into our national airspace sy stem as it is in the public's interest to do so. WRSA lightweight s UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safet y record in similar industries, WRSA light duty s UASs are ideal recipients of exemption by the intent of the Reform Act.Considerations for relief inc lude a combination of sUAS phy sical 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 mi litary),

- Tightl y controll ed operation in populated areas. II Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 • Operation of the s UAS by VLOS. (Visual L ine Of Sight) • Coordination by

a minimum of 2 persons, 2 staff members of WRSA and one safet y official from job location. WRSA may assign a safet y 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 b y 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 safet y 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 co nsideration of the size, weight, speed, operational capability , and proximity to airports and pop ulated areas of the particular s UAS. In all cases, an anal ys is of these criteria demonstrates that the s UAS 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 s UAS to be operated b y 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 se cured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by

both the pilot (PI C), 'spotter' role designated to act as both the remote sensing controller and secondary

monitor for safet y issues, and a technician, which assists in matters related to maintaini ng the s UAS and also monitors for safety concerns and liaisons to the on

- site safet y officials. These enhancements to current safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safet y to the public and propert y 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 th ere is no intrinsic credible threat to national securit y posed by the s UAS, 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.

1 4 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks include onl y 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;' "light

sport;' "experimental;' or "provisional;' as applicable. Even though the s UAS will have noairworthiness 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 s UAS, 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

- comm ercial operations. Because the s UAS will not

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations b y requiring a ground cre w member to have a private pilot's license rather than a commercial p ilot's license to operate this s UAS. Unlike a conventional aircraft that carries the pilot and passengers, the s UAS 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 associ ated with the operation of the s UAS 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 le vel of safet y achieved b y 14 C.F .R. §61.1 13 (a) & (b). The equivalent level of safety provided by the fact
, that neither a pilot nor passengers wil l be carried in the aircraft by the size and speed of the aircraft. Enhancing this safet y is the technology inherent in the remote controls utilizing digital communi cations which is paired to the s UAS 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 fo r 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 an y combination thereof . The s UAS, given its size and configuration has no ability to carry a phy sical flight manual on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control po int where the pilot flying the s 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, 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 safet y of flight. As FAA approved rotorc raft 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 withthe help of s UAS experts, the manufacturer, the regional s UAS 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 fu lly 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 fun ctional 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 b y the FAA. As this exemption is for a sUAS that c losel y mimics the behavi or 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 s UAS 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 securit y officials tasked with ensuring public safet y, and where buildings and people will not be exposed to operations without their pre

obtained consent and training. The equi valent level of safet y will be achieved given the size, weight, speed of the s UAS 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 propert y or local official s i n the case of public propert y or private propert y 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. Compar ed 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, an y risk associated with these operations is far less than those presentl y presented with conventiona l 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 Altimet er 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 safet y will be achieved b y the operator, confirming the altitude of the launch site shown on the GPS altitude indicator before fli ght. The PI C 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 fl y after that for at le ast 30 minutes; or (2) At night, to fly after that for at least 45 minutes:' The battery powering the sUASprovides approximately 15 minutes of powered flight in hover mode without payload. WRSA sUAS will not be able to meet the 30 minute reserve requireme nt in 14 CPR §91.151. Operating the small UAS, in a tightly controlled area where only people and propert y owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve power, does not engender the ty pe 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 b y limiting flights to »10 minutes or 25% of battery power whichever happens first. This re striction would be more than adequate to return the sUAS toils planned landing zone from any where in its limited operating area. Similar exemptions have been granted to other operations, including Ex emptions 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 airworthine ss 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 m ore 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 l evel of safet y will be achieved b y keeping these documents at the ground control point where the pilot fl yi ng the sUAS wil l have immediate access to them to the extent they

are applicable to the sUAS. The FAA has issued numerous exemptions to this regulati on. 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 repaire d 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 onl y to aircraft with an airworthiness certificate, these sections will not apply

to th e 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 onl y in restricted area s 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 maintenanc e, 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 airworth y condition to provide the equivalent level of safety. An ex emption granted to WRSA would permit its operation of lightweight, unmanned, remotel y controlled, sUASs in a tightl y controlled environment with limited airspace. WRSA utilizes local business' safet y officers in specificall y determined areas (designed flight zone) to mitigate in jury and propert y damage while fulfilling clients' goals. Technical enhancements to current safety

c ontrols 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 Transp ortation. 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 DJ I In spire 1, s UAS’s for commercial photograph/video , GI S and 3D mapping. WRSA plans on using the UAV to pr ovide 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 hobb yi st and future pr ofessionals of UAS. Granting WRSA request for exemption will reduce current risk levels and ther eb y enhance safety . Further, WRSA operates at lower altitu des and in controlled airspace. WRSA

owner have strong ties to its community to affect change if exemption is granted. s UAS's and therefore the likelihood of death or serious bodily injury are significantl y limited.

In closing Drone Servic es Hawaii LLC E xemption #12675 h elped 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 Safet y. 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 grant s its exemption request without delay . The FAA has the authorit y to issue the exemption sought by WRSA pursu ant to the Federal Aviation Act, 85 P.L . 726 (1958), as amended (the "Act").

Wesley R. Segawa CEO