INTEGRATED TESTING AND ENGINEERING COMPANY OF SAN ANTONIO, LP

GEOTECHNICAL & ENVIRONMENTAL ENGINEERING* CONSTRUCTION SERVICES* GEOLOGIC ASSESSMENTS

12028 RADIUM SAN ANTONIO, TEXAS 210 525 9033

OFFICE

210 525 9032

FAX

www.intec-sa.com

April 14, 2015

From: Randall Connell

To: Federal Aviation Administration

To Whom it May Concern,

Since 1991 INTEC SA has been provided engineering services in geotechnical engineering and construction 

materials testing and has expanded services to include environmental and geological assessment services.

In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to safely accelerate the integration 

of civil unmanned aircraft systems into the national airspace system” and, under Section 333 of that law, gave the 

FAA power to grant innovators “expedited operational authorization” to do so. By this petition, INTEC SA is seeking 

authorization to conduct sUAS operations on our own sites to improve safety for our employees and ensure quality 

assurance for the facilities we are inspecting. 

Further, granting this request will do nothing more than allow INTEC SA to do what thousands of hobbyists and 

manufacturers of model aircraft do every day, except we will abide by much stronger safety measures. INTEC SA

has hired a licensed private pilot to manage our sUAS program. Under his supervision we would provide a safe 

level of operation that is superior to current regulations. His experience as a FAA licensed private pilot gives him an 

understanding of how manned aircraft safely navigate the National Airspace System (NAS). This invaluable 

experience applied to INTEC SA’s UAS program equates to safe sUAS use on our projects with no confliction with 

manned aircraft.

A. Mailing address and other contact information: 

Randall Connell

Project Manager

InTEC of San Antonio, LP

12028 Radium Drive

San Antonio, Texas 78216

210-525-9033 office

210-627-5135 cell

bootfit@gmail.com

http://www.intec-sa.com/
INTEGRATED TESTING AND ENGINEERING COMPANY OF SAN ANTONIO, LP

GEOTECHNICAL & ENVIRONMENTAL ENGINEERING* CONSTRUCTION SERVICES* GEOLOGIC ASSESSMENTS

12028 RADIUM SAN ANTONIO, TEXAS 210 525 9033

OFFICE

210 525 9032

FAX

www.intec-sa.com

B. The specific section or sections of 14 C.F.R from which INTEC SA seeks exemption. 

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

3. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 

4. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 

5. 14 CFR 91.119 Minimum Safe Altitudes. 

6. 14 CFR 91.121 Altimeter Settings. 

7. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions. 

8. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations. 

9. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)(1) Observer Medical. 

C. The extent of relief INTEC SA seeks, and the reason INTEC SA seeks the relief. 

INTEC SA seeks exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 91, and FAA 

Notice 8900.227 to the extent necessary to engage in commercial operations of a sUAS on our own 

sites. If granted these exemptions we would operate the sUAS with the property owner’s 

written permission. INTEC SA’s intent is to use a sUAS for the following inspections: 

1. Quality Control / Quality Assurance Inspections

2. Aerial Surveys 

We have detailed below a significant set of safeguards that will apply to our proposed sUAS inspection operations. 

Operations under these safeguards will provide a level of safety exceeding the level of safety required of similar 

sUAS operations that the FAA authorizes currently. In addition, our operations will not create a hazard to users of 

the national airspace system or the public or pose a threat to national security and are thus consistent with the 

congressional mandate in Section 333 of the FAA modernization and Reform Act of 2012, which gives the FAA a 

mechanism to allow certain UAS to operate safely in the national airspace system.

D. The reasons why granting INTEC SA’s request would be in the public interest; that is, how it would 

benefit the public as a whole. 

This would benefit the public by giving INTEC SA a capable risk mitigated inspection platform. The proposed sUAS 

gives INTEC SA an alternative to sending our employees into dangerous situations in order to accomplish 

necessary and required construction inspections. This in turn could prevent accidents and/or construction related 

deaths. This would have a positive trickledown effect to families of our employees and people that work on site 

which ultimately benefits the public. 
INTEGRATED TESTING AND ENGINEERING COMPANY OF SAN ANTONIO, LP

GEOTECHNICAL & ENVIRONMENTAL ENGINEERING* CONSTRUCTION SERVICES* GEOLOGIC ASSESSMENTS

12028 RADIUM SAN ANTONIO, TEXAS 210 525 9033

OFFICE

210 525 9032

FAX

www.intec-sa.com

E. The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which INTEC SA seeks the 

exemption. 

INTEC SA sUAS operations will provide a level of safety that far exceeds the level of safety required by the FAA for 

hobbyists and manufacturers of model aircraft. The following operating procedures will apply during the sUAS 

inspection operations under this exemption request.

1. The sUAS that INTEC SA has chosen to work with is the Phantom Vision 2 and/or 3 and will be powered via a 

battery source. INTEC SA will only use sUAS that are below 4.4 pounds now and in the future. 

2. INTEC SA inspection operations will be conducted:

i. within the visual line of sight of the Pilot in Command (PIC) and one or more Visual Observers (VO).

ii. at less than 400 feet AGL

iii. within Class G airspace. 

3. INTEC SA inspection operations will be conducted in a confined area over isolated private property located at 

least 5 miles away from any airport, heliport, seaplane base, spaceport or other location with aviation activities, and 

any military or U.S. government installations or airfields. If we are within the 5 mile radius of any of the above 

installations INTEC SA will seek written approval from that installation’s owner before sUAS inspection operations 

take place. If said installation owner requires stricter guidelines for operation then INTEC SA will comply. 

4. All sUAS operations will remain within the lateral and vertical boundaries of the operating area, taking into 

account all factors, including wind, gross weight and glide distances, that may affect the capability of the sUAS to 

remain within the airspace boundary; moreover, the ceiling height will be no more than 400 feet AGL. 

5. INTEC SA sUAS inspection operations under this exemption will be conducted under the supervision designated 

PIC who ultimately has final responsibility for the operation in accordance with 14 C.F.R. 91.3 and holds a FAA 

private pilot license.

6. PIC will maintain the sUAS system in a condition for safe operation, and conduct a pre-flight inspection prior to 

each flight so as to ensure that the sUAS, control station, data link equipment, camera, and support equipment are 

in a condition for safe operation and in a configuration appropriate for the purpose of the intended flight. 

7. The PIC and VO will maintain two-way communications with each other during all operations; if unable to 
INTEGRATED TESTING AND ENGINEERING COMPANY OF SAN ANTONIO, LP

GEOTECHNICAL & ENVIRONMENTAL ENGINEERING* CONSTRUCTION SERVICES* GEOLOGIC ASSESSMENTS

12028 RADIUM SAN ANTONIO, TEXAS 210 525 9033

OFFICE

210 525 9032

FAX

www.intec-sa.com

maintain two-way communications, or if any condition occurs that may otherwise cause the operation to be unsafe, 

the operator will immediately conclude the operation. 

8. Each sUAS that INTEC SA will employ under this exemption will safely return automatically to a home location 

designated by the PIC if the communications link is lost. 

9. The aircraft documentation required by 14 C.F.R. §§ 91.9 and 91.203(b), as applicable, will be available to the 

PIC referred to above at any time INTEC SA sUAS are operating.

INTEC SA will effectively operate under our own standard operating procedures that will provide additional 

safeguards that go far beyond the level of safety for public model airplane fields. 

F. A summary the FAA can publish in the Federal Register, stating: (1) The rule from which you seek 

the exemption; and (2) A brief description of the nature of the exemption you seek. 

1. Petitioner: InTEC SA

2. Sections of 14 C.F.R. Affected: §§ Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121; 91.151; Subpart E; 

and 8900.227 para(16)(4). 

3. Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ Part 21, Subpart H; 

91.203; 45.23; 91.9; 91.119; 91.121; 91.151; Subpart E; and 8900.227 para(16)(4)in order to conduct commercial 

small unmanned aircraft system operations on supported sites with owner approval subject to operating procedures 

that meet or exceed those that FAA requires for similar operations.

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

Please see the introduction to this exemption request.

H. If you want to exercise the privileges of your exemption outside of the United States, the reason why you 

need to do so. 

InTEC SA does not wish to exercise the privileges of this exemption outside of the United States at this time. 
INTEGRATED TESTING AND ENGINEERING COMPANY OF SAN ANTONIO, LP

GEOTECHNICAL & ENVIRONMENTAL ENGINEERING* CONSTRUCTION SERVICES* GEOLOGIC ASSESSMENTS

12028 RADIUM SAN ANTONIO, TEXAS 210 525 9033

OFFICE

210 525 9032

FAX

www.intec-sa.com

Thank you for your consideration and I look forward to your response. I can be contacted directly 

via email or cell phone at your convenience.

Sincerely,

InTEC of San Antonio, LP

 

Randall W Connell, EP

Environmental Professional

Project Manager

Environmental Services Division

Murali Subramanian, Ph.D., P.E.

Copies: one, via email