Name and Address of Applicant:

Corey Ingalls

Technical Specialist

NMotion UAS

216 N. Mosley, Suite #210

Wichita, KS 67202

July 8th 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington D.C. 20590

U.S. DOT/FAA Request for Additional Information:

NMotion UAS Petition for Exemption (Docket No. FAA-2015-1239-0001)

To Whom it may concern:

The substance of this request is essentially the same as that granted to Unmanned Aerial

Assessment & Video LLC, Docket Number FAA-2015-0018 in that NMotion UAS is 

committed in public safety, as well as, aerial photography and inspection of structures in the 

public's interest.

Request for an exemption from §§ 45.23(b), 61.113 (a) and (b), 91.7 (a), 91.9 (b)(2), 91.103(b), 

91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 

91.409 (a)(2), 91.417 (a) and (b), and Subpart H of part 21 of Title 14, Code of Federal 

Regulations (14 CFR). 
Public Interest 

 In compliance with the requirements of § 11.81, granting the petition would be in the public 

interest because:

The Congress of the United States has determined that early accommodation of sUAS 

into the National Airspace System advances the public interest. The Committee Report leading 

the House to adopt H.R. 658 said:

"The successful integration of unmanned aircraft systems (UAS) into the National Airspace 

System (NAS) can support more than 23,000 high-paying jobs in the United States. . . . The 

absence of a plan to integrate UASs into the NAS is a barrier to such job creation . . . ."

1.) Granting the Petition represents a step toward such integration, in the absence of a 

comprehensive regulatory regime for sUAS, and thus would serve the Congressional goal and 

the public interest.

2.) Granting the Petition will facilitate a new era in emergency response activities, one in which 

the responders themselves will have a tool to safely, quickly and remotely assess a situation 

without placing lives in harm’s way. In comparison, the EOD robots have saved countless lives 

since their inception, a feat that will become common place for aerial assessments.

3.) Granting the Petition will enable Petitioner to demonstrate the commercial viability of creating

new safety techniques and tactics with new aeronautical technology, thereby improving the 

efficiency of emergency responders around the world and making for a safer society.The rules 

from which Petitioner seeks exemption artificially and irrationally limit the effective use of new 

technologies to expand emergency response safety and improve the efficiency of markets, 

thereby subverting the public interest.

4.) Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation 

technologies advances the public interest. The FAA itself has recognized the public interest in 

its role of “Encouragingand developing civil aeronautics, including new aviation technology.” 

Granting the Petition willenhance FAA fulfillment of that commitment, thereby serving the public 

interest. Air commerceflourishes in the United States because of the rapid pace of innovation in 

aeronautical and associated technologies, followed by their commercialization and their 

introduction into the marketplace. The sUAS technology that the Petitioner uses exemplifies the 

latest innovative leap forward in aeronautical technology. Preventing it from using this in air 

commerce subverts achievement of the goal.

5.) Granting the Petition will fulfill the Congressional determination that integrating sUAS 

technology into the NAS serves the public interest. Section 330 of the FAA Modernization and 

Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from the

deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the 

availability of these technologies in the National Airspace System, thereby representing a 

congressional determination that the public interest is served by making these technologies 
more widely available at the earliest practicable date. The Petition represents a way for the FAA

to move incrementally, while still satisfying its congressional mandate and meeting its obligation 

to enhance the public interest by making new technologies available by allowing the use of 

sUAS technologies in a manner that protects the public and the rest of the aviation community 

from significant risk. The commercial activities by Petitioner proposed in the Petition represent 

contributions to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under

the 2012 Act.

6.) Granting the Petition will enhance aviation safety, thereby advancing the public interest. The 

Petitioner has committed itself in the Petition to safety practices that reduce or eliminate 

hazards to aircraft in the National Airspace System and to persons and property on the ground. 

Many others are flying sUAS without regard to these hazards. Granting the Petition will offer the 

Petitioner up as an example of how the FAA is willing to accommodate the new technology 

when it is constrained by appropriate limitations to enhance safety. It will also allow the 

Petitioner to be a role model for safe commercial sUAS operations. Users of the National 

Airspace System are confronted by mushrooming threats from sUAS flown in defiance of the 

FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe operation of 

sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying the 

hazards to manned aircraft and to persons and property on the ground. The Petitioner's 

proposed operations satisfy the criteria provided in Section 333 of the Reform Act relating to 

size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight, and national security. The Petition justifies grant of the 

requested exemptions to allow the Petitioner to commercially provide sUAS to organizations.

Thank you for the time and consideration. Please contact Mr. Corey Ingalls for more 

information or questions that arise.

Corey Ingalls

Corey Ingalls 

Technical Specialist 

NMotion UAS, LLC. 

216 N Mosley St #210 Wichita, KS 67202 

(316) 305-6275 

corey@nmotionuas.com