July 10, 2015

Supplement December 21, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS)

Re: Supplemental Information for

Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviati

on Regulations

Dear Brittany Newton:

Pursuant to letter dated December 11, 2015 requesting additional information for our request in

accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 C.F.R. Part 11, Wynfred C. Sibley, Jr., P.E. a.k.a. W. C. Sibley, PE seeks an

exemption from Federal Aviation Regulations (“FARs”) detailed below for the following

described Unmanned Aerial System (UAS) called in this application the W. C. Sibley, PE

System, which includes an Unmanned Aircraft (UA) and ground station-based equipment and

crew we are providing this additional information.

UAS Operating Exemptions Requested:

W. C. Sibley, PE is requesting an exemption from the following regulations 14 CFR § 11.81(d &

e).

APPLICATIONS AND PUBLIC INTEREST

Th e req uested exem ption w ould allow W . C. Sibley, PE to operate th e DJI Phantom 2, DJI

Phantom 3, and DJI Inspire 1 for th e purposes ofphotographingto support professional operations

in engineering, forensics, land surveying, architecture, real estate and other related professional

activities. Th ese inspections and investigations are com pleted on residential, com m ercial,

m unicipal, and public properties and are typically conducted in supportofth e property insurance

industry.Use ofUASforth ese applications w illoffersignificantadvantages related to safety,tim e,

and cost. M ostproperties th rough outth e country are insured,and property ow ners h ave an interest

in insurance underw riting, coverage, and claim s processing;th erefore itis clear th atgrantofth is

exem ption w ould be in th e public interest.

Currentoptions for gath ering th e data w h ich under th is exem ption w ould be collected using UA,

include use ofladders,lifts,and m anned aircraft. Use ofladders and lifts are inh erently dangerous

and resultin num erous injuries each year. Use of m anned aircraftis typically notfeasible and

th erefore valuable inform ation rem ains beyond th e reach ofth e investigator. In m ostcases, use

ofa UA is q uick er and easier th an any oth er alternative and often yields better inform ation.

W. C. Sibley, PE proposes use of its UAS provided equivalent or augmented levels of

safety for each of the uses proposed herein:
The present systems of inspecting the roofs of buildings and large structures site surveys are now

conducted by either humans climbing on the roofs and structures that are steep, tall, slippery,

weakened or otherwise hazardous or by the use of conventional aircraft. The current procedures

can result in significant injuries to the people who must climb on the roofs or require the use of

aircraft that are orders of magnitude greater in size than the UAS. Either method, manual

inspection or large conventional aircraft, results in increased risk of injury due to personnel

falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous

spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft

inspecting buildings after damage from storms or other disasters, such as earthquakes or fires.

Such flights are, of course, significantly more expensive than those undertaken with a UAS. The

present system exposes those not only in the immediate area of inspection, but those who are

along the path of flight associated with the arrival and departure of the conventional aircraft at

the inspection site because the aircraft must be flown to and from the site. By contrast, the UAS

is carried to the site and transits no other property. Conventional aircraft carry flammable fuels

that are not carried by the UAS and emit pollutants associated with internal combustion engines.

Due to their small size and the fact they carry no fuel, the UAS pose a very low risk of damage to

persons or structures on th e ground. Because th ese UA are electric pow ered, th ey create no

h arm fulem issions and m ak e very little noise.

Safety and reduced injuries are in the public’s interest with the reduction in the use of public

resources and emergency responders for emergency medical personnel, transportation and rescue

activities.

Conclusion

W. C. Sibley, PE respectfully requests that the FAA grant the exemption sought in this request.

W. C. Sibley, PE believes that considering the small size and weight of the UAS, along with the

UAS PIC training and certification requirements stipulated above and the strict operating

guidelines proposed herein, it is clearly demonstrated that the UAS will be operated safely in the

national air space (NAS) with an equivalent or greater level of safety compared to manned

aircraft.

We are prepared to modify or amend any part of this request as deemed necessary by the FAA to

satisfy the need for an equivalent level of safety. Please contact us at any time if you require

additional information or clarification.

Sincerely,

/s/ Wynfred C. Sibley, Jr., P.E.

Wynfred C. Sibley, Jr., P.E.

Principal

W. C. Sibley, PE

2146 Sixth Avenue

Morton, PA 19070

610-809-9879

WCSibleyPE@verizon.net