3000 Dovera Drive

Suite 200

Oviedo, FL 32765

P: 407‐971‐8850

F: 407‐971‐8955

www.inwoodinc.com

Transportation

Water Resources

Environmental

Parks & Trails

Public Involvement

Utilities June 11, 2015            

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12‐140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 2012

and Part 11 of the Federal Aviation Regulations

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, Inwood Consulting Engineers, Inc. (“Inwood”) seeks an exemption from Federal

Aviation Regulations detailed below for the following described Unmanned Aerial System

(“UAS”) which includes an Unmanned Aircraft (“UA”), ground station based equipment, and

crew.  This exemption will permit Inwood to operate a UAS within the National Airspace

System (NAS) for the commercial purpose of conducting aerial photography and videography,

aerial mapping, aerial surveying, aerial inspection of commercial structures, wildlife surveys,

wetland surveys, and evaluation of environmental impacts.

THE UNMANNED AIRCRAFT (UA):

 Manufactured by DJI, Model – Inspire 1.

 A lightweight UA (7.5 lb. gross weight with all on‐board equipment), battery operated

4‐motor rotorcraft in the form of a quadcopter that takes off and lands vertically and

has a maximum operating airspeed of 50 miles per hour.   

 An on‐board flight computer with GPS navigation and location ability that receives

signals for flight controls from a ground‐based transmitter/controller;

 An on‐board camera capable of capturing imagery in the form of full color, high

definition still photos and video;

 An on‐board telemetry system that delivers flight data from the on‐board flight

computer to the on‐board radio transmitter including altitude AGL, horizontal and

vertical speed, compass direction of flight and direction back to its launch site;

 Various safety systems including return to launch point in case of communication or

mechanical failure.

 Attached as Exhibit 1 are the Inspire 1 Maintenance Manual, Quick Start Guide, Safety

Guidelines, User Manual with Features, and Intelligent Flight Battery Safety Guidelines.

THE GROUND STATION BASED PART OF THE SYSTEM:

 A Pilot in Command (PIC) in operational control of a flight operation from beginning to

end and who controls the UA while in the air;

 A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UA

while in flight;

 Ground Station which receives real time system telemetry from the UA;

 A Visual Observer (VO) who personally provides a second pair of eyes to visually track

the UA while in flight.
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BASIS FOR PETITION

The requested exemption will support an application for a commercial Certificate of

Authorization to use the above described UAS to conduct aerial photography and videography,

aerial mapping, aerial surveying, aerial inspection of commercial structures, wildlife surveys,

wetland surveys, and evaluation of environmental impacts.

The UA, powered by batteries, is smaller, lighter, and more maneuverable than large aircraft

running on combustible fuel; it operates at lower altitudes (under 500’) with no people on

board thereby reducing current risk levels and enhancing public safety.

The Petitioner will apply to register the UAS with the FAA prior to conducting operations.  The

registration will be in accordance with the FAA’s guidance to COA holders from the FAA UAS

Integration Office dated November 5, 2014 or as updated from time to time.

The UAS will be operated in the field with both a PIC and a VO in accordance with FAA Policy

N8900.227 Section 14 “Operational Requirements for UAS” and with the following restrictions:

1. No flight will be made with a UA gross weight exceeding 55 pounds;

2. All operations will occur in FAA Class G airspace at no more than 400 feet AGL, at an

airspeed not to exceed the maximum UA operating airspeed recommended by the

aircraft manufacturer or 87 knots, whichever is less;

3. All operations will be conducted within visual line‐of‐sight of the PIC and VO at all

times;

4. The PIC and VO must be able to communicate verbally at all times during flight

operation;

5. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe

flight;

6. The UAS operated under this exemption will comply with all manufacturer

maintenance, overhaul, replacement, inspection, and life limit requirements for the

aircraft and aircraft components;

7. The UAS operated under this exemption will comply with all manufacturer safety

bulletins;

8. Any changes to the UAS due to maintenance or other alterations that affect the

operation or flight characteristics will require a functional test flight prior to

conducting further operations under this exemption;

9. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

10. The radio frequency spectrum used for operation and control of the UA will comply

with the Federal Communications Commission (FCC) and other appropriate

government oversight agency requirements;

11. All documents needed to operate the UAS in accordance with the conditions and

limitations of any exemption granted by the FAA will be readily available and

accessible during UAS operations;
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12. The PIC must possess at least a sport pilot certificate and at least a valid U.S. driver’s

license issued by a state, the District of Columbia, Puerto Rico, a territory, a

possession, or the Federal government.  The PIC must also meet the flight review

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his

or her pilot certificate.

13. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles, and structures.  PIC

qualification flight hours and currency must be logged in a manner consistent with 14

CFR § 61.56(b).  Flights for the purposes of training the operator’s PICs and VOs

(training, proficiency, and experience‐building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption.  However,

training operations may only be conducted during dedicated training sessions.  During

training, proficiency, and experience‐building flights, all persons not essential for flight

operations are considered nonparticipants, and the PIC must operate the UA with

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

14. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.  All

operations must be conducted under visual meteorological conditions (VMC).  Flights

under special visual flight rules (SVFR) are not authorized.

15. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted

with an ARP, the center of the airport symbol as denoted on the current FAA‐

published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder.  The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

16. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a pre‐

determined location within the private or controlled‐access property.

18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the

reserve power recommended by the manufacturer if greater.

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).  All

operations shall be conducted in accordance with an ATO‐issued COA.  The exemption

holder may apply for a new or amended COA if it intends to conduct operations that

cannot be conducted under the terms of the attached COA.

21. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification (N‐
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Number) markings in accordance with 14 CFR part 45, Subpart C.  Markings must be as

large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS

and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the aircraft is operating.  

These documents must be made available to the Administrator or any law

enforcement official upon request.

23. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present thatsufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident.  The operator

must ensure the nonparticipating persons remain under such protection.  If a

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately in a

manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects and determined that it does

not present an undue hazard.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

26. All operations shall be conducted over private or controlled‐access property with

permission from the property owner/controller or authorized representative.  

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported

to the FAA’s UAS Integration Office (AFS‐80) within 24 hours.  Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov.

The combination of the UA’slight weight, flight performance, stability, fully qualified flight

crew, strict operation under the guidelines established in FAA Policy N 8900.227, and under all

of the restrictions 1 through 27 listed above, the FAA can have full confidence that the

operation will have an equivalent or greater level of safety than manned aircraft performing

the same mission.

   
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The name and contact information for the applicant is:

Inwood Consulting Engineers, Inc.

Attn: Edwin H. Buck, III

3000 Dovera Drive, Suite 200

Oviedo, FL 32765

Phone: 407‐971‐8850

Email: ebuck@inwoodinc.com

Petitioner, Inwood Consulting Engineers, Inc. pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section

333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator

to operate the Inspire 1 UAS within the NAS, and for an exemption from the requirements of:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. 45.23(b)

 14 C.F.R. 61.113(a) & (b) (1)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.9(b) (2)

 14 C.F.R. 91.103

 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) & (b)

 14 C.F.R. 91.405(a)

 14 C.F.R. 91.407(a) (1)

 14 C.F.R. 91.409(a) (1) & (a) (2)

 14 C.F.R. 91.417(a) & (b)

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

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 14 C.F.R. 91.203(a) (1).  Given the size and

limited operating area associated with the UA to be utilized by the petitioner, an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the FMRA.  The Federal Aviation Act (49 U.S.C. 44701 (f)) and Section 333 of

the FMRA 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 UA.  In all cases, an analysis of

these criteria demonstrates that the UA 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.
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The UA to be operated hereunder is less than 55 lbs. fully loaded, is by definition unmanned

and carries neither a pilot nor passenger, carries no explosive materials or flammable liquid

fuels, and operates exclusively within a limited flight area.  Unlike other civil aircraft,

operations under this exemption will be tightly controlled and monitored by the operator and

will remain in compliance with local public safety requirements.  These safety requirements

which already apply to civil aircraft provide a greater degree of safety to the public and

property owners than conventional 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 credible threat to national security posed by the UA due to its

size, speed of operation, location of operation, lack of explosive materials or flammable liquid

fuels, and inability to carry a substantial external load.

The FAA has previously determined that no airworthiness certification is necessary for UAS

platforms and has issued the following exemptions to this regulation: Exemption No. 11110.   

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," "light‐sport,"

"experimental," or "provisional," as applicable. Even though the UA will have no airworthiness

certificate, an exemption may be needed as the UA will have no entrance to the cabin, cockpit

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

two‐inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in

compliance with 45.29 (f).  

The equivalent level of safety will be provided by having the UA marked on its fuselage as

required by 45.29 (f) where the pilot, observer and others working with the UA will see the

identification of the UA as "Experimental."   

The FAA has issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738,

10167, and 10167 A.

14 C.F.R. 61.113(a) & (b) (1), Private Pilot Privileges and Limitations: Pilot in Command

The regulation provides that no person that holds a private pilot certificate my act as pilot in

command of an aircraft for compensation or hire.  Subparagraph (b) allows a private pilot to

act as pilot in command of an aircraft in connection with any business or employment if: (1)

The flight is only incidental to that business or employment; and (2) The aircraft does not carry

passengers or property for compensation or hire.

The Petitioner seeks an exemption to 14 C.F.R. 61.113 (a)’s commercial limitation and

subparagraph (b) (1)’s requirement that the flight be incidental to the business or

employment.

The equivalent level of safety will be provided by requiring the PIC to hold a private pilot’s

certificate rather than a commercial pilot’s certificate to operate the UA.  Unlike a conventional

aircraft that carries the pilot and passengers, the UA is remotely controlled with no passengers
7-10 

on board.  The area of operation is controlled and restricted, and all flights are planned and

coordinated in advance.  Considering the proposed area of operations, operating limitations,

the parallel nature of private pilot aeronautical knowledge requirements to those of

commercial pilots, and the airmanship skills necessary to safely operate the UA, the Petitioner

submits that the additional manned airmanship experience of a commercially certified pilot

would not correlate to the airmanship skills necessary for the UA’s specific proposed flight

operations.

The PIC will not be allowed to operate the UA unless that PIC has demonstrated, by meeting

minimum flight‐hour requirements, that the PIC is able to safely operate the UA in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles, and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R.

61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a

UAS pilot with a multi‐rotor UAS (with a minimum of 5 of those hours as a UAS pilot operating

the same make and model of UAS to be used for operations under the exemption).  In addition

to the hour requirements, the PIC must accomplish 3 take‐offs and landings in the preceding

90 days (for currency purposes).

The FAA has issued the following exemptions to this regulation: Exemptions Nos. 11062,

11110, 11153, 11160, and 11170.

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 herein for the use of safety check

lists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. 91.9(b) (2), Civil Aircraft Flight Manual in the Aircraft

This regulation provides that no person may operate an aircraft unless a current, approved

flight manual is in the aircraft.  Given the size, configuration, and load capacity, the UA has no

ability to carry such a manual on the aircraft.

The equivalent level of safety can be provided by maintaining the UA flight manual at the

ground control point where the pilot flying the UA will have immediate access to it.

The FAA has issued the following exemptions to this regulation: Exemptions Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R 91.103, Preflight Action

This regulation requires each PIC to become familiar with specific information before each

flight, including information contained in the FAA approved Flight Manual on board the

aircraft.  As an FAA approved flight manual will not be provided for the UA, an exemption is

requested.
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The equivalent level of safety can be provided by following the Aircraft Operations Manual

comprehensive preflight checklist.  The PIC will take all actions, including reviewing weather,

flight battery requirements, landing and takeoff distances, and aircraft performance data

before initiation of flight.

The FAA has issued the following exemptions to this regulation: Exemption No. 11109.  

14 C.F.R. 91.109, Flight Instruction; Simulated Instrument Flights and Certain Flight Tests

The regulation states that “No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls”.  UA 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 equivalent level of safety can be provided without dual controls based on the size and

speed of the UA, because no pilot or passengers are aboard the UA, and all persons will be a

safe distance away should the UA experience any difficulties during flight instruction.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 5778K and

9862A.

14 C.F.R. 91.119, Minimum Safe Altitudes

This section prescribes the minimum safe altitudes under which aircraft may not operate,

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non‐congested areas.  Section 91.119(d) (1) allows for a helicopter to operate at less than

those minimum altitudes when it can be operated “without hazard to persons or property on

the surface,” provided that “each person operating the helicopter complies with any routes or

altitudes specifically prescribed for helicopters by the FAA.”  Since the UA will only be

operating at a maximum of 400 feet AGL an exemption is needed.

The equivalent level of safety will be provided given the size, weight, speed of the UA, as well

as the location where it is operated.  No flight will be taken without the permission of the

property owner or local officials.  Because of the advance notice, all affected individuals will be

aware of the planned flight operations.  In addition, the low‐altitude operations of the UA will

ensure separation between the UA and other conventional aircraft that are subject to the

minimum safe altitude regulations.

14 C.F.R. 91.121, Altimeter Settings

This regulation 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 barometric

pressure.  An exemption is required because the UA does not have a barometric altimeter but

rather a GPS altitude read out.

The equivalent level of safety will be provided by confirming the altitude of the launch site

shown on the GPS altitude indicator before flight.  The PIC will use the GPS altitude indicator to

constantly monitor the UA height, thus ensuring operation atsafe altitudes.

14 C.F.R. 91.151(a), Fuel Requirementsfor Flight in VFR Conditions
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This section (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.  An exemption is required because the UA is powered by a battery which provides

less than 30 minutes of powered flight.

The equivalent level of safety will be provided by limiting flights to 20 minutes or 20%

remaining battery power, whichever occurs first.  This restriction would be more than

adequate to return the UA to its planned landing zone from anywhere within its limited

operating area.  Operation of the UA within a controlled operating area does not engender the

type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the

UA platform.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 2689F, 5745,

10673, and 10808.

14 C.F.R. 91.203(a) & (b), Carrying Civil Aircraft Certification and Registration

This section states that (a) no person may operate a civil aircraft unless it has within it the

following: (1) an appropriate and current airworthiness certificate.  It also requires that (b) no

person may operate a civil aircraft unless the airworthiness certificate is displayed at the cabin

or cockpit entrance so that it is legible to passengers or crew.  An exemption is required

because the UA’s load capacity and size does not allow it to carry certification and registration

documents, the UA does not have a cabin or cockpit entrance where documents could be

displayed, and there are no passengers or crew for whom the certificates need to be displayed.

To the extent that these regulations are applicable to the proposed UAS operations, an

equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the UA will have immediate access to them.

The FAA has issued the following exemptions to this regulations:  Exemption Nos. 9565, 9665,

9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. 91.405(a); 91.407(a) (1); 91.409(a) (1) & (a) (2); 91.417(a) & (b), Maintenance

Inspections

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part

43.  An exemption to these regulations is needed because Part 43 and the stated sections

apply only to aircraft with an airworthiness certificate, which the UA will not have.

The equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the manufacturer maintenance manual and instructions.  The

PIC will ensure that the UA is in working order prior to initiating flight, oversee and assist in

performance of required maintenance, and keep a log of any maintenance performed.  If

mechanical issues arise, the UA can land immediately and will be operating from no higher

than 400 feet AGL in an unpopulated area.  The UA’s small size, limited carrying capacity, and

the fact that flight operations will only take place in restricted areas for limited periods of time,

create less risk than the same factors associated with conventional fixed‐wing aircraft and

rotorcraft performing the same operation.
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FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b) (1); 14 C.F.R.

91.7(a); 14 C.F.R. 91.9(b) (2); 14 C.F.R. 91.103; 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) & (b); 14 C.F.R. 91.405(a); 14

C.F.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (1) & (a) (2); and 14 C.F.R. 91.417(a) & (b) to

operate a small unmanned aerial system (UAS) for the purpose of conducting aerial

photography and videography, aerial mapping, aerial surveying, aerial inspection of

commercial structures, wildlife surveys, wetland surveys, and evaluation of

environmental impacts.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UAS for conducting aerial

photography and videography, aerial mapping, aerial surveying, aerial inspection of

commercial structures, wildlife surveys, wetland surveys, and evaluation of environmental

impacts will enhance safety by reducing overall risk to personnel and the public.  The operation

of UA weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide

an equivalent level of safety which supports the grant of the exemptions requested herein,

including exempting the applicant from the requirements of Part 21 and allowing commercial

operations.  The UA are battery powered and create no emissions.  In the event of any impact

there is not fuel to ignite and explode.  The public’s interest is furthered by minimizing the

ecological impact of an accident and by reducing the human exposure to potentially harmful

emissions associated with manned aircraft.

PRIVACY CONSIDERATIONS

All flight operations will occur over public or controlled access property in areas clear of

spectators or uninvolved participants.  All permissions will be gained by all official personnel,

landlords, organizations, and individuals present in the surveyed or photographed area.

CONCLUSION

Given the foregoing, Petitioner’s proposed usage does not pose a hazard to the NAS or to the

public.  Considering the statutory language in Section 333 of the FMRA, the equivalent level of

safety to the public and the NAS, and the reduction of environmental effects, the grant of the

requested exemptions is in the public interest.  Accordingly, Petitioner respectfully requests

that the FAA grant the requested exemptions allowing commercial operation of the

Petitioner’s UAS.

Very truly yours,

Edwin H. Buck, III, P.E.

Executive Vice President

Inwood Consulting Engineers, Inc.