October 15, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

*** SUBMISSION OF MISSING Section 14 CFR Part 11.83 (d)
Dear Sir or Madam : How This Request Will Benefit the Public As A Whole: Tower/Utility Inspection Allowing the requested use will provide significant benefits to the public, Perkins
Cinders Inc . (PCI) customers, and PCI employees. Using sUAS to inspect utility/tower
infrastructure can be safer and more efficient than traditional methods of infrastructure inspection, such as the use of helicopters and bucket trucks. The increased safety and efficiency o f using sUAS to inspect infrastructure following significant weather events is especially important to PCI, where storms occur with frequency as well as during controlled outages required for maintenance. An infrastructure inspection process that is
safer and more efficient can help to lower operations and maintenance costs and more quickly resolve problems in the delivery of public utilities and supporting infrastructure,
both of which will benefit customers.

Use of the sUAS will increase ground safety. C urrently, electrical companies and other public utilities conduct visual inspections using manned helicopters in very close physical proximity to power lines and transmission towers. Power lines transmitextremely high voltage electricity and are in both r ural and heavily populated urban areas. All lines need to be inspected, both on the surface and internally.

As the FAA has recognized, use of manned helicopters to conduct tasks which could otherwise be completed with sUASs can be dangerous, as they are l arge, operated by an onboard pilot in addition to other onboard crewmembers, carry highly flammable fuel, and are operated over large distances. Inspecting power lines with a manned helicopter is very dangerous for all the crew members involved as the air craft is required to fly slowly and very close to the power lines. Manned helicopters are susceptible to weather patterns as well.

There have been several instances in recent years in which inspectors and crew members lost their lives performing such insp ections. Three people were killed in an accident in Silt, Colorado in January 2014. The helicopter struck the power line and crashed, quickly killing all those on board. Exhibit 11. Two people lost their lives in a similar situation in August 2014 in Alaba ma. Exhibit 12. In Texas, in 2013, two transmission line inspectors that were suspended from the helicopter by large cables were killed when the cables struck the power line and snapped. Exhibit 13. Moreover, especially in populated areas, the use of manne d helicopters to conduct these inspections creates a substantial risk of injury or death for individuals on the ground.

Moreover, the requested use presents a compelling case for the Administration moving forward with efforts to integrate sUAS into the na tional airspace system as required by Section 333. The public has a significant interest in efficient and safeinspection of energy infrastructure to ensure reliable delivery of power and other public
utilites , and PCI has proposed using sUAS to further th is public interest in a way that is at least as safe as operation of aircraft under existing regulations. Applicant’s request, therefore, provides the Administration an appropriate vehicle to further Congress’ mandate to expedite integration of UAS. In add ition, Applicant’s operational experience resulting from the use of sUAS in utility operations may be valuable to the Administration in developing comprehensive rules governing sUAS for the electric industry.

Precision Photogrammetry and Mapping

Granting P CI for exemption will further the public interest because PCI seeks to perform necessary and vital services for public and private organizations. Such services include research, education, agricultural, search and rescue. The PCI unmanned aircraft
fleet is battery

- powered UAS that serve as a safe, efficient, and economical alternative to the demand aircraft traditionally utilized in obtaining aerial imagery within these industries. An exemption allowing PCI’s s UAS fleet to operate would reduce the amount
of manned aircraft operating in the NAS, reduce noise and air pollution. In addition, the safety of life and property both in the air and on the ground would be improved.

By reducing the number of manned aircraft operating in the NAS airport congestion caused by arriving and departing aircraft will be reduced. The PCI’s sUAV fleet does not require an airport to take off or land. A reduction of manned aircraftconducting aer ial imagery flights would mean air traffic control handling less traffic during the ground, takeoff, departure, arrival and landing phases of flight operations.

Aerial imagery missions using the PCI’s s UAS fleet, instead of manned aircraft, benefits the p ublic by drastically reducing air and noise pollution generated during manned aircraft operations. The PCI’s s UAS fleet, a battery powered electric motor, is the most viable environmentally conscious alternative to internal combustion aircraft. The

maximum gross weight of 15 pounds per s UAS has less physical mass for collateral damage to life and property whether on the ground or in the air.

Aerial Imagery of Commercial and Residential Properties

Aerial videography for geographical awareness of real estate marketing has been around for a long time through manned fixed winged aircraft and helicopters, but for small business owners, its expense has been cost prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Fur ther, my small UAS, when used properly, will pose no threat to the public given its small size and lack of
combustible fuel when compared to larger manned aircraft. The operation of his UAS
will minimize ecological damage and promote economic growth by pro viding information to companies looking t o relocate or build in the area s serviced by PCI

. One final comment, the use of a sUAS has already proven to increase the marketability of a home. For example please review the article published January 7, 2015

in t he San Diego source entitled “drone use in real estate may increase” , (also added as an attachment). The article cites the FAA’s exemption given to Douglas Trudeau, but alsodescribes a record high price for an area home that used a drone for aerial photog raphy.
“When broker Kurt Wannebo added an aerial video to the listing for a Carmel Valley house, located on a large corner lot overlooking canyons on two sides, he saw web traffic noticeably increase.”

Reasons Why Perkins C inders Inc.’s Exemption WILL NOT Adversely Affect Safety and How The Exemption WILL Provide a Level of Safety At Least Equal To Existing Rule: Granting Perkins Cinders Inc. exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of ne w and novel, as of yet undiscovered safety protocols for development in cooperation with the FAA. In addition I submit the following representations of enhancements to current aerial videography and photography:

1. PCI’s s UAS weighs less than 15 pounds compl ete with a small ultra light weight high quality camera;

2. PCI will only operate our fleet of s UAS below 300 feet (well within the400foot permissible ceiling set by the FAA Modern ization and Reform Act of 2012)

3. PCI’s s UAS only operates for 18

- 22 minutes pe r flight

4. PCI will land our s UAS prior to 20% Battery Remaining

5. PCI will pilot our s UAS through remote control only by line of sight

6. PC I will p ilot our s UAS only w ith a visual observer