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 of 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. Currently, 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 transmit 
extremely high voltage electricity and are in both rural 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 large, 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 aircraft 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 inspections. 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 Alabama. 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 manned 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 national airspace system as 

required by Section 333. The public has a significant interest in efficient and safe 
inspection of energy infrastructure to ensure reliable delivery of power and other public 

utilites, and PCI has proposed using sUAS to further this 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 addition, 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 PCI 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 sUAS 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 aircraft 
conducting aerial 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 sUAS fleet, instead of manned aircraft, 

benefits the public by drastically reducing air and noise pollution generated during 

manned aircraft operations. The PCI’s sUAS 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 sUAS 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. Further, 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 providing

information to companies looking to relocate or build in the areas 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 the 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 also 
describes a record high price for an area home that used a drone for aerial photography. 

“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 Cinders 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 new 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 sUAS weighs less than 15 pounds complete with a small ultra light weight 

high quality camera;

2. PCI will only operate our fleet of sUAS below 300 feet (well within the400foot 

permissible ceiling set by the FAA Modernization and Reform Act of 2012)

3. PCI’s sUAS only operates for 18-22 minutes per flight

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

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

6. PCI will pilot our sUAS only with a visual observer