LV	Aerial	Imaging 13	August 2015

Attn.: Dewey	Gray

9724	Royal	Lamb	Drive

Las	Vegas,	NV	89145

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

SUBJECT: Exemption Request Section 333 of the FAA	 Reform Act	 for	 aerial	

imaging	for	commercial	purposes AMENDMENT	1

To	Whom	It	May	Concern:

On	5	May	2015,	LV	Aerial	 Imaging	submitted	a	Section	333	exemption	request	 to	operate	

small	 Unmanned	 Aerial	 Systems.	 	 This	 amendment	 is	 filed	 to	 comply	 with	 request	 for	

additional	information	requested	by	FAA	letter	dated	23	July	2015.

Specific	additional	Information	requested	is:	PUBLIC	INTEREST and	ADDITIONAL	VIEWS	

TO	SUPORT	REQUEST.		Both	are	addressed	below.

Reasons	why	granting	LV	Aerial	Imaging	request	will	be	in the	public	interest	AND	how	it	

would	benefit	the	public	as	a	whole.	

Reason	1	– Expanding	the	availability	of	affordable	aerial	photos	for	industry	

Granting	this	petition	will	further	the	public	interest	by	expanding	the	availability	of	

economically	 affordable	 aerial	 cinematography	 and	 photography.	 Historically,	 the	

public	 has	 used	 aerial	 photos	 for	 a	 variety	 of	 reasons.	 These	 aerial	 photos	 and	

videos	have	been	obtained	using	manned	aircraft,	costing	hundreds	and	thousands	

of	 dollars	 per	 hour	 to	 operate.	 Granting	 this	 petition	 will	 increase	 the	 quality	 of	

aerial	 photography	 services,	 while	 at	 the	 same	 time	 decreasing	 the	 price.	 This	

service	will	allow	for	the	following:

• Enhanced and	 dynamic	 real	estate	marketing,	 benefiting	property	owners,	

real	estate agents,	and	building/roofing	inspectors

• Crop surveying	 for	 the	 agricultural	 industry	 (field	 drainage	 monitoring,	

crop	insurance	 documentation,	 pesticide	monitoring,	 etc.),	which	will	lead	

to	increased	farming	efficiency	benefiting	both	farmers	and	consumers	

• Insurance	 claim	 documentation	 for	 insurance	 companies	 such	 as	 hail	

damage,	crop	damage,	bridge	collapses,	flooding,	etc.,	which	will	benefit	the	

insurance	companies	and	consumers	of	insurance	products	

• Construction progress	 for	 residential,	 commercial, and	 industrial	

construction	companies.	

• Wetland and	 water	 drainage	 mitigation	 for	 public	 works	 departments,	

which	will	enhance	the	ability	of	civil	engineers	to	plan	 for	water	drainage	

mitigation	
• Power	 line and	 pipeline	 utility	 inspection	 services	 for	 utility	 companies	 -

many	more	potential	applications	exist	

• The	 increased	 efficiency	 and	 lower	 cost	 of	 operating	 a	 UAV	 for	 aerial	

applications	 will	 benefit	 the	 economy	 as	 a	 whole	 by	 allowing	 scarce	

resources,	 such	 as	 aircraft	 fuel,	 to	 be	 used	in	 other	 areas	 of	 the	 economy.	

This	 will	 ensure	 that	 the	 United	 States	 remains	 competitive	 on	 the	 global	

market	for	aerial	applications	and	ensure	that	more	jobs	stay	located	within	

the	United	States.	

Reason	2	– Reduced	Levels	of	Air	and	Noise	Pollution

Replacing	 manned	 aircraft	 with	 DJI	 Phantom	 and	 Inspire	 series	 sUAS to	 conduct	

aerial	 operations	 will	 provide benefit	 to	 the	 public	 by	 reducing	 air	 and	 noise	

pollution.	Small	UAVs	have	significant energy and	environmental efficiencies	when	

compared to traditional	 manned	 aircraft.	 	 	 DJI	 Phantom	 and	 Inspire	 series	 sUAS	

utilize	 very	 efficient	 small	 electric	 motors	 that are	 non-polluting and	 much	 more	

environmentally	 friendly	 than the	 traditional	 four	 to	 six	 cylinder	 internal	

combustion	 aircraft	 engines	 that	 are	 typically	 utilized	 for	 aerial	 video	 and	

photography.	 These	manned	aircraft	burn	approximately	10-25	gallons	per	hour	of	

leaded	 aviation	 fuel.	 The	 DJI	 Phantom	 and	 Inspire	 series	 sUAS further	 offer	 the	

added	benefit	of	reduced	noise	pollution	by	their small	propeller	blades	and	electric	

motors	 producing only	 a	 fraction	 of	 the	 noise	 level	 that	 traditional	 fixed-wing	

aircraft	or	helicopters	produce.	

Reason	3	– Increased	Public	Safety

The	 public	 will	 benefit	 from	 the	 safety	 and	 efficiency	 Of	 The	 DJI	 Phantom	 and	

Inspire	series	sUAS	very	light	weight; which	poses	a	very	small	threat	to	people	and	

property	 on	 the	ground	in	 the	event	 of	a	crash.	The	potential	mishap	damage	of	a

lightweight sUAV	compared	to	the	damage	that	a	4000	lb. aircraft	with	hundreds	of	

gallons	 of	 fuel	 onboard is	 substantially	 reduced.	 	 By	 reducing	 weight	 and	 speed	

while	eliminating	combustible fuel	requirements,	the	risk	of	collateral	damage	to	life	

and	property	in	the	event	of	a	mishap	is	vastly	reduced.

Reason	4	– Reduced	Congestion	of	the	National	Airspace	System

Granting	this	request	also	benefits	the	public	as	a	whole	by	reducing	the	congestion	

of	 manned	 aircraft,	 leading	 to	 decreased	 congestion	 of	 the	 NAS.	 By	 reducing	 the	

number	of	manned	aircraft	operating	in	the	NAS,	it	will	relieve	the	air	traffic	control	

system	of	unnecessary	aircraft	traffic.		Since	DJI	Phantom	and	Inspire	series	sUAS	do

not	need	a	runway	or	airport	to	operate, the	demands	on	an	already	busy	Air	Traffic	

Control	system	and	controllers	is	reduced.

Respectfully,

Dewey	Gray

LV	Aerial	Imaging

lvai@blueskies.us

(702)	586-8800