TO: 

Brittany Newton 

Program Analyst, Airmen and 

Airspace Rules Division 

16 July 2015 

This letter is in response to your letter dated 1 July 2015 pertaining to a request for additional 

information. The following information will explain how our petition for exemption will not 

adversely affect safety, and site other exemptions to further support our request. 

14 C.F.R Part 11.81 (e)- The reasons why granting the exemption would not adversely affect safety, 

or how the exemption would provide a level of safety at least equal to that provided by the rule from 

which petitioner seeks the exemption: 

Using UAS technology to collect photographic/videography data is beneficial to the public as a 

whole as it significantly risks to workers who must scale heights to collect information (risk of fall), 

it reduces risks to the public as a whole due to the reduction of helicopters and small aircraft as the 

UASs carry no combustible materials on board. Battery Powered UASs serve as a safe, efficient and 

economical alternative to manned aircraft traditionally used for capturing aerial images. They provide 

high levels of safety to person and property since no pilot or crew need to be airborne. UASs provide 

greater operational flexibility and reduced costs. Better aerial imagery can be obtained by using 

UASs due to their small size, maneuverability and flight performance characteristics. Less time is 

needed in the air to obtain the footage, thereby reducing the number of aircraft in the NAS. Reduction 

of noise will benefit the public as well. Finally, the UAS industry is expected to grow to $11.5B by 

2024 (military and civilian), which ultimately will contribute to the US economy by creating jobs and 

increasing consumer spending. 

The use ofUASs can significantly reduce the risk to workers of falls while inspecting, surveying, or 

monitoring sites. UASs can inspect, photograph, and collect data on hard to access areas that 

otherwise would require worker inspection. Falls are a leading source of workplace fatality and injury 

on construction sites and reducing falls through UASs use for site imaging could save workers lives. 

Additionally, UASs could replace the use of helicopters and small aircraft to monitor sites. The UASs 

we propose to fly in this application are less than 25 pounds, and carry no combustible material on 

board, as opposed to the much larger conventionally powered small aircraft. Shifting to UASs from 

helicopters presents a marked safety increase for our workers and the public. Lastly, UASs reduce the 

environmental impact by dramatically decreasing the energy used for aerial imaging and data 

collection over a construction site. Our UASs use rechargeable batteries, as opposed to fossil fuels 

burned in operation of small aircraft that are many hundreds oftimes heavier. 

The operating limitations proposed by Sensorflight provide for at least an equivalent or higher level 

of safety because the operations further enhance the safety of aerial digital imaging over using 

conventional aircraft. In addition to following all instructions as provided by the manufacturer, 

Sensorflight shall include the following conditions and limitations in all operations: 

1} Flights will be operated within line of sight of a pilot and/or observer. 
2) Flights will be terminated at 20% battery power reserve. 

3) Flights will be operated at an altitude of no more than 400ft AGL 

4} Flights will only be operated in reasonably safe environments that are strictly controlled, are away 

from airports, power lines, elevated lights, and/or actively populated areas. 

5) A briefing will be conducted for planned UAS operations prior to each flight. 

6) Consent will be obtained from all persons involved in the operation and only authorized personnel 

will be allowed within 500 feet of the flight operation. 

7) Written permission will be obtained from the relevant property owners. 

8) If the UAS loses communications, the UAS will be placed in "Return to Home" mode and will 

return to its point of takeoff. 

9) The UAS flight will be aborted should circumstances arise that created a potential hazard to person 

or place. 

• Any additional information, views, or arguments available to support your request 

Reference from similar granted exemptions: 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, 

Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA- 2014- 0382), 

and 11213 to Aeryon Labs, Inc. (see Docket No. FAA- 2014-Q642), the FAA found that the enhanced safety 

achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition 

to flammable fuel, gives the FAA good cause to fmd that the UAS operation enabled by this exemption is in 

the public interest. 

I believe that our petition is similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213. The reasons stated by the FAA for granting Exemption 

Nos. 11062, 11109, 11112, and 11213 also apply to our presented petition and we feel a grant of exemption is 

in the public interest. 

Respectfully, 

Aransas Pass, TX 78336