TO: BrittanyNewton Program Analyst, Airmen and Airspace Rules Division 16 July 2015

This letter is inresponse 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 ourrequest.

14 C.F.R Part 11.81 (e)

- The reasons why granting the exemption wouldnotadversely affect safety , or how the exemption would provide a level of safety at least equal to thatprovidedby the rule from whichpetitioner seeks the exemption: Using UAS technology to collectphotographic/videography data is beneficial to the public as a whole as it significantly risks to workers who must scale heights to collect information (risk offall), itreduces risks to the public as a whole due to the reduction ofhelicopters 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. Theyprovide high levels ofsafety 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 airto obtainthe footage, thereby reducing the number ofaircraft in the NAS. Reduction ofnoise 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 creatingjobs and increasing consumer spending. The use ofUASs can significantly reduce the risk to workers offalls 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 ofworkplace 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 ofhelicopters 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 con ventionally 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 ofsmall aircraft that are many hundreds oftimes heavier. The operating limitations proposed by Sensorflightprovide for at least an equivalent or higher level ofsafety because the operations further enhance the safety ofaerial digital imaging overusing 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 ofsight ofa pilot and/or observer.2) Flights will be terminated at 20% battery powerreserve. 3) Flights will be operated at an altitude ofno more than400ftAGL 4} Flights will only be operated inreasonably 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 inthe operation and only authorizedpersonnel will be allowed within 500 feet ofthe flight operation. 7) Written permission will be obtained from the relevant property owners. 8) Ifthe UAS loses communications, the UAS will be placed in "Returnto Home" mode and will return to its point oftakeoff. 9) The UAS flight will be aborted should circumstances arise thatcreated a potential hazard to person orplace

.

• Anyadditional information , views, or arguments available to supportyour request Reference from similar granted exemptions: In Grants ofExemption Nos. 11062 to Astraeus Aerial (see DocketNo. 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 ofsignificantly greaterproportions, carrying crew in addition to flammable fuel, gives the FAA good cause to fmd thatthe UAS operation enabled by this exemption is in the public interest. I believe that ourpetition is similar in all material respects to reliefpreviously 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 ourpresented petition and we feel a grant ofexemption is in the public interest.
Respectfully,

Aransas Pass, TX 78336