August 4, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Thank you for the opportunity to give examples as to why granting Aerial West LLC the 

requested exemption would be in the public interest, and how it would benefit the public as a 

whole. Please find that following examples, as well as the attached support memos from 

professional and charitable organizations supporting this exemption. 

1. UAV use in Disaster Response

Aerial West has been disaster trained with the Red Cross as a first responder (first for Haiti), 

and has offered it services for deployment. Aerial West has helped ‘Team Rubicon’ on the 

potential development of their UAV division. Team Rubicon is a veteran based fast response 

disaster relief organization based in the United States, with international reach. Consultation

includes the safe operation of a UAV, guidelines for a safe training program, and strict 

media/disaster victim privacy rule structure. TR is currently reviewing the use of UAV’s and if 

their use is warranted. Intentions upon 333 exemption include actual flight operations to assist 

immediate disaster recovery efforts, UAV training; and UAV flight training. 

Public Good: Disaster Response

UAV’s are used in documentation and evaluation of a disaster area, to triage deployment of 

teams to areas to quickly render help. Aerial West LLC would use UAV technology to document 

damage, search for victims in difficult to access areas, locate cadavers, animals, and possibly 

render direct assistance to victims in distress.

UAV use for 3D mapping of the disaster area for use in the database to triage the areas affected 

parties is critical. Cataloging structures that are damaged is currently a large scale, difficult 

endeavor taking the time of several teams of people on the ground who often do have access 

to the best vantage point. When this function is provided by a UAV, it drastically reduces the 

time needed to deploy help, and would be virtually impossible with full sized aircraft, and 
dramatically cost prohibitive, and more dangerous.

2. UAV use as an alternative to large, manned aircraft using combustible fuel in Cinema

The UAV, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels to both the pilots aboard and people below, thereby 

enhancing safety and drastically diminishing the likelihood of death or serious bodily injury. The 

small weight and minimal payload allows for high quality aerial video at safety levels before 

unseen.

Public Good: Closed Set Cinematography

Aerial West can offer the same aerial videography a production is requesting without any of the 

danger associated with a traditional full sized manned helicopter using combustible fuel when 

flying over a set. GPS stabilized stationary angles and low altitudes, predictable flight paths with 

full coordination between people on the ground without need for complicated communication 

systems, and the ability to land safely in a comparably smaller area to a full sized aircraft all 

increase safety and public good. The costs of the production are drastically lowered and safety 

is raised. High quality aerial cinematography becomes accessible to smaller productions, 

facilitating market growth and public job creation.

3. UAV use in Aerial Photography

UAV use in photography creates dramatic versatility never before possible. The impact of this 

versatility creates immediate value to small and large businesses, charity organizations, and 

private citizens. Small businesses would never have access to the production value of an aerial 

photo without great expense, usually reserved for larger corporations. Having access ot this for 

promotion needs is a large benefit to businesses. 

Public Good examples: Charity benefits

The ability to operate as an aerial photography business would afford AERIAL WEST LLC the 

opportunity to direct more efforts to assist local charities. Aerial West LLC currently, at its own 

cost without the ability to network and do business with potential interested parties, donates 

aerial photography gallery wrapped canvases to charity auctions like 310YP 

(http://www.310yp.org ), whom donate the proceeds to organizations like ‘Toast Our Vets’ 

whom assist veteran organizations financially. AERIAL WEST LLC would like to offer these 

services to interested businesses or private parties so that they may increase their own 

business reach.

Public Good examples: Real estate and Boat/Ship Sales

The benefits of reduced cost and improved quality of presentation from the UAV will be 

valuable to and benefit many buyers and sellers of real property and marine property, 
increasing the effectiveness of that market. Low level oblique photos and video from several 

angles are far more effective than ground-based imagery for displaying the characteristics of 

large, complex properties. Sales are increased, costs are lowered, and the market benefits.

Public Good Examples: Travel and Tourism

Benefits of reduced cost and improved quality of presentation from the UAV for tourism areas 

has an immediate impact. Clients can show the beauty of their area and present this in a way 

never before fiscally or safely possible so that their city, attraction, or state will increase 

tourism, thereby helping local businesses, economy, and ultimately the families in the area.

Thank you again for the opportunity to give examples as to why granting Aerial West LLC the 

requested exemption would be in the public interest, and how it would benefit the public as a 

whole.

Sincerely,

Bill Palmatary, Owner

Aerial West, LLC

834 15th PL Suite B

Hermosa Beach, CA 90254

323-539-8828 office