1 Stephen C. Denty 8810 Leeshire Lane Ra leigh, NC 27615 919.669.7286 sdenty@nc.rr.com

**To:** Brittany Newton , Program Analyst and Airspace Rules Division **From:** Stephen C. Denty **Subject:** Additional Information Requested FAA Letter **Date:** August 6, 2015 **REFERENCE** : ATTACHED LETTER FROM THE FAA DATED JULY 30, 2015 REQUESTING FURTHER INFORMATION. **Files:** 2015
- 1507
- 000 1 , 2015
- 1507
- 0002 **ENCLO S**  **U RES**  :

 July 30 , 2015 letter from the US D EPARTMENT OF TRANSPORTATION /FAA  Original Exemption Request Paperwork. In response to your communication to Stephen C. Denty dated July 30, 2015 attached , I am seeking an exem ption from

the FARs listed below : 14 C.F.R § 61.113(a) & (b); 14 C.F.R § 61.133(a) 14 C.F.R §91.7(a) 14 C.F.R § 91.119(c.) 14 C.F.R §91.151 14 C.F.R § 91.405(a) 14 C.F.R §91.407(a)(1) 14 C.F.R §91.409(a) &(b) **ANWSER TO THE QUESTION IN YOUR LETTER**  **: Why will granting the r**  **equest for an exemption be in the public interest and**  **benefit the public as a w hole?** 2

Stephen C. Denty is seeking the exemption set fo rth in original exemption request ( attached) to operate commercially a small unmanned vehicle (55 lbs. or less) in aerial survey operations. Approval of this exemption for commercial aerial survey operations will enhance safety by reducing risk. Conventional operations, using jet or piston powered aircraft, operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures. Such manned operations present the risks associated with vehicles that can weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the project location. In contrast , a sUAS weighing fewer than 4 lbs. or less and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the target area and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the ris ks associated with manned aircraft. O ther reasons why a grant of the exemption would be in the public interest:

 The operator would be able to have access and therefore supply the public with mo re com

plete data on buildings, aerial surveys, news gathering, topography , agriculture and other target areas .  The general public wil l gain large amounts of data at a much lower cost than with manned aircraft in a shorter period of time
.  Greatly reduced risk in comparison to manned aircraft of all types.  The risk to onboard pilot and crew during an accident is eliminated with the use of a sUAS. The use of a sUAS increases safety, reduces cost and provides a detailed data source and therefore is in the publics best interest as discussed above
.3

**Safety** The risk of any proposed sUAS operation in the request for exemption attached interfering with manned aircraft is minimized by the low altitude at which the sUAS will operate, the location and the FAA airspace requirements. Additionally, the petitioner is a certified flight instr uctor, instrument rated, helicopter, airplane with many years of experience both teaching low level flight, airspace and safety.
**Summary that can be published in the Federal Register proposal**  : Docket No. FAA
- 2015_________ Petitioner: Stephen C. Denty Sections of 14 CFR: 61.113(a) and (b), 9.7(a), 91.119(b) and (c), 91.121, 91.15, 91.405(a), 91.407(a)(1) and (2), and 91.417(a)and (b) **Sections of Relief Sought** : Petitioner seeks exemption to conduct small UAS commercial operations for Aerial Surveying , collect analyse, conduct aerial photography, remote sensing, structure assessment, land survey photogrammetry, news gathering, construction site inspection and monitoring, and industry survey. **Proposed Conditions and Limitations** The small UAS operations previously proposed in the attached Petition is consistent with previously granted small UAS Section exemptions and FAA guidance. All small UAS operation will:

 Have a gross weight less than 55 lbs including all pyload, energy s ources and equipment.  Ground speed less than 55 knots4

 Maxim

um flight time of 25 minutes  The sUAS will be identified by its serial number and registered with the FAA in accordance with FAR Part 47.  The sUAS will have identification markings (N number) in ac cordance with FAR 45 being as large as practicable.  The sUAS will operate in accordance with applicable sUAS airspace regulations. **sUAS Manuals** Petitioner is in possession of all operational manuals both printed and electronically, also published by DJI the manufacture. The manuals include preflight inspections, safe operations and the like. As a licensed pilot, Petitioner will follow the required weather minimums and forecasts as published by the FAA in METAR, TAF, current radar views, wind, altimeter s etting, and other available weather information. This response to additional information is respectfully submitted
. Stephen C. Denty