September 27, 2015

Contact: Danny Frisby-Griffin,

Chief Executive Officer

Danny.frisby-griffin@saunterraven.com

RE: RESPONSE TO REQUEST FOR PUBLIC INTEREST EXPLANATION FOR OUR

EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM ACT AND PART

11 OF THE FEDERAL AVIATION REGULATIONS

Dear Sir/Madam,

September 10, 2015 we received your letter requesting the reasons why granting our request

on behalf of Saunter Raven, LLC filed in Docket No. FAA-2015-2676 would be in the public’s

interest. Please see our explanation below:

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT

This exemption request will permit Saunter Raven, LLC to operate its sUAS commercially for the

purpose of aerial filming and photographing to include: commercial and residential real estate,

precision agriculture, herd management, crisis/emergency response, infrastructure inspections,

construction, architecture, scientific research, environmental assessment, land surveying and

mapping and other applicable areas. Saunter Raven, LLC will provide a service that is beneficial

to industries and organizations that are already using, and seeking to use, sUASs for these

purposes with a legal and safe option. This will benefit the public with the controlled operation of

sUASs and increase integration into the national airspace system (NAS).

Granting the present petition will further the public interest by allowing Saunter Raven, LLC to

perform safely, efficiently, and economically, aerial video and photography of construction sites,

real estate, and landscape over certain areas of the United States. Additionally, use of our sUAS

will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the

economy.

The integration of sUASs into the NAS will not only replace traditionally more expensive options

or approaches, it will enable work to be done and decisions to be made in ways that were simply

impossible to do previously. The commercial deployment of small unmanned aircraft systems

offers the public a new, highly efficient and relatively inexpensive platform for collecting, analyzing

and utilizing data and photographic/video imagery.
In deploying its sUAS, Saunter Raven, LLC has developed specific performance standards,

operating requirements, protocols and work processes that are aligned with the FAA’s continuing

mission, and result in safe operating practices that are consistently applied and continuously

improved. For its part, Saunter Raven, LLC recognizes the important role it plays in educating the

public and building awareness of both the promise and precautions that accompany the

commercial deployment of this new and exciting platform.

The sUAS utilized by Saunter Raven, LLC are battery-powered and serve as a safe, efficient and

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery and

intelligence. A grant of exemption would allow Saunter Raven, LLC to contribute to the reduction

of manned aircraft needed to perform the aerial acquisition of data, video and photographic

content and subsequently reduce the volume of manned aircraft in the NAS.

Conducting aerial intelligence acquisitions with our sUAS platforms, instead of manned aircraft,

will greatly benefit the public by drastically reducing the levels of air and noise pollution generated

during traditional aerial video and still photography flight operations. By using battery power and

electric motors, the DJI Phantom 3, Lockheed Martin Indago and Aeryon Sky Ranger sUAS

Platforms produce no air pollution, and is the most viable environmentally conscious alternative to

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial

video and photography, while burning approximately 8-20 gallons per hour of leaded aviation fuel.

While our sUAS platforms reduce the carbon footprint of aerial acquisitions, they also sharply

reduce noise pollution, as the sUAS platforms are propelled by battery powered electric motors,

rather than an internal combustion engine.

The substantial risk to life and property in the air and on the ground, which is usually associated

with traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated by using our sUAS platforms to perform aerial intelligence acquisitions. All three of our

systems weigh less than 6 pounds including battery, payload and propellers with no fuel on

board. These sUAS have less physical potential for collateral damage to life and property on the

ground, and in the air, compared to the manned aircraft that typically conduct similar operations

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34

feet, and a fuel capacity of 180 gallons).

Previously, such services as high-resolution digital aerial real estate photography, surveying and

inspections were limited and affordable to a relatively small group of agencies, companies and

organizations with significant operating capital. The granting of this exemption will enable Saunter

Raven, LLC to change this by deploying its sUAS in ways that make aerial photography and other

sUAS services accessible and affordable to a significantly larger portion of individuals,

organizations and businesses. The many new forms of aerial intelligence will have an immediate

and direct benefit to service providers, business owners and consumers alike.

In attachment 1, Lake County (South Dakota) Sheriff Tim Walburg provides additional support for

why granting our request would be in the public interest. As stated in our original document,

Saunter Raven, LLC requests to use its sUAS to service first responders nearby when assistance
is required, including local fire fighters, the police, the sheriff, etc., while remaining subject to all

limitations cited in this application as we do so.

Saunter Raven, LLC is prepared to modify or amend any part of this request to satisfy the

need for an equivalent level of safety. Please contact us at any time if you require additional

information or clarification. We look forward to working with your office.

Thank you for the opportunity to respond and provide justification as well as demonstrate how we

can meet a genuine public interest.

Best Regards,

Danny Frisby-Griffin

Chief Executive Officer