October 14, 2015

Stacey Chance Discovery Bay Studios 1854 Seal Way Discovery Bay, CA 94505 captainchance@gmail.com Cell 925

- 216

-4454
FAA Docket Management Facility U.S. Department of Transportation 1200 New Jersey Avenue, SE West Building, Ground Floor, Room W12

- 140 Washington, DC 20590 Dear Exemption Manager, In reference to Docket No. FAA

- 2015

- 2744 dated June 24, 2015. I am submitting the requested additional information regarding why granting Discovery Bay Studios th e Exemption for Unmanned Aircraft Systems operations would be in the public interest and how it would benefit the public as a whole. **The Reasons Why Discovery Bay Studios Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As**  **A Whole.** Granting the present p etition will further the public interest by allowing Discovery Bay Studios to safely, efficiently, and economically perform aerial video and photography of real estate, events, civic landscape , architectural, and constructi on sites over local areas of the United States. Additio nally, use of the DJI Phantom UAS will decrease congestion of the NAS, reduce pollution, and provide signi ficant benefits to the economy. Normally these functions would require larger manned aircraft. Notably, the benefits of Discovery Bay Studios proposed operation of the DJI Phantom UAS will be realized without implicating any privacy issues. **1. The Public Will Benefit From Decreased Congestio n Of The NAS.**  The DJI Phantom UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain ae rial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allo wing the use of a DJI Phantom U AS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and depa rting aircraft will be reduced. The DJI Phantom UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewe r aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landi ng phases of flight operations.**2. The Public Will Benefit From The Safety And Effic iency Of The DJI Phantom**  **UAS.**

Conducting aerial acq uisitions with the DJI Phantom UAS, 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 el ectric motors, the DJI Phantom UAS 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 20

- 30 gallons pe r hour of leaded aviation fuel. The DJI Phantom UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion en g ine. By using the DJI Phantom UAS to perform aerial acquisitions, 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 re duced or comp letely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom UAS (weighing less than 3 pounds at their maximum gross weight, and with no fuel on board), has less physical potential for collateral damage to li fe and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds, and a fuel capacity of 180 gallons). **3. Performing Aerial Video and Photography O perations With**  **The DJI Phantom UAS Will Benefit The**  **Economy.** In addition to being safe and efficient, the DJI Phantom UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom UAS will all ow United States based companies, like Discovery Bay Studios, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasin g out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating th e battery powered DJI Phantom UAS is one such technology that not only allows c ompanies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom UAS, companies such as Discovery Bay Studios, can remain competitive and profitable, a nd therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through com mercial use of the DJI Phantom UAS, provides a stable wor kforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

Sincerely, Stacey Chance Discovery Bay Studios