Department of Transportation 

800 Independence Ave. SW

Washington. DC 20591

Attn:

Brittany Newton

Program Analyst, 

Airmen and Airspace Rules Division

Re: CA Drone Supply Additional Information Section 333 Exemption Request 

Brittany, 

In response to the letter dated August 6th 2015 denying our request for Section 333 exemption due to 

the lack of information regarding public interest and public good. 

 The reasons why granting the request would be in the public interest: that is, how it would 

benefit the public as a whole.

 Any additional information, views, or arguments available to support your request.

Please allow me to clarify. 

PUBLIC GOOD:

The inherent ability of the UAS is to capture imagery from a low altitude including oblique photos and 

video from several angles is far more effective than ground-based imagery for displaying the 

characteristics of buildings, sites and properties being developed or marketed for sale. Probably 50% of 

my business comes from the commercial real estate market. 

I also acquire video and imagery for weddings and special events. The ability to fly at a low altitude and 

hover quietly without distraction is very important to my clients. Conventional aircraft or helicopters are 

too loud, obvious, and expensive for most of these unique shoots. 

These same factors apply when we are capturing video and imagery for local retailers who contract us to 

provide data used in producing commercials or print marketing materials.

I have been fortunate to provide acquisition services for the major television networks and some of the 

more popular cable networks due to my proximity to the major studios in the area. 

As a veteran (former Navy Seal support specialist) I also provide acquisition services to first responders 

including the military and san Diego Police Department. 
The applicant prior to becoming involved in UAS technology would charter fixed wing aircraft and/or 

helicopters for these purposes. However, these methods have proven more costly than many of my 

current and potential clients have been able to afford, resulting loss of opportunities. I can offer these 

services using a small unmanned system for a fraction of the cost.

Further, there are now many competitors in my area who have successfully received their Sec 333 

exemptions and are operating legally. These firms are at an advantage only because they have received 

their exemption and now coming after my clients. Without receiving my own exemption, I will be driven 

out of business soon. 

PUBLIC SAFETY: 

UAS, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel; they operate at lower altitudes (under 400’) and weigh under 55lbs with 

no people on board thereby reducing current risk levels and enhancing public safety. In the event of 

catastrophic failure a small drone leaves very little impact and there are no people on board to suffer 

tragedy. Small planes used for similar services have in the past caused or been involved in midair

collisions resulting in significant loss of life both in the air and on the ground. With a small payload and 

maximum flight time of approximately 22 minutes, UA’s offer little or no risk to national security.

Further, the terminology and structure of our exemption request are very similar to authorized 

exemptions # 12026, 12366 and 12369 all approved within the last 2 weeks. 

Sincerely,

John Santry, 

Owner

CA Drone Supply 

1608 India St #505 

San Diego, CA 92101

Phone: 804-852-7355

Email: john@revolutionaryus.com