### Weldon & Associates, Inc. (DBA OrlandoAerial.com), Orlando FL - Section 333 Exemption Petition

	




PO Box 740487 Orange City, Florida 32774-0487 Phone: (386) 873-0020 Fax: (386) 202-4287 www.WeldonAssoc.com info@WeldonAssoc.com Monday, April 6 th , 2015

RE: Regulations.gov Docket No: FAA-2015-0324 Subject: Public Interest Amendment to Exemption/Rulemaking Dear Jake Troutman, FAA Program Analyst, Airmen and Airspace Rules Division, Consistent with the requirements of 14 CFR §11.81(d), the Petitioner “Weldon & Associates, Inc. (dba OrlandoAerial.com)” offers the following reasons why granting this petition for exemption is in the public’s interest, i.e., how granting it would benefit the public as a whole. Approval of exemptions allowing commercial operations of small and lightweight sUAS in the utility aerial services industry benefits the public as a whole in many ways. Approving an exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act, namely, the FAA Administrator's assessment of whether certain sUAS may operate safely in the National Airspace System before completion of the rulemaking required under Section 332 of the Reform Act. To enhance safety standards, petitioner conducts research and development into safe operations every time it flies its sUAS. Flight data, visual inspections, recorded observations and flight analysis are compiled to further enhance current safety protocols. Allowing us to log more flight time directly relates to our research and our ability to further enhance current safety measures. 1. Real Estate Property Photos and Cinematic Services The public has an interest in reducing the danger, cost and emissions associated with current aerial photography and cinematic filming methods, namely, full size manned helicopters and airplanes. Our sUAS is battery powered and creates no emissions. If our sUAS crashes there is no fuel to ignite, explode or compromise the environment. The impact of our lightweight sUAS is negligible when compared to a full size helicopter or airplane, notwithstanding the statistically noteworthy safety record of full size manned aircraft used in motion picture filming. The public’s interest is furthered by minimizing ecological and crash impacts by permitting photo and motion picture filming through our lightweight sUAS. Safety standards using unmanned systems are un-paralleled with any other systems. Progression of the arts and sciences has been fundamental to our society since its inclusion in the United States Constitution. Indeed, Congress mandated the integration of sUAS commercial operations into our national airspace system, in part, to achieve progression in this noteworthy, and inevitable, field. Permitting the petitioner to immediately fly within the United States furthers these goals.

### Weldon & Associates, Inc. (DBA OrlandoAerial.com), Orlando FL - Section 333 Exemption Petition

	




PO Box 740487 Orange City, Florida 32774-0487 Phone: (386) 873-0020 Fax: (386) 202-4287 www.WeldonAssoc.com info@WeldonAssoc.com 2. Cell Tower Inspections This type of operation significantly improves safety and reduces risk by alleviating human exposure to danger associated with current telecommunications survey and inspection methods, namely, tower climbs. The public's interest is furthered by reducing human exposure to death or serious injury associated with personnel performing telecommunications and utility structure or tower inspections and patrols. Petitioner's DJI S1000 sUAS is battery powered and creates no emissions. If Petitioner's sUAS crashes, there is no fuel to ignite, explode or compromise the environment. Any impact of Petitioner's sUAS is, obviously, far less than potentially harmful emissions associated with cranes and lift equipment. The public's interest is furthered by minimizing ecological impact of an accident and by reducing human exposure to emissions. Visual surveys are valuable tools for telecommunications and utility structure inspections. However, the obstructed environment with cables and power lines impede aerial surveys and inspections from conventional manned aircraft. The use of the sUAS addresses these problems and is a powerful tool for performing a wide-range of telecommunication and utility structure inspection and patrol applications. The public as a whole will benefit from the safer and more cost-effective utility aerial services that these operations provide.
Conclusion Whether it is the amalgam of scientific discoveries applicable to feature film making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or advancements in equipment available to law enforcement personnel / first responders that does not cost millions of dollars, granting this exemption request substantially furthers the public’s interest in ways known and currently unknown. Granting this request will also allow small business owners and home owners to be able to afford high quality aerial images and video that they would otherwise have no access to, due to several factors, cost being the biggest. Sincerely,

Christopher Weldon President Si ncer el y,

Ch risto p her Weldon P id t