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 6th, 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 

Sincerely,

Christopher Weldon 

P id t