February 3, 2015

Anton A. Ewing, JD Video Solutions, LLC 2175 Cowley Way San Diego, CA 92110 619

- 719

- 9640 Anton@antonewing.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE West Building Ground Floor Room W12

- 140 Washington, DC 20590 Nia Daniels, ARM

- 108 Federal Aviation Administration Office of Rulemaking, Airmen & Airspace Rules Division 800 Independence Avenue, SW Washington, DC 20591

RE: Petition for Section 333 Exemption for Anton Ewing/Video Solutions, LLC Dear Ms. Daniels: We are writing in response to your correspondence dated February 3, 2015 wherein you requested the following:

“ [A] statem ent that shows how this exemption would serve the public interest?” In response to this request, we provide the following analysis: Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than 500 feet AGL. UAS on the other hand are best when flown between 50 and 300 feet AGL an d in fact the best video quality is 50 to 100 feet. A largemanned helicopter could also cause very serious damage to persons or property on

the ground and even to pilots and passengers inside a manned helicopter. A UAS weighing in at approximately six p ounds would not be nearly as hazardous. Additionally, a regular helicopter is normally larger than a standard automobile whereas the UAS is smaller than a basketball. It is substantially safer for the public to have a UAS accomplish the job of aerial pho tography than a manned helicopter just based on size alone. In addition, the UAS can be operated f or substantially less costs than a regular manned helicopter. The public is significantly served by reducing the cost of videography via UAS aircraft. A UA S is operated by sealed battery and electric driven motors. The entire machine remains cool to the touch throughout the flight. A regular manned helicopter can be very hot and carries large amounts of flammable fuel. The UAS is safer for the public base d on the operational temperature and being devoid of flammable or explosive materials. It should also be noted that the exemption applied for proposes that only daytime flight would be approved and no IFR conditions allowed. There also may be occasion to em ploy the UAS to inspect large wind turbines that are used throughout the United States to general electricity . Currently this work is done by persons hanging from long ropes. The use of persons to hang from ropes is hazardous. With the use of a UAS s ystem , the inspection of this equipm ent can be done quickly and safely without risk of injury to any human. Regular manned helicopters and fixed

- wing airplanes fly at well over 30 mp h. The UAS flies at forward airspeeds of less than 25 mph. The UAS is
smaller, slower, and lighter and would be carried to the location rather than flown. This greatly reduces risk to the public. Additionally, the proposed UAS will have a GPS system and the onboard
com puter will not allow it to take off when near any tower controlled airport. It is in the public interest to grant an exemption only to those who propose to fly a UAS with these safety features built into the machine. Based on each of the above states reasons it is within the public interest to grant the Sect ion 333 exemption as outlined in the petition and as previously granted by the FAA in other similar applications and petitions for UAS commercial operations.Respectfully submitted,

/s/ Anton A. Ewing, JD FAA license helicopter and fixed

- wing pilot