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] statement 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 and in fact the best video quality is 50 to 100 feet. A large 
manned 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 pounds 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 photography than a manned 

helicopter just based on size alone.

In addition, the UAS can be operated for substantially less costs than a 

regular manned helicopter. The public is significantly served by reducing the cost 

of videography via UAS aircraft.

A UAS 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 based 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 employ 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 system, the inspection of this 

equipment 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 

mph. 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 

computer 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 Section 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