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14 CFR 11.81 (d) - The reasons why granting U.T.R.’s request would be in the 

public interest; that is, how it would benefit the public as a whole:

Granting the exemption will further public interest by allowing U.T.R. to safely, efficiently, and 

economically perform operations to further safe UAS integration into the listed industries. An 

overarching goal of safely integrating sUAS into the listed industries is to promote regulatory 

compliance and environmental responsibility for the public, while, at the same time, 

enhancing operational efficiencies and cost savings and avoidance for private companies.

With a strong safety and risk culture, and experience in UAS testing, our team will ensure 

safe sUAS integration. Safe sUAS operations will reduce risk and unnecessary exposure for 

inspectors and pilots as compared to legacy processes. Risk and change management 

remain critical components of this sUAS integration.

The use of sUAS will improve incident response and preparedness. Compared to manned 

aircraft, sUAS typically operate at less than 1% of the fuel usage. Due to lower operating 

costs, increased inspections will result in proactive maintenance and repair. Safe sUAS 

operations will enhance situational awareness, and allow for early detection and early action 

when incidents occur.

The Public will benefit from improved regulatory compliance through aerial 

inspections and monitoring.

U.T.R. will be supporting the said industries through the development and use of sUAS in the 

aerial inspection and monitoring of facilities, freestanding structures, and infrastructure. The 

efficient nature of UA allows for more frequent inspections increasing the likelihood of early 

detection of any potentially dangerous or harmful structural breaches. Further certain 

inspections are potentially dangerous operations, unnecessarily placing personnel at risk. UA 

can perform these inspections, preventing personnel from having to enter potentially 

hazardous situations. Through benefit analysis, UA are proving safer than legacy inspection 

processes. UA usage will minimize injuries (and reduce risk to inspectors and lost time injury 

rates for employees).The Public will benefit from the enhanced efficiency of the UA.

Many operations U.T.R. intends to perform are currently conducted by manned rotorcraft or 

fixed-wing aircraft. Compared to manned aircraft, UA will generate significantly less air and 

noise pollution while conducting those same operations. Additionally the efficient nature of 

UA enable increased inspection frequencies thereby allowing earlier detection of potentially 

harmful leaks and spills. UA will reduce the carbon footprint for comparable inspections. 

Further, increased inspections will also enhance regulatory compliance and environmental 

responsibility.
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The Public will benefit from the increased safety of UA.

The scope of work accomplished across the said industries requires operations in remote 

areas and in challenging terrain or within hazardous industrial facilities. Successful 

integration of UA will allow for safer operations in remote or difficult to access areas. They 

will also increase safety in hazardous facilities where inspections are required. Additionally, 

UA's ability to support first responders in emergency situations provides a significantly 

increased level of safety while coordinating response efforts. The potential for increased 

inspection cycles on infrastructure will further reduce risks to our client's employees and the 

public-at-large.

The Public will benefit from enhanced situational awareness provided by UA 

to Emergency Responders.

UA serve as a safe and efficient way to provide an overhead view of emergency 

situations; allowing Emergency Response efforts to be coordinated more efficiently and 

further minimize risks to responders and to the public.
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U.T.R.’s Petition for Exemption additional information 

To whom it may concern,

During my time in the survey and inspection industry I have come upon many 

instances that a small unmanned vehicle would have eased the concern of my 

crewman’s safety greatly in the areas of terrain data, offshore and onshore petroleum

platform inspections, flare inspections, bridge deck design and inspections, etc.

The first of many instances was a time that a crewman and I had to gather the 

elevations crossing a remote location along the Trinity River south of Dallas, Texas. The 

banks were full of dense vegetation for more than a mile in each direction with the 

exception of a narrow clearing for an electrical distribution line crossing the river. Rather 

than facing the logistical problems of flanking the tree line in each direction, we opted to 

take the electrical easement to the top bank. Of course it wasn’t going to be that easy, 

we were met with a fifteen to twenty foot drop to the bottom of the river during a 

drought. At that time, the crewmember I was with was nursing a knee injury. We 

repelled to the bottom tying off on a wood pole along the said electrical easement with 

the needed equipment on our backs. This was back in the summer of 2002.

At that time, along with many others since then, small unmanned technology was 

limited compared to today’s standards as well as the software that was available to 

process the needed data.

In recent times, the need for the use of small unmanned aircraft is not always 

seen at the time of the project budget proposal. I have personally found many instances 

in my career that the availability of this technology would greatly improve the time and 

safety of the required work which will save U.T.R.’s clients money, money that can be 

allocated to market creation and innovation for the future of America.