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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 industr ies . An overarching goal of safely integrating sUAS into the listed in dustr ies 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 exper ience 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 i ntegration.

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 industr ies 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 t he 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 c onducting 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.
Fur ther, increased inspections will also enhance regulatory compliance and environmental responsibility.Page 2 of 3

The Public will benefit from the increased safety of UA.

The scope of work accomplished across the said industr ies 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. A dditionally, 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.Page 3 of 3



### 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, off shore 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 excepti on of a narrow clearing for an electrical distribution line crossing the river. Rather than facing the logistical problem s 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 b e 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 alo ng the said electrical easemen t 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.

I n recent times, the nee d 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 an d innovation for the future of America.