January 6, 2016

Via Electronic Filing Attn: Docket Operations U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Public Interest Supplement in
Docket No. FAA-2015-4328 Exemption Petition of Carolina Reprographics, LLC pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

To the Flight Standards Service:

This letter shall serve as a supplement to the petition for a Section 333 Exemption filed July 14, 2015, in Docket No. FAA-2015-4328 (the “July 14 Petition”) for my client Carolina Reprographics, LLC (“Petitioner” or “Carolina Reprographics”) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95, 126 Stat. 11 (2012) (“Section 333”), and certain sections of Part 11 of Title 14 of the Code of Federal Regulations. By letter dated December 14, 2015, the FAA Staff has requested additional information regarding the Public Interest that would be served by a grant of the July 14 Petition. See Letter from Brittany Newton dated December 14, 2015 (attached hereto).

As set forth in the text of the July 14 Petition, grant of the July 14 Petition would serve the public interest by allowing for economic growth and the safe introduction by Petitioner of sUAS video and photography services into the marketplace prior to the conclusion of the sUAS rulemaking proceeding. In addition, the public interest will be served by granting the July 14 Petition because Congress has established a national policy that favors early integration of UAS into the NAS in controlled, safe working environments such as those proposed in the July 14 Petition. Thus, by granting the July 14 Petition, the FAA will further Congressional goals as embodied in Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012



### , namely the FAA Administrator’s assessment of whether and which unmanned aircraft and UAS operators may undertake safe operations prior to adoption of UAS rules of general applicability as required by law.

As discussed in the July 14 Petition, Carolina Reprographics’ proposed UAS operations stands to reduce risk and improve safety by reducing the public’s exposure to certain risksassociated with traditional aerial data collection methods, in particular the use of full size fixedwing aircraft and rotorcraft. As set forth in the July 14 Petition, the unmanned aircraft for which Petitioner seeks authority to operate are lightweight and battery powered, and they generate no toxic or flammable emissions; thus, in the unlikely event that one of Petitioner’s unmanned aircraft were to crash, there is no fuel to ignite or explode. Accordingly, any accident involving Petitioner’s small lightweight UAS would present significantly less danger to the individualsCarolina Reprographics, LLC

Supplement to Petition for Exemption Pursuant to Section 333 January 6, 2016 Page 2

on the ground (including both those individuals involved in the UAS operations and members of the general public) than one involving a full size helicopter or other manned aircraft.

Finally, as stated in the July 14 Petition:

Grant of this Petition and Section 333 Exemption, including waiver of the above-referenced FARs, will permit Carolina Reprographics to operate its sUAS in furtherance of its business opportunities, including video production, photography, and other data-gathering activities. The grant will result in a reduction of risk and concomitant enhancement of safety as compared to the use of manned aircraft (such as a helicopter) for such activities. Unlike manned aircraft, Petitioner’s UAS operations will not use combustible fuel, and Petitioner’s unmanned aircraft are smaller, quieter, lighter, safer, and more cost-effective than manned aircraft employed for similar purposes. Moreover, Petitioner’s sUAS operations will be in controlled airspace, away from people, and in a safe environment. Accordingly, it is believed that such sUAS operations will be at least as safe—and perhaps safer—than manned aircraft operations used for the same purposes.

Carolina Reprographics respectfully reiterates its requests that the FAA grant the July 14 Petition, which has now been pending for nearly 6 months, using the “summary grant” procedure.

Should any questions arise during the course of your consideration of this supplement or the July 14 Petition, kindly contact the undersigned.

Respectfully submitted,

Stephen Hartzell Counsel to Carolina Reprographics, LLC