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 risks

associated 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 individuals
Carolina 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