2700 South Quincy Street, Suite 400 • Arlington.VA 22206 • 703.845.9671 • 703.845.9679 fax

25 March 2015**.'.P~l** 

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Docket Management Facility U.S. Department ofTransportation 1200 New Jersey Avenue SE West Building Ground Floor, Room W12-140 Washington, DC 20590

_____**-~ject:** Cor:nments_to_fAA Docke! Numb.er t:AA-2015.-:03n,_Midstream lntegrity.Ser.vices,.LLCJ?etition
____ for Exemption
To whom it may concern, The Association for Unil_1anned Vehicle Systems International (AUVSI), the world's largest non-profit

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### . . ..... :· . organization representing**t~e** unmanned systems industry, with more than 7,000 members worldwide, including 600 corporate members, supports Midstream Integrity Services, LLC's (MIS) exemption petition that would authorize their utilization of unmanned aircraft systems (UAS) for inspections of vertically developed structures, pipelines, right ofways, and provide cost effective aerial imagery services while also inspecting for hydrocarbon gas leaks. Unmanned aircraft systems hold tremendous potential to create jobs, boost local economies, and keep people safe. In a report issued in 2013 1, AUVSI found that the UAS industry is poised to create more than 100,000 new jobs and over $80 billion in economic impact within the first 10 years following the integration of UAS into the national airspace system. In recognition of the growth potential of this new industry, in Feb. 2012, Congress mandated the FAA writethe rules to safely integrate UAS intothe national airspace by 20152, a deadline the U.S. Department ofTransportation InspectorGeneral3 and GovernmentAccountability Office4 have regrettably said will not

----- -- be-met:-Luckily,-Congress had theforesight-to-include-section-333-in-the-FAA.Modernization and Reform. Act (Public Law 112-955) which allows the Secretary of Transportation to determine if certain UAS may operate safely in the airspace before the FAA finalizes rules for widespread commercial use ofsmall UAS. AUVSI recognizes thatthe leadership team at MIS (Mr. Steven Fargo and Mr. Landon Phillips) has a proven track record in aviation with over 4,000 hours combined flight time in fighter and trainer aircraft, instructor pilot certifications, evaluatpr pilot certifications, instrument pilot certifications, commercial pilot certifications, and U.S. Air Force flight safety officer/mishap investigation training. Additionally, AUVSI believes MIS has addressed all the requests a,nd requirements set forth by Section 333 relief guidance and that their request is in line with previously approved relief requests.

1 www.auvsi.org/ecohreport 2https://www.faa.gov/regulations_policies/reauthorization/media/PLAW-112publ95[1].pdf 3**http://www.oig.dot.gov/sites/dot/files/FAA%2~0versigh~_%20of%20,U.nmanned%20Aircraft%20Sy~tem~%SE6-.2~-14_0.pdf** 4 http://www.gao.gov/assets/670/660683.pdf · · · ·· · · shttps://www.faa.gov/regulations_policies/reauthorization/media/PLAW-112publ95[1].pdf

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·- -· - -----------Although AUVSI applauds the FAA's efforts to consider UAS exemption requests6, AUVSI remains concerned the FAA is more than three years late in issuing safety regulations for the wide-spread commercial use ofsmall UAS7• On 8 April 2014, AUVSI and 32 other association representing the manned aviation community, airtraffic controllers, and future users of UAS, including agriculture groups, realtors, media organizations, and public safety organizations, sent a letter to the FAA strongly encouraging them to grant exemptions absent official regulatory rulemaking8

. The commercial UAS industry will not be allowed to fully take off until all necessary regulations, notjust exemptions and rules for operating UAS 55 pounds and under, are finalized. Troublingly, FAA officials have publicallysaid that regulations willtake at least 16 months afterthe relevant public comment periods end before any are finalized. That is simply unacceptable. Accelerating commercial UAS use will not only help businesses harness the tremendous potential of UAS, they will also help unlock the economic impact and job creation potential ofthe technology. AUVSI looks -----forwardto continuing

### t~ work

### ~ith the- FAA

### ~ndothe7stakeholde~to**~su-;:eui\s -;e-hlteg~ated**  safely and responsibly as quickly as possible. The FAA should promptly grant this exemption request, look for ways to allow for more commercial use of UAS immediately, and get on with rulemaking. Respectfully submitted, 

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Brian Wynne President 

### &CEO AUVSI**~--** 

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6 http://www.auvsi.org/auvsinews/associationnews 7http://www.dot.gov /regulations/report-on-significant-rulemakings s http://higherlogicdownload.s3.amazonaws.com/AUVSI/958c920a-7f9b-4ad2-9807-
. . f9a4e95dlefl/UploadedFiles/Joint%20Letter%20to%20FAA%20on%20Expediting%20UAS%20rulemaklng%20Final.pdf