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

25 March 2015 .'.P~l -- I :~, .o: n s 

Docket Management Facility 

U.S. Department of Transportation 

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 . . . ..... :· . 

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 of ways, 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 20131

, 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 

write the rules to safely integrate UAS into the national airspace by 20152

, a deadline the U.S. Department 

of Transportation Inspector General3 and Government Accountability 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 of small UAS. 

AUVSI recognizes that the 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 

2 https://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 · · · · · · · 

s https://www.faa.gov/regulations_policies/reauthorization/media/PLAW-112publ95[1].pdf 

I ' o • ,: I~ 

·--· - -----------
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 of small UAS7

• On 8 April 2014, AUVSI and 32 other association representing the manned 

aviation community, air traffic 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, not just 

exemptions and rules for operating UAS 55 pounds and under, are finalized. Troublingly, FAA officials 

have publically said that regulations will take at least 16 months after the 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 of the technology. AUVSI looks 

-----forward to 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, 

/Zjj#:.-<---

Brian Wynne 

President & CEO 

AUVSI 

~-- -- --~--- -- ----------- --~ ------- --- -----

6 http://www .auvsi.org/auvsinews/associationnews 

7 http://www .dot.gov /regulations/ report -on-significant -rulema kings 

s http://higherlogicdownload.s3.amazonaws.com/AUVSI/958c920a-7f9b-4ad2-9807- . . 

f9a4e95dlefl/UploadedFiles/Joint%20Letter%20to%20FAA%20on%20Expediting%20UAS%20rulemaklng%20Final.pdf