Top View Aerial Photography, LLC

Att: Jose A. Cancel

194 Glenellen Rd.

West Roxbury, MA 02132

Ph: 617-460-9200

Tony.cancel@topview aerialshd.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act.

Dear Sir or Madam:

Granting an exemption for Top View Aerial Photography LLC. to utilize UAS for aerial photography and videography for 

professional, private and for public service activities, including but not limited to real estate, architecture, land survey, 

public events, cinematography, news gathering, search and rescue, and fire safety would provide a great benefit to the 

public. For example, aerial photography for use in real estate marketing has been utilized for several years through the use 

of manned fixed wing aircraft and helicopters. Photography and videography using these means has traditionally been 

cost prohibitive, especially for the small business owner. There are also limitations of terrain and the risks of low altitud e

flying. The use of a UAS is much more affordable to the public and can provide owners an advantage in marketing their 

property. Statistics have shown that properties that market using aerial photography sell at a much faster rate than those 

that do not. Another advantage to using a small UAS as opposed to a larger manned aircraft is public safety. When used 

properly following FAA regulations a small UAS will pose no threat to the public. The use of UAS eliminates the need 

for combustible fuel thus making it safer and it also minimizes ecological damage. The use of a UAS for the sale of 

properties can benefit potential buyers in a variety of ways. It allows encompassing views of the entire property and land, 

views of the neighborhood and surrounding area, including the homes proximity to amenities, views of civic developments 

or local improvement districts that the buyer’s property taxes might contribute to, and be useful for property maps and 

surveys. As you can see, there are many benefits to the use of UAS to the public as a whole.

Another area Top View Aerial Photography would like to utilize UAS is Public Safety. As a 15 year veteran of the Boston 

fire Department I have witnessed many hazardous conditions that would have benefited from the use o f a UAS. For 

example, during large brush fires, in heavily wooded area, many departments rely on other agencies, like The State Police, 

to utilize their Helicopter to gather information which helps put together a strategy to effectively stop the spread of the fire 

and suppress the fire. There are many disadvantages to using this method. One disadvantage is the economic burden to the 

local government to use a helicopter. Another disadvantage is communication. Once the pilot gathers information, he then 

relays it to his dispatch center; the dispatch center then relays the information to a representative at the fire scene who in 

turn relays the information to the commanding officer of the incident. Because of the unpredictability of these types of 

incident, there is a risk of conditions changing before the message arrives to the commanding officer, thus putting 

firefighters in grave danger. The use of UAS has many benefits in these situations. The economic burden to local agencies 

is greatly diminished with the use of a UAS. Furthermore, the use of live video feed ensures that the commanding officer 

would be seeing the changing conditions of the incident as they happen thus being able to revise strategies quickly and 

lessening the risk to firefighters. As with other uses, when used properly following FAA regulations a small UAS will 

pose no threat to the public. The use of UAS eliminates the need for combustible fuel thus making it safer and it also 

minimizes ecological damage.

In summary, the use of UAS would greatly benefit the public as a whole. Some of these benefits include:

 Economic growth, by allowing small business the opportunity to use aerial photography and videography without 

the economic burden of a fixed wing aircraft or helicopter. Businesses can use this technology for innovative 

marketing strategies to expand their reach.

 Environmentally friendly, because the UAS is a battery powered aircraft, there is little impact on the 

environment as compared to an fixed wing aircraft or helicopter which have a considerable carbon footprint.

 Public safety, because our UAS weights less than 10 lbs, the risk to the public or property is very minimal in the 

event of any failure as compared to a fixed wing aircraft or helicopter.
 Public interest, by allowing more businesses to use this technology due to its low cost, will allow those 

businessesto provide more for their customers. As in real estate, potential buyers would benefit from aerial 

images thus allowing them to make an informed decision on their purchase.

 Economic burden, the use of UAS could greatly reduce the economic burden to local governments and private 

parties who depend on the use of this technology.

 Live video feed, in public safety incidents, a live video feed could be instrumental in allowing commanding 

officers to make quick decisions to lessen the risks to public safety officers and the public in general. Fires, 

building collapse, floods, search and rescue, all incidents that could greatly benefit from this technology.

 Aircraft, our UAS are made with the latest technology in the market. Features like “Return to Home” ensure that 

the UAS returns to a safe location in case of signal or battery failure. Furthermore, given that the UAS 

operates at low altitude, it can be brought in for landing in a very short period of time without th e need for a 

runway.

Top View Aerial Photography’s mission is to operate in the safest manner while following all FAA’s regulations. Our goal 

is to bring this technology to more people and educate the public in the safe use of UAS.

Sincerely,

Jose A. Cancel