THE VREELAND INSTITUTE

17 Aug 2015

Ms. Brittany Newman, Manager

Airmen and Aerospace Rules Division

Federal Aviation Administration

800 Independence Avenue, S.W.

Washington, D.C. 20591

Dear Ms. Newman:

I am writing in response to your letter of 30 July 2015, regarding

our 333 Exemption request, public docket No. FAA-2015-1719. As

requested, the additional information you identified is attached,

and is being submitted as a comment to the public docket filing.

This information pertains to the reasons why granting our request

would be in the public interest.

Thank you in advance for your consideration of our Section 333

Exemption request, including this additional information.

Sincerely,

Thomas S. Vreeland

Director

529 County Route 7A, Copake NY 12516 ~ 518 620-6380 - info@vreelandinstitute.org
17 August 2015

Public Docket No. FAA-2015-1719

ADDITIONAL INFORMATION:

PUBLIC INTEREST: The reasons why granting the petition would be In the public interest;

that is, how it would benefit the public as a whole:

1. The Congress of the United States has determined that early accommodation of sUAS into

the National Airspace System advances the public interest. The Committee Report leading the

House to adopt H.R. 658 said: "The successful integration of unmanned aircraft systems

(UAS) into the National Airspace System (NAS) can support more than 23,000 high-paying

jobs in the United States. . . . The absence of a plan to integrate UASs into the NAS is a

barrier to such job creation . . . ." Granting the Petition represents a step toward such

integration, in the absence of a comprehensive regulatory regime for sUAS, and thus would

serve the Congressional goal and the public interest.

2. Granting the Petition will facilitate a new era in emergency response and disaster relief

activities, one in which the responders themselves have a tool to safely, quickly and remotely

assess a situation without placing lives in harm’s way. Likewise, explosive ordinance disposal

(EOD) robots have saved countless lives since their inception, an accomplishment that will

become commonplace for aerial assessments as well.

3. Granting the Petition will enable the use of sUAS to improve public safety and reduce risk

by alleviating the public's exposure to danger and emissions associated with conventional

aerial methods (full size aircraft) that are very heavy, fast and carry passengers, flammable

fuel and cargo.

4. Granting the Petition will enable Petitioner to demonstrate the commercial viability of

creating new safety techniques and tactics with new aeronautical technologies, thereby

improving the efficiency of emergency responders and disaster relief personnel and making

for a safer society.

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation

technologies advances the public interest. The FAA itself has recognized the public interest in

its role of "Encouraging and developing civil aeronautics, including new aviation technology."

Granting the Petition will enhance FAA fulfillment of that commitment, thereby serving the

public interest. Air commerce flourishes in the United States because of the rapid pace of

innovation in aeronautical and associated technologies, followed by their commercialization

and their introduction into the marketplace. The sUAS technology that the Petitioner uses

exemplifies the latest innovative leap forward in aeronautical technology. Preventing it from

using this in air commerce subverts achievement of the goal.

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS

technology into the NAS serves the public interest. Section 330 of the FAA Modernization and

Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from

the deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the

availability of these technologies in the National Airspace System, thereby representing a

congressional determination that the public interest is served by making these technologies

more widely available at the earliest practicable date. The Petition represents a way for the

FAA to move incrementally, while still satisfying its congressional mandate and meeting its

obligation to enhance the public interest by making new technologies available by allowing the

use of sUAS technologies in a manner that protects the public and the rest of the aviation

community from significant risk. The commercial activities by Petitioner proposed in this

Petition represent contributions to new forms of air commerce, thereby fulfilling the FAA’s

statutory mandate under the 2012 Act.
7. Granting the Petition will enhance aviation safety, thereby advancing the public interest.

The requested exemption would permit the operation of SUAV under controlled conditions in

airspace that is 1) limited 2) predetermined; and 3) controlled as to access. The Petitioner has

committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in

the National Airspace System and to persons and property on the ground. Granting the

Petition will enable the Petitioner to be a role model and an exemplar for safe commercial

sUAS operations.

8. Granting the Petition will provide immediate employment opportunities for individuals and

businesses whose livelihood may be directly or indirectly improved through career

opportunities and job creation in a growing technology sector of the economy.

The petitioner asserts that the requested exemptions would result in a major increase in safety,

minimization of public resources/funding and contribution to economic growth, all of which

which would be in the public interest.