October 2, 2015

FROM: Timmons Group

1001 Boulders Parkway

Suite 300

Richmond, Virginia 23225

TO: Brittany Newton 

Program Analyst 

Airmen and Airspace Rules Division 

This letter is in response to your letter dated September 15, 2015 pertaining to a request for additional 

information. The following information will explain why granting our request for exemption would be in 

the public interest and how it would benefit the public as a whole, and site other exemptions to further 

support our request. 

14 C.F.R Part 11.81 (d) - The reasons why granting the exemption would be in the public interest; that is, 

how it would benefit the public as a whole: 

Using UAS technology to collect photographic/videography data is beneficial to the public as a whole as 

it significantly reduces risks to workers who must scale heights to collect information (risk of fall), it 

reduces risks to the public as a whole due to the reduction of helicopters and small aircraft as the UASs 

carry no combustible materials on board. Battery Powered UASs serve as a safe, efficient and 

economical alternative to manned aircraft traditionally used for capturing aerial images. They provide 

high levels of safety to person and property since no pilot or crew need to be airborne. UASs provide 

greater operational flexibility and reduced costs. Better aerial imagery can be obtained by using UASs 

due to their small size, maneuverability and flight performance characteristics. Less time is needed in 

the air to obtain the footage, thereby reducing the number of aircraft in the NAS. Reduction of noise will 

benefit the public as well. Finally, the UAS industry is expected to grow to $11.5B by 2024 (military and 

civilian), which ultimately will contribute to the US economy by creating jobs and increasing consumer 

spending. 

The use of UASs can significantly reduce the risk to workers of falls while inspecting, surveying, or 

monitoring sites. UASs can inspect, photograph, and collect data on hard to access areas that otherwise 

would require worker inspection. Falls are a leading source of workplace fatality and injury on 

construction sites and reducing falls through UASs use for site imaging could save workers lives. 

Additionally, UASs could replace the use of helicopters and small aircraft to monitor sites. The UASs we 

propose to fly in this application are less than 25 pounds, and carry no combustible material on board, 

as opposed to the much larger conventionally powered small aircraft. Shifting to UASs from helicopters 

presents a marked safety increase for our workers and the public. Lastly, UASs reduce the 

environmental impact by dramatically decreasing the energy used for aerial imaging and data collection 

over a construction site. Our UASs use rechargeable batteries, as opposed to fossil fuels burned in 

operation of small aircraft that are many hundreds of times heavier. 

The operating limitations proposed by Timmons Group provide for at least an equivalent or higher level 

of safety because the operations further enhance the safety of aerial digital imaging over using 
conventional aircraft. In addition to following all instructions as provided by the manufacturer, Timmons 

Group shall include the following conditions and limitations in all operations: 

1) Flights will be operated within line of sight of a pilot and/or observer. 

2) Flights will be terminated at 20% battery power reserve. 

3) Flights will be operated at an altitude of no more than 400ft AGL 

4) Flights will only be operated in reasonably safe environments that are strictly controlled, are 

away from airports, power lines, elevated lights, and/or actively populated areas. 

5) A briefing will be conducted for planned UAS operations prior to each flight. 

6) Consent will be obtained from all persons involved in the operation and only authorized 

personnel will be allowed within 500 feet of the flight operation. 

7) Written permission will be obtained from the relevant property owners. 

8) If the UAS loses communications, the UAS will be placed in "Return to Home" mode and will 

return to its point of takeoff. 

9) The UAS flight will be aborted should circumstances arise that created a potential hazard to 

person or place. 

14 C.F.R Part 11.81 (g) - Any additional information, views, or arguments available to support your 

request.

Reference from similar granted exemptions: 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, 

Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA- 2014- 0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA- 2014-Q642), the FAA found that the enhanced safety 

achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and 

carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, 

carrying crew in addition to flammable fuel, gives the FAA good cause to fmd that the UAS operation 

enabled by this exemption is in the public interest. 

We believe that our petition is similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213. The reasons stated by the FAA for granting Exemption 

Nos. 11062, 11109, 11112, and 11213 also apply to our presented petition and we feel a grant of 

exemption is in the public interest. 

Regards,

Christopher R. Dodson, PWS

Principal, Director of Field Operations