2844 PABLO AVENUE -IIIINCG TALLAHASSEE, FL 32308 

P:850.385.1179 

NOBLES CONSULTING.GROUP,INC F:850.385.1404 

July 23, 2015 

U.S. Department of Transportation 

Docket Management System 

West Building — Ground Floor, Room W 12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Regarding: FAA Docket Number 2015-1510-002 Notice of Request for Additional Information 

Dear Madam or Sir, 

We are in receipt of your request for additional information and seek to continue review of our 

exemption request. In response to your request for additional information it has been noted that 

in order for our application to be considered further we must submit the following: 

"The reasons why granting the request would be in the public interest: that is, how it would 

benefit the public as a whole." 

and 

"Any additional information, views, or arguments available to support your request." 

In response to your request for additional information we provide the following: 

The use of UAS for the proposed operations will provide significant public benefit, including 

reduction of environmental impacts such as reduced emissions associated with UAS use for 

aerial data collection as opposed to normal full sized rotary or fixed wing aircraft. Also the use 

of UAS for the proposed operations can reduced the time of aircraft exposure in the NAS. The 

aircraft selected is battery operated, can take off and land vertically and use will be confined to 

the area of operation instead of having to travel from another location. Also, since the proposed 

UAS is battery powered and carries no fuel reducing risk of fire of fuel spillage or in the event of 

a mishap thus benefitting public safety. 

Additionally, NCG is seeking exemption from pilot certification requirements to utilize UAS 

commercially, NCG's exemption request specifically states that any NCG Pilot in Command 

PENSACOLA NICEVILLE CHIPLEY TALLAHASSEE VALDOSTA 
(PIC) will be required to participate in and satisfactorily complete in a UAS Based ground school 

with a focus on FAA flight regufation and requirements, and participate in appropriate UAS flight 

training in accordance with aircraft manufacturer requirements. For security purposes, NCG 

has provided that any NCG PIC will have to undergo and clear a background check thorough 

enough to obtain a Transportation Worker ldentification Credential (TWIC) card. Although, this 

is not in keeping with how recent exemptions have been issued, the level of safety provided will 

be equivalent to those that have been previously granted Section 333 exemptions and is in the 

public interest and will benefit the public in that the operator will be trained. The requirement 

that the PIC must have pilot certification is not a guarantee that the UAS will be operated in a 

safe manner. For many certified pilots, being a PIC for a UAS is outside of their core 

competency and training is still required. The only difference is that the certified pilot has actual 

in the air flight time and has undergone training for operating in the NAS. This is why NCG 

provides that any PIC is required to have formal training on flight regulation, and flight training 

with the proposed airframe. NCG's approach is inherently more safe than the average uncredentialed hobbyist flying unregistered aircraft in the NAS without any formal training 

regarding FAA rules and regulations. Although we don't like to think about it, this is an all too 

often occurring scenario since the advent of the "off the shelf' easily flown UAV's. Additionally, 

there are companies that are currently providing commercial UAV services that have not gone 

through the exemption request process that are gaining a competitive edge on those of us that 

are compelled to follow the rules. 

I hope this is the information that you are seeking from us. 

If you have any further questions or need any additional information please contact us as soon 

as possible. 

Sincerely, 

~ 

David Mason 

Project Manager 

Nobles Consulting Group