E agle Digital Imaging, Inc

10 August 2015

U.S. Department of Transportation

Federal Aviation Administration Airmen and Airspace Rules Division 800 Independence Ave., SW Washington, D. C . 2059 1

Re: Additional Information Requested for Docket No FAA

- 2015

- 1591

Dear Sir or Madam:

Pursuant to your letter dated 30 July 2015 and a 6 August 2015 phone conversation with Jesse Schrecengost f

ro m the FAA ’s Airspace and Rules Division, Eagle Digital Imaging (EDI), Inc is pleased to provide the additional inf ormation requested to allow processing of our Section 333 petition for exemption

. We are anxious to receive the exemption and feel confident this additional information will allow us to be in full compliance with the

Rule M aking Procedures as specified in Part 11, Subpart A, Section 11.81. We respectfully request your earliest attention in consider ing this additional information.

1. Introduction

EDI is a remote sensing and analysis company that has safely operated manned aircraft profitably for over a decade providing a broad range of aerial data collection services.

We submitted our original petition for exemption to use Unmanned Aircraft Systems (UAS) on 30 April 2015 (entered o n 14 May 2015)

. EDI is not currently using UASs and petitioned for an e xemption to be allowed to legally operate UASs in the pursuit of improving operational safety, expanding business opportunities and benefitting the public. Our goal was to be legally allowed to a dd on

- demand commercial UAS operations to our existing and fu ture suite of business services

.

Your letter stated t hat our petition (Docket No. FAA

- 2015

- 1591) could not be processed due to the lack of sufficient reasons why granting the request would be in the public

interest. The purpose of this letter is to prov ide those additional reasons and supporting

information to show how our exemption would be in the public interest and benefit the public as a whole

.

2

. Public Interest and How the Public will Benefit

EDI offers high quality imagery acquisition and analy sis services to customers in the forestry, precision agriculture, natural resource and mining industries. Some specific

areas where deploying UASs would provide public benefit are:

 Stockpile volume measurements Power line tower and insulator inspections

 Agricultural crop scouting and precision agriculture

 Forest stand based management

 Non profit environmental organizations

Stockpile Volume Measurements

Traditional stockpile v o lume measur ement s are performed by worker s cl im bing over and around extremely large piles of gravel, sand, rock and reclaimed asphalt in a work

environment that includes numerous types of large earthmoving equipment , huge conveyor systems, rock crushers and trucks. The work is dirty, hot and dangerous and accidents occur regularly ; it is also difficult to obtained accurate measurements the first

time due to the se working conditions

.

The use of UASs would greatly improve worker safety and also increase accuracy thereby decreasing the number of times the measurements need to be ma de (less worker exposure to hazardous conditions)

. Fewer accidents translate to fewer insurance claims helping to keep health care costs under control for all citizens

.

Powerline T ower and I nsulator I nspections

In sp ection of electrical transmission lin e s and their associated hardware is commonly performed us ing manned aircraft, specifically helicopters

, and requires the crew to fly

low and slow over hundreds of miles of powerlines visually inspecting them. The fuel, equipment and labor costs for this method makes the operational costs for th e inspection s extremely expensive.

A downed power line can cause major disruptions to the grid causing hardships to the public when power is cut off suddenly. The use of UASs would provide a less costly

method for performing the inspections allowing the money saved to be used to increase the frequency and thoroughness of inspections. Th e use of UASs would thereby benefi t the public by improving power suppl y uptime and reducing outages

.

Agricultural C rop S coutin g and P recision A griculture

The bene fits to agriculture by the incorporation of U A Ss ’ quick and cost effective information on crop health, yield and pest infiltration has been well studied and documented by numerous organizations including the landmark st udy by the Association for Unmanned Vehicle Systems International ( AUVSI )

.

Providing more consistent and accurate crop yields is just one UAS enabled value

foreseen by fa rmers and crop advisors and this translates directly to the increased public good b y increas ing supply and decreasing food costs

. In addition, UASs with their quiet electric propulsion systems w ould be less intrusive in the rural agricultural environment than manned aircraft, another benefit to the people living there.Forest Stand Based Management

The use of UASs in forest management applications are numerous and include gathering timberland data, mapping of harvested areas, checking on young tree survivability, determining the extent of completing vegetation and monitoring stream buffer compliance along fish bearing streams. Three specific areas where EDI would deploy UASs in forestry and create public good are:

1. Knowing more accurately how much herbicide is needed to control completing vegetation is one area directly benefiting t he public by limiting the amount o f herbicide that gets sprayed to only what is needed. Less herbicide means less of

it gets into rivers and streams which directly impact s local communities’ water supplies.

2. Accurately u nder s tand ing the true wood volume i n a timber stand helps the public know the amount of carbon sequestered there , a vital set of data for evaluating and understanding the impact on forests due to climate change.

3. A thorough mapping o f stream buffers improves management of fish habit

result ing in an improv ement in a fisheries’ survivability . Better managed fisheries

are the key to profitable commercial fishing operations , a consistent supply of fish

for consumers and availability of recreational angler opportunities

.

Non

- Profit Environment al Organizations

EDI provides services at no charge to a number of non profit organizations as a way of supporting good environment stewardship and giving back to the community . Having the ability to use UASs in these applications could provide additiona l information in small areas not currently covered economically with our manned platforms. The public and specifically the local communities in which many of our customers are located benefit

from these non

- p rofits’ work on behalf of the environment. EDI ’s pro bono work with UASs would directly help the non

- profits continue their vital work on behalf of the public good.

3 . Request

EDI respectfully requests that the FAA review the additional information provided in this document and approve Docket No FAA

- 2015

- 1591 allowing Eagle Digital Imaging Inc

to use UASs to improve operational safety, provide public benefit s and expand its business opportunities.

Respectfully,

David J. Shear, President Eagle Digital Imaging, Inc

435 NW 5 th Street, Suite B

Corvall is Oregon 97330

Ph: 541 754 9310 david.shear@eagleimaging.net