Eagle 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. 20591

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 from the FAA’s Airspace and Rules Division, Eagle Digital Imaging 

(EDI), Inc is pleased to provide the additional information 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 Making Procedures as specified in Part 11, Subpart A, Section 11.81. We 

respectfully request your earliest attention in considering 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 on 14 May 2015). EDI is not currently using UASs and 

petitioned for an exemption 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 add on-demand commercial UAS 

operations to our existing and future suite of business services. 

Your letter stated that 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 provide 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 analysis 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 volume measurements are performed by workers climbing 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 these 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 made (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 Tower and Insulator Inspections

Inspection of electrical transmission lines and their associated hardware is commonly 

performed using 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 the inspections

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. The use of UASs would thereby benefit

the public by improving power supply uptime and reducing outages. 

Agricultural Crop Scouting and Precision Agriculture

The benefits to agriculture by the incorporation of UASs’ quick and cost effective 

information on crop health, yield and pest infiltration has been well studied and 

documented by numerous organizations including the landmark study by the Association 

for Unmanned Vehicle Systems International (AUVSI). 

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

foreseen by farmers and crop advisors and this translates directly to the increased public 

good by increasing supply and decreasing food costs. In addition, UASs with their quiet 

electric propulsion systems would 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 the public by limiting the amount of

herbicide that gets sprayed to only what is needed. Less herbicide means less of 

it gets into rivers and streams which directly impacts local communities’ water 

supplies.

2. Accurately understanding the true wood volume in 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 of stream buffers improves management of fish habit 

resulting in an improvement 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 Environmental 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 additional 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-profits’ 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 benefits and expand its 

business opportunities.

Respectfully,

David J. Shear, President

Eagle Digital Imaging, Inc

435 NW 5th Street, Suite B

Corvallis Oregon 97330

Ph: 541 754 9310

david.shear@eagleimaging.net