U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: 333 Exemption for Farmspace Systems LLC---clarification for Public Interest
Dear Sir or Madam : 6 August 2015

In response to your letter received yesterday (dated July 23 , 20 15) concerning Farmspace Systems ' request for Unmanned Aerial Systems (UAS) exemption under section 333 , we offer the followingjustification to support our request concerning Public Interest:

We believe the use ofa UAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact compared to similar operations conducted with a manned aircraft carrying a crew and flammable fuel. Plus, our operations will enhance agricultural production, safely and environmentally friendly, and help feed bil1ons ofpeople throughout the world in the coming years
. 

### The Reasons For Granting Farmspace System's Request Would Be In The Public Interest; How It Would Benefit The Public As A Whole.
Granting the Petition will further the public interest by allowing Farmspace Systems to safely, efficiently, and economically perform aerial images and research within the NAS , commercially, in support ofgovernment entities , agriculture, scientific studies, railroad industry, and national power industries

. Additionally, use ofthe UAS will decrease congestion ofthe NAS , reduce pollution, and provide significant benefits to the economy
. Notably, the benefits offarmspace Systems ' proposed operation ofthe UAS will be realized without causing any privacy issues. l. The Public Will Benefit From UAS In Support OfPrecision Agriculture. Farmspace Systems proposed use of UAS in precision agriculture will help farmers significantly reduce the loss ofnutrients from farm fields in the middle Mississippi River basin by further enabling them to provide the right amount ofnutrient inputs. A recent report by the USDA's Natural Resources Conservation Service (NRCS) documented that managing nutrients has reduced runoffs ofnitrogen by 21 percent and phosphorous by 52 percent. UAS will provide additional means to continue this progress improving drinking water and contributing to sustainable agriculture.


### 2. The Public Will Benefit From the Aerial Acquisition And Research Performed. Farmspace Systems submits the request for commercial UAS operations, in support of government entities, agriculture, scientific studies, mining, and industry (e.g. , railroad, gas, and oil industries)

. The UAS will provide safe, efficient, and economical aerial photography and



### 1research operations to further each ofthese fields , all ofwhich are critical to the well-being of the general public

. The specific operations that Farmspace Systems will perform with the UAS demonstrate how the requested exemption will directly benefit the above-referenced industries and the public

. In the referenced industries, the UAS will be used to: aid in crop health monitoring, infrastructure inspections ; surveying, damage assessment cause by storms, natural disasters , and accidents; and perform right ofway analysis. The UAS may also further enviromnental management by mapping deforestation and surveying conservation plots

. 3. The Public Will Benefit From Decreased Congestion OfThe NAS. The UAS is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial inspections, an exemption allowing the use ofa Farmspace System UAS would reduce the amount oftnanned aircraft in the NAS , reduce noise and air pollution, and increase the safety of life and property in the air and on the ground.
Furthermore by reducing the number ofmanned aircraft operating in the NAS , congestion around airports caused by arriving and departing aircraft will be reduced. The UAS does not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial survey missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff , departure, arrival, and landing phases offlight operations

. 4. The Public Will Benefit From The Safety And Efficiency OfThe Farmspace System UAS: Conducting aerial photography with the UAS , instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial survey flight operations

. By using battery power and electric motors, the UAS produce no air pollution, and is the most viable environmentally conscious alternative to the traditional internal combustion engine aircraft that are typically utilized for aerial acquisitions , and bum approximately 20-30 gallons per hour ofleaded aviation fuel. The UA, while reducing the carbon footprint ofaerial photography, also reduces noise pollution, as the UA is propelled by battery powered electric motors, rather than an internal combustion engine

. By using the UAS to perform aerial inspections, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight-crew members located onboard the aircraft, the UA' s (weighing from 3.0

- 15.0 pounds at their maximum gross weight; measuring approximately 10

- 70 inches

**diagonally~** and carrying no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial inspections (weighing approximately 6,500 pounds with a wingspan ofapproximately 40 feet, a length of34 feet, and a fuel capacity of 180 gallons).



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### 5. Performing Aerial Inspections Operations With The UAS Will Benefit The Economy. In addition to being safe and efficient, the UAS are also an economical alternative to using manned aircraft to conduct aerial photography. As such, operation ofthe UAS will allow United States based companies, 1 ike Farmspace Systems, to remain competitive and contribute to the growth ofthe U.S. economy, by creatingjobs for rural America and our military veterans. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels , U

.S

. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the UAS , companies such as Farmspace Systems, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S

. economy. Improved financial performance ofU

.S. companies, through commercial use ofthe UAS , provides a stable workforce that increases consumer spending; improves local , state, and federal tax revenues ; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.


### 6. There Are No Privacy Issues. Similar to the manned aerial inspection flight operations that have been conducted for decades, Farmspace Systems ' proposed operation ofthe UAS wi11 not implicate any privacy issues

. Specifically, UAS will only be operated pursuant to the specific established conditions and limitations set forth , and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C

.F

.R

. 

### § 91.119.

Derick E. Seaton VP-Aviation Operations Farmspace Systems LLC P.O. Box 307 Alamo, TN 38001 Cell 731-727-7021 Email: Derick.Seaton@ FarmspaceSystems.com Website: http://www.farmspacesystems.com

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