U.S. Department of Transportation 

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 Farm space 

Systems' request for Unmanned Aerial Systems (UAS) exemption under section 333, we offer 

the following justification to support our request concerning Public Interest: 

We believe the use of a UAS in lieu of a 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 of people 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 of government entities, agriculture, scientific studies, railroad industry, and national 

power industries. Additionally, use of the UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits offarmspace 

Systems' proposed operation of the 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 of nutrients from farm fields in the middle Mississippi River basin by further 

enabling them to provide the right amount of nutrient inputs. A recent report by the USDA's 

Natural Resources Conservation Service (NRCS) documented that managing nutrients has 

reduced runoffs of nitrogen 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 

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research operations to further each of these fields, all of which 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 of way analysis. The UAS may also further enviromnental management by 

mapping deforestation and surveying conservation plots. 

3. The Public Will Benefit From Decreased Congestion Of The 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 of a 

Farmspace System UAS would reduce the amount of tnanned 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 of manned 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 takeoff or land. Likewise, a reduction of manned 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 of flight operations. 

4. The Public Will Benefit From The Safety And Efficiency Of The Farmspace System 

UAS: 

Conducting aerial photography with the UAS, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air 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 of leaded aviation fuel. The UA, while reducing the 

carbon footprint of aerial 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 of flight-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 of approximately 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 of the UAS will allow United 

States based companies, 1 ike Farm space Systems, to remain competitive and contribute to the 

growth of the U.S. economy, by creating jobs for rural America and our military veterans. 

Specifically, with the rising cost of aviation 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 of a traditional manned aircraft. 

By operating the UAS, companies such as Farmspace Systems, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the 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, 

Farm space Systems' proposed operation of the 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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