13460 S.W. 24 St. Miami, FL 33175 

TEL: 305-877-9722 

August 29, 2015 

Ms. Brittany Newton 

Program Analyst, Airmen and Airspace Rules Division. 

800 Independence Ave. S.W. 

Washington D.C. 20591 

Dear Ms. Newton: 

In response to the letter I received and dated July 31, 2015, requesting additional information to proceed with my 

request for exception form Part 21 §§ 45.23(b), 61.113(a) and (b), 61.3 , 91.7(a), 91.9(b)(2), 91.103 , 91.109, 

91.119, 91.121 , 9l.15l(a), 9l.203(a) and (b), 91.205, 91.215, 91.405, 91.407(a), 91.409(a)(l) and (2), and 91.417(a) 

and (b) of Title 14, Code of Federal Regulations (14 CFR). Requesting the following additional information:

• The reasons why granting the request would be in the public interest; that is, how it would benefit 

the public as a whole. 

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

I am submitting additional information to assist with the request for exception process. If there is any additional 

information Juan C. Melendez D.B.A. Orthotek can provide to expedite this request, please let us know. Thank you 

for your time and consideration in regards to this matter. 

Best regards. 

Juan C. Melendez DBA Orthotek 

Juan C. Melendez 

13460 S.W. 24 St. 

Miami, FL 33175 

TEL: 305-877-9722 

orthotek@otwkmap.com 
13460 S.W. 24 St. Miami, FL 33175 

TEL: 305-877-9722 

• The Reasons Why Granting Juan C. Melendez DBA Orthotek Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Juan C. Melendez DBA Orthotek to 

safely, efficiently, and economically perform aerial imagery acquisition for surveying and mapping purposes 

over certain areas of the United States. Additionally, use of the 3D Robotics X8+ sUAV will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the

benefits of Juan C. Melendez DBA Orthotek proposed operation of the 3D Robotics X8+ sUAV will be 

realized without implicating any privacy issues. 

• The Public Will Benefit From Decreased Congestion Of The NAS. 

The 3D Robotics X8+ sUAV are battery powered and serve 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 acquisitions, an exemption allowing the use of a 3D Robotics X8+ sUAV 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 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 3D Robotics X8+ sUAV do not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial photography 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. 

• The Public Will Benefit From The Safety And Efficiency Of The 3D Robotics X8+ SUAV.

Conducting aerial acquisitions with the 3D Robotics X8+ sUAV, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional 

aerial still photography flight operations. By using battery power and electric motors, the 3D Robotics 

X8+ sUAV produce no air pollution, and is the most viable environmentally conscious alternative to 

combustion engine aircraft that are typically utilized for aerial photography, 3D Robotics X8+ sUAV, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the sUAV are 

propelled by battery powered electric motors, rather than an internal combustion engine. 

By using the 3D Robotics X8+ sUAV to perform aerial acquisitions, 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 3D Robotics X8+ UA (weighing approximately 7 pounds 7 ounces, at their 

maximum gross weights with lengths of 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm), and with 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 similar operations. 
13460 S.W. 24 St. Miami, FL 33175 

TEL: 305-877-9722 

• Performing Aerial Photography Operations with 3D Robotics X8+ sUAV Will Benefit The Economy. 

In addition to being safe and efficient, the 3D Robotics X8+ SUAV also an economical alternative to using 

manned aircraft to conduct similar aerial operations. Performing these operations with the 3D Robotics X8+ 

sUAV will help companies like Juan C. Melendez DBA Orthotek to remain competitive and contribute to the 

growth of the U.S. economy. 

Submitted on August 29, 2015

Juan C. Melendez DBA Orthotek 

Juan C. Melendez

13460 S.W. 24 St. 

Miami, FL 33175 

TEL: 305-877-9722 

orthotek@otwkmap.com