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 wit h 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 sup port your request.

**I am submitting additional information to assist wi th the request for exception process. If there is a**  **ny additional**

**information Juan C. Melendez D.B.A. Orthotek can pr ovide 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 W ould Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

**Granting the present Petition will further the publ ic interest by allowing Juan C. Melendez DBA Orthot**  **ek to**  **safely, efficiently, and economically perform aeria l imagery acquisition for surveying and mapping pur**  **poses over certain areas of the United States. Additional**  **ly, use of the** 3D Robotics X8+ **sUAV will decrease congestion of the NAS, reduce pollution, and provid**  **e 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, effi cient, and economical alternative**  **to the manned aircraft traditionally utilized to ob tain aerial imagery. By reducing the amount of mann**  **ed 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 N**  **AS, reduce noise and air pollution, as well as incr ease**  **the safety of life and property in the air and on t he ground. Furthermore, by reducing the number of m**  **anned aircraft operating in the NAS, congestion around ai**  **rports caused by arriving and departing aircraft wi ll be** 
**reduced. The** 3D Robotics X8+ **sUAV do not require an airport to takeoff or land. Likew**  **ise, a reduction of manned aircraft conducting aerial photography missi**  **ons would result in fewer aircraft that must be han dled**  **by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight op**  **erations.**



### • 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 leve ls of air and noise pollution generated during trad**  **itional aerial still photography flight operations. By usin**  **g battery power and electric motors, the** 

### 3D Robotics X8+ **sUAV**

**produce no air pollution, and is the most viable e nvironmentally conscious alternative to**  **combustion engine aircraft that are typically utili zed for aerial photography,**  

### 3D Robotics X8+ **sUAV**

**, while reducing the carbon footprint of aerial acqui**  **sitions, also eliminates noise pollution, as the** 

### sUAV **are propelled by battery powered electric motors, rathe**  **r than an internal combustion engine.**

**By using the** 3D Robotics X8+ **sUAV to perform aerial acquisitions, the substantia l risk to life and property**  **in the air and on the ground, which is usually asso ciated with traditional manned aircraft flight oper**  **ations, will be substantially reduced or completely elimina**  **ted. Aside from the lack of flight crew members loc ated**  **onboard the aircraft, the** 3D Robotics X8+ **UA (weighing approximately 7 pounds 7 ounces, at th eir**  **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 collater**  **al damage to life and property on the ground, and i n the air,**  **compared to the manned aircraft that typically cond uct similar operations.** 13460 S.W. 24 St. Miami, FL 33175

TEL: 305-877-9722 • Performing Aerial Photography Operations with 3D Robotics X8+ sUA V Will Benefit The Economy.

**In addition to being safe and efficient, the 3D Rob otics X8+ SUAV also an economical alternative to u**  **sing manned aircraft to conduct similar aerial operation**  **s. Performing these operations with the 3D Robotic s X8+**  **sUAV will help companies like Juan C. Melendez DBA Orthotek to remain competitive and contribute to th**  **e 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**