Paul Alley

12512 SE 72nd Street

Newcastle, WA

98056

Federal Aviation Administration

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12­140 1200

New Jersey Avenue, SE

Washington, DC

20590

Response to 333 Exemption Request Denial

I received a letter informing me that the FAA is unable to process my request for an exemption

from Title 14, Code of Federal Regulations (14 CFR). The letter stated that in order for my

exemption request to be considered further, I must send the following:

● 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

Please consider my responses to these items below:

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

would benefit the public as a whole

The public stands to benefit from this exemption in the following ways:

● Providing public agencies with a lower cost, safer alternative to collecting aerial imagery

used in long term monitoring and and GIS analysis of solid waste facilities (dumps) and

other large capital projects.

● Providing services which allow public stormwater management agencies to improve

monitoring and compliance with the EPA mandated National Pollutant Discharge

Elimination System by providing real­time aerial imagery and impact analysis after large

storm or flood events.

● Providing public agencies with tools to monitor compliance of commercial landowners

and leaseholders on public lands with regards to changes in vegetation (loss) and/or

impervious surface management.
● Aerial imagery subscription services provided to commercial developers would help them

meet and demonstrate pollution and stormwater management “Best Management

Practices” (BMPs) throughout the construction and bonding transfer stage between

private developers and public entities.

● All services, equipment, etc would be available for volunteer (free) use for situations

where aerial imagery and/or mapping could assist with emergency management efforts.

● My services would allow real estate agents and other entities interested in aerial imagery

to seek out a safer, regulated alternative to do­it­yourself hobbyists who may not

consider airspace and other safety related issues, thereby improving airspace safety for

everyone.

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

● As demonstrated by a lifelong professional commitment to public service in the science

and municipal utilities sectors, I am passionate about improving the life of citizens and

the public as a whole. Leveraging my close relationships with regional municipalities

and utility agencies, in addition to my deep industry knowledge surrounding municipal

stormwater and landfill management, I believe strongly that the professional aerial

imaging services covered under this exemption request would improve the ability of

project, land, and municipal managers to meet or exceed legally mandated compliance

and monitoring objectives, while simultaneously minimizing cost and risk to the public.

Several agencies I have met with have expressed a strong interest in utilizing a legal and

regulated contractor to provide mapping and imagery services via UAS.

● Since filing my original petition for exemption, I have completed seminar/course from

Forrester University’s Department of Civil Engineering: “Drones: Revolutionizing Site

Inspections” (certificate attached). This course highlighted research and techniques in

the areas of using GPS enabled UAS for mapping and imaging stormwater management

sites in regular compliance monitoring programs, and post­storm­event documentation

(attached below).