Bruce Barton

T: +15706883181

director@rescueinternational.org

July 10 2015

u.s. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 

CPR 61.113 (a) & (b); 91.7 (a); 91.9(b) (2); 91.103 (b); 91.109; 91.119; 

91.121; 91.151 (a); 91.203(a) & (b); 91.407(a) 0); 91.409 (a) (2); 91.417 

(a) & Cb) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. 

Part 11, Rescue International, developer, educator and operator of small Unmanned Aircraft Systems 

("UAS") equipped to conduct aerial Search and Rescue Operations in the US have seen higher success rates 

on (SAR) operations and help prevent contamination of lands if there was a manned aircraft accident, hereby 

applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial/public 

safety flights of UASs, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of small 

Unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe 

operations in SAR missions presently using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to

establish requirements for the safe operation of such aircraft systems in the national airspace system."

RI will be working to promote safe use of UAS for public safety and specific Search and Rescue 

applications thru the development of training materials and training classes for UAS pilots, Observers and 

flight support staff. As the current FAA pilot certifications are too restrictive for UAS operations with 

many requirements like, actual manned flight hours including cross country flights, that have very little 

application to safe UAS operations, RI asks that a PIC exception for public safety operations, as current PIC 

certifications were not intended for UAS operations and place an unreasonable burden on the development 

and deployment of public safety, lifesaving use of UAS, this being in the best interest of the public be made

till FAA rules for UAS operations are developed. We request an exception to PIC rules or issuance of a 

special temporary certification for PS UAS PIC operations to allow Public Safety flight and educational 

development and legal and safe deployment of UAS for life saving rescue and recovery use. We request that 

this application be expedited by the FAA to all extent possible as its approval is in the public’s best interest.

The name and address of the applicant is: 

Rescue International, Inc

Attn: Bruce Barton, Director of Operations

Ph: 570-688-3181

Email:

director@rescueinternational.org

Address: Po Box 544

Delaware Water Gap

PA 18360
The conditions proposed by the applicant are drawn in part from order 8900.1 CHG 0 & 

exemption 11282

Regulations from which the exemption is required 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a)(l) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’s goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rule making required under Section 332 of the Reform Act. In making this determination, 

the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the following: 

 The UASs size, weight, speed, and operational capability 

 Operation of the UAS in close proximity to airports and populated areas; and 

 Operation of the UAS within visual line of sight of the operator. 

Reform Act Section 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in 

the national airspace system." ID Section 333( c) (emphasis added) 

The Federal Aviation Act expressively grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is defined under section 

40101 of the Act, that includes UAS’s, from the requirement that civil aircraft must have a current 

airworthiness certificate. 

Applicant interprets this provision to place the duty on the Administrator not only process 

applicants for exemptions under section 333, but for the administrator to craft conditions for the safe 

operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval. 

2 
The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if

the Administrator finds the exemption in the public interest. 49 U.S.C. Section 44701(f) see 

also 49 USC Section 44711(a); 49 USC Section 44704; 14 CFR Section 91.203 (a) (1). 

Rescue International, Inc. , UASs are rotorcraft, and fixed wing UASs weighing 55 or fewer or 

lbs. including payload. They operate, under normal conditions at a speed of no more than 70 

knots and in the case of our multirotors, they will have a capability to hover, and move in the 

vertical and horizontal plane simultaneously. They will operate in a line of sight and will 

operate only within search areas determined to be save and these areas are mostly made up of 

farm land, rural lands, bodies of water and water ways. Rescue device deliveries will be limited 

to short line of sight delivers of rescue devices and rescue lines by trained 1st responders under 

rescue mission deployments and following written procedures and guidelines.

Given the small size of the UAS’s involved and restricted operational environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial and public safety operations of UAS’s to commence immediately. Also due 

to the size of the UAS’s and the restricted areas in which the relevant UASs will operate, 

approval of the application presents no national security issue. Given the clear direction in 

Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced public safety, reduction in environmental 

impacts, including reduced emissions and chemical spills, exemptions now associated with 

allowing UASs for agricultural operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. As we are in active tornado season and face an active

upcoming hurricane season were RI can deploy this resource to assist in SAR and disaster 

rescue and recovery operations with the use of SAR UAS from RI chapters in the USA.
AIRCRAFT AND EQUIAVLENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to aircraft that have the 

characteristics and that operate within the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe, law enforcement 

and public safety air response resources currently being used with conventional aircraft. 

1. The UASs will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and observer and they will at all times be 

able to communicate by voice

3. Maximum total flight time for each operational flight will be 30 minutes for multirotor 

application and 60 minutes for fixed wing operation. Flights will be terminated at a 15% battery 

power reserve should that occur prior to the manufacturer recommended limit for safe return. 

4. Flights will be operated at an altitude of no more than 200 feet AGL. Meeting the March 2015 

blanket COA requirement for flights no higher than 200 feet AGL

5. Minimum crew for each operation will consist of the UAS Pilot (UAS rated PIC), and Trained 

Visual Observer. 

6. UAS Pilot will be certified as a UAS pilot by taking an approved class developed and 

administered by Rescue International Training Academy (RITA) including a written test

covering UAS flight operations, FAA required manuals, SOPs and Logs, FAA rules, Emergency 

Procedures, Operational Safety, Airspace requirements and restrictions, maintaining the UAS, 

FAA reporting requirements., a class of 20 hours of instruction and 8 hours of group hands on 

flight training with a UAS rated PIC, plus pre-class 10 hrs. of logged RCC or UAS SAR formal 

flight training, No medical certificate is required. A government driver’s license is required. 

7. A RITA certified or equivalent trained and tested UAS Pilot, will be pilot in command (PIC). Or 

other required FAA certificate as may be required by final ruling.

8. The UAS will only operate within a confirmed "safe area" and have a "Security Perimeter" for 

the aerial search flight operation area. UASs are covered by 1 million dollar liability policy

9. A briefing will be conducted in regard to the planned UAS operations prior to each search flight 

with staff assisting with flight operations. It will be mandatory that all personal who will be 

performing duties within boundaries of the safety perimeter be present for this briefing. 

10. The operator will not need a FAA Form 7711-1 filed or its equivalent, as modified in light of the 

requested exemptions covering this action, as applicant will not engage in Movie or TV 

production activities. The FAA Blanket 200 Ft. COA as issued will be followed for all aerial 

search flights for lost or missing person.

11. The operator will obtain the consent of all persons involved in the launch area and ensure that 

only consenting persons be allowed within 100 feet of the flight operation home point

12. The operator or agency staff will during an emergency flight conditions make a Plan of 

Activities to the FSDO 30 minutes before the proposed search flights if the operator needs to 

request a reduction of the 100 foot distance to a lower range.

13. Pilot and observer will have been trained in the operation of the UAS technical functionality and 

received up-to-date information on the particular UAS is use. PIC shall have the. Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual

14. Aerial search operations will be launched from and with written/or oral permission from the 

relevant property holders will be obtained were required. 

15. If the UAS losses communications with PIC’s flight controller, the UAS will have capability to 

return to a pre-determined home location within the Security Perimeter and land. 

16. The UAS will have advance flight capabilities to abort flight in case of unpredictable 

emergencies, encroachment on limitations to airports or loss of pilot’s data link or active control.

17. The UAS shall be marked by exception to 45.29 (f) with the markings of “RESCUE” in a 

noticeable manor and/ size and/or display a N number as may be required by the FAA

18. UASs to be used under this ruling are DJI Phantom 2 Plus, Phantom Three (3) and DJI Inspire 

series airframes and systems.
14 C.F.R. Part 21, Subpart H: Airworthiness certificates 14 C.F.R. Section 91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR Section 91.203 (a) (1). Given the size and 

limited operating area associated with aircraft to be utilized by the Applicant, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, proximity to airports 

and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the 

UAS operated without an airworthiness certificate, in a restricted environment and under the conditions 

proposed will be at least as safe, or safer, than conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the retractions and conditions proposed. 

The UAS to be operated here under, is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials, flammable materials or liquid fuels, and operates exclusively 

within a secured launch area as set out in manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and pursuant to the 

requirements, and in compliance to local public safety requirements, to provide security of the area of 

operation as is now done with conventional aircraft support to SAR missions. The FAA will have 

advance notice of required operations. These safety enhancements, which already apply to civil aircraft 

operated in connection to SAR and public safety operations , provide a greater degree of safety to public 

and property owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is 

no credible threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels and inability to carry a substantial 

external load. 

14 C.F.R. Section 45.23 (b). Marking of the aircraft 

The regulation requires: 

When marks include only the Roman capital letter ''N'' and the registration of the 

number is displayed on limited, restricted or in a light-sport category aircraft or 

experimental or provisionally certified aircraft, the operator must also display on the 

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words “limited," “restricted," "light spot," 

"experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, and exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "experimental" 

can be placed. Given the size of the UAS, the two inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on it’s fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAV will see the 

identification of the UAV as "Experimental." Or if approved by this ruling the use of “RESCUE” as 

acceptable markings for the UASs under this exemption. This marking is in the best public interest as it 

provides a quick visual identification as to the public safety use of the UAV. A FAA N number will be 

displayed as required in the largest reasonable manner possible, as/if required by the FAA ruling.

The FAA has issued similar exemptions to this regulation by Exemptions Nos. 10700, 8738, 

10167A. 
14 C.F.R. § 61.113 (a) & (b): Private pilots Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have formal UAS training class of 20 hours and 

more than 10 logged flight hours of operation done under private use RCC rules of operation of small 

UAS or by hours of supervised training under this exception by a qualified RITA or equivalent UAS 

rated pilot.. Unlike a conventional aircraft that carries a pilot and passengers, the UAS is remotely 

controlled with no living thing onboard. The area of operation is controlled and restricted, and all flights 

are planned and coordinated in advance as set forth by in the S.O.P. The level of safety provided by the 

requirements included in the S.O.P exceeds that provided by a single individual holding a commercial 

pilot's certificate operating a conventional aircraft. The risks associated with the operation of the UAS 

are so diminished from the level of risk associated with the operation of a commercial operations 

contemplated with Part 61 when drafted, we request a exception from 61.113 allowing operations of the

UAS as requested with a formally trained UAS pilot as the PIC, this we believe meets or exceeds the 

present level of safety achieved by 14 C.F.R. §61,113 (a) & (b). for UAS flights and is in the publics best 

intrest. 

14 C.F.R. §91.7 (a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthiness 

condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft and the requirements contained in the SOP for maintenance and use of safety check lists prior to 

each flight an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

Section 91.9 (b) (2) provides: 

No person may operate a US-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placard, or any 

combination thereof. 

The UAS, given its size and configuration has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot onboard, but because there is no room or capacity to carry 

such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the UAS will have access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10602,32827, and 10700. 

6 
14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure 

the safety of the flight. As the FAA approved rotor craft flight manuals will not be provided as set 

forth in sections the SOP. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

UASs and remotely controlled aircraft, by their design do not have fully functioning dual 

controls. Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functioning dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See exemption Nos.5778K & 9862A. The equivalent level of safety provided by that neither 

a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operations of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As 

exemption is for the UAS that is a helicopter and the exemption requests authority to operate at 

altitudes of up to 200 feet AGL for rotorcraft and fixed-wing, or not more than 200 feet above an 

elevated platform such as radio towers, an exemption may be needed to allow such operations. As set 

forth by herein, except for the limited conditions stated in the SOP, the UAS will never operate 

higher than 200 AGL for rotorcraft and 200 AGL for fixed-wing per the FAA March 2015 Blanket 

COA for flights up to 200 feet. UASs will however be operated in a restricted area with a security 

perimeter, where buildings and people will not be directly exposed to operations without their 

pre-obtained consent for routine flight operations and an exemption shall be implied by persons in 

need of rescue were a UAS will be deployed for location of persons at risk and delivery of rescue 

lines or devices to be used to save a life of persons at risk of injuries or loss of life.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice if required to the property owner and 

participants in the activity, all affected individuals will be aware of the planned flight operations as 

set forth in the SOP. An exemption shall be implied by persons in need of rescue were a UAS will 

be deployed for delivery of rescue lines or devices to be used to save a life of persons at risk of 

injuries or loss of life. State laws as to rights of public safety 1st responders shall apply as to access to 

private property during emergency responses and rescue operations. Compared to flight operations 

with aircraft or rotorcraft weighing far more than the maximum 551bs. proposed herein and the lack 

of flammable fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these small UAS 'operations and the operations 

of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." As the UAS may not have a barometric altimeter, but instead a 

GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by

the operator, pursuant to the launch and Safety Check list, confirming the altitude of the launch site w
4 C.F.R. §91.1S1

(a): Fuel Requirements for Flight in VFR l Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and assuming normal cruising speed - (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the UAS provides approximately 35 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CPR §91.151, UAS flights would be limited to 

approximately 5 minutes in length. Given the limitations on the UAS's proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

compliance with FAR 91.15l(a)). Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed or 

person in need of rescue display an implied consent to being rescued by the 1st responders and a 

UAS, with less than 30 minutes of reserve fuel, does not engender the type of risk that Section 

91.151(a) was intended to alleviate given the size speed of the small UAS. Additionally, limiting 

UAS flights to 5 minutes would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 

15% of battery power whichever happens first. This restriction would be more than adequate to 

return the UAS to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673 and 10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it 

has within it the following: 

 (1) An appropriate and current airworthiness certificate 

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the 

cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. 

As such, there is no ability or place to carry certification and registration documents or 

display them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the UAS will have immediate access to them, to 

the extent they are applicable to the UAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exemptions includes. Exemption Nos. 

9565,9665,9789, 9789A, 9797,9816A, 10700. 

14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & (b) 

These regulations require that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, except 

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter," and others shall inspect or maintain the aircraft in compliance with part 43. 
Given that this section and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the application. Maintenance will be accomplished by

the operator pursuant to the flight manual and operating handbook as referenced in the Manual. 

An equivalent level of safety will be achieved because these small UAS’s are very limited in 

size and will carry a small payload and operate only in restricted areas or temporary areas of 

emergency response to an unplanned event for limited periods of time. If mechanical issues arise 

the UAS can land immediately and will be operating from no higher than 200 feet AGL 

rotorcraft and 200 feet AGL for fixed-wing. As provided in the SOP, the operator will ensure 

that the UAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance preformed. Moreover, the operator is the person most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

Pursuant to 14 C.F.R Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. §§ 61.113 (a) & (b); 

91.7 (a); 91.9 (b) (2);91.103 (b); 91.109; 91.119;91.121;91.151 (a); 91.203 (a) and (b); 91.405 

(a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (551bs or less) in the Agricultural 3d Mapping Service Operations. 

Approval of exemptions allowing commercial operations of UAS’s in the Agricultural 

3D mapping/scanning and tower inspection industry will enhance safety by reducing risk. 

Conventional operations using jet or piston aircraft, operate at extremely low altitudes just feet 

from the equipment and livestock and structures; and present the risks associated with vehicles 

that weigh in the neighborhood of 3,000-5,000 lbs., carrying large amounts of Jet A or other fuel 

in most cases helicopters operating with 140 gallon fuel tanks. The UAS will carry no

passengers or crew and therefore, will not expose them to the risks associated with manned 

aircraft flights. 

The operations of small UAS’s, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

Part 21 and allowing commercial operations. These lightweight UAS’s operate at slow speeds, 

close to the ground and in sterile environment and as a result, are far safer than conventional 

operations conducted with a piston and or turbine aircraft operating close to the ground. 

Public Acknowledgement/Privacy 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012,-'size, 

weight, speed, operating capabilities, proximity to populated areas and or close proximity to 

airports and operations within visual line of sight provides more than adequate justification 

for the grant of the requested exemptions allowing public safety/commercial operation of 

applicant's UAS.

Sincerely

Bruce Barton

Director of Operations, CEO, Rescue International Inc.

cc: Board Members 
19.