ASSOCIATION FOR UNMANNED VEHICLE SYSTEMS INTERNATIONAL
22 September 2014
Docket Management Facility 2700 South Quincy Street, Suite 400 • Arlington,VA 22206 • 703.845.9671 • 703.845.9679 fax

U.S. Department ofTransportation 1200 New Jersey Avenue SE West Building Ground Floor, Room W12-140 Washington, DC 20590
Subject: Comments to FAA Docket Number FAA-2014-0727, SenseFiy Petition for Exemption
To whom it may concern, The Association for Unmanned Vehicle Systems International {AUVSI), the world's largest non-profit organization representing the unmanned systems industry, with more than 7,000 members worldwide, including 600 corporate**members~·** supports SenseFly's 'exemption petition ·that would authorize commercial operations'usirigthe eBee for mapping applicationsthat may include agriculture applications, mining, construction and survey/GIS operations and urges the FAA to grant their request immediately. Furthermore,the 'eBee is an ultra-light UAV platform made of flexible foam. with no sharp edge characterized 

# by a high level of pre-programmed control and various built-in technical capabilities (pr'ogramliling of a geocfence, automatic wind detection) that limit the potential for operation outside of the operatihgconditions. Moreover, the kinetic energy ofthe aircraft in-flight is 38 Joules ("J") in case of acontrolled emergency landing. In comparison, the kinetic energy ofafootball is about 110

### Jwhen thrown by hand. ..l Unmariried Aircraft Sysfems have been successfully and safely operated in Japan, Australia, and South Korea for more than 20 years, which have logged more than 2 million flight hours, without anyone being injured. In Japan alone, UAS treats more than 2.4 million acres offarmland each year. Because manned "agriculture pilots are at increased risk for fatal injury compared with pilots in all other industries"\ the use of an unmanned aircraft systems {UAS) for agriculture will save time, money, and most importantly; lives, by notjeopardizing a human in an aircraft. Unmanned aircraft systems hold tremendous potential to create jobs, boost local economies, and keep people safe. In a report issued last year2, AUVSI found that the UAS industry is poised to create more than 100,000 new jobs and over $80 billion in·economic impact within the first 10 years following the integration of UAS into the national airspace system. Eighty percent ofthefuture commercial UAS market will be in precision agriculture, including remote sensing. Therefore, there is a compelling need for the FAA to expedite the commercial use of UAS. In recognition ofthe growth potential ofthis new industry, in Feb. 2012, Congress mandated the FAA write the rules to safely integrate UAS into the national airspace by20153
, a deadline the U.S. Department

1 http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5315a4.htm 2 www.auvsi.org/econreport 3 https://www.faa.gov/regulations_policies/reauthorization/media/PLAW-112publ95[1].pdfofTransportation InspectorGeneral4 and GovernmentAccountability Office5 have regrettably said will not be met. Luckily, Congress had the foresight to include section 333 in the FAA Modernization and Reform Act (Public Law 112-956) which allows the Secretary of Transportation to determine if certain UAS may operate safely in the airspace before the FAA finalizes rules for widespread commercial use of small UAS. In the opinion of AUVSI, SenseFiy has a deep and well-known experience in terms of safe integration of remote controlled aircrafts in the national airspace system for low-altitude operations and their exemption outlines at least an equivalent level ofsafety over the use of a manned aircraft and they have adequately addressed the safety requirements in a number offederal aviation regulations7

. Although AUVSI applauds the FAA's efforts to consider UAS exemption requests8
, AUVSI remains concerned the FAA is more than three years late in issuing safety regulations for the wide-spread commercial use ofsmall UAS9

. On 8 April 2014, AUVSI and 32 other association representing the manned aviation community, airtraffic controllers, and future users of UAS, including agriculture groups, realtors, media organizations, and public safety organizations, sent a letter to the FAA strongly encouraging them to grant exemptions butto also expedite the public notice and comment for small UAS rulemaking 10

. The FAA expects to release its notice of proposed rulemaking for small UAS in November11 • The commercial UAS industry will not be allowed to fully take off until regulations, notjust exemptions, are finalized. Troublingly, FAA officials have publically said the regulations will take at least 16 months afterthe public comment period ends before it is finalized. That is simply unacceptable. Accelerating commercial UAS use will not only help businesses harness the tremendous potential of UAS, they will also help unlock the economic impact and job creation potential ofthe technology. AUVSIIooks forward to continuing to work with the FAA and other stakeholders to ensure UAS are integrated safely and responsibly as quickly as possible. The FAA should promptly grant this exemption request, look for ways to allow for more commercial use of UAS immediately, and get on with rulemaking. Respectfully submitted,

Michael Toscano President & CEO AUVSI

4 http://www.oig.dot.gov

### Isites/dot/files/FAA%200versight%20of%20Unrna nned%20Aircraft%20Systerns%5 E6-26-14

_0.pdf 5 http:/ /www.gao.gov/assets/670/660683.pdf 6 https:/ /www.faa .gov

### Iregulations_policies/rea uthorization/rnedia/PLAW-112pu bl95[1].pdf

7 49 U.S.C. §44704, 14 CFR Parts 21, 27, 137, 45.23(b), 61.113(a)(b), 91.7(b), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.203(a)(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)(b), and 91.1501 8 http:/ /www.auvsi.org/auvsinews/associationnews 9 http://www.dot.gov

### Iregulations/report-on-significant-rulerna kings 10 http:/ /higherlogicdownload.s3.arnazonaws.corn/AUVSI/958c920a-7f9b-4ad2-9807- f9a4e95d1ef1/UploadedFiles/Joint%20Letter%20to%20FAA%20on%20Expediting%20UAS%20rulernaking%20Final.pdf 11 http://www.dot.gov /regulations/report-on-significant-rulernakings