Edward Roske

Digital GIS, LLC

1164 Sedgewood Circle

West Melbourne, FL 32904

Jim Williams

UAS Integration Office

Federal Aviation Administration

800 Independence Avenue SW

Washington, DC 20590  

November 6, 2015  

RE: Request for an Amendment to Exemption No. 12619 (Regulatory Docket No. FAA‐2015‐2141) to

Include Additional UAS Models  

Dear Mr. Williams:  

On August 26, 2015 Digital GIS, LLC, (“Petitioner”) received a grant for an exemption from the Federal

Aviation Administration (“FAA”), Exemption No. 12619 (“Exemption”), under which the Petitioner is

permitted to commercially operate an unmanned aircraft system (UAS) to conduct aerial surveying,

photography, cinematography, and inspections of buildings and land within the United States.  

The Petitioner would like to request an Amendment to the Exemption to include additional UASs. The

Petitioner’s requested changes are supplemental to and do not alter the material terms of the initial

petition and, if granted, will conform within the guidelines and limitations imposed by the FAA in

Exemption No. 12619.  

I. The Petitioner Respectfully Requests the FAA to Grant the Request for An Amendment to Permit the

Use of Additional Unmanned Aircraft Systems. The Petitioner would like to request the FAA to amend

the Exemption No. 12619 to include, in addition to the approved UASs, the following UASs: DJI Phantom

and DJI Inspire. All of the UASs proposed to be added to Exemption No. 12619 conform within the

conditions and limitations as set by the FAA in the aforementioned Exemption. Specifically, each

additional proposed UAS weighing less than 55 pounds including payload, will not be operated at a

speed exceeding 87 knots and will be operated at an altitude of no more than 400 feet above ground

level. A list of the proposed aircraft to be added to Exemption No.12619:  

A. DJI Phantom  

a. Petitioner would like to refer the Examiner to Exemption Nos. 11778A, 11067B, 11366A, 11778A in

which the FAA previously determined that in consideration of the size, weight, speed and limited

operating area associated with the aircraft and its operations, the Secretary of Transportation

determined that this aircraft meets the conditions of Section 333. 3  

B. DJI Inspire  
a. Petitioner would like to refer to Exemption Nos. 11253A, 11336, 11778A in which the FAA previously

determined that in consideration of the size, weight, speed and limited operating area associated with

the aircraft and its operations, the Secretary of Transportation determined that this aircraft meets the

conditions of Section 333.  

C. Sensefly eXom

a. Petitioner would like to refer to Exemption Nos. 12106, 11263A, 12284 in which the FAA previously

determined that in consideration of the size, weight, speed and limited operating area associated with

the aircraft and its operations, the Secretary of Transportation determined that this aircraft meets the

conditions of Section 333.  

D. Altavian Nova F6500

a. Petitioner would like to refer to Exemption Nos. 12588, 12496, 11605A in which the FAA previously

determined that in consideration of the size, weight, speed and limited operating area associated with

the aircraft and its operations, the Secretary of Transportation determined that this aircraft meets the

conditions of Section 333.  

E. AeroVironment Puma AE  

a. Petitioner would like to refer to Exemption Nos. 11253A, No. 11261 in which the FAA previously

determined that in consideration of the size, weight, speed and limited operating area associated with

the aircraft and its operations, the Secretary of Transportation determined that this aircraft meets the

conditions of Section 333.  

F. PrecisionHawk Lancaster

a. Petitioner would like to refer to Exemption Nos. 11253A in which the FAA previously determined that

in consideration of the size, weight, speed and limited operating area associated with the aircraft and its

4 operations, the Secretary of Transportation determined that this aircraft meets the conditions of

Section 333.  

Each UAS proposed to be added carries a difference primarily in the physical appearance and the

performance capabilities from the original UAS included in Exemption No. 12619. The Petitioner

respectfully draws the attention of the FAA to the rapidly expanding market of available UASs and the

technological advances and improvement in their safety. It is in the public interest to allow the

Amendment for the addition of the proposed UASs in order to provide commercial services with safe

and improved technology and expand the services offered to the community.

The Petitioner will continue to follow all Safety Standards and procedures as outlined in the original

petition, including following the pre‐flight checklist of actions to be performed prior to each flight as

well as be in compliance with all conditions and limitations stated in Exemption No. 12619. The

Petitioner will also commit to following all safety procedure and precaution parameters as outlined in

the owner manuals for each respective UAS.  

The Petitioner respectfully states that there are no changes in the conditions and reasons relative to

public interest and safety that were the basis for granting the original exemption. Additionally, the

Petitioner believes that as this is an Amendment to the original petition there exists good cause for not

publishing a summary of the Petition in the Public Register and the UASs authorized in the original grant
are comparable in type, size, weight, speed and operating capabilities as the UAS in the original petition

and should be permitted to be included in Exemption No. 12619.  

Very Truly Yours,

Edward Roske

Digital GIS, LLC

1164 Sedgewood Circle

West Melbourne, FL 32904

Edward@digitalgis.com