85203.1 11/23/2015

One PPG Place  30t h Floor  Pittsburgh, PA 15222

Phone: (412) 209-2500  Fax: (412) 209-2570

DELAWARE MARYLAND MASSACHUSETTS NEW JERSEY NEW YORK PENNSYLVANIA WASHINGTON, DC

A DELAWARE LIMITED LIABILITY PARTNERSHIP

Justine M. Kasznica

Phone: (412) 209-2537

Fax: (412) 209-2588

jkasznica@saul.com

www.saul.com

November 16, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Amendment to Exemption No. 13248 Issued to Near Earth Autonomy, Inc. Pursuant to 

Section 333 of the FAA Reform Act (Regulatory Docket No. FAA-2-15-2324)

Dear Sir or Madam:

Near Earth Autonomy, Inc. (“Near Earth”) received Exemption No. 13248 on October 20, 2015 

(the “Exemption”), allowing Near Earth to operate the Pulse VAPOR 35 and Pulse VAPOR 55 

unmanned aircraft systems (“UAS”) to conduct aerial demonstrations, surveying, mapping, 

inspections and site monitoring. 

Near Earth hereby requests an amendment to the Exemption to include additional UAS platforms

that fully comply with the conditions and limitations contained in the Exemption. 

Near Earth seeks to include the following additional UAS as part of its Exemption:

 DJI S1000/S1000+ Spreading Wings

 DJI Matrice

 3D Robotics X8/X8+

These are off-the-shelf UAS commonly used in connection with commercial operations. The 

FAA has previously granted multiple exemptions from Section 91.151 and other FARs and 

approved the conditional operation of these particular type of UAS. Examples of previously

granted exemptions for each of the three systems include:

 DJI S1000/S1000+ Spreading Wings 

o Exemption 11467 (granted to Aerial Inspection Resources, Inc. for aerial data 

collection)

o Exemption 11305 (granted to Flying Cross Aerial Productions for aerial 

photography and filmography)
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o Exemption 11253 (granted to Drone Fleet & Aerospace Management, Inc. for 

aerial data collection)

 DJI Matrice

o Exemption 11646A (granted to BioSensing Systems LLC for aerial data 

collection)

o Exemption 12378A (granted to XO Innovations for industrial, real estate, 

agriculture, motion picture, and television industry for scripted closed set filming)

 3D Robotics X8/X8+

o Exemption 11646A (granted to BioSensing Systems LLC for aerial data 

collection)

o Exemption 11672A (granted to Aerial Impressions, LLC for aerial data 

collection)

o Exemption 12084 (granted to Robert Dreer for photography, videography, 

inspection of infrastructure, surveying, mapping and photogrammetry, precision 

agriculture, and scientific and

environmental research

Information about the above UAS platforms, including the technical specifications of the UAS, 

information about the ground control systems (“GCS”), and the operator’s manuals, is publicly

available. Such additional information is included in the attached Exhibit A.

The three additional UAS mentioned above are comparable in type, size, weight, speed and 

operating capabilities to the UAS authorized in the Exemption. The UAS will be used for the 

same operations that were authorized in the Exemption, and will fully comply with the terms of 

the Exemption. Additionally, there has been no change in the conditions and reasons relative to 

public interest and safety that were the basis for granting the Exemption.

As this is an amendment to an existing exemption seeking the addition of supplementary UAS,

Near Earth respectfully submits that good cause exists such that notice does not need to be 

published in the Federal Register for the requested amendment. This amendment has been filed 

electronically on November 16, 2015 using the Federal Docket Management System.

Please do not hesitate to contact me with any questions by phone at +1.412.209.2537 or by email 

at jkasznica@saul.com. Thank you for your consideration.

Sincerely, 

Justine M. Kasznica

Counsel for Near Earth Autonomy, Inc.
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EXHIBIT A

DJI S1000/S1000+ Spreading Wings

 The S1000 and S1000+ are two platforms that are alike in all material respects 

(www.dji.com/products/compare-spreading-wings). 

 Technical Specifications:

o S1000: www.dji.com/product/spreading-wings-s1000/spec

o S1000+: www.dji.com/product/spreading-wings-s1000-plus/spec

 Ground control station (GCS):

o The S1000/S1000+ uses the iPad ground station. See www.dji.com/product/ipadground-station and www.dji.com/product/ipad-ground-station/download

 Operation/Operator’s Manual:

o S1000: The operator manual and release notes are available at 

www.dji.com/product/spreading-wings-s1000/download

o S1000+: www.dji.com/product/spreading-wings-s1000-plus/download

o DJI Fly Safe information: flysafe.dji.com 

 Maintenance Information

o Same as provided by Near Earth and approved as part of the Exemption

DJI Matrice 100

 Technical Specifications:

o https://developer.dji.com/matrice-100/specs/

 GCS:

o The N1 flight controller for the Matrice 100 does not use the standard DJI ground 

control station. It uses a DJI RC transmitter and the DJI GO app. The Matrice is 

designed to be a development platform with optional control from an onboard 

computing platform. The GO app and a developer account from DJI are required 

for initial activation of the developer mode on the platform. See 

http://www.dji.com/product/goapp. See also https://github.com/dji-sdk/OnboardSDK.
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 Operation/Operator’s Manual:

o Links to the user manual, flight battery guidelines, simulator, firmware release 

notes, safety guidelines (with flight checklist), etc. can be accessed here: 

https://developer.dji.com/matrice-100/downloads/

 Maintenance Information:

o Same as provided by Near Earth and approved as part of the Exemption

3D Robotics X8/X8+

 Technical Specifications:

o X8+: http://store.3drobotics.com/products/x8-plus

o X8 is the X8+ predecessor; technical specifications are substantially similar to 

those of the X8+

 GCS:

o 3DRs website states that an ArduPilot compatible GCS can be used with their

UAS. See http://www.3drobotics.com/kb/ground-station. The GCS listed on the 

3DR site vary by platform: DroidPlanner 2 (Android), Mission Planner 

(Windows), and APM Planner (Mac). Near Earth intends to use the X8 and X8+ 

with the PixHawk PX4 firmware (http://px4.io), with a QGroundControl ground 

station (qgroundcontrol.org).

 Operation/Operator’s Manual:

o The operator manual and release notes for the X8 and X8+ are available at 

http://3drobotics.com/x8/info/?_ga=1.18487225.1831196767.1445861136

 Maintenance Information:

o Same as provided by Near Earth and approved as part of the Exemption