85203.1 11/23/2015 One PPG Place  30 t 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”) receiv ed Exemption No. 13248 on October 20, 2015 (the “ Exemption ”), allowing Near Earth to operate the Pulse VAPOR 35 and Pulse VAPOR 55 unmanned aircraft s ys tems (“ UAS ”) to conduct aerial demonstrations, survey ing, mapping, inspections and site monitoring. N ear Earth hereb y requests an amendment to the Exemption to include additional UAS platforms that fully compl y with the conditions and limitations contained in the Exemption. Near Earth seeks to include the following additional UAS as part of its Exempti on:  DJI S1000/S1000+ Spreading Wings  DJI Matrice  3D Robotics X8/X8+ These are off

- the - shelf UAS commonly used in connection with commercial operations. T he FAA has previousl y granted multiple exemptions from Section 91.151 and other FARs and approved the conditional operation of the s e particular ty pe of UAS. Examples of p revious ly granted exemptions for each of the three s ys tems include:  **DJI S1000/S1000+ Spreading Wings** o Exemption 11467 (granted to Aerial Inspection Resources, Inc. for aerial data colle ction) o Exemption 11305 (granted to Flying Cross Aerial Productions for aerial photography and filmography)85203.1 11/23/2015 o Exemption 11253 (granted to Drone Fleet & Aerospace Management, Inc. for aerial data collection)  **DJI Matrice** o Exemption 11646A (granted to BioSensing Sy stems 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 BioSens ing S ys tems 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 photograph y, videograph y, inspection of infrastructure, surveying, mapping and photogr ammetry , precision agriculture, and scientific and environmental research In formation about the above UAS platforms, including the technical specifications of the UAS, information about the ground control sy stems (“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 E xemption. As this is an amendment to an existing exemption seeking the addition of supplementary UAS , Near Earth r espectfull y s ubmits that good cause exists s uch that notice does not need to be published in the Federal Register for the requ ested amendment. This amendment has been filed electronically

on November 16, 2015 using the Federal Docket Management Sy stem. 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. Sincerel y, Justine M. Kasznica Counsel for Near Earth Autonomy , Inc.85203.1 11/23/2015 **EXHIBIT A**

**DJI S1000/S1000+ S preading 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/ipad ground - 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 DJIFl y Safe information: fly safe.dji.com  Maintenance Information o Same as provided b y 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 DJ I ground control station. It uses a DJIRC transmitter and the DJ I 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 DJ I 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/Onboard SDK .85203.1 11/23/2015

 Operation/Operator’s Manual : o Links to the user manual, flight battery guidelines, simulator, firmware release notes, safet y guidelines (with flight checklist), etc. can be accessed here: https://developer.dji.com/matrice - 100/downloads/  Maintenance Information : o Same as provided b y 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 substantiall y 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 th e 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 b y Near Earth and approved as part of the Exemption