# THE DOBB INS COMPANY INDUSTRIAL liQUIDATIONS & APPRAISALS SINCE 1975 August 12, 2015 U.S . Department of Transportation Docket Management System 1200 New Jersey Ave ., SE Washington , DC 20590 Re : Petition for Amendment of Existing Section 333 COA to Expand Commercial Utilization of UAV . Submitter Information The Dobbins Company d/b/a Sky Sight Imaging 3827 Cliff Crest Dr Smyrna , GA 30080 Att: Rick Dobbins 404-451-1595 rick @dobbinscom pan Y-.com Previous 333 Information Exemption No . 11373 . Regulatory Docket No . FAA-2015-0060 Dear Sir or Madam , The Dobbins Company d/b/a Sky Sight Imaging (SSI) has been granted a Section 333 Exemption along with a blanket COA to allow the use of a DJI Phantom 2 and Phantom 2 Vision for the purposes of Aerial Data Collection . On May 27 , 2015 The Dobbins Company subsequently subm itted a Petition for Amendment to the original 333 asking for the addition of another UAV, a SenseFiy eXam quadcopter. This amendment request did not ask for any changes to the original blanket COA . Given that the eXam is sim ilar aerodynamically to the Phantom 2 UAVs , no COA changes were requested at that time and the eXam has previously received a 333 exemption given to SenseFiy (the manufacturer) , we are assuming that this amendment request will be given in the near future . The tracking number for this request on Regulations .gov is 1jz-8j36 -7axw. The eXa m UAV is a uniq ue aircraft . Th is is a professional inspection drone that has capabi lities not currently avai lable on any other civil UAV . As to hardware , this UAV has 5 ultrason ic senso rs that allow the d rone to get close up to structures for detai led inspection . The distance from the structure can be set from the ground control stati on. It also has 4 cameras that allow the operator to see forward , right, left and rear to visually see the structure being inspected and th e distance from the UAV. As a fail-safe , the dron e's props are shroud ed where if the UAV does come into contact with the structure , it will bounce off with out causing an accident. The sensors on this dron e consist of a 36 MP digital camera , a 1080p video cam era and a the rmal P. 0. Box 20001 • Atlanta, GA 30325 • 404-352-2638**·~-** ,. I J• ,_ I 

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# .imaging camera . This allows the eXom to produce exceptional inspection imaging of bridges , cell towers , constructio n sites , commercial properties , mines and agricultural fields . The software controlling the eXom is called eMotion . This software is very sophisticated and allows full autonomous operation of the UAV (within VLOS) , autonomous/manual operation or full manual operation . It has geofencing capability as well as all the normal safety features typical on today's UAVs . Given the capabilities of this UAV , SSI is requesting the following expanded COA authorization : Increase maximum altitude from 200 feet AGL to 400 AGL • A decrease in minimum distance allowed from non-participating structures from 500 feet to 200 feet. This would be for commercial structures only ; not residential structures . • The ability to fly a UAV under a bridge that carries vehicles and pedestrians with the permission of a city, county or state Department of Transportation (or equivalent). The ability to operate a drone under these parameters will be of great benefit to many industries and government entities as further described below . Increase maximum altitude from 200 feet AGL to 400 AGL The need for this is critical for several UAV missions . The eXom will be of great use to the cell phone tower industry. There are over 100 ,000 cell phone towers in the USA. These towers must be inspected on a regular basis . SSI will be able to inspect these towers safely with its eXom . There are many towers that fall within the 200-foot requirement. But there are many more that are in the 200-400 foot category. Being able to inspect these taller towers with our eXom will greatly reduce cost to the tower operators and be much safer than sending climbers to make routine inspections. In addition to towers , the ability to fly up to 400 feet will enhance the imaging capability when collecting data for the mining and agricultural industries . Given all the other requirements of the existing blanket COA , increasing the maximum operating altitude of SSI 's eXom drone to 400 feet should not cause any additional safety or ATC concerns. A decrease in minimum distance allowed from nonto 200 feet. This would be for commercial structures not residential structures. SSI 's eXom drone will be utilized exclusively for commercial purposes . Although there may be circumstances where the eXom would be used over residential properties , this COA amendment is only requesting a decrease in the minimum operation distance from commercial structu res. A commercial structure being defined a place of business where no people are domiciled. Given there are relatively few privacy issues in typical business operations , a 200 foot minimum operating distance from a non-participating structure would be a safe operating distance. By allowing this decrease in minimum operating distance , SSI would be able to inspect many more cell phone towers and perform digital modeling of more participating commercial structures .The ability to fly a UAV under a bridge that carries vehicles and Redestrians with the permission of a city, county or state Department of Transportation (or equivalent). One of the most exciting capabilities of the eXam is the ability to inspect the underside of bridges. This task is required by governments and agencies on a regular basis . A typical bridge inspection requires visual observation of the top , bottom and sides along with other various types of measurement equipment . This is particularly difficult when inspecting the under side of a bridge . The eXam has the capability of rotating its sensor head 180 degrees where it can look straight up or straight down . This , along with its ultrasonic proximity sensors , will allow this drone to safely get very close to the underside and into very tight spaces . This is a revolutionary use for a UAV. This capability will significantly reduce cost and down time to a bridge inspection . Bridges basically fall into 2 categories : traffic (or Rail Road) over/under pass or water over pass . When inspecting the underside of a road or highway water (or RR) over pass bridge , the UAV will have the bridge structure acting as a barrier between vehicles and the UAV. SSI requests a COA amendment that allows the operation of a UAV when there is a concrete and/or steel structure between the UAV and vehicles to allow for these types of inspections. When inspecting a traffic over/under pass type bridge , the Dept . of Transportation or regulating jurisdiction will be responsible for stopping traffic during the inspection . This COA request is only for inspection of the underside of a bridge with a concrete and/or steel barrier between the UAV and vehicles . If the entire bridge were to be inspected , with the top & sides in addition to the underside, then the DOT would be responsible for traffic control during the actual flight time while over the bridge . This COA request is only for inspecting the underside of a bridge with the eXam drone with the express permission of the local DOT. This concludes our COA modification request. Thank you for your consideration . 

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Rick Dobbins , COO The Dobbins Company