THE DOBBINS 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 submitted 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 similar 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 eXam UAV is a unique aircraft. This 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 ultrasonic 

sensors that allow the drone to get close up to structures for detai led inspection. The distance 

from the structure can be set from the ground control station. It also has 4 cameras that allow 

the operator to see forward, right, left and rear to visually see the structure being inspected and 

the distance from the UAV. As a fail-safe, the drone'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 drone consist of a 36 MP digital camera, a 1 080p video camera and a thermal 

P. 0. Box 20001 • Atlanta, GA 30325 • 404-352-2638 

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imaging camera. This allows the eXom to produce exceptional inspection imaging of bridges, 

cell towers , construction 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 1 00,000 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 structures. 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. 

Ji$L 

Rick Dobbins, COO 

The Dobbins Company