~OLSINELLI 1515 Wynkoop, Suite 600, Denver, CO, 80202 • 303.572.9300 

August 7, 2015 

VIA FED EX ONLY (TRACKING #774239805700) 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Ramsey Ammar 

303-582-8229 

rammar@polsinelli.com 

Re: Amendment to Exemption No. 11584, Regulatory Docket No. FAA-2015-

0446, Issued to UAS Professionals. Inc., Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

Dear Sir or Madam: 

UAS Professionals, Inc. ("UAS") was issued Exemption No. 11584 on May 14, 2015 

(hereinafter "the Exemption") authorizing commercial operations, with conditions and 

limitations, for a DJI Innovations S800 sUAS for the purpose aerial data collection to include 

precision aerial surveying and mapping. 

UAS now requests an amendment to the Exemption allowing it to operate additional 

sUASs pursuant to the same conditions and limitations contained in the Exemption. In addition, 

UAS specifically incorporates into this correspondence all materials related to safe operations as 

expressed in UAS's initial submission for the Exemption and to treat all materials as if the 

requested aircraft were included in the original submission. 

The additional aircraft for which relief from 14 CFR Part 21, Certification procedures for 

Products and Parts, Subpart H - Airworthiness Certificates and additional FAR's as contained in 

the original Exemption will be required and which UAS requests be included in its exemption 

are: 

1. DJI Inspire 1 

polsinelli.com 

Atlanta 

St. Louis 

Chicago Dallas 

Washington, DC 

Polsinelli PC, Polsinelli LLP in California 

Denver 

Wilmington 

Kansas City Los Angeles Nashville New York Phoenix San Francisco 
US Department of Transportation 

August 7, 2015 

Page 2 

2. DJI Phantom 2 VisionPlus 

3. 3D Robotics X8 

4. MDAP X-UA V Talon 

5. SDAP M680 

UASPI has an Operators Handbooks for each additional aircraft herein requested to be 

added to the Exemption. A copy of the Operator's Handbooks for each requested aircraft are 

attached to this correspondence 1

. UASPI also has in its possession all available manufacturer 

safety and user guides and specifications. Upon your request, UASPI can provide to you all 

applicable manufacturer documents. 

These additional aircraft fall within the limitations prescribed in the Exemption for 

weight, size, and performance. In addition, the additional aircraft may be safely operated within 

the Conditions and Limitations contained in the Exemption. In addition, the addition of the 

proposed five aircraft continue to support UASPI's public policy arguments and support greater 

public safety while providing a quality and demanded commercial good. 

The additional aircraft requested have also been included in exemptions previously 

granted by the FAA, indicating the FAA's prior consent to deem such aircraft safe. Specifically, 

the FAA has previously granted exemptions for these and similar aircraft in the following 

exemptions 11398, 11652, 11654, 11801, 12194, 12128, 11956, 11998, and 11066. 

UAS respectfully submits that this amendment qualifies for summary grant approval. 

The FAA has previously granted exemptions for the operation of the additional aircraft requested 

in this amendment. Similarly, as the proposed operations of these additional aircraft will be in 

full conformance with the other conditions and limitations of the Exemption, there is no need for 

the FAA to repeat the analysis performed for the original exemption on which this amendment is 

based. For the same reasons, good cause exists to preclude the requirement to publish the 

requested amendment in the Federal Register. 

Please feel free to contact me if there are any questions or any additional information 

needed to process this amendment to include these other aircraft on Exemption 11584. 

Sincerely, 

Ramsey Ammar 

1 These five documents contain confidential commercial and/or proprietary information to 

UASPI and are not generally available to the public and are protected from release under the 

Freedom of Information Act, 5 U.S.C. §552 et seq. As such, UAS requests that these documents 

be kept confidential. 
I . ' 

US Department of Transportation 

August 7, 2015 

Page 3 

Encls: 

UAS Professionals, Inc. Fixed-wing sUAS Operator's Handbook; Medium Range Data 

Acquisition Platform ("MDAP") (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

All manufacturer safety and user guides available upon request 

UAS Professionals, Inc. uUAS Operator's Handbook; 3D Robotics X8 

(CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

All manufacturer safety and user guides available upon request 

UAS Professionals, Inc. sUAS Operator's Handbook; Phanton Vision II Plus 

(CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

All manufacturer safety and user guides available upon request 

UAS Professionals, Inc. sUAS Operator's Handbook; Short Range Data Acquisition 

Platform (SDAP). (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

All manufacturer safety and user guides available upon request 

UAS Professionals, Inc. sUAS Operator's Handbook; DJI Inspire 1. (CONFIDENTIAL 

-NOT FOR PUBLIC RELEASE) 

All manufacturer safety and user guides available upon request