April 21 , 2016

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Amendment to Section 333 exemption # 16008 from t he FAA

Reform Act and Part 11 of the Federal Aviation Regulations in Regulatory Docket

FAA

- 2015

- 6988

Dear Sir or Madam;

Aerobotic Imaging S e rvices LLC seeks to amend the original 333 exemption # 16008 application as follows:

1. Night Operations

2. Operations from a moving devi ce or vehicle
3. Additional operation s /missions

Each change request ed to the exemption is separate and independent and should be viewed as such with regard to approval, denial, or request for more information.

1 Night Operations

Aerobotic Imaging S e rvices LLC holds 333 Exemption # 16008 under with docket FAA

- 2015

- 6988 (hereinafter the Exemption) without the purpose Night Operations

. Aerobotic Imaging S e rvices LLC herby requests an amendment to the Exemption to allow Night Operations that full y complies with the conditions of the Exemption. A erobotic Imaging S e rvices LLC believes that we can safely operate UAV ’ s / UAS ’ s safely at night

, without increased harm to the public or property , at the same safety assumed for the original Exemption

. The attached UAS night training program file has been emailed and not included into the public because it holds proprietary training information not intended for the public

. Night operations is a major need for A erobotic Imaging S e rvices LLC when conducting inspections and closed set filming , certain temperature sensitive inspections, and search and res c ue

. Conditions for Night Operations

1. PIC Shall have a medical without wa i ver for color vision

2. PIC Sh all complete Aerobotic Imaging Services night training

3. PIC Shall abide by the Aerobotic Imaging Services night training currency requirements

We seek to amend this 333 Exemption #16008 on the basis of previously approved Exemption 16341 Industrial Skyworks (USA), Inc

. and seek the similar relief of night operations and similar restrictions.

2

. Operations from a moving device or vehicleAerobotic Imaging S e rvices LLC seeks exemp tion to operate from a moving device or moving land and

water vehicle s

. We feel that safety of the operation will not be compromised and the assumed safety of the original 333 exemption will be maintained.

The conditions of operation would be such that the operator of the vehicle would :

1. be required to hold a valid driver’s licen se 2. abide by all local and state driving laws

3. cannot be the PIC of the UAV/UAS

4. cannot be the visual observer

5. cannot operate or be distracted by any electronic device or handheld device

6. cannot operate on any public right

- of

- way o r publicly maintained road without the controlling agency perm ission

7. trained according to Aerobotic Imaging S e rvices LLC vehicle training manual

The conditions of the moving device or vehicle the PIC would be in or on in such operation would:

1. have an open top to allow the visual observer and/or PIC to maintain open air visual line of sight.

2. B e operated in accordance with the local and state laws if applicable

3. B e operated no faster than 2 2.5 mph.

Aerobotic Imaging S e rvices LLC feels that with proper training and practice demonstrated in our training requirements we can safely operate from a moving vehicle. The attached UAS moving vehicle/device training program file has been emailed and not included into the public because it holds proprietary training information not intended for the public

. Aerobotic Imaging S e rvices LLC needs to o perate from

a moving vehicle for the pur pose of operating longer distances required for our operations while still
maintain ing line

- of

- sight during operatio ns such as search and rescue

. Since there is no restriction that the PIC be stationary during operations, r iding in or on a vehicle would be in many ways safer than walking for both the operator and those on the ground that could be affected if the operator tripped or
stumbled wh ile moving under his or her own power.

3

. Additional operation/missions

Aerobotic Imaging S e rvices LLC se eks to add additional operation s /missions to the existing Exemption
for clarif ication and based on the previously approved E xemption # 16055 by Silver OctopusLLC

.

Aerobotic Imaging S e rvices LLC seeks operations for:

Private and commercial marine vessel videography, photography, inspection and patrolling; aerial photography, videography, and surveying; closed

- set filming and aerial photography; surveying, monitoring, inspections, videography, photography and filmmaking ; aerial imaging for safety, monitoring, inspecting and/or recording of secured and controlled environment construction sites,proposed development sites, inspections of property, and photography for realty advertisements;

precision photogrammetry and crop scouting; search and rescue and disaster operations; educational research, technical demonstrations and training; precision agriculture, market research, surveying, mapping and inspection; and oil and gas pipeline inspections, solar installation inspectio ns, power line/cable inspections, cooling tower inspections, forestry, critical infrastructure inspections, wind turbine inspections, and radiation measurement and monitoring

A erobotic Imaging S e rvices LLC believes that we can safely operate UAV ’s / UAS ’s safe l y during these

missions

, without increased harm to the public or property , at the same safety assumed for the original Exemption

.

There has been no change in the conditions and reasons relative to public interest and safety that were the basis for granting the original exemption.

P lease contact the undersigned should you have any question concerning this request for an
amendment to the e xemption request

. Sincerely yours,

Stephen Dixon

,

Member Aerobotic Imaging Services LLC