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 the FAA

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

FAA-2015-6988

Dear Sir or Madam;

Aerobotic Imaging Services LLC seeks to amend the original 333 exemption # 16008 application as

follows:

1. Night Operations

2. Operations from a moving device or vehicle

3. Additional operations/missions

Each change requested 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 Services LLC holds 333 Exemption # 16008 under with docket FAA-2015-6988

(hereinafter the Exemption) without the purpose Night Operations. Aerobotic Imaging Services LLC 

herby requests an amendment to the Exemption to allow Night Operations that fully complies with the 

conditions of the Exemption. Aerobotic Imaging Services 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 Aerobotic Imaging Services LLC when conducting inspections and 

closed set filming, certain temperature sensitive inspections, and search and rescue.

Conditions for Night Operations

1. PIC Shall have a medical without waiver for color vision

2. PIC Shall 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 vehicle
Aerobotic Imaging Services LLC seeks exemption to operate from a moving device or moving land and 

water vehicles. 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 license

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 or publicly maintained road without the 

controlling agency permission

7. trained according to Aerobotic Imaging Services 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. Be operated in accordance with the local and state laws if applicable

3. Be operated no faster than 22.5 mph.

Aerobotic Imaging Services 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 Services LLC needs to operate from

a moving vehicle for the purpose of operating longer distances required for our operations while still 

maintaining line-of-sight during operations such as search and rescue. Since there is no restriction that 

the PIC be stationary during operations, riding 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 while moving under his or her own power.

3. Additional operation/missions

Aerobotic Imaging Services LLC seeks to add additional operations/missions to the existing Exemption 

for clarification and based on the previously approved Exemption #16055 by Silver OctopusLLC. 

Aerobotic Imaging Services 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 

inspections, power line/cable inspections, cooling tower inspections, forestry, critical infrastructure 

inspections, wind turbine inspections, and radiation measurement and monitoring

Aerobotic Imaging Services LLC believes that we can safely operate UAV’s / UAS’s safely 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.

Please contact the undersigned should you have any question concerning this request for an 

amendment to the exemption request.

Sincerely yours, 

Stephen Dixon, 

Member Aerobotic Imaging Services LLC