1 Karina D. Dodor, Esq. 35 Highland Circle Needham, MA 02494

US DEPARTMENT OF TRANSPORTATION 1200 New Jersey Avenue

SE Room W

- 12

- 140 West Building Ground Floor Washington, DC 20590

- 0001

June 28, 2015

RE: Request for an Amendment to Exemption No. 11325 (Regulatory Docket

No. FAA

- 2015

- 0017) to Include Additional UAV Models

Dear Administrator:

On April 16, 2015 Cambervision, Inc., (“Petitioner”) received a grant for an exemption from the Federal Aviation Administration (“FAA”), Exemption No. 11325 (“Exemption”)

, under which the Petitioner is permitted to commercially operate an unmanned aircraft system (UAS) for training workshops, research and development, an d aerial inspections of buildings and land within the United States.

The Petitioner would like to request an Amendment to the Exemption to include aerial photography and videography as well as additional UASs . The Petitioner’s

req uested changes are supplemental to and do not alter the material terms of the initial petition and, if granted, will conform within the guidelines and limitations imposed by the FAA in Exemption No. 11325.

I. The Petitioner Respectfully Requests the FAA to Gran t the Request to Perform Aerial Photography and Videography in Addition to the

Current Permitted Actions.

The Petitioner, in error, excluded the request to perform Aerial Photography and Videography from it’s initial Petition and would like to request the FAA to amend the previously granted Exemption to permit the Petitioner to perform Aerial Photography and Videography under Exemption No. 11325.

The proposed Amendment is in the public interest and proposes to follow the same safety procedures and im posed condition and limitations as required by the FAA in Exemption No. 11325, to perform Aerial Photography and Videography, as outlined in the Petitioner’s original request for an exemption from the requirements of Title 14 of the Code of Federal Regulat ion concerning the operation of an Unmanned Aircraft System,2

for commercial use and operation within the United States filed under Docket ID: FAA

2015

- 0017. The Petitioner respectfully notes that the public interest served, safety procedures

to be followe d and all other concerns related to the performance of Aerial Photography and Videography are vastly similar, if not identical, to the performance of training workshops, research and development, and aerial inspections of buildings and lands

within the Uni ted States

. Petitioner would like to request the FAA to consider granting the Amendment to the existing Exemption as no material facts are changed from the original petition and the granted Amendment would provide safer alternative services to the public as are cu rrently unavailable today. The petitioner would like to request the FAA to clarify the definition of Aerial Data Collection to include aerial photography and videography as the FAA so noted Footnote 1 of Exemption No. 11818 in which i t defined that Aerial Data Collection “...includes any remote sensing and measuring by an instrument(s) aboard the UA S

. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical me asurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.”. Petitioner requests to add the specific wording of permitted uses to include “aerial photography and videography”.

II. The Petitioner Respectfully Reque sts the FAA to Grant the Request

for An Amendment to Permit the Use of Additional Unmanned Aircraft Systems.

The Petitioner would like to request the FAA to amend the Exemption No. 11325 to include, in addition to the approved DJI Phantom 2, version 2, t he following UASs: DJI Phantom 3, DJI Inspire, DJI S900, DJI S1000, 3D Robotics Solo, 3D Robotics Aero, Aero Vironment Puma AE, PrecisionHawk Lancaster, AirRobot AR180 and AirRobot AR200 and 3D Robotics Spektre Industrial Multi

- Rotor Aerial Vehicle. All of the UASs proposed to be added to Exemption No. 11325 conform within the conditions and limitations as set by the FAA in the aforementioned Exemption. Specifically

, each additional proposed UAS weighing less than 55 pounds including payload, will no t be operated at a speed exceeding 87 knots and will be operated at an altitude of no more than 400 feet above ground level. A list of the proposed aircraft to be added to Exemption

No.11325:

A. DJI Phantom 3

a. Petitioner would like to refer the Examiner to Exemption Nos. 11778A, 11067B, 11366A, 11778A in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its operations, the Secretary of Transportation determined tha t this aircraft meets the

conditions of Section 333.3 B. DJI Inspire

a. Petitioner would like to refer to Exemption Nos. 11253A, No. 11336, 11778A in which the FAA previously determined that in consideration of the size, weight, speed and limited operating a rea associated with the aircraft and its operations, the Secretary of Transportation

determined that this aircraft meets the conditions of Section 333.

C. DJI S900

a. Petitioner would like to refer to Exemption Nos. 11314A in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its operations, the Secretary of Transportation determined that this aircraft

meets the conditions of Section 333.

D. DJI S1000

a. Petitioner would lik e to refer to Exemption Nos. 11818, 11426A, 11778A in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its operations, the Secretary of Transportation

determine d that this aircraft meets the conditions of Section 333.

E. 3D Robotics Solo

a. Petitioner would like to refer to Exemption Nos. 11778A in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area associate d with the aircraft and its operations, the Secretary of Transportation determined that this aircraft

meets the conditions of Section 333.

F. 3D Robotics Aero

a. The size, weight, speed overall operating procedures of the UAS are similar in scope to that of the DJI Phantom 2, version 2, which has been determined by the FAA in Exemption No. 11325 as meeting the

conditions of Section 333.

G. Aero Vironment Puma AE

a. Petitioner would like to refer to Exemption Nos. 11253A, No. 11261 in which the FAA previously determi ned that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its operations, the Secretary of Transportation determined that this

aircraft meets the conditions of Section 333.

H. PrecisionHawk Lancaster

a. Pet itioner would like to refer to Exemption Nos. 11253A in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its4 operations, the Secretary of Transportation determi ned that this aircraft

meets the conditions of Section 333.

I. AirRobot AR180

a. Petitioner would like to refer to Exemption Nos. 11253A, 11206 in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area as sociated with the aircraft and its operations, the Secretary of Transportation determined that this

aircraft meets the conditions of Section 333.

J. AirRobot AR200

a. Petitioner would like to refer to Exemption Nos. 11253A, 11206 in which the FAA previously det ermined that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its operations, the Secretary of Transportation determined that this

aircraft meets the conditions of Section 333.

K. 3D Robotics Spektre In dustrial Multi

- Rotor Aerial Vehicle

a. Petitioner would like to refer to Exemption Nos. 11253A, 11206 in which the FAA previously determined that in consideration of the size, weight, speed and limited operating area associated with the aircraft and its opera tions, the Secretary of Transportation determined that this

aircraft meets the conditions of Section 333.

Each UAS proposed to be added carries a difference primarily in the physical appearance and the performance capabilities from the original UAS included in Exemption No. 11325. The Petitioner respectfully draws the attention of the FAA to the rapidly expanding market of available UASs and the technological advances and improvement in their safety. It is in the public interest to allow the Amendmen t for the addition of the proposed UASs in order to provide commercial services with safe and improved technology and expand the services offered to the community.

The Petitioner will continue to follow all Safety Standards and procedures as

outlined in the original petition, including following the “Cross

- Check Quadrant TM ” a customized pre

- flight checklist of actions to be performed prior to each flight as well as be in compliance with all conditions and limitations stated in Exemption No. 11325. The

Pet itioner will also commit to following all safety procedure and precaution parameters as outlined in the owner manuals for each respective UAS.

The Petitioner respectfully states that there are no changes in the conditions and reasons relative to public in terest and safety that were the basis for granting the original exemption. Additionally, the Petitioner believes that as this is an Amendment to the original petition there exists good cause for not publishing a summary of the Petition in the Public Regist er and the UASs authorized in the original grant are comparable in type,5

size, weight, speed and operating capabilities as the UAS in the original petition and should be permitted to be included in Exemption No. 11325.

Very Truly Yours,

Karina D. Dodor Esq. Attorney for Cambervision Inc.

35 Highland Circle Needham, MA 02494 Tel: (617) 991

- 5677