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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, and 

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 

requested 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 Grant 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 imposed 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 Regulation concerning the operation of an Unmanned Aircraft System, 
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for commercial use and operation within the United States filed under Docket ID: FAA2015-0017.

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

to be followed 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 United 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 currently 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 it defined that Aerial Data Collection 

“...includes any remote sensing and measuring by an instrument(s) aboard the UAS. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement 

(precision surveying, RF analysis, etc.), chemical measurement (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 Requests 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, the 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 not 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 that this aircraft meets the 

conditions of Section 333.
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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 area 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 like 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 

determined 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 associated 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 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.

H. PrecisionHawk Lancaster

a. Petitioner 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 its 
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operations, the Secretary of Transportation determined 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 associated 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 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.

K. 3D Robotics Spektre Industrial 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 operations, 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 Amendment 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 QuadrantTM” 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 

Petitioner 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 interest 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 Register and the UASs authorized in the original grant are comparable in type, 
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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