Planck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph: (619) 770-8150 www.planckaero.com

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Ammendment 1

8 July 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Ammendment to Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations, FAA-2015-1479

Dear Sir or Madam:

The following constitutes an amendment to Planck Aerosystems request for exemption that was 

entered into the public docket on 21 April 2015 (No FAA-2015-1479). It is in response to the letter titled 

U.S. DOT/FAA - Request for Additional Information that was posted in the docket on 26 June 2015. In 

particular, the letter requests detail on how the exemption request complies with section 11.81(d) of

the 14 CFR rulemaking procedures. 

Public Interest

Granting the exemption request to Planck Aerosystems would be in the public interest and benefit the 

public as a whole. The goal of the exemption request is to operate a small unmanned vehicle over 

bodies of water in order to conduct aerial surveying and identification of surface and subsurface objects 

in water, including boats, logs, fish, rocks, kelp, reefs, marine mammals, etc. Such surveys are both 

scientifically and agriculturally relevant to the public interest. 

From a scientific perspective, there is a consistent need to survey and monitor objects, including marine 

life, in the water. Many efforts by public agencies seek data obtained by these surveys. In many cases, 

these surveys much be conducted at a very high cost from deployed equipment, or at increased safety 

risks from manned aircraft. Conducting surveys over water from small unmanned vehicles enables 

access to high quality data at a much lower cost and risk than what is currently available. Members of 

the public scientific community that would benefit include, but is not limited to, NOAA, universities, fish 

and wildlife agencies, and other research institutions. 

Fishing is a major component of the country’s agricultural production. As such, it is important for 

fisherman to catch fish in an efficient and sustainable manner. Aerial surveys and monitoring over 

bodies of water provides information that fisherman can use to reduce their fuel use, reduce their 

bycatch, and ensure that they are operating in a safe and sustainable way. This applies equally to wild 

caught fish as well as fish farming (aquaculture). This benefits the public interest by helping ensure that 
Planck Aerosystems Inc, 3106 Maple St, San Diego, CA 92104 Ph: (619) 770-8150 www.planckaero.com

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the nation’s fisheries are sustainably harvested and the public has access to reasonably priced, highly 

nutritious fish. 

Under these circumstances, it should be clear that conducting aerial surveying of surface and subsurface 

objects in water using small unmanned aerial vehicles in a safe manner is in the public interest and 

benefits the public as a whole. 

All other considerations included Planck Aerosystems original exemption request remain unchanged. 

We are prepared to amend this request for exemption to satisfy the FAA’s recommendation. Please 

contact us for any additional information or clarification

Sincerely,

David Twining

Chief Operating Officer

Planck Aerosystems