6 October 2015

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

Re: Docket FAA 2015

- 1228 , Petition for Amendment to Exemption No. 11 881

Dear Sir or Madam:

Empire Unmanned received FAA Exemption No. 11 881 on June 23 , 2015 authorizing us to operate DJI

multi

- rotors in order to conduct aerial data collection

. We received an amendment to this exemption permitting us to fly an additional DJI aircraft as well as the SenseFly eXom on September 25, 2015. This petiti on is for an amendment to that e xemption , namely to am end proximity restrictions in order to permit

th e survey of bridges and roadways.

Our multi

- rotor aircraft weigh less than 10 pounds and can produce a detailed 3

- dimensional

mode l s of roadways, bridges, and construction sites , as well as perform inspections under structures that would be impossible for manned aircraft . These models assist engineers and county planners in maintaining and i mproving public infrastructure, and are in the public

interest.

However, t he restrictions of our exemption prevent us from conduct ing these surveys . Item 26 requires that we fly no closer than 500 feet to persons, vessels, vehicles, and structures without their permission. In coordination with the Idaho Department of Transportation we studied the apparent solution of stop ping traffic for the short duration of the se flight s

. T his was ruled out

since s topping traffic not only inconveniences the public

, it greatly increases the risk of collision

. Furthermore, o btaining permission from t he drivers using the roadway is not only impractical, it

would slow traffic and create additional distractions

.

In order to provide benefit to the public with surveys of infrastructure while minimizing additional risk, w e requ est the fo llowing amendment be added to E xemption No. 11881 and

11881

- A

.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensurin g the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those obje cts and determined that it does not present an undue hazard.c. A local government agency, such as a state transportation department or county highway

department, has conducted a safety risk assessment and approved risk mitigation procedures to safely co nduct a flight in the vicinity of public roadways , bridges and easements. These procedures must be made available to the Administrator or any law enforcement official upon request.

We feel this change would allow local experts to study each operation and ensure safety without creating an additional burden on the FAA

.

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarification.

Sincerely,

Bradley J. Ward

Chief Pilot , Empire Unmanned

Empire Unmanned LLC Attn: Bradley Ward

Ph: 208

- 844

- 7775 Email: bradw@empireunmanned.com