October 14, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Application for Amendment to Exemption No. 12060, Field Data Solutions, Inc. dba 

Electronic Data Solutions FAA Docket 2015-1334

Dear Sir or Madam:

Field Data Solutions, Inc. dba Electronic Data Solutions (“Elecdata”) is requesting an 

amendment to add the following aircraft to Exemption No. 12060 for commercial use in aerial 

data collection:

1. Trimble ZX5

2. DJI Phantom 3

3. DJI Inspire 1 

4. DJI Spreading Wings S1000+

5. 3D Robotics Aero-M

6. SenseFly eBee

7. SenseFly eXom

The Trimble ZX5 is a rotorcraft weighing a maximum of 11 lbs. at takeoff, with payload. 

It will not operate at a speed greater than 87 knots. Preflight maintenance will be accomplished 

as set forth in the Operations Manual submitted with this request.

The DJI Phantom 3 is a rotorcraft weighing a maximum of 4.5 lbs. at takeoff, with 

payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request.

The DJI Inspire 1 is a rotorcraft weighing a maximum of 7 lbs. at takeoff, with payload. It 

will not operate at a speed greater than 87 knots. Preflight maintenance will be accomplished 

as set forth in the Operations Manual submitted with this request.

The DJI Spreading Wings S1000+ is a rotorcraft weighing a maximum of 25 lbs. at 

takeoff, with payload. It will not operate at a speed greater than 87 knots. Preflight

maintenance will be accomplished as set forth in the Operations Manual submitted with this 

request.

The 3D Robotics Aero-M is a fixed wing aircraft weighing a maximum of 8 lbs. at takeoff, 

with payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request.

The SenseFly eBee is a fixed wing aircraft weighing a maximum of 2 lbs. at takeoff, with 

payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request.
2

The SenseFly eXom is a rotorcraft weighing a maximum of 4 lbs. at takeoff, with 

payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request.

All the listed aircraft will be operated in accordance with the procedures set forth in the 

submitted manuals. The FAA has issued exemption grants in circumstances similar in all 

material respects to those presented in this petition. In Exemption No. 11110B to Trimble 

Navigation (see Docket No. FAA-2014-0367), No. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), No. 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), No. 11112 to 

VDOS Global, LLC (see Docket No. FAA−2014−0382), and No. 11213 to Aeryon Labs, Inc. (see 

Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an 

unmanned aircraft (“UA”) with the specifications described by the petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions carrying 

crew in addition to flammable fuel, gave the FAA good cause to find that the UAS operation at 

issue was in the public interest.

Elecdata intends to use all aircraft included in both this amendment request and the 

original granted exemption no. 12060 for the commercial purpose of aerial data collection. This 

may include activities such as aerial surveying, mapping, aerial photography, aerial 

videography, LIDAR surveying, and other forms of remote sensing. Applications may include

agriculture, mining, forestry, vector control, real estate imaging, wildlife monitoring, wildland fire 

suppression support, post-fire remediation and monitoring, aerial inspections, vegetation 

monitoring, solid waste management, telecommunications, utilities, oil and gas, natural 

resources, environmental surveys, archaeology, crew member training, and others.

To the extent necessary, Elecdata refers the FAA to its original exemption request 

submitted in Docket FAA-2015-1334 for a listing of regulations for which an exemption is being 

sought; a demonstration of the public interest; and a showing of an equivalent level of safety. 

Based on the foregoing and for all the reasons set forth in Elecdata’s previous filings in Docket 

2015-1334, which are now incorporated by reference, Elecdata notes that the FAA has granted 

similar exemptions, as set forth above, for aerial data collection, and it, therefore, believes that 

this amendment request is subject to the FAA’s already announced Summary Exemption 

Process.

Sincerely,

Linda Dean Glover

Co-owner, Vice President

Field Data Solutions, Inc. dba Electronic Data Solutions

154 1st Ave W

Jerome, Idaho 83338

(208)324-8006

linda@elecdata.com