Aaron Totten

Seiclone Surveys Inc.

763-316-0280

Aaron.totten@seiclonesurveys.com

11040 183rd Circle NW Suite C.

Elk River, MN 55330

February 22nd, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Application for Amendment to Exemption 14560, Seiclone Surveys Inc.

FAA–2015–5426

Dear Sir or Madam:

On February 22nd , 2016, Seiclone Surveys Inc., through its attorneys, submitted

applications for amendments to Exemption 14560, originally issued January 28th , 2016 in FAA

Docket 2015-5426 to (1) update the terms of the conditions contained in Exemption 14560 to those 

that are being issued currently to all exemption holders under Section 333 for the FAA Modernization 

and Reform Act of 2012. On February 2nd, the FAA issued Exemption 14560 allowing the

commercial operation of the UX5 and UX5 HP with updated standard terms and conditions. This

letter is a further request for an amendment to add the following aircrafts and usages to the amended

Exemption 14560 for commercial use in aerial data collection:

AMENDEDED USAGES:

- Real estate 

- Construction site monitoring

- Inspection of buildings and structures

- Agriculture

- Environmental monitoring

- Civil planning

- Stock aerial photography

- Wedding photography and video

AMDENDED AIRCRAFTS:

1) Trimble Navigation LTD. Multirotor ZX5

The Trimble-drone ZX5 is a rotor aircraft weighing a maximum of 11 Ibs. at takeoff (in any event, less 

than 551bs.), 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 confidentially with this application. 

Attachment link 1 to this petition for amendment is a listing of operations manuals submitted 

confidentially.

2) DJI Phantom 3 Multirotor Professional Model

The DJI Phantom 3 Professional is a rotor aircraft weighing a maximum of 3 Ibs. at takeoff (in any event, 

less than 551bs.), 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 confidentially with 

this application. Attachment link 2 to this petition for amendment is a listing of operations manuals 

submitted confidentially.

3) DJI Phantom 3 Multirotor Advanced Model

The DJI Phantom 3 Advanced is a rotor aircraft weighing a maximum of 3 Ibs. at takeoff (in any event, 

less than 551bs.), 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 confidentially with 

this application. Attachment link 3 in the comment section to this petition for amendment is a listing of 

operations manuals submitted confidentially.

4) DJI Phantom 3 Multirotor Standard Model

The DJI Phantom 3 Standard is a rotor aircraft weighing a maximum of 3 Ibs. at takeoff (in any event, 

less than 551bs.), 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 confidentially with 

this application. Attachment link 4 to this petition for amendment is a listing of operations manuals 

submitted confidentially.

5) DJI Phantom 3 Multirotor 4K Model

The DJI Phantom 3 4K is a rotor aircraft weighing a maximum of 3 Ibs. at takeoff (in any event, less than 

551bs.), 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 confidentially with this application. 

Attachment link 5 to this petition for amendment is a listing of operations manuals submitted 

confidentially.

6) DJI Inspire 1 Multirotor

The DJI Inspire 1 is a rotor aircraft weighing a maximum of 7 Ibs. at takeoff (in any event, less than 

551bs.), 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 confidentially with this application. 

Attachment link 6 to this petition for amendment is a listing of operations manuals submitted 

confidentially.

7) DJI Spreading Wings S1000+ Multirotor

The DJI Spreading Wings S1000+ is a rotor aircraft weighing a maximum of 25 Ibs. at takeoff (in any 

event, less than 551bs.), 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 confidentially with 

this application. Attachment link 7 to this petition for amendment is a listing of operations manuals 

submitted confidentially.

8) Sensefly Exom Multirotor

The Sensefly Exom is a rotor aircraft weighing a maximum of 4 Ibs. at takeoff (in any event, less than 

551bs.), 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 confidentially with this application. 

Attachment link 8 to this petition for amendment is a listing of operations manuals submitted 

confidentially.
AII the listed aircraft will be operated in accordance with the procedures set forth in the manuals

listed above and submitted confidentially. The FAA has issued exemption grants in

circumstances similar in all material respects to those presented in this petition. In Exemption

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.

To the extent necessary, Seiclone Surveys Inc. refers the FAA to its original exemption request 

submitted in Docket FAA-2015-5426 for a listing of regulations (as amended by Exemption 14560) 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 Seiclone Surveys 

Inc.’s previous filings in Docket 2015-5426, which are now incorporated by reference, Seiclone Survey 

Inc. 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. Finally, as set forth in more detail in its February 22nd amendment request, 

Seiclone Surveys Inc. requests that all of its aircraft granted authorization to conduct commercial 

operations under this amendment be allowed to operate without a separate Certificate of Operation 

("COA") in Class G airspace, at 400 feet AGL and below, and at least 5 nautical miles from the 

geographic center of an airport unless a letter of agreement with the airport's management is obtained.

1 Applicant interprets Section 333 as placing a duty on the administrator not only to process

applications for exemptions under Section 333 but, if he determines that the conditions set forth

herein do not fulfill the statutory requirements for approval, to craft conditions for the safe

operation of the UAS.

If you have any questions, please contact me at your earliest convenience.

Very Truly Yours,

Aaron Totten

C.E.O/President of Seiclone Surveys Inc.