Aaron Totten

Seiclone Surveys Inc.

763

- 316

- 0280 Aaron.totten@seiclonesurveys.com

11040 183 rd Circle NW Suite C.
Elk River, MN 55330

February 22 nd , 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 22 nd , 2016

, Seiclone Surveys Inc., through its attorneys, submitted applications for amendments to Exemption 14560, originally issue d January 28 th , 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 33 3 for the FAA Modernization

and Reform Act of 2012. On Feb ruary 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 aircraft s 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 monitorin g

- 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 kno ts. 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 a ircraft 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. Preflightmaintenance will be accomplished as set forth in the Operations Manual submitted confidentially wit h

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 a ircraft 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 M anual submitted confidentially wit h 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 a ircraft weighi ng 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 wit h this appl ication. At

tachment 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 a ircraft weighing a maximum of 3 Ibs. at takeoff (in any event, less tha n 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 wit h 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 a ircraft 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 wit h this application.

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

7) DJI Spre ading Wings S1000+ Multirotor The DJI Spreading Wings S1000+ is a rotor a ircraft 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 wit h 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 a ircraft 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 confiden tially wit h 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. (se e 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 specifi cations 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 t he 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 dem onstration 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 S urvey 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. F inally, as se t forth i n more detail in its February 22 nd amend ment request, Seiclone Surveys Inc. requests that all of its aircraft granted authorization to conduct c ommercial operations under this amendment be allowed to operate without a separate Certificat e of Operation (" COA") in Class G airspace, at 400 feet AGL and below, and at least 5 nautical m iles from the geographic center of an airport unless a letter of agreement with the airport's management is obtained.

1 Applicant interprets Sectio n 333 as placing a duty on the a dministrator 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 y ou have any questions, please contact me at your earliest convenience.

Very Truly Yours,

Aaron Totten

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