The Law Office of Darrell J. Green, LLC

770 S. Willow Park Drive

Lehi, UT 84043

Telephone: $6q 624-2181

Email : gr een.7 7 0 @comcast.net

October 5,2015

VIA ELECTRONIC SUBMISSION

Federal Docket Manasement WeFsitg

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption No. 12052

Regulatory Docket No. FAA-201 5-1563

Petition to Amend ExemptionNo. 12052

Dear Sir or Madam:

On May 2,2015 Silverhawk L.L.C. d/b/a Silverhawk.Aerial Imaging (Silverhawk)

petitioned for regulatory and statutory relief pursuant to Seetion 333 of the FAA Modemization

and Reform Actof 2012 (the Reform Act) and 14 C.F.R. Part 11 to allow commercial operations

of its small Unmanned Aircraft (UA). The Director, Flight Standards Service, Mr. John S.

Duncan granted Silverhawk's request for exemption subject to conditions and limitations as

stated within its July 15, 2015 letter.

Silverhawk is requesting an amendment to FAA Exemption No. 12052 granted to

Silverhawk to add the following small unmanned aircraft which weigh less than 55 pounds

including payload:

1. DJI, Phantom Vision 3, Standard, Professional and Advanced

2. DJI, Spreading Wings, S800EVO, S900, S1000, and S1000+

Silverhawk is only adding these small UA to FAA Exemption No. 12052 and is not

requestiruq an amendment to its proposed operations. There is no change in the conditions and

reasons relative to public interest and safety that were the basis for granting the original

exemption.

The name and address of the applicant requesting the amendment is:

Silverhawk L.L.C. d/b/a Silverhawk Aerial Imaging

Attn: Mr. David Terry

Telephone: (801) 920-4178

Email : pilot@silverhawkai.com

Address: 4859 Burch Creek Dr South Ogden, UT 84403
The unmanned aircraft authorized in the original grant of exemptionNo. 12052 are

comparable in type, size, weight, and speed and operating capabilities to those in this petition:

A. DJI. Phantom Vision 3. Standard, Professional and Advanced

The DJI, Phantom Vision 3, Standard, Professional and Advanced are small UA

manufactured commercially by DJI and available for purchase in the United States weighing less

than 55 pounds. These aircraft will be operated in accordance with all conditions and limitations

as stated within Silverhawk's July 15,2015 exemption No. 12052. The DJI, Phantom Vision 3,

Standard, Professional and Advanced UA will be operated and maintained in accordance with all

manufacturers' specifications as required in the following documents:

1. Phantom 3 Standard Release Notes (Attachment A)

2. Phantom 3 Standard User Manual (EN) vl.2 (Attachment B)

3. Phantom 3 Standard Quick Start Guide (EN) vl.0 (Attachment C)

4. Phantom 3 Standard Safety Guidelines and Disclaimer vl.2 (Attachment D)

5. Charging Hub for Phantom 3 Intelligent Flight Batteries v1.0 (Attachment E)

6. Phantom 3 Professional Firmware v1.2 (Attachment F)

7. Phantom 3 Advanced Firmware v1.2 (Attachment G)

8. Phantom 3 Professional Release Note (Attachment H)

9. Phantom 3 Advanced Release Note (Attachment I)

10. Phantom 3 Professional Quick Start Guide (EN) vl.2 (Attachment J)

11. Phantom 3 Advanced Quick Start Guide (EN) vl.2 (Attachment K)

12. Phantom 3 Professional User Manual (EN) vl.4 (Attachment L)

13. Phantom 3 Advanced User Manual (EN) vl.a (Attachment M)

14. Phantom 3 Intelligent Flight Battery Safety Guidelines vl.0 (EN) (Attachment N)

15. Phantom 3 Professional and Advanced Safety Guidelines and Disclaimervl.2

(Attachment O)

16. Silverhawk Operational Procedures Inspire and Phantom 3 Series UA (Attachment P -

proprietary document via email)

B. DJI. Spreadine Wings. S800EVO. 3900. S1000" and S1000+

The DJI Spreading Wings series of small UA (S800EVO, 5900, S1000, and 51000+) are

manufactured commercially by DJI and available for purchase in the United States weighing less

than 55 pounds. These UA are modular in design and assembled by the purchaser. These small

UA vary from six (6) to eight (8) motors r,vhich will utilize either a DJI A2 Multi-Rotor

stabilization controller (Flight Controller) or a WooKong-M flight control system for

commercial, industrial and professional multi-rotor platforms. Failsafe procedures for operation

of these UA are set forth in the attached manufacturer's documentation. These UA will be

assembled, operated and maintained in accordance with manufacturers' specifications and

manuals, and Silverhawk's Operational Procedures (Attachments Q * DD). The Silverhawk

Operational Procedures are proprietary and are set forth in Attachment DD which willbe

submitted via email to : 3 3 3exemptions@faa. gov.

Page 2 of6
1. 5800 EVO 3800 EVO Release Notes (Attachment Q)

2. 5800 EVO User Manual vl.l0 (Attachment R)

3. 5800 EVO Usage Notes (Attachment S)

4. 5900 Release Notes (Attachment T)

5. 5900 User Manual v1.2 (Attachment U)

6. 51000 Release Notes (Attachment V)

7. S1000 User Manual vl.10 (Attachment W)

8. 51000+ Release Notes (Attachment X)

9. 51000+ User Manualvl.2 (Attachment Y)

10. A2 Flight Control System User Manual Y1.22 (AttacbrrrcntZ)

17. M Product Release Notes (Attachment AA)

12. WooKong Multi Rotor Product Release Notes (Attachment BB)

13. WooKong-M Quick Start Guide V1.14 (Attachment CC)

14. Silverhawk Operational Procedures Spreading Wings Series UA (Attachment DD -

proprietary document via email)

The tabular specifications for the DJI Spreading Wings series (Attachment EE) are submitted

as a proprietary document and will be emailed to: 333exemptions@faa.gov.

C. Transmitters

The Spreading Wings series of small UA will be operated with a Spektrum Model DX9

transmitter or a Futaba Model 14SG which are both FCC compliant.

1. The general specifications for the Spektrum Model DX9 are:

When utilizing this transmitter with any of the Spreading Wing series UA, operations will be

in accordance with the Spektrum DX9 Instruction manual which includes detailed specifications

(see Attachment FF, Spektrum DX9, Instruction Manual)I.

x the Spektrum DX9 Instruction Manual (Attachment FF) is comprised of 46 pages although the last page of text in

the document is numbered 223. The instruction manual may be downloaded at:

insuz / DSIVD(

I

lNumber of Channels

Itt tzzms

It - + tset to Mode 2 by default

Page 3 of6
2. The general specifications for the Futaba SG14 are:

A l4-channel system wrrh2.4 GHz FASSTest technology compatible with Futaba FASST

and S-FHSS protocols. The 14SG can transmit and receive telemetry data. When utilizing this

transmitter with any of the Spreading Wing series UA, operations will be in accordance with the

Futaba 14SG Instruction Manual whieh ineludes detailed specifications (see Attachment GG,

Futaba 14SG Instruction Manual).

Summary

The DJI, Phantom Vision 3, Standard, Professional and Advanced, and the DJI Spreading

Wings, Series S800EVO, 5900, S1000, and S1000+ will be operated in accordance with all

conditions and limitations as stated within Silverhawk's July 15,2015 exemption No. 12052. In

addition, these UA will be operated and maintained in conformance with all manufacturers'

documentation as required in the aforementioned documents and the Silverhawk Operational

Procedures.

Silverhawk is requesting that these aforementioned UA be added to the aircraft delineated

in FAA Exemption No. 12052 and is not reauesting an amendment to its prior proposed

ooerations. There is no change in the conditions and reasons relative to public interest and safety

that were the basis for granting the original exemption.

Publication in the Federal Register is unnecessar.y

The Administrator has stated that it may:

o'. 

. . issue a suflrmary grant when it finds it has already granted a previous

exemption similar to the new request. Summary grants are far more efficient

because they don't need to repeat the analysis performed for the original

exemption on which they are based. Summary grants are a tool the FAA can use

in all exemption areas, not just UAS.

The FAA's experience in reviewing the Section 333 petitions shows they

generally fall into two categories: film/television production and aerial data

collection. Most exemptions in these categories will likely be handled through the

summary grant process. For unique requests, the agency will still publish the

petition in the Federal Register for public comment and will conduct a detailed

analysis." Federal Aviation Administration. (2015). Petition for Exemption or

Rulemaking Retrieved March 8,2015, from:

http:i/Www.faa.gov/regulationsJolicies/rulemaking/petition/#exemptions

It is the position of Silverhawk that this request for an Amendment to Exemption 12052

is similar in all material respects to relief previously granted to Silverhawk in Grant of

Exemption No. 12052 dated July 15, 2015. Silverhawk is only adding a number of different UA

to the original request. There is no change in the conditions and reasons relative to public interest

and safety that were the basis for granting the original exemption.

http ://www.horizonhobby. com/pdfl SPMR9900-Manual_EN.pdf

Page 4 of6
Therefore, Silverhawk requests the Administrator issue a swnmary grant of Amendment

to Exemption 12052 in the instant request.

Summary Language if Necessary to Publish Request for Amendment to Exemption in the

Federal Register

Should the Administrator determine that this Request for Amendment to Exemption No.

12052 must be published in the Federal Register, Silverhawk provides the following summary

for the publication:

Silverhawk L.L.C. d/b/a Silverhawk Aerial Imaging (Silverhawk) seeks to amend

ExemptionNo. 12052 dated July 15,2015 by addingthe following small Unmanned Aircraft

(UA) to the Exemption: DJI, Phantom Vision 3, Standard, Professional and Advanced, and DJI

Spreading Wings, S800EVO, 5900, S1000, and 51000+. Silverhawk will operate the UA in

accordance with the prior operating conditions and limitations as set for the in FAA Exemption

t2052 and in accordance with the manufacturers' maintenance and operational specifications and

Silverhawk's Operational Procedures. There is no change in the conditions and reasons relative

to public interest and safety that were the basis for granting the original exemption.

Law Office of Darrell J. Green

Counsel for Silverhawk L.L.C. d/b/a Silverhawk Aerial lmaging

D6,U u/V""''''-";

David Terry

Silverhawk L.L.C. d/b/a Silverhawk Aerial Imaging

Attachments:

Attachment A - Phantom 3 Standard Release Notes

Attachment B - Phantom 3 Standard User Manual (EN) vt.2

Attachment C - Phantom 3 Standard Quick Start Guide (EN) v1.0

Attachment D - Phantom 3 Standard Safety Guidelines and Disclaimer vl.2

Attachment E - Charging Hub for Phantom 3 Intelligent Flight Batteries vl.0

Attachment F - Phantom 3 Professional Firmware vl.2

Attachment G - Phantom 3 Advanced Firmware vl.2

Attachment H - Phantom 3 Professional Release Note

Attachment I - Phantom 3 Advanced Release Note

Attachment J - Phantom 3 Professional Quick Start Guide (EN) v1.2

Attachment K - Phantom 3 Advanced Quick Start Guide (EN) vl.2

Sincerely,

Page 5 of6
Attachment L - Phantom 3 Professional User Manual (EN) vl.a

Attachment M - Phantom 3 Advanced User Manual (EN) vl.a

Attachment N - Phantom 3 Intelligent Flight Battery Safety Guidelines vl.0 @N)

Attachment O - Phantom 3 Professional and Advanced Safety Guidelines and Disclaimer vl.2

Attachment P - Silverhawk Operational Procedures Inspire and Phantom 3 Series UA -

Proprietary via email

Attachment Q - 5800 EVO Release Notes

Attachment R - 5800 EVO User Manual vl.lO

Attachment S - 5800 EVO Usage Notes

Attachment T - 5900 Release Notes

Attachment U - 5900 User Manual vl.2

Attachment V - S1000 Release Notes

Attachment W - 51000 User Manual v1.l0

Attachment X - 51000+ Release Notes

Attachment Y - 51000+ User Manualvl.Z

Attachment Z - A2 Flight Control System User ManualYl.22

Attachment AA - A2 Product Release Notes

Attachment BB - WooKong Multi Rotor Product Release Notes

Attachment CC - WooKong-M Quick Start Guide Vl.14

Attachment DD - Silverhawk Operational Procedures - Proprietary via email

Attachment EE - Tabular specifications for the DJI Spreading Wings series - Proprietary via

email

Attachment FF, Spektrum DX9, Instruction manual

Attachment GG, Futaba 14SG Instruction Manual

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