September 11 , 2015

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

Re: Amendment to Granted Section 333 Exemption 11533 & COA FAA

- 2015

- 0462

- 333E

.

Dear Sir or Madam:

AviTronics Integrated Solutions, LLC (“AviTronics”), the operator

, David A. Akers (the applicant), planned operator of Unmanned Aircraft Systems ( UAS s ) equipped to conduct aerial photography and digital point cloud survey s for various industries hereby applies for a n amendment to previously granted E xemption 11533, to allow commercial operation of additional UAS s , so long as such operations are conducted within and

under the conditions outlined in the granted E xemption and accompanying Certificate of

Authorization FA A

- 2015

- 0462

- 333E.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The appli cant proposes that the amendment requested herein apply to civil aircraft that

have the characteristics of UAS and that operate wi th the limitations listed in E xemption

11533 and COA FAA

- 2015

- 0462

- 333E

. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure as the proposed operations represent a safety enhancement to the already safe aerial commercial photogr aphy and survey operations conducted with conventional aircraft.

The additional UAS s planned to be operated are the DJI Phantom 3 Advanced and DJI

Phantom 3 Professional rotorcraft . Each unmanned aircraft (UA) is equipped with four

rotors that are driven by electric motors

, powered by batteries, and weigh less than 4 pounds

, including payload. The UA would have a maximum airspeed of 30 knots. The principal construction material of these UA is plastic. Operation s will be performed in

accordance with previously granted E xemption and issued COA , to insure that the UAS

will "not create a hazard to users of the national airspace system or the public." Given

the small size of the UAS involved and the pre

- planned environment within which they will op erate, the applicant believes that these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also, operation in a researched (to include applicable NOTAMs), pre

- defined area will prevent the possibility of a national secur ity issue. The operation of UAS s by knowledgeable professionals with experience in the NAS will serve to enhance safety, add to the p ublicbenefit and reduce environmental impacts related to current methods of aerial

photography and survey.

It is the applicant's belief that the size, speed, operating environment, limitations

, and level of applicant's experience provides an "equivalent level of safety" or better when operating a UAS for the public interest as outlined in Section 333 in the FAA

Modernization and Reform Act of 2012. I t is requested that the FAA issue an amendment to granted E xemption 11533 and COA FAA

- 2015

- 0462

- 333E to pe rmit safe, legal, commercial UAS operation by the applicant as soon as possible.

Sincerely,

David Akers, President AviTronics Integrated Solutions, LLC

P.O. Box 1644 Rockwall, TX 75087

972

- 708

- 1535

Appendix A DJI Phantom 3 Advanced User Manual Appendix B DJI Phantom 3 Professional User Manual