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 (UASs) equipped to

conduct aerial photography and digital point cloud surveys for various industries hereby 

applies for an amendment to previously granted Exemption 11533, to allow commercial

operation of additional UASs, so long as such operations are conducted within and 

under the conditions outlined in the granted Exemption and accompanying Certificate of 

Authorization FAA-2015-0462-333E.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the amendment requested herein apply to civil aircraft that

have the characteristics of UAS and that operate with the limitations listed in Exemption 

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 photography and survey operations conducted with conventional aircraft.

The additional UASs 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. Operations will be performed in 

accordance with previously granted Exemption 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 operate, 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 security issue. The operation of UASs by knowledgeable 

professionals with experience in the NAS will serve to enhance safety, add to the public 
benefit 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. It is requested that the FAA issue an

amendment to granted Exemption 11533 and COA FAA-2015-0462-333E to permit 

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