Cooley 

M. Anne Swanson 

+1 202 776 2534 

aswanson@cooley.com 

January 15, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. , SE 

Washington, DC 20590 

By Electronic Filing 

Re: Supplement to Application for Amendment to Exemption 11520, 

AeroVironment, Inc. 

FAA Docket 2015-0330 

Dear Sir or Madam: 

On May 11, 2015, the FAA issued Exemption 11520 to AeroVironment, Inc. 

("AeroVironment") allowing commercial operation of the AeroVironment Shrike under 

Section 333 of the FAA modernization and Reform Act of 2012. 1 On December 22, 

2015, AeroVironment filed an application to amend Exemption 11520 to add five 

AeroVironment manufactured aircraft? 

This supplement requests a further amendment to include the following additional 

aircraft in Exemption 11520 for commercial use in aerial data collection operations, 

including powerline inspections: 

1) Aerialtronics Altura Zenith 

As stated in its December 22, 2015 request for amendment, AeroVironment is willing to 

accept what have become the standard conditions that the FAA uses in summary 

processing of Section 333 exemption requests for aerial data collection.

3 

To the extent necessary, AeroVironment refers the FAA to its previously filed exemption 

requests for a listing of regulations for which an exemption is being sought, a 

demonstration of the public interest, and a showing of an equivalent level of safety.4 

1 See Exemption No. 11520, May 11 , 2015, Docket No. FAA-2015-0330. In addition to 

Exemption 11520, AeroVironment has received the following three Section 333 Exemptions: 

Exemption 11435, April27, 2015, Docket No. FAA-2015-0214 (AeroVironment Shrike); 

Exemption 11264, April 1, 2015, Docket No. FAA-2014-0762 (AeroVironment Puma AE DOL); 

and Exemption 11261 , April1, 2015, Docket No. FAA-2014-0715 (AeroVironment PumaAE 

DOL). 

2 AeroVironment's December 22, 2015 request for amendment has not yet been docketed. For 

reference, AeroVironment provides the FAA comment tracking number associated with that 

filing in hopes that these two submissions can be processed at the same time. That comment 

tracking number is 1jz-8myk-35q2. 3 See, e.g., Precision Overview, LLC, Jan. 13, 2016, Docket No. FAA-2015-4924. 

4 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 

Cooley LLP 1299 Pennsylvania Avenue, NW, Suite 700 Washington, DC 20004-2400 

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Cooley 

U.S. Department of Transportation 

January 15, 2016 

Page Two 

AeroVironment notes that the FAA has granted similar exemptions for aerial data 

collection using the Aerialtronics Altura Zenith specified in this amendment.5 For all the 

reasons set forth in AeroVironment's Section 333 exemption requests, which have been 

granted and are incorporated herein by reference, the FAA should grant 

AeroVironment's instant amendment request. 

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

( Vp ._truly ours, '--(). ~ ~ /1----------

M. Anne Swanson 

Counsel for AeroVironment, Inc. 

cc: Mr. Rick May 

Mr. Jake Troutman 

Mr. Dean Griffith, Esquire 

Mr. Dan Ngo 

Mr. Jonathan Scott 

Mr. Douglas Scott, Esquire 

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

operation of the UAS. 5 See Strat Aero International, Inc., Exemption No. 12655, August 28, 2015, Docket No. FAA2015-1606. 

Cooley LLP 1299 Pennsylvania Avenue. NW, Suite 700 Washington, DC 20004-2400 

t: (202) 842-7800 f: (202) 842-7899 cooley.com