200 Mamaroneck Ave, Suite 304®

11 Broadway, Suite 615 White Plains, NY 10601
New York, NY 10004 p 914.948.8044

r 914.948.8058 Alimonti Law Offices, P.C. VIA Elec tr on i
• .iling U. S. Department
of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 December 31,2015 RE: Petition for Amendment Rotor Air Cam, LLC Exemption Number: 11995 Docket Number: 2015-1230 Dear Sir/Madam: Pursuant
to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Rotor Air Cam, LLC ("Rotor") respectfully applies for an amendment

to its current UAS Exemption (No. 11995) and COA. The sole purpose of this amendment

is to extend Rotor's current COA so that it conforms with its current Exemption (No.11995) and extends permissible operations from that of the Blanket COA of 200' AGL to a more practical 400' AGL. In seeking this exemption, Rotor respectfully notes the following: Reason for R guest Certain applications

of aerial mapping and surveying are best accomplished over 200' AGL. This is particularly applicable

to surveys of various towers and stacks, often having

a height in excess of 200' AGL, e.g., power lines and towers, oil well pads, oil flare stacks, and chimneys,

to name

a few. In all such examples, the additional altitude will help ensure additional and adequate obstacle clearance. The Altitude Extension

is in the Public Interest We respectfully submit that the requested extension
of Rotor's COA to 400' AG L will not adversely affect safety, and is in fact

a safety enhancement. We respectfully note further as follows:Petition for Amendment: Exemption# 11995/Docket No. 2015-1230 Page2
•Rotor's current exemption allows for operations "no morethan 400 feet above ground level (AGL)." This requestwill conform Rotor's COA to its granted Exemption.
As youareaware,this 400' AGL limit is the uniform ceiling for SUAS operations

in the vast majority of approved Exemptions. •Section 107.51 of the proposed S U ASFARs provides for the operation of SUAS systemsbelow 500',

1 00' above the minimum Rotor now proposes. •By restricting
its operations

to non-congested areas, operations below 400' AGL will effectively createa 1 00' buffer from operating manned aircraft asRotor will operate
atanaltitude and proximity

toobstacles prohibited
by FAR 91.119. •The increased altitude will enhance the visibility
of the SUAS tothe operatorand observer
in areas having obstructions, and/or in hilly terrain. •The increased altitude will offer more landing options in the eventof an unplanned controlled descent and/or loss of power. Accordingly, RotorAir Cam, LLC respectfully requeststhat its current Exemption (No.l1995) and associated COA be amended
to modify Section "C", Flight Planning, paragraph (1)from allowing operations

atorbelow 200' AGL to"atorbelow 400' AGL." Wealso notethat weareamenable

to increasing the minimum distance from airports
asset outin Section "C", paragraph

2toadistance acceptable

tothe Administrator

if it is thought that this will further enhance safety. Rotorseeks noother amendment

toits currentCOA and Exemption and will nototherwise modify its approved operations. Thank youfor yourtime and consideration. Sincerely,----

--------- **~~ ~~~**  Frederick Alimonti Counsel
toRotorAir Cam LLC Alimonti Law Offices, PC 200 Mamaroneck

A venue White Plains, NewYork 10601 (914) 948-8044 fpa@alony.com