# THompSON ATLANTA CLEVELAND DAYTON WASHINGTON, D.C.



# HINE CINCINNATI COLUMBUS NEW YORK

June 4, 2015


### Via Regulations.gov

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. Washington, D.C. 20590

Re: Docket No. FAA-2014-0838, Petition for Amendment to Exemption No. 11239, Southern Company Services, Inc.

Dear Sir or Madam:

Southern Company Services, Inc. ("Southern" or "Petitioner") hereby requests an amendment to FAA Exemption No. 11239, Docket No. FAA-2014-0838, to allow for the use of the following unmanned aircraft systems ("UAS"), in addition to the Aeryon Skyranger, and for the additional purpose of aerial inspection of utility infrastructure and to conduct flight training and demonstration: • DJI Inspire 1 • DJI Phantom 2 Vision Plus • SenseFly eBee • SkyCatch

The small UAS authorized in the original grant, the Aeryon Skyranger, is comparable in type, size, weight, speed and operating capabilities to those listed above and the subject of this petition.

The FAA previously determined the airworthiness of the DJI Inspire 1 in Exemption No. 11295 (RoboFlight Systems LLC) and Exemption No. 11279 (CineDrones, LLC). The FAA previously determined the airworthiness of the DJI Phantom 2 Vision Plus in Exemption No. 11260 (First Flight Photography, LLC) and Exemption No. 11295 (RoboFlight Systems LLC). The FAA previously determined the airworthiness of the SenseFly eBee in Exemption No. 11441 (Eagle UAV Services) and Exemption No. 11285 (Chustz Surveying, Inc.). Lastly, the FAA previously determined the airworthiness of the SkyCatch in Exemption No. 11109 (Clayco, Inc.) and Exemption No. 11343 (Woolpert, Inc.).

All operations of the additional UAS will be in full compliance with the terms of our current FAA Exemption No. 11239 (the "Exemption"). Condition/limitation number one of the Exemption will need to be modified to include the DJI Inspire 1,

THOMPSON HINE LLP 1919 M Street, N.W. www.ThompsonHine.com

ATTORNEYS AT LAW Suite 700 Phone 202.331.8800 Washington, D.C. 20036-3537 Fax 202.331.8330

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DJI Phantom 2 Vision Plus, the SenseFly eBee and the SkyCatch aircraft. The description of the operating documents will also need to be modified to include DJI's, SenseFly's and SkyCatch's technical manuals for these aircraft. Other than an expansion of the purposes, the addition of the aircraft listed above, and the operating documents, there will be no change in the conditions and reasons relative to public safety that were the basis for the initial grant of exemption. Technical manuals for the aircraft listed above have already been submitted in connection with FAA's previous airworthiness determinations.l

Since the requested amendment to Southern's exemption would not set any precedent or raise any novel issue, and because Petitioner seeks to begin these operations without delay, Southern respectfully requests the FAA to determine that good cause exists to dispense with publication of the summary of this petition in the Federal Register and grant the requested amendment expeditiously by summary

means.
Based on the foregoing, Petitioner hereby requests that the FAA grant this petition and provide such further relief as deemed appropriate for the operations proposed herein.

Please feel free to contact the undersigned if you should have any questions.

Respectfully submitted,

G. Brent Connor Jason D. Tutrone Counsel for Southern Company Services, Inc.

Cc: James Williams, FAA Robert Pappas, FAA Dexter Lewis, Southern Company Services, Inc. Joe Schatz, Southern Company Services, Inc. Griff Waters, Southern Company Services, Inc.

1 To the extent that the FAA requires another submission of the technical manuals, Southern would be happy to comply with FAA's request.