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 
THO MI NE ON 

H - 

June 4, 2015 

Page 2 

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. 

1To the extent that the FAA requires another submission of the technical manuals, Southern would 

be happy to comply with FAA's request.