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October 16, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Keystone Aerial Surveys, Inc. Petition to Amend Section 333 Exemption No. 11472, Docket No. FAA-2015-0301 Keystone Aerial Surveys, Inc. (Keystone) petitions to amend its small Unmanned Aerial Systems (sUAS) Section 333 Exemption (No. 11472) to include the following Vertical Takeoff and Landing (VTOL) aircraft: DJI Spreading Winds S1000+ and SteadiDrone Mavrik X8. Below are summaries of each aircraft: • The DJI Spreading Wings S1000+ is an octocopter rotor aircraft that has been included in hundreds of exemptions through September 2015, most notably Nos. 

### 11571, 12574 and 12112 were granted for use in aerial survey missions similar to those requested to be conducted by Keystone. • The SteadiDrone Mavrik X8 is an octocopter rotor aircraft that has been included in Exemption Nos. 11914, 12078 and 11230A for use in aerial survey missions similar to those requested to be conducted by Keystone. These aircraft will allow Keystone to better serve its clients through greater flexibility in airborne capture and sensor type. Keystone will be able to use the aircraft for small area collection (less than 10 acres) in a cost effective manner and with a more robust image sensor and great image capture angle. A previous amendment (No. 11472A) altered item #1 of the original exemption to state: 1. Operations authorized by this grant of exemption are limited to the Altavian Nova F6500, DJI Phantom 3, DJI Inspire 1, Altavian Nova R8400, 3D Robotics X8-M, and SteadiDrone Mavrick X4 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

Keystone proposes that item #1 be further amended to read: 1. Operations authorized by this grant of exemption are limited to the Altavian Nova F6500, DJI Phantom 3, DJI Inspire 1, Altavian Nova R8400, 3D Robotic,s X8-M, SteadiDrone Mavrik X4, SteadiDrone Mavrik X8 and DJI Spreading Wings S1000+ when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

Northeast Philadelphia Airport o P.O. Box 21059 Philadelphia, PA 19114 • V:215.677.3119 • F:215.464.2889 

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### AIl operations of these aircraft will continue to be in accordance with the exemption

previously granted, including, but not limited to, operation below 400 ft., visual line of sight piloting by FAA certificate holders, less than 55 pound weight of system with payload and a speed not to exceed 87 knots. Keystone is NOT requesting any change in its proposed use. Keystone's Flight Operations Manual (submitted with previous exemption request) contains special instructions for the operation of rotor craft. These and other pilot instructions for all UAS will be followed in order to maintain the safety of the crew and ground participants.


### A User Manual for the Mavrik X8 is available here: https://onedrive.live.com/redir?resid=A430DE0FF38CC7C2! 244232&authkex =!ALTAtTON82qcWMk&ithint=file%2cpdf

A User Manual for the DJI S1000 is available here: htt2s://onedrive.live.com/redir?resid=A430DE0FF38CC7C2! 244231&authke,y =!AL57X CW-C3IaNM&ithint=file°lo2cpdf

Sincerely, 

# b~ David Day Executive Viceresident Keystone Aerial Surveys, Inc.

Northeast Philadelphia Airport • P.Q. Box 21059 Phitadetphia, PA 19114 • V:215.677.3119 • F:215.464.2889 

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