September 11 , 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Application for Amendment to Exemption No. 12663, Seiler Instrument FAA Docket 

2015-2130 

Dear Sir or Madam: 

Seiler Instrument ("Seiler") is requesting an amendment to add the following aircraft to 

Exemption No. 12663 for commercial use in aerial data collection: 

1. Trimble ZX5 

2. 3D Robotics Iris 

3. 3D Robotics SOLO 

4. DJI Phantom 3 

5. DJI Inspire 1 

The Trimble ZX5 is a rotorcraft weighing a maximum of 11 lbs. at takeoff, with payload. 

It will not operate at a speed greater than 87 knots. Preflight maintenance will be accomplished 

as set forth in the Operations Manual submitted with this request. 

The 3D Robotics Iris is a rotorcraft weighing a maximum of 4.5 lbs. at takeoff, with 

payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request. 

The 3D Robotics SOLO is a rotorcraft weighing a maximum of 4.5 lbs. at takeoff, with 

payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request. 

The DJI Phantom 3 is a rotorcraft weighing a maximum of 4.51bs. at takeoff, with 

payload. It will not operate at a speed greater than 87 knots. Preflight maintenance will be 

accomplished as set forth in the Operations Manual submitted with this request. 

The DJIInspire 1 is a rotorcraft weighing a maximum of 71bs. at takeoff, with payload. It 

will not operate at a speed greater than 87 knots. Preflight maintenance will be accomplished 

as set forth in the Operations Manual submitted with this request. 

All the listed aircraft will be operated in accordance with the procedures set forth in the 

submitted manuals. The FAA has issued exemption grants in circumstances similar in all 

material respects to those presented in this petition. In Exemption No. 111108 to Trimble 

Navigation (see Docket No. FAA-2014-0367), No. 11062 to Astraeus Aerial (see Docket No. 

FAA-2014-0352), No. 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), No. 11112 to 

VDOS Global, LLC (see Docket No. FAA-2014-0382), and No. 11213 to Aeryon Labs, Inc. (see 

Docket No. FAA-2014-0642), the FAA found that the enhanced safety achieved using an 

unmanned aircraft ("UA") with the specifications described by the petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions carrying 
crew in addition to flammable fuel, gave the FAA good cause to find that the UAS operation at 

issue was in the public interest. 

To the extent necessary, Seiler refers the FAA to its original exemption request 

submitted in Docket FAA-2015-2130 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. 

Based on the foregoing and for all the reasons set forth in Seiler's previous filings in Docket 

2015-2130, which are now incorporated by reference, Seiler notes that the FAA has granted 

similar exemptions, as set forth above, for aerial data collection, and it, therefore, believes that 

this amendment request is subject to the FAA's already announced Summary Exemption 

Process. 

Very truly ypurs, 

~~~ 

2 

Tom Seiler 

Seiler Instrument 

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