Cooley 

M. Anne Swanson 

+1 202 776 2534 

aswanson@cooley.com 

December 22, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

By Electronic Filing 

Re: Application for Amendment to Exemption 11520, AeroVironment, Inc. 

FAA Docket 2015-0330 

Dear Sir or Madam: 

On May 11, 2015, the FAA issued Exemption 11520 to AeroVironment, Inc. 

("AeroVironment") allowing commercial operation of the AeroVironment Shrike under 

Section 333 of the FAA modernization and Reform Act of 2012.

1 

This letter requests an amendment to add the following AeroVironment 

manufactured aircraft to Condition 1 of Exemption 11520 for commercial use in aerial 

data collection operations, which would include powerline inspections: 

1) AeroVironment Puma II AE 

2) AeroVironment Raven 

3) AeroVironment WASP 

4) AeroVironment Qube 

5) AeroVironment Boomerang 

AeroVironment is willing to accept what are now the standard conditions that the FAA 

issues in Section 333 exemptions for aerial data collection. (See, e.g., Exemption 

13996 issued to Texas-New Mexico Power Company.) 

To the extent necessary, AeroVironment refers the FAA to its previously filed exemption 

requests 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. 2 

AeroVironment notes that the FAA has granted similar exemptions for aerial data 

1 See Exemption No. 11520, May 11, 2015, Docket No. FAA-2015-0330. In addition to 

Exemption 11520, AeroVironment has received the following three Section 333 Exemptions: 

Exemption 11435, April27, 2015, Docket No. FAA-2015-0214 (AeroVironment Shrike); 

Exemption 11264, April 1, 2015, Docket No. FAA-2014-0762 (AeroVironment Puma AE DOL); 

and Exemption 11261, April1, 2015, Docket No. FAA-2014-0715 (AeroVironment PumaAE 

DOL). 

2 Applicant interprets Section 333 as placing a duty on the Administrator not only to process 

applications for exemptions under Section 333 but, if he determines that the conditions set forth 

herein do not fulfill the statutory requirements for approval, to craft conditions for the safe 

operation of the UAS. 

Cooley LLP 1299 Pennsylvania Avenue, NW, Suite 700 Washington, DC 20004-2400 

t: (202) 842-7800 f: (202) 842-7899 cooley.com 
Cooley 

U.S. Department of Transportation 

December 22, 2015 

Page Two 

collection. 3 For all the reasons set forth in AeroVironment's Section 333 exemption 

requests, which have been granted and are incorporated herein by reference, the FAA 

should grant AeroVironment's instant amendment request. 

If you have any questions, please contact us at your earliest convenience. 

( Ve~;I!C-

"----Counsel ~ for Swans AeroVironment~ , Inc. 

cc: Mr. Rick May 

Mr. Jake Troutman 

Mr. Dean Griffith, Esquire 

Mr. Dan Ngo 

Mr. Jo~athan Scott 

3 See, e.g., GR Innovative Mediaworks, Ltd., Exemption No. 14001, December 16,2015, Docket 

No. FAA-2015-3445; Texas-New Mexico Power Company, Exemption 13996, December 16, 

2015, Docket No. FAA-2015-3563. 

Cooley LLP 1299 Pennsylvania Avenue, NW, Suite 700 Washington, DC 20004-2400 

t: (202) 842-7800 f: (202) 842-7899 cooley.com