U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE Washington, DC

20590

Re: Application for Amendment to Exemption No. 12610- Patrick C. Randall

; FAA Docket No. FAA-2015-2450

Dear Sir or Madam:

On August 26, 2015, the FAA issued Exemption No. 12610 to Mr. Roger W. Meyer, PLS, d.b.a. 

Montana Land Surveys ("Mr. Randall"), allowing commercial operations using the DJI Phantom 3 and 

DJI Inspire 1 under Section 333of the·FAA Modernization and·Reform Act of 2012. Mr. Randall now

respectfully applies for an amendment to Exemption No: 12610 to allow Mr. Randall to operate

additional UAS under the same conditions as approved in Exemption No. 12610.

Mr. Randall seeks exemption for the following additional UAS, which have already been approved 

under similar exemptions as indicated below, for similar purposes related to aerial data collection:

3D Robotics X8+

Specifications: 

 Battery: 4S 14.8V 10,000 mAh 10C

 Battery Dimensions: 6.6 in x 2.6 in x 1.4 in (16.7 cm x 6.5 cm x 3.5 cm)

 Battery Weight: 803 g

 Autopilot hardware: Pixhawk v2.4.5

 Autopilot firmware: ArduCopter 3.2

 GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update)

 Ground Station Radio: 3DR Radio v2 (915 MHz or 433 MHz)

 Motors: SunnySky V2216-12 KV800 II (The images above show conical nuts; X8+ ships with hex 

nuts.)

 Controller: FlySky FS-TH9X with FrSky telemetry module

 Frame Type: X

 Propellers: APC Propeller 11x4.7 SF (4), APC Propeller 11x4.7 SFP (4)

 Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm)

 Payload Capacity: 800 g (1.7 lbs). Additional payload possible up to over 1kg with reduced flight time.

 Vehicle Weight with Battery: 2.56 kg (5.6 lbs)

 Maximum Estimated Flight Time: 15 min

This small unmanned aerial system (sUAS) is a multi-rotor vertical take-off and landing (VTOL)

weighing less than 55 lbs including payload. Each UAS is battery- powered and allows for piloted

control or the use of flight management software and onboard GPS for mission planning and

monitoring. Each additional UAS will have a camera for collection of images that will be used for the

aerial imaging purposes outlined in the original petition. And each additional UAS allows for manual

control to override any autonomous actions or to manually initiate autonomous actions to return home
or land. Accordingly, each additional UAS has substantially the same capabilities, will be operated in

substantially the same manner, and will be operated for substantially the same purpose as the UAS

permitted under current Exemption No. 12610.

Relevant operating documents, including Operation Manuals, Flight Checklist, and/or Safety Manuals for

the 3D Robotics X8+, which may be updated and/or revised from time to time, are incorporated by

reference and are available in other Exemption files, such as those referenced herein, and are also

available online, such as those located at the web addresses cited in the postscript below. Mr. Randall

will continue to operate UAS in compliance with all federal, state, and local regulations, as well as the

UAS manufacturers' recommendations and the terms of the Exemption.

There has been no change in the conditions or reasons relative to public interest, benefit, and safety that

were the basis for granting the original exemption. To the extent necessary, Mr. Randall refers the FAA

to its original exemption request submitted in Docket No. FAA-2015-2540 for a listing of regulations, as

amended by Exemption No. 12610, for which a waiver is being sought and the reasons why such waiver

is being sought, a demonstration of public interest, and a showing of an equivalent level of safety.

Finally, because this request seeks only to add additional types of UAS under an existing exemption,

and because the UAS have previously been approved for commercial use under other exemptions

(listed above), and further because the conditions under which Mr. Randall will operate remain

essentially the same, notice need not be provided in the Federal Register nor public comment solicited.

For reference, contact information for Mr. Randall is:

Patrick C Randall

160 Mesa Ave.’

Newbury Park, CA 91320

Phone: 805 390-5501

Email: prandall_2000@yahoo.com

Patrick C. Randall

Postscript:

• 3D Robotics X8+ Operations Manual: https://3drobotics.com/wp-content/uploads/2015/04/X8-

Operation-Manual-vC.pdf

• 3D Robotics X8+ Flight Checklist: https://3drobotics.com/wp-content/uploads/2015/04/X8-ChecklistvB.pdf

• 3D Robotics X8+ Flight Checklist: https://3drobotics.com/kb/drone-safety/