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785­261­9591 ­ ​www.apisremote.com

U.S. Department of Transportation /

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

For: Request for Amendment to Exemption No. 11567, Regulatory Docket No.

FAA–2015–0388 Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations Concerning Operation of an Unmanned Aerial System Pursuant to

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

Submitted: July 11, 2015

Beau Dealy

Managing Partner

Apis Remote Sensing Systems, LLC

1702 Agnes Dr

Hays, Kansas 67601

785­261­9591

beau@apisremote.com
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785­261­9591 ­ ​www.apisremote.com

July 11, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Amendment to Exemption No. 11567, Regulatory Docket No.

FAA–2015–0388 Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 C.F.R. Part 11, Apis Remote Sensing Systems, LLC (Apis), seeks to

amend exemption No. 11567, Regulatory Docket No. FAA–2015–0388; submitted by

Apis for review February 16, 2015 and subsequently granted by the FAA on May 12,

2015.

The original exemption made a request to allow operations of the AgEagle Robotic

Aircraft System (AgEagle) for commercial operations in precision agriculture, market

research, surveying, mapping and inspection. This letter requests the addition of the DJI

Phantom 3 Professional (Phantom 3) multirotor aircraft for commercial use in the

aforementioned service operations.

The Phantom 3 is a multirotor aircraft weighing approximately 2.83 pounds, including its

power supply and camera payload. It has a maximum operating speed of approximately

31 knots. Like the AgEagle, operations safety failsafes of the Phantom 3 will be

augmented and enhanced utilizing the autopilot and data processing solution provided

by DroneDeploy, a San Francisco, California­based company.

Apis will adhere to the safety and maintenance guidelines set forth by the DJI, Inc., the

manufacturer of the Phantom 3, as outlined in the operations manual. The manual is

made available by the manufacturer at http://www.dji.com/support.

Pursuant to the summary exemption process by which exemption No. 11567 was

approved, Apis puts forth that similar circumstances exist for the operation of the

Phantom 3. Approval for exemption No. 11567 as part of the summary exemption
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785­261­9591 ­ ​www.apisremote.com

process was granted in the context of the material respects presented in Grants of

Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to

Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No.

FAA−2014−0642). In these circumstances, 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, gives the

FAA good cause to find that the UAS operation enabled by this exemption is in the

public interest.” To that extent, Apis pledges to operate the Phantom 3 under the same

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“Conditions and Limitations” put forth by the FAA in the original exemption approval.

Further details regarding Apis Remote Sensing Systems, and its mission to bring

unmanned systems technology to the rural marketplace can be found in Appendix B of

the original exemption request. Likewise, Appendix C of the original application makes

point of the reliability, fault tolerance, and emergency procedures specific and inherent

to our utilization of the DroneDeploy system.

Apis is prepared to amend or append this request in order to satisfy the requirements of

safe operation as new standards and requirements continue to evolve. Please do not

hesitate to contact us concerning any additional requirements, materials, or clarification.

With sincere regards,

Beau Dealy

Managing Partner

Apis Remote Sensing Systems, LLC

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