ATLANTA AUSTIN BANGKOK BEIJING BRUSSELS CHARLOTTE DALLAS HOUSTON LONDON LOS ANGELES 

McLEAN MIAMI NEW YORK NORFOLK RALEIGH RICHMOND SAN FRANCISCO TOKYO WASHINGTON 

www.hunton.com 

HUNTON & WILLIAMS LLP 

RIVERFRONT PLAZA, EAST TOWER 

951 EAST BYRD STREET 

RICHMOND, VIRGINIA 23219-4074 

MICHAEL E. SIEVERS 

DIRECT DIAL: 804 • 788 • 8532 

EMAIL: msievers@hunton.com 

January 5, 2016 FILE NO: 39377.000097 

Via Regulations.gov 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. FAA-2014-0838; Petition for Amendment to Exemption No. 11239A; 

Southern Company Services, Inc. 

Dear Sir or Madam: 

Southern Company Services, Inc. (“Southern” or “Petitioner”) hereby respectfully requests an 

amendment to FAA Exemption No. 11239A, Docket No. FAA-2014-0838, to allow for the 

use of the following unmanned aircraft systems (“UAS”), and more particularly described on 

the attachment hereto (the “Additional UAS”), in addition to those UAS permitted under 

Exemption No. 11239 (March 26, 2015), as previously amended by Exemption No. 11239A 

(August 19, 2015) (the original exemption, as so amended, being hereinafter referred to as, 

the “Existing Exemption”): 

• Ascending Technologies (AscTec) Falcon 8 

• DJI Phantom 3 

• DJI S1000 

• 3DRobotics X8+ 

• SenseFly eXom 

The FAA has determined the airworthiness of each of the Additional UAS in connection with 

multiple prior exemption grants. By way of example, the airworthiness of the Ascending 

Technologies (AscTec) Falcon 8 was determined in Exemption No. 11208 (Sky-Futures UAS 

Inc.), the DJI Phantom 3 in Exemption No. 11696 (Midwest UAV Imaging), and the DJI 

S1000, 3DRobotics X8+, and SenseFly eXom in Exemption No. 12106 (Duke Energy 

Business Services, LLC).1

 

1

 The foregoing list of precedent exemptions is not a comprehensive list of all exemptions granted with

respect to each of the Additional UAS but rather a singular example for each. 
U.S. Department of Transportation 

January 5, 2016 

Page 2 

The Additional UAS are comparable in type, size, weight, speed, and operating capabilities as 

those in the Existing Exemption and all operations of the Additional UAS will be in full 

compliance with the terms of thereof. Condition No. 1 to the Existing Exemption will only 

need to be updated to add the Additional UAS and the description of the operating documents 

will need to be modified to include the technical manuals for each of the Additional UAS. 

Accordingly, there will be no changes in the conditions and reasons relative to public interest 

and safety that were the basis for the Existing Exemption. 

Since the requested amendment to Petitioner’s exemption would not set any precedent or raise 

any novel issue, and because Petitioner seeks to begin these operations without delay, 

Petitioner respectfully requests that the FAA determine that good cause exists to dispense 

with publication of the summary of this petition in the Federal Register and grant the 

requested amendment expeditiously and by summary means. 

Based on the foregoing, Petitioner hereby requests that the FAA grant this petition and 

provide such further relief as deemed appropriate for the operations proposed herein. 

Please feel free to contact the undersigned in the event you have any questions. 

Respectfully submitted, 

Michael E. Sievers 

Counsel for Southern Company Services, Inc. 

Attachment – Description of Additional UAS 

cc: Marke “Hoot” Gibson, FAA 

 Earl Lawrence, FAA 

 Dexter Lewis, Southern Company Services, Inc. 

 Joe Schatz, Southern Company Services, Inc. 

 Griff Waters, Southern Company Services, Inc. 

39377.000097 EMF_US 58810518v1 
DOCKET NO. FAA-2014-0838 (Southern Company Services, Inc.)

Additional UAS Amendment

No. Make Model Type Description Weight w/o Paylo

1 Ascending Technologies Falcon 8 Rotorcraft (Octocopter) VTOL 2.30 kg (5.07 lb

2 DJI Phantom 3 Rotorcraft (Quadcopter) VTOL, retractable gear 1.28 kg (2.82 lb3 DJI S1000 Rotorcraft (Octocopter) VTOL, retractable gear 4.2 kg (9.26 lb4 3DRobotics X8+ Rotorcraft (Quadcopter) VTOL, retractable gear 2.56 kg (5.6 lb5 SenseFly eXom Rotorcraft (Quadcopter) VTOL 1.70 kg (3.7 lb)

*All indicated weights are taken from publicly available specifications and are without payload except as otherwise noted . Any weights spec

only for reference and not by way of limitation.

 **Weight includes integrated payloads.

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