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MICHAEL E. SIEVERS

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EMAIL: msievers@hunton.com

FILE NO: 39377.000097 January 5, 2016

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 Amendmen t to Exemption No. 11239A; Southern Company Services, Inc.

Dear Sir or Madam:

Southern Company Services, Inc. (“Southern” or “Pet itioner”) hereby respectfully requests an amendment to FAA Exemption No. 11239A, Docket No. F AA-2014-0838, to allow for the use of the following unmanned aircraft systems (“UA S”), and more particularly described on the attachment hereto (the “Additional UAS”), in ad dition 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 am ended, 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 Ex emption No. 11208 (Sky-Futures UAS Inc.), the DJI Phantom 3 in Exemption No. 11696 (Mi dwest UAV Imaging), and the DJI S1000, 3DRobotics X8+, and SenseFly eXom in Exempti on 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, we ight, 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 th e description of the operating documents

will need to be modified to include the technical m anuals for each of the Additional UAS. Accordingly, there will be no changes in the condit ions and reasons relative to public interest and safety that were the basis for the Existing Exe mption.

Since the requested amendment to Petitioner’s exemp tion would not set any precedent or raise any novel issue, and because Petitioner seeks to be gin these operations without delay, Petitioner respectfully requests that the FAA deter mine 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 me ans.

Based on the foregoing, Petitioner hereby requests that the FAA grant this petition and provide such further relief as deemed appropriate f or 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 58810518v1DOCKET NO. FAA-2014-0838 (Southern Company Services, Inc.)Additional UAS AmendmentNo.MakeModelTypeDescriptionWeight w/o Payload*Max. Flight Endurance1 Ascending Technologies Falcon 8 Rotorcraft (Octocopter) VTOL2.30 kg (5.07 lb) 22 minutes2 DJI Phantom 3 Rotorcraft (Quadcopter) VTOL, retractable gear 1.28 kg (2.82 lb) 23 minutes3 DJI S1000 Rotorcraft (Octocopter) VTOL, retractablegear 4.2 kg (9.26 lb) 15-20 minutes4 3DRobotics X8+ Rotorcraft (Quadcopter) VTOL, retractable gear 2.56 kg (5.6 lb) 15 minutes5 SenseFly eXom Rotorcraft (Quadcopter) VTOL1.70 kg (3.7 lb)** 22 minutes*All indicated weights are taken from publicly available specifications and are without payloadexcept as otherwise noted.Any weights specified with payload are providedonly for reference and not by way of limitation.**Weight includes integrated payloads.Page 1 of 1