Mark McKinnon

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102-4832

United States

email: mark.mckinnon@dentons.com

T 703.336.8808

F 703.336.8750

Salans FMC SNR 

Denton

McKenna Long

dentons.com

February 1, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Amendment to Exemption 11400A (Docket No. FAA–2015–0155)

To Whom it May Concern:

As you are aware, this office represents Contend LLC ("Contend")regarding the abovereferenced Petition for Exemption, which was granted on July 8, 2015. Contend hereby requests 

an amendment to its Exemption to include several additional aircraft, the DJI Inspire 1, DJI 

Inspire 1 Pro, Gryphon Dynamics X8, Freefly Alta, DJI S1000, DJI Phantom 2, DJI Phantom 2 

Vision, DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Matrice.

I. The Proposed UAS Operations Meet the Requirements of Section 333 of the Reform 

Act

Based on their weight, size and operational capabilities, all of the UAS requested to be 

added to this Exemption meet the requirements of the FAA Modernization and Reform Act of 

2012. Accordingly, all of the requirements to operate these vehicles been satisfied and the 

petition is suitable for a summary grant. 

DJI Inspire: See, Exemption No. 11254 to Upward Aerial; Exemption No. 11659 to 

Fovea Aero Systems; Exemption No. 11668 to Sky-Forge Robotics LLC. 

Gryphon Dynamics X8: See, Exemption No. 12381 to Bryan Harvey Films;

Freefly Alta, See, Exemption No. 12830 to Aerial Experts, LLC;

DJI S1000, See, Exemption No. 12793 to West Coast Aerial Productions;

DJI Phantom 2, See, Exemption No. 13405 to Skydrone UAVS, Inc.;

DJI Phantom 2 Vision, See, Exemption No. 13342 to Blue Sky Crop Consulting;

DJI Phantom 2 Vision+, See, Exemption No. 12796 to Richard W. Moore;

DJI Phantom 3, See, Exemption No. 12800 to William English;
February 1, 2016

Page 2

Salans FMC SNR Denton

McKenna Long

dentons.com

 

DJI Matrice, See, Exemption No. 12697 to Django Greenblatt-Seay.

DJI Inspire 1 Pro: At the time of this filing, it does not appear that permission has 

previously been granted to operate the Inspire 1 Pro. However, the Inspire 1 Pro is substantially

similar in its design, weight, and operating characteristics to the Inspire 1. There are currently 

pending 143 Petitions for Exemption seeking permission to operate the Inspire 1 Pro, and all of 

the technical information regarding the Inspire 1 has been previously submitted to the FAA. See,

FAA-2015-6764-0001. 

As this is an amendment to an existing exemption seeking the addition of a 

supplementary UAS model that is substantially similar to the one currently authorized for use 

under the Exemption, contend respectfully submits that good cause exists so that notice does not 

need to be published in the Federal Register for the requested amendment.

II. The Requested Amendment is in the Public Interest

The above listed UAS offer substantial safety benefits for aerial data collection over 

conventional operations using helicopters or fixed wing aircraft. 

If you have any questions regarding this amendment, or require any additional 

information to process this Petition, please do not hesitate to contact us. 

Very Truly Yours, 

Mark E. McKinnon

Counsel for Contend LLC