August 20, 2015

Amendment

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Exemption No. 12523

Regulatory Docket No. FAA-2015-0986

Submitted Electronically via the Federal Docket Management System (FDMS)

Re: Amendment to add additional Unmanned Aerial Systems to current 

Exemption No. 12523

Dear Sir or Madam:

I, Brett Kanda, Partner at Verascan Inc., have prepared the following amendment

to our Current Exemption No. 12523 approved on August 20, 2015. This 

amendment allows for the inclusion of one additional Fixed Wing system and four 

additional Vertical Take-Off and Landing (VTOL) Multi-Rotor UA's as follows:

• Parrot Sensefly eBee RTK Fixed Wing, Under 9lbs Single Motor UA

• Parrot Sensefly eXom, Under 31 lbs (4 Motor), Multi-Rotor UA

• A DJI Phantom 2 Vision+, Under 31lbs (4 Motor) Multi-Rotor UA

• A DJI Phantom 3, Under 31lbs (4 Motor) Multi-Rotor UA

• Ascending Technologies Falcon 8, Under 31lbs ( 8 rotor) Multi-rotor UA
CHARACTERISTICS OF THE AIRCRAFT: The eBee is a small (38 inches 

wingspan) and ultra-light (maximum take-off weight of 1.7 pounds) platform made 

of flexible foam that performs precision aerial mapping missions thanks to the 

onboard GPS and the related flight management software (eMotion) that allows 

the operator to plan safely and efficiently a mission in 3D, and then monitor it in 

real-time. The four main characteristics of the eBee are: 

a. Very light weight The eBee is so light that the operator can launch it by hand 

and let it land on almost any surface without requiring a parachute or landing net 

(belly land). Its low kinetic energy (60 Joules (“J”) at cruise speed) also 

significantly reduces the risk of hazardous situations. Finally, the wings of the 

eBee are detachable and made of flexible foam with no sharp or hard edges and 

almost no internal strengthening structure. 

b. Electric-powered The eBee is electric-powered. A brushless engine technology 

makes it silent and reliable. The propeller is attached with two rubber bands to 

the body of the plane so that it can easily flex away in case of contact with any 

object. 

c. Semi-automatic flight The artificial intelligence incorporated within the eBee 

autopilot system continuously analyzes data from the Inertial Measurement Unit 

and from the onboard GPS and takes care of all the aspects of the flight under 

the supervision of the operator. 

d. Option for Manual control Additionally, the eBee provides an override 

capability that allows the operator to take manual actions during the flight (Go to 

Home, Go Land, Hold and Resume the mission) and also suspend automated 

operations and take manual control of the aircraft should it become necessary to 

respond emergent circumstances, thanks to the remote controller provided with 

the system.

CHARACTERISTICS OF THE AIRCRAFT:

1 flight, 3 types of imagery With eXom you can switch between capturing video, 

still and thermal imagery during the same flight, without landing to change 

cameras. The field of view remains unobstructed throughout the 180o vertical 
range of motion allowing you to capture clear and stabilized imagery ahead, 

above and below the drone. · Advanced situational awareness eXom features 

five dual-sensor modules, positioned around the drone. These provide the 

situational awareness required to operate eXom close to structures and surfaces, 

to achieve sub-millimetre image resolutions (without the movement issues 

sometimes caused by zooming from afar, and even in confined environments). ·

Choose your flight mode eXom offers full flight mode flexibility. Choose the mode 

that best fits your project: an Autonomous, GPS-guided mapping mission or a 

live-streaming Interactive ScreenFly flight. Or start in mapping mode and ‘go live’ 

on demand.

CHARACTERISTICS OF THE AIRCRAFT:

• The DJI Models: Phantom 2 Vision+ and Phantom 3 are lightweight (under

551b gross weight), battery operated Multi-Rotor VTOL aircraft

• Each uses an on-board flight computer with GPS navigation and location ability 

that receives signals for flight controls from a ground-based transmitter/controller

• The Phantom 2 Vision+, Phantom 3 have an on-board camera attached to the 

UA via a three axis gimbal, capable of capturing full color, high definition 

imagery.

• The DJI models all have an on-board telemetry system that delivers flight data 

from the onboard flight computer to the on-board radio transmitter including; 

altitude (AGL), horizontal and vertical speed, compass direction of flight, and 

direction back to its launch site.

THE GROUND STATION-BASED PART OF THESE SYSTEMS:

• A Pilot in Command (PIC} in operational control of a flight operation from 

beginning to end and who controls the UA while in the air

• A radio transmitter/controller operated by the (PIC} to control the UA while in 

flight

• A Ground Station (Laptop, Tablet or Smart Phone based App) which receives 

and displays real time system telemetry and imagery from the UA
• A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA while in flight.

CHARACTERISTICS OF THE AIRCRAFT:

Falcon 8: All flight data saved in Blackbox: All relevant parameters of the flight 

system, pilot inputs and external factors like GPS satellite constellations are 

saved to a SD card at 10Hz safe from manipulation. 3 Safety modes if data link is 

lost: “Direct landing”, “Come home straight” (at its current height) or “Come home 

high” (at max. mission height). Redundant control link: Two completely 

independent digital data links are responsible for the transmission of all 

commands and telemetry data. The failure of one of these links has no influence 

on the control of the flight system. This leads to a very robust communication 

between the RC and the UAV, even in industrial or urban areas with sources of 

disturbance or multi-path effects. Triple redundant sensor data verification: All 

important sensor and system parameter values from the AscTec Falcon 8 are 

assessed permanently. Automated pre-flight check: The system automatically 

checks itself in the moment it is switched on. So you can’t take off with any 

critical malfunctions. 3. Safe operation /// The AscTec Falcon 8 is remotely 

controlled with the Mobile Ground Station. All relevant flight data is displayed live 

on the MGS. The pilot can fly the system with GPS aided position and barometric 

pressure aided height control, but can also deactivate these functions anytime 

and fly manually. A single motor failure, bend-, broken- or lost-propeller is 

automatically compensated by the autopilot, to allow for a safe landing. Software 

updates can be loaded onto the AscTec Falcon 8 via an USB interface. In 

preprogrammed waypoint flights the pilot can overtake control at anytime and will 

overwrite these commands by manual control input. /// The Mobile Ground 

Station consists of: Remote Control via Diversity Datalink: The Futaba FX-22 

remote control is only used as a control input device and for powering the 

Diversity Datalink and Status Display. The wireless transmission is done via the 

Diversity Datalink implemented by Ascending Technologies.
Status Display: The pilot receives all telemetry data like GPS position, flight 

altitude and airspeed, battery voltage, data link or GPS quality and information 

about external factors like strong wind. It is displayed on the Status Display of the 

Mobile Ground Station.

INTENDED USE:

The requested amendment would allow us to use the UA for aerial image 

acquisition to support various mapping and surveying applications as well as 

video documentation for the public good. Typical applications would include, but 

are not limited to:

• Aerial Photography

• Aerial Surveys

• Volumetric Surveys

• Architectural Surveys

• Bridge Inspections

• Utility Corridor Vegetation Management

• Building Inspection Surveys

• Disaster Response

This Amendment makes no other changes to the original request including 

exemptions sought, reasons for exemption request, and/or operating parameters. 

Verascan Inc. will operate these additional UA's under the same conditions and 

limitations provided in Exemption No. 12523. The name and contact information 

of the applicant remains the same.

PUBLIC INTEREST:

Granting Verascan Inc. Request For Amendment is In The Public Interest, that is, 

the public as a whole benefits, as described below. Granting the present petition 

for amendment(s) will continue to further the public interest as set forth in Grant 

of Exemption No. 12523, beginning on page 8, in which the Administrator found 
good cause for Verascan Inc.’s proposed UAS operation because enhanced 

safety is achieved by using an unmanned aircraft with the specifications 

described by Verascan Inc., and by carrying no passengers or crew, as 

compared to a manned aircraft of significantly greater proportions, which carries 

crew in addition to flammable fuel. Granting the requested amendments is in the 

public interest by alleviating human exposure to danger by working at extreme 

elevations, and/or in proximity to high-voltage. The types of inspections proposed 

herein improve the quality of inspection services while decreasing operating 

costs associated therewith, comparative to conventional flight operations. 

Additionally, Verascan Inc.’s proposed operations significantly reduce hazards, 

as well as emissions, associated with the common practice of manned helicopter 

utilization to conduct similar inspection operations. Verascan Inc. proposed UAS 

operations will provide benefits to energy, science, and civil engineering. 

Furthermore, the benefits of Verascan Inc. proposed operation of the mentioned 

UAS will be realized without implicating any privacy issues. Granting of Verascan 

Inc. proposed amendment will fulfill the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, by allowing Verascan Inc. to safely, 

efficiently, and economically operate the mentioned UAS commercially within the 

NAS. Granting these amendments would ensure Verascan Inc.’s inspection 

operations are confined to flights at an altitude of no more than 400 feet AGL, or 

only exceed that height to a vertical ceiling of 100 feet above an existing 

structure when inspection conditions warrant the necessity to do so. All FAA 

mandated procedures and notifications including provisions for obtaining a 

Certificate of Authorization or waiver (COA), and publishing of a Notice To 

Airmen (NOTAM) as outlined in 14 CFR § 91.119 as well as Grant of Exemption 

12523 shall be strictly adhered to. Verascan Inc. respectfully submits that an 

equivalent level of safety will be maintained, as presented in Grant of Exemption 

No. 12523, as all other previously granted conditions and limitations shall remain 

in effect.

AIRCRAFT SPECIFICATIONS LINKS:

https://www.sensefly.com/drones/ebee-rtk.html
https://www.sensefly.com/drones/exom.html

http://www.dji.com/product/phantom-2-vision-plus

http://www.dji.com/product/phantom-3/spec

http://www.asctec.de/en/uav-uas-drones-rpas-roav/asctec-falcon-8/#pane-0-1

Sincerely,

Brett Kanda

Partner, Verascan Inc.

4603 Visconti Way

Las Vegas, NV.

89141