August 20 , 2015

A mendment 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 t he Federal Docket Management System (FDMS) Re : A mendment to add additional Unmanned Aerial Systems to current Exemption No. 1 2523

Dear Sir or Madam:

I , Brett Kanda , Partner at Verascan Inc., have prepared the following a mendment 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 9lb s Sing le Motor UA

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

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

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

- Rotor UA

• Ascending Technologies Falcon 8, Under 31 l b s ( 8 rotor) Multi

- rotor UACHARACTERISTICS 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 re lated 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 operato r 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 wing s 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 fr om 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 t o 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 cont roller 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 verticalrange of motion allowing y ou to capture clear and stabiliz ed imagery ahead, above and below the drone.
· Advanced situational awareness eXom features five dual

- sensor modules, positioned around the drone. These pr ovide 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 fli ght 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 O F 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 f or 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

- b oard 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 STAT ION

- 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
comma nds 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

- pat h effects. Triple redundant sensor data verification: All important sensor and system parameter values from the AscTec Falcon 8 are assessed permanen tly

. 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

u pdates 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 Con trol 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 Technologi es.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 Mobil e 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 A mendment makes no other chang es 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. 1 2523. The name and con tact 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 foundgood cause for Verascan Inc.’s proposed UAS operation because enhanced safety is achieved by using an unmanned aircr aft 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 associat ed 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 inspe ction 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 iss ues. Granting of Verascan Inc. proposed amendment will fulfill the Congressional mandate of the FAA Modernization and R eform Act of 2012, by allowing Verascan Inc. to safely, efficiently, and economically operate the mentioned UAS commercially within the N AS. 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 c onditions 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 a s 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. 1 2523 , as all other previously granted conditions and limitations shal l remain in effect. AIRCRAFT SPECIFICATIONS LINKS: https://www.sensefly.com/drones/ebee

- rtk.htmlhttps://www.sensefly.com/drones/exom.h tml

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