January 8, 2016 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 397 Spruce Glen Road lexington, SC 29072 (703) 599-3277

Re: Supplement to Exemption Request FAA-2015-5593-0001 Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations to add two (2) additional Small Unmanned Aircraft Systems ("sUAS") to the Exemption Attachment A: Phantom 3 Professional Platform Description Attachment B: Link to Phantom 3 Professional Operations User Manual and Quick Start Guide Attachment C : senseFly eBee Operational Checklist Attachment D: Phantom 3 Professional Operational Checklist Dear Sir or Madam, Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, ENDEAVOR UNMANNED SOLUTIONS, LLC seeks to supplement 333 Exemption Request FAA2015-5593-0001 to add two {2} DJI Phantom 3 Professional sUAS's {Phantom 3s) to the one (1) senseFiy eBee sUAS (eBee) already requested (Section 1). This supplement will also provide greater detail on how ENDEAVOR UNMANNED SOLUTIONS, LLC operations will not adversely affect safety

. Copies are provided ofthe detailed checklists used forthe eBee and Phantom 3s that showthe company's focus on safety (Section 2)

. F inally, this supplement contains information to bolsterthe reasons why ENDEAVOR UNMANNED SOLUTIONS, LLC will benefit the public as a whole (Section 3}. Section 1. The requested supplement to the exemption would allow commercial operation of ENDEAVOR UNMANNED SOLUTIONS, LLC's Phantom 3s ofwhich weigh under 2.91bs

. (with fixed camera). Both sUAS's will perform the same missions and underthe same conditions and limitations listed in the current 333 exemption request (and expounded upon in section 3 of this supplemental)

. The Phantom 3's will be used in addition to the single eBee and will achieve an equivalent or greater level of safety. See attachments A and Bfor a description ofthe DJI Phantom 3 Professional sUAS and a computer linkto the Operations User Manual and Quick Start Guide (

.pdfcopies too large toadd as attachments). The DJI Phantom 3 series sUAS is the single most popularsUAS flying in theworld today and the single sUAS with the most FAA 333 Exempt ion approvals to date (as of 30 December 2015). Characteristics oftheAircraft. The Phantom 3 is a small (23.2 inches wingspan, propellers turning) and ultra-light (maximum take-offweight of2.9 pounds) platform madeof molded plastic that performs pre-programmed precision aerial mapping missions thanks to the on-board Global Positioning System (GPS) and the related flight management software (DroneDeploy) that allows the operatorto plan safely and efficientlya mission in 30, and then monitor it in realtime. Thanks tothefixed camera the Phantom 3 takes a collection of high-definition still images that are used laterto generate maps and contour lines ofthe surveyed area. The four main characteristics ofthe Phantom 3's are : a. Very Light Weight. The Phantom 3 is very lightweight

. The sUAS can be carried in one hand

. The operator launches the Phantom 3 through manual control orautomatic means
. The sUAS is so lightweight that it can be landed on almost any surface

. Itdoes not require a parachute

. b

. Electric-Powered

. The Phantom 3 is electric powered

. Four proven brushless motors make it (relatively) quiet and very reliable. The propellers are attached using a screw pattern opposite ofthe direction of rotation giving it self-tightening properties

. c. Semi-Automatic Flight

. The artificial intelligence incorporated withinthe Phantom 3 autopilotsystem continuously analyzes data from the Inertial Measurement Unit (IMU) and fromthe onboard GPS and takes care ofall the aspects ofthe flight underthe supervision ofthe operator. The Phantom 3s have a " Return to Home" feature that can be initiated manually bythe operatoror occur automatically when eitherthe communication link is interrupted betweenthe Phantom 3 and hand-held remote controller orthe battery charge reaches 20% (or as set bythe operator- see checklist). The "Return to Home" altitude is set manually priortoflight by the PIC to avoid obs tacles (a checklist item)

. d

. Option for Manual Control. Additionally, the Phantom 3 provides an override capability thatallows the operatorto take manual actions duringthe flight. Placing the Phantom 3 in manual mode ("P" ) suspends automated operations ("F"). The operator can take manual control ofthe aircraft at anytime should it become necessaryto respond to emergent circumstancesthanks tothe remote controller provided with thesystem

. The manual feature allows rapid maneuvering (primarily in thevertical axis- descent) to avoid manned aircraft in the event it is necessary. Section 2. Attachments Cand Dare operational checklists used by ENDEAVOR UNMANNED SOLUTIONS, LLC. These checklists have been expanded from those contained in the Operations User Manuals and are based on other user checklists and personal flight experience. They are "living" documents and will amended and expanded as new information is published bythe FAA 

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.............. __________________ ___ - -- --- - -- ---and the manufacturer, and overtime with user experience

. The checklists contain comprehensive pre-flight, in-flight, and post-flight procedures expressly focused on safety offlight

. Several steps are labeled "Go/No Go". Ifthe specific checklist item can't be completed orfails the check theflight is suspended untila correction is made. 

### Section 3. Granting the present Petition (FAA-2015-5593-001) will further the public interest by allowing ENDEAVOR UNMANNED SOLUTIONS, LLC to safely, efficiently, and economically perform photography and aerial video of agriculture, conduct land survey and aerial inspections, and support first responders overvarious areas ofthe United States. Additionally, use ofthe eBee and Phantom 3s will decrease congestion ofthe National Airspace (NAS), reduce pollution, and provide significant benefits to the economy. Notably, the benefits of ENDEAVOR UNMANNED SOLUTIONS, LLC's proposed operation ofthe eBee and Phantom 3s will be realized without implicating any privacy issues.
a. The eBee and Phantom 3s are battery powered and serve as safe, efficient, and economical alternatives to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofthe eBee and Phantom 3s would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safetyof life and property in the air and on the ground. This would reduce the congestion around airports caused by arriving and departing aircraft. Neitherthe eBee nor Phantom 3s require an airport totakeoff or landing. b. Conducting aerial acquisitions with the eBee and Phantom 3s, instead of manned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations

. By using battery power and electric motors, the eBee and Phantom 3s produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately20-30 gallons per hourof leaded aviation fuel. The eBee and Phantom 3s, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the sUAS's are propelled by battery powered electric motors, rather than an internal combustion engine.
c. By usingthe eBee and Phantom 3s to perform aerial acquisitions, the risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the eBee and Phantom 3s have less physical potential for collateral damage to life and property onthe ground, and in the air, compared to the manned aircraftthat typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). d. In addition to being safe and efficient, the eBee and Phantom 3s are also an economical alternative to using manned aircraftto conduct similar aerial operations. As such, operation of the eBee and Phantom 3s will allow United States based companies, like ENDEAVOR UNMANNED SOLUTIONS, LLC, to remain competitive and contributeto growth ofthe U

.S. economy. Specifically, with the cost of aviation fuel and the Environmental Protection Agency

### ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in orderto remain competitive. Operating the battery powered eBee and Phantom 3s is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft.
e. Similarto the manned aerial acquisition flight operationsthat have been conducted for decades, ENDEAVOR UNMANNED SOLUTIONS, LLC's proposed operation ofthe eBee and Phantom 3s will not cause any privacy issues. Specifically, the eBee and Phantom 3s will be operated only in compliance with operating documents (i.e., the ENDEAVOR UNMANNED SOLUTIONS, LLC checklists, Monthly Maintenance Logs, and eBee and Phantom 3 Operations User Manuals) which require property owner involvement as well as FAA and, when required, local law enforcement notification, and in accordance with the Federal Aviation Regulations, includingthe minimum altitude requirements of 14 C.F.R. § 91.119. CONCLUSION ENDEAVOR UNMANNED SOLUTIONS, LLC is a survey operator. We are a service provider engaged in high precision mapping products. Our services and products save our clients time giving the abilityfor them to make better decisions. The eBee and Phantom 3s are safer than having ENDEAVOR UNMANNED SOLUTIONS, LLC's employees out in the field for specific projects, and also very safe for other aircraft because ofthe mission specifications (below400 ft.) and eBee and Phantom 3 integrated safety features

. ENDEAVOR UNMANNED SOLUTIONS, LLC is prepared to modify or amend any part ofthis request to satisfythe need for an equivalent level ofsafety. We lookforward toworking with your office. Please contact us at any time ifyou require additional information or clarification. Yours sincerely,

Timothy E. Coolidge FAA Certificate 3610935