January 8, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey 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 of the FAA 

Reform Act and Part 11 of the 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: sense Fly eBee Operational Checklist 

Attachment D: Phantom 3 Professional Operational Checklist 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 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 of the detailed checklists used for the eBee and Phantom 3s 

that show the company's focus on safety (Section 2). Finally, this supplement contains 

information to bolster the 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 of which weigh under 2.91bs. (with 

fixed camera). Both sUAS's will perform the same missions and under the 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 B for a description of the DJI Phantom 3 Professional sUAS and a 

computer link to the Operations User Manual and Quick Start Guide (.pdf copies too large to 
add as attachments). The DJI Phantom 3 series sUAS is the single most popular sUAS flying in 

the world today and the single sUAS with the most FAA 333 Exempt ion approvals to date (as of 

30 December 2015). 

Characteristics of the Aircraft. The Phantom 3 is a small (23.2 inches wingspan, propellers 

turning) and ultra-light (maximum take-off weight of 2.9 pounds) platform made of 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 operator to plan safely and efficiently a mission in 30, and then monitor it in realtime. Thanks to the fixed camera the Phantom 3 takes a collection of high-definition still images 

that are used later to generate maps and contour lines of the surveyed area. 

The four main characteristics of the 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 or automatic means. The sUAS is so lightweight that it 

can be landed on almost any surface. It does not require a parachute. 

b. Electric-Powered. 

The Phantom 3 is electric powered. Four proven brush less motors make it (relatively) quiet and 

very reliable. The propellers are attached using a screw pattern opposite of the direction of 

rotation giving it self-tightening properties. 

c. Semi-Automatic Flight. 

The artificial intelligence incorporated within the Phantom 3 autopilot system continuously 

analyzes data from the Inertial Measurement Unit (IMU) and from the onboard GPS and takes 

care of all the aspects of the flight under the supervision of the operator. The Phantom 3s have 

a "Return to Home" feature that can be initiated manually by the operator or occur 

automatically when either the communication link is interrupted between the Phantom 3 and 

hand-held remote controller or the battery charge reaches 20% (or as set by the operator- see 

checklist). The "Return to Home" altitude is set manually prior to flight by the PIC to avoid 

obstacles (a checklist item). 

d. Option for Manual Control. 

Additionally, the Phantom 3 provides an override capability that allows the operator to take 

manual actions during the flight. Placing the Phantom 3 in manual mode ("P" ) suspends 

automated operations ("F"). The operator can take manual control of the aircraft at any time 

should it become necessary to respond to emergent circumstances thanks to the remote 

controller provided with the system. The manual feature allows rapid maneuvering (primarily in 

the vertical axis- descent) to avoid manned aircraft in the event it is necessary. 

Section 2. Attachments C and 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 by the FAA 

I 

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and the manufacturer, and over time 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". If the specific checklist item 

can't be completed or fails the check the flight is suspended until a 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 over various areas of the United States. Additionally, 

use of the eBee and Phantom 3s will decrease congestion of the National Airspace (NAS), 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of 

ENDEAVOR UNMANNED SOLUTIONS, LLC's proposed operation of the 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 of the eBee and Phantom 3s would reduce the amount of manned aircraft in the NAS, 

reduce noise and air pollution, as well as increase the safety of life and property in the air and 

on the ground. This would reduce the congestion around airports caused by arriving and 

departing aircraft. Neither the eBee nor Phantom 3s require an airport to takeoff or landing. 

b. Conducting aerial acquisitions with the eBee and Phantom 3s, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air 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 aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of 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 using the 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 of flight 

crew members located on board the aircraft, the eBee and Phantom 3s have less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to 

the manned aircraft that typically conduct similar operations (weighing approximately 6,000 

pounds with a wingspan of approximately 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 aircraft to 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 contribute to growth of the 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 order to 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 of a traditional manned aircraft. 

e. Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, ENDEAVOR UNMANNED SOLUTIONS, LLC's proposed operation of the 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, 

including the 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 ability for 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 of the mission specifications (below 400 

ft.) and eBee and Phantom 3 integrated safety features. 

ENDEAVOR UNMANNED SOLUTIONS, LLC is prepared to modify or amend any part of this request 

to satisfy the need for an equivalent level of safety. We look forward to working with your office. 

Please contact us at any time if you require additional information or clarification. 

Yours sincerely, 

Timothy E. Coolidge 

FAA Certificate 3610935