415 Freyer Drive

Marietta GA 30060

(770) 362-4080

matt@gauav.com

December 15th, 2015

U.S. Department of Transportation

Docket Management Systems

1200 New Jersey Ave SE

Washington, DC 20590

RE: Petition for Amendment to Exemption No. 13833 issued to GA UAV Services, LLC Pursuant 

to Section 333 of the FAA Reform Act (Docket No. FAA-2015-4118)

To Whom It May Concern,

GA UAV Services, LLC (hereafter “the Exemptor”), was issued Exemption No. 13833 on 

December 3rd, 2015 allowing the operations of sUAS for aerial photography and aerial data 

collection. GA UAV Services now is presenting this petition seeking an amendment to 

Exemption 13833 to permit the operations of additional aircraft along with the following multirotor and fixed wing aircraft that were approved in the initial request:

MultiRotor

DJI Phantom 3

Quantum HexaCopter with DJI NAZA V2 Flight Controller

Gaui HexaCopter with DJI NAZA V2 Flight Controller

DJI Flame Wheel with DJI NAZA V2 Flight Controller

Fixed Wing Electric Powered sUAS Aircraft

Go Discovery with Spectrum and Eagle Tree Flight Controller

(4 foot wing span - Foam airframe)

Volantrex FirstStar V2 with EagleTree Flight Controller

(4 foot wing span - Fiberglass/Foam airframe)

Hobby King Scale version of Scan Eagle with Eagle Tree Flight Controller

(4 foot wing span - Fiberglass airframe)

ProJet MQ-9 Reaper with Eagle Tree Flight Controller

(4 foot wing span - Fiberglass airframe)

Newly acquired aircraft will provide additional capabilities and safe operations. The DJI 

Phantom 3 Professional will expand our fleet of multi rotor with additionally-featured Quadcopter 

for the real estate operations. This is an upgrade version of DJI’s Phantom 2 which has 

previously been approved in our exemption and has been approved in other 333 exemptions by 

the FAA.

Both the DJI NAZA V2 and Eagle Tree Flight Control system provide the same 

functionality as the previous authorized aircraft flight control systems approved in 333 

Exemption Number 13833. The use of the familiar DJI flight controller with different airframes 

provides a more stable (safer) and economical platform to provide services to our customers.
415 Freyer Drive

Marietta GA 30060

(770) 362-4080

matt@gauav.com

As provided in the previous petition, DJI NAZA V2 flight controller provides all the same 

safety features such as the “Return to Home”function in the event of lost communication as the 

DJI Phantom 2 (The DJI NAZA V2 flight controller used in the Phantom 2), DJI Inspire, and A2 

flight controller systems. Therefore, we ask for the amendment to our Exemption No. 13833 in 

include these additional multi rotor aircraft requested in our original petition. 

Eagle Tree Flight controllers are widely used for stability control of fixed wing aircraft as 

the DJI flight controllers are used with multi-rotors. Eagle tree flight controllers utilize the same 

functionality of GPS flight control. In addition, they provide telemetry data to the pilot during 

flight operations. The Eagle Tree flight controller has an integrated “return to home” function. 

In the event communication between aircraft and ground station are lost, the aircraft will return 

to its home position and land, or else loiter above the ground until the pilot can regain 

operational communication with the aircraft. Therefore, with the added safety this flight 

controller offers, similar to the proven DJI multi rotor flight controller, we respectively request 

that the FAA approve the amendment to our Exemption 13833 to include the Eagle Tree flight 

controller and the fixed wing aircraft listed above. 

GA UAV Services LLC believes that an amendment adding the above list of aircraft to 

the previously approved Exemption No. 13833 is in the public interest as it would reduce 

hazards and emissions associated with alternative use of manned aircraft to conduct similar 

aerial data collection, videography, and imaging. 

All of the above aircraft all have a maximum take-off weight if less than 55 lbs and a 

maximum airspeed of 30 knots. The aircraft all have advanced safety features such as fail-safe 

mode and an advanced return to home system that becomes active in the event of lost link or 

communication..

Moreover, the above aircraft all follow the size, weight, design, and performance 

specifications set out in the requirements of Section 333 of the FAA Modernization and Reform 

Act of 2012. Accordingly the requested amendment should be granted.

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

sUAS model aircraft, GA UAV Services, LLC respectfully submits that good cause exists that 

notice does not need to be published in the Federal Registry for the requested amendment.

If you have any questions or to request additional information, please contact the 

undersigned.

Very Truly Yours,

Matthew Beebe

CEO/President

GA UAV Services, LLC