# . PeRKINSCOle

August 7, 2015
VIA CERTIFIED MAIL**RETU&~** RECEIPT REQUESTED U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590 2901 North Central Avenue Suite 2000 Phoenix, AZ 85012-2788

Stephen A. Brookman SBrookman@perkinscoie.com D. (602)351-8058 F. (602)648-7019 0 +1.602.351.8000 G +1.602.648.7000 perkinscoie.com

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Re: Application for Amendment to Exemption No. 11257- Roger W. Meyer, PLS d.b.a. Montana Land Surveys; FAA Docket No. FAA-2014-0889 Dear Sir or Madam: On April2, 2015, the FAA issued ExemptionNo. 11257 to Mr. Roger W. Meyer, PLS, d.b.a. Montana Land Surveys ("MLS"), allowing commercial operations using the SenseFly eBee and Trimble Navigation Limited UX5 aitctaflunder Section 333ofthe·FAAModemizatiO'n and··' Reform Act of2012. MLS nowrespectfully applies for an amendmentto Exemption

### No: 11257 to allow MLS to operate additional aircraft under the same conditions as approved in Exemption No. 11257. MLS seeks exemption for the following additional aircraft, whichhave already been approved under similar exemptions as indicated below, for similarpurposes related to aerial data collection:
• DJI (Spreading Wings) S-1000
o See Exemption No. 11398 in Regulatory DocketNo. FAA-2015-0145 (granting exemption for aerial inspections); ExemptionNo. 11153A in Regulatory Docket No. FAA-2014-0519 (granting amendmentto add DJI S1000 for aerial photography and inspection)
• DJI Phantom 3 Professional
o See ExemptionNo. 11481 in Regulatory DocketNo. FAA-2015-0217 (granting exemption for risk management services); Exemption No. 11267A in Regulatory DocketNo. FAA-2014-0918 (granting amendment to add DJI Phantom 3 for aerial data collection)U.S. Department ofTransportation- ExemptionNo. 11257; FAA-2014-0889 August 7, 2015 Page 2

• DJI Phantom 3 Advanced

o See ExemptionNo. 11481 in Regulatory DocketNo. FAA-2015-0217 (granting exemption for risk management services); ExemptionNo. 11267A in Regulatory DocketNo. FAA-2014-0918 (granting amendmentto add DJI Phantom 3 for aerial data collection) Each additional aircraft is a multi-rotor vertical take-offand landing (VTOL) small unmanned aerial system (sUAS) weighing less than 55 lbs including payload. Each aircraft is batterypowered and allows for piloted control orthe use offlight management software and onboard GPS for missionplanning and monitoring. Each additional aircraft will have a camera for collection ofimages that will be used for the aerial imaging purposes outlined inthe original petition. And each additional aircraft allows for manual control to override any autonomous actions or to manually initiate autonomous actions to return home or land. Accordingly, each additional aircraft has substantially the same capabilities, will be operated in substantially the same manner, and will be operated for substantially the same purpose as the aircraft permitted under current ExemptionNo. 11257. Relevant operating documents, including Flight Manuals, Operation Manuals, User Manuals, and/or Safety Manuals for each ofthe DJI S-1000, DJI Phantom 3 Professional, and DJI Phantom 3 Advanced, which may be updated and/or revised from time to time, are incorporated by reference and are available in other Exemptionfiles, such as those referencedherein, and are also available online, such as those located at the web addresses cited in the postscript below. MLS will continue to operate UAS in compliance with all federal, state, and local regulations, as well as the UAS manufacturers' recommendations and the terms ofthe Exemption. There has been no change in the conditions orreasons relative to public interest, benefit, and safety that were the basis for granting the original exemption. To the extentnecessary, MLS refers the FAA to its original exemption request submitted in DocketNo. FAA-2014-0889 for a listing ofregulations, as amended by ExemptionNo. 11257, for which a waiver is being sought and the reasons why such waiver is being sought, a demonstration ofpublic interest, and a showing ofan equivalent level ofsafety. In conjunction withthese requests, MLS seeks an extension oftimebeyondthe April30, 2017 termination date currently placed on Exemption No. 11257 to the extentthe FAA deems appropriate in light ofthe amendments. In addition, MLS requests that the FAAreissue the Small UAS Operations Certificate ofWaiver or Authorizationpreviously issued to MLS in association with the grant ofExemptionNo. 11257, to reflect all aircraft covered in the amended Exemption. Finally, because this request seeks only to add additional types ofaircraft under an existing exemption, and because the aircraft have previously been approved for commercial use under other exemptions (listed above), and further because the conditions under which MLS willU.S. Department ofTransportation- Exemption No. 11257; FAA-2014-0889 August 7, 2015 Page 3
operate remain essentially the same, notice need notbe provided in the Federal Register nor public comment solicited. Forreference, contact information for MLS is: Roger W. Meyer PLS, d.b.a. MontanaLand Surveys Mailing Address: PO Box 176 Physical Address: 22 N. Main Lambert, MT 59243 Phone: 406-774-3390 Email: surveyor@midrivers.com Respectfully submitted,

# ¥-?1~ Stephen A. Brookman
cc: Mr. Roger W. Meyer Postscript:

• DJI Spreading Wings S-1000 User Manual: http://download.djiinnovations.com/downloads/s1 000/en/S1000 User Manual v1.10 en.pdf

• DJI Spreading Wings S-1000 Release Notes: http://download.djiinnovations.com/downloads/s1000/en/S1000 release note en.pdf

• DJI Phantom 3 Professional User Manual: http://download.djiinnovations.com/downloads/phantom 3/en/Phantom 3 Professional User Manual v1.2

en.pdf

• DJI Phantom 3 Advanced User Manual: http://download.djiinnovations.com/downloads/phantom 3/en/Phantom 3 Advanced User Manual v1.2 e n.pdf

• DJI Phantom 3 Professional and Advanced Safety Guidelines and Disclaimer:.!.illp://download.djiinnovations.com/downloads/phantom 3/en/Safety Guidelines Disclaimer en.pdf**~erkl'IS** Co1e LLP