October 7, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: ADDENDUM TO GOLDER ASSOCIATES INC’S JULY 13, 2015 EXEMPTION REQUEST 

UNDER SECTION 333 OF THE FAA REFORM ACT AND PART 11 OF THE FEDERAL 

AVIATION REGULATIONS

COMMENT TRACKING #1JZ-8JZ8-1OAL

Dear Madam/Sir:

Golder Associates Inc. has prepared the following Addendum to our Exemption Request dated July13,

2015. This addendum is for the inclusion of the following vertical takeoff and landing (VTOL)-capable 

multi-rotor unmanned aircraft systems (each a “VTOL/Multi-Rotor UAS”):

 3DRobotics X8-M

 3DRobotics X8+

 3DRobotics Solo

 DJI Phantom 2

 DJI Phantom 3

 DJI Inspire 1

 DJI S1000 and S900

Golder’s original Exemption Request related to operation of a senseFly eBee (“eBee”) Unmanned Aircraft 

System (“UAS”). Operating procedures for a VTOL/Multi-Rotor UAS differ in some respects from those of 

an eBee UAS. General characteristics of the VTOL/Multi-Rotor UAS covered by this Addendum are 

described in section 2.0 hereof. Additional procedures related to safe operation of each VTOL/MultiRotor UAS, as such procedures may differ from those required for safe operation of an eBee UAS, are 

described in the various Operating Manuals attached to this Amendment and described in Attachment 1 

to this Addendum (attached hereto and incorporated herein by reference).

1.0 INTRODUCTION AND INTERESTS OF APPLICANT

As an industry leader in the ground engineering and environmental consulting services, Golder is 

regularly called on to provide technical expertise in hazardous terrain or contaminated sites that are 

difficult and/or dangerous to access. This addendum will allow us to dramatically increase the level of 

safety and efficiency with which Golder is able carry out its surveying operations in areas that are more 

accessible with a UAS capable of VTOL operations.

FAA 333 Multi-Rotor Addendum to eBee Exemption Request 10_07_2015 (00000002).doc

Golder Associates, Inc.

14607 San Pedro Ave., Suite 250

San Antonio, TX 78232 

Tel: (210) 655-1185 Fax: (210) 655-0818 www.golder.com

Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation
U.S. Department of Transportation 2 October 7, 2015

2.0 CHARACTERISTICS OF THE UNMANNED AIRCRAFT 

All of the VTOL/Multi-Rotor UAS listed above have the following characteristics:

 Are capable of VTOL operations

 Weigh less than 55 lbs and have an air speed of 25 mph or less

 Are stabilized by flight computers with onboard GPS navigation that receives flight control 

information from ground-based controller under the operation of the PIC

 Carry an onboard digital camera

 Transmit telemetry data including altitude (AGL), horizontal and vertical speed, direction 

of flight and GPS positioning from the onboard flight computer to a ground control station 

(GCS)

 Have emergency “return to home” fail safe which is automatically actuated should the 

UAS’ radio signal connection to the ground-based controller be interrupted.

3.0 CONCLUSION

Other than as set forth herein, this Addendum makes no additional changes to the original request 

including exemptions sought, reasons for exemption request, and/or operating parameters.

Yours sincerely,

GOLDER ASSOCIATES INC.

By:

Name: Bob Anderson

Title: Principal and Vice President, Western Region
Attachment 1

Golder Associates Inc.

Addendum to Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations

VTOL/Multi-Rotor UAS Operating Manuals

 3DR-Solo_v5_09_03_15

 Inspire_1_User_Manual_v1.4_en

 Phantom_3_Professional_User_Manual_v1.4_en_0915

 PHANTOM2_User_Manual_v1.4_en

 RTF-X8-Manual-V2

 S1000_User_Manual_v1.08_en

 S900_User Manual_v1.2_en

 X8+-Operation-Manual-vA

 X8M-Operation-Manual-v1

FAA 333 Multi-Rotor Addendum to eBee Exemption Request 10_07_2015 (00000002).doc

Golder Associates, Inc.

14607 San Pedro Ave., Suite 250

San Antonio, TX 78232 

Tel: (210) 655-1185 Fax: (210) 655-0818 www.golder.com

Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation