. PeRKINS COle 

August 7, 2015 

VIA CERTIFIED MAIL 

RETU&~ RECEIPT REQUESTED 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey 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 Exemption No. 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 aitctafl under Section 333ofthe·FAA ModemizatiO'n and··' 

Reform Act of2012. MLS now respectfully applies for an amendment to 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, which have already been approved 

under similar exemptions as indicated below, for similar purposes related to aerial data 

collection: 

• DJI (Spreading Wings) S-1 000 

o See Exemption No. 11398 in Regulatory Docket No. FAA-2015-0145 (granting 

exemption for aerial inspections); Exemption No. 11153A in Regulatory Docket 

No. FAA-2014-0519 (granting amendment to add DJI S1000 for aerial 

photography and inspection) 

• DJI Phantom 3 Professional 

o See Exemption No. 11481 in Regulatory Docket No. FAA-2015-0217 (granting 

exemption for risk management services); Exemption No. 11267A in Regulatory 

Docket No. FAA-2014-0918 (granting amendment to add DJI Phantom 3 for 

aerial data collection) 
U.S. Department of Transportation- Exemption No. 11257; FAA-2014-0889 

August 7, 2015 

Page 2 

• DJI Phantom 3 Advanced 

o See Exemption No. 11481 in Regulatory Docket No. FAA-2015-0217 (granting 

exemption for risk management services); Exemption No. 11267 A in Regulatory 

Docket No. FAA-2014-0918 (granting amendment to add DJI Phantom 3 for 

aerial data collection) 

Each additional aircraft is a multi-rotor vertical take-off and landing (VTOL) small unmanned 

aerial system (sUAS) weighing less than 55 lbs including payload. Each aircraft is batterypowered and allows for piloted control or the use of flight management software and on board 

GPS for mission planning and monitoring. Each additional aircraft will have a camera for 

collection of images that will be used for the aerial imaging purposes outlined in the 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 Exemption No. 11257. 

Relevant operating documents, including Flight Manuals, Operation Manuals, User Manuals, 

and/or Safety Manuals for each of the 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 Exemption files, such as those referenced herein, 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 of the Exemption. 

There has been no change in the conditions or reasons relative to public interest, benefit, and 

safety that were the basis for granting the original exemption. To the extent necessary, MLS 

refers the FAA to its original exemption request submitted in Docket No. FAA-2014-0889 for a 

listing of regulations, as amended by Exemption No. 11257, for which a waiver is being sought 

and the reasons why such waiver is being sought, a demonstration of public interest, and a 

showing of an equivalent level of safety. 

In conjunction with these requests, MLS seeks an extension oftime beyond the April30, 2017 

termination date currently placed on Exemption No. 11257 to the extent the FAA deems 

appropriate in light of the amendments. In addition, MLS requests that the FAA reissue the 

Small UAS Operations Certificate of Waiver or Authorization previously issued to MLS in 

association with the grant of Exemption No. 11257, to reflect all aircraft covered in the amended 

Exemption. 

Finally, because this request seeks only to add additional types of aircraft 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 will 
U.S. Department ofTransportation- Exemption No. 11257; FAA-2014-0889 

August 7, 2015 

Page 3 

operate remain essentially the same, notice need not be provided in the Federal Register nor 

public comment solicited. 

For reference, contact information for MLS is: 

Roger W. Meyer PLS, d.b.a. Montana Land 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/s 1 000/en/S 1 000 User Manual v 1.10 en.pdf 

• DJI Spreading Wings S-1 000 Release Notes: http://download.djiinnovations.com/downloads/s 1 000/en/S 1000 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