Mark McKinnon

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102-4832

United States

email: mark.mckinnon@dentons.com

T 703.336.8808

F 703.336.8750

Salans FMC SNR 

Denton

McKenna Long

dentons.com

December 15, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Amendment to Exemption 13294 granted to DroneView Technologies (Docket 

No. FAA–2015–3269)

To Whom it May Concern:

As you are aware, this office represents DroneView Technologies (hereinafter DVT)

regarding the above-referenced Petition for Exemption, which was granted on October 22, 2015. 

DVT hereby requests an amendment to its Exemption to add eleven additional aircraft, the 

Kespry UAV, DJI Phantom 3, DJI S900, DJI S1000, Sensefly eBee, Sensefly eXom, Trimble 

UX5, Trimble UX5 HP, Trimble ZX5, SkyCatch Evolution3, and Lockeheed Martin Indago.

 

I. Description of Proposed Operations

DVT seeks to amend its Exemption to add the aircraft listed above for use in support of 

its aerial data collection activities. 

II. The Proposed UAS Operations Meet the Requirements of Section 333 of the Reform 

Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

The FAA has already ruled that the listed aircraft meet all of the criteria set forth in 

Section 333 of the FAA Modernization and Reform Act of 2012. Accordingly, all of the 

requirements to operate these vehicles been satisfied and the petition is suitable for a summary 

grant. 

● Kespry UAV: Exemption 11455A to High Flight Photo, Docket FAA 2015-0228.

● DJI Phantom 3: Exemption No. 11783 to Precision Design and Drafting, Inc.; 

Exemption No. 11788 to Birds Eye Aerial Photography, Inc.; Exemption No. 11696 to 

Midwest UAV Imagining; Exemption No. 11335A to Voler, Inc.; Exemption No. 

11267A to ETAK Systems, Inc.; Exemption No. 11306A to Hawk Aerial, LLC; 
December 15, 2015

Page 2

Salans FMC SNR Denton

McKenna Long

dentons.com

● DJI S900: See, Exemption No. 12640 to Revolution UAS, LLC, Docket No. FAA-2015-

2422; Exemption No. 12636 to AirGo Media, LLC, Docket no. FAA-2015-2425.

● DJI S1000: Exemption No. 13405 to Skydrone UAVS Inc., Docket No. FAA–2015–

3164

● Sensefly eBee: Exemption No. 13270 to Independence Excavating Inc., Docket No. 

FAA–2015–2824

● Sensefly eXom: Exemption No. 12106 to Duke Energy Business Services, LLC, Docket 

No. FAA-2015-0789

● Trimble UX5: Exemption No. 11806 to Terra Imaging LLC, Docket No. FAA–2015–

0386

● Trimble UX5 HP: Exemption No. 13138 to Western Data Systems, Docket No. FAA–

2015–3080.

● Trimble ZX5: Exemption No. 11110B to Trimble Navigation Ltd, Docket No. FAA2014-0367

● SkyCatch Evolution3: Exemption No. 11808 to AECOM, Docket No. FAA–2015–0473 .

● Lockeheed Martin Indago: Exemption No. 11447 to enrGies, Inc., Docket No. FAA-2014-

1010.

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

UAS models that have already been approved for other operators, DVT respectfully submits that 

good cause exists so that notice does not need to be published in the Federal Register for the 

requested amendment.

III. The Requested Amendment is in the Public Interest

The above listed UAS offer substantial safety benefits for aerial data collection over 

conventional operations using helicopters or fixed wing aircraft. 

If you have any questions regarding this amendment, or require any additional 

information to process this Petition, please do not hesitate to contact us. 

Very Truly Yours, 

Mark E. McKinnon

Counsel for DroneView Technologies