April 21, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Amendment to Section 333 petition for exemption docket FAA-2016-4885 from the FAA

Reform Act and Part 11 of the Federal Aviation Regulations in Regulatory Docket

FAA-2016-4885

Dear Sir or Madam;

ACTSDRONES LLC seeks to amend the original 333 petition for exemption docket FAA-2016-4885

application as follows:

1. Night Operations

2. Operations from a moving device or vehicle

3. Additional operations/missions

Each change requested to the exemption is separate and independent and should be viewed as such 

with regard to approval, denial, or request for more information.

1 Night Operations

ACTSDRONES LLC 333 petition for exemption docket FAA-2016-4885 under with docket FAA-2015-6988

(hereinafter the Exemption) without the purpose Night Operations. ACTSDRONES LLC herby requests an 

amendment to the Exemption to allow Night Operations that fully complies with the conditions of the 

Exemption. ACTSDRONES LLC believes that we can safely operate UAV’s / UAS’s safely at night, without 

increased harm to the public or property, at the same safety assumed for the original petition for 

exemption docket FAA-2016-4885. The attached UAS night training program file has been emailed and 

not included into the public because it holds proprietary training information not intended for the 

public. Night operations is a major need for ACTSDRONES LLC when conducting inspections and closed 

set filming, certain temperature sensitive inspections, and search and rescue.

Conditions for Night Operations

1. PIC Shall have a medical without waiver for color vision

2. PIC Shall complete ACTSDRONES night training

3. PIC Shall abide by the ACTSDRONES night training currency requirements

We seek to amend this 333 petition for exemption docket FAA-2016-4885 on the basis of previously 

approved Exemption 16341 Industrial Skyworks (USA), Inc. and seek the similar relief of night operations 

and similar restrictions.

2. Operations from a moving device or vehicle
ACTSDRONES LLC seeks exemption to operate from a moving device or moving land and water vehicles. 

We feel that safety of the operation will not be compromised and the assumed safety of the original 333 

petition for exemption docket FAA-2016-4885 will be maintained. 

The conditions of operation would be such that the operator of the vehicle would:

1. be required to hold a valid driver’s license

2. abide by all local and state driving laws

3. cannot be the PIC of the UAV/UAS 

4. cannot be the visual observer

5. cannot operate or be distracted by any electronic device or handheld device

6. cannot operate on any public right-of-way or publicly maintained road without the 

controlling agency permission

7. trained according to ACTSDRONES LLC vehicle training manual

The conditions of the moving device or vehicle the PIC would be in or on in such operation would:

1. have an open top to allow the visual observer and/or PIC to maintain open air visual line of 

sight.

2. Be operated in accordance with the local and state laws if applicable

3. Be operated no faster than 22.5 mph.

ACTSDRONES LLC feels that with proper training and practice demonstrated in our training requirements 

we can safely operate from a moving vehicle. The attached UAS moving vehicle/device training program

file has been emailed and not included into the public because it holds proprietary training information 

not intended for the public. ACTSDRONES LLC needs to operate from a moving vehicle for the purpose 

of operating longer distances required for our operations while still maintaining line-of-sight during 

operations such as search and rescue. Since there is no restriction that the PIC be stationary during 

operations, riding in or on a vehicle would be in many ways safer than walking for both the operator and 

those on the ground that could be affected if the operator tripped or stumbled while moving under his 

or her own power.

3. Additional operation/missions

ACTSDRONES LLC seeks to add additional operations/missions to the existing Exemption petition for 

exemption docket FAA-2016-4885 for clarification and based on the previously approved Exemption 

#16055 by Silver OctopusLLC. 

ACTSDRONES LLC seeks operations for:

Private and commercial marine vessel videography, photography, inspection and patrolling; aerial 

photography, videography, and surveying; closed-set filming and aerial photography; surveying, 

monitoring, inspections, videography, photography and filmmaking; aerial imaging for safety, 
monitoring, inspecting and/or recording of secured and controlled environment construction sites, 

proposed development sites, inspections of property, and photography for realty advertisements; 

precision photogrammetry and crop scouting; search and rescue and disaster operations; 

educational research, technical demonstrations and training; precision agriculture, market research, 

surveying, mapping and inspection; and oil and gas pipeline inspections, solar installation 

inspections, power line/cable inspections, cooling tower inspections, forestry, critical infrastructure 

inspections, wind turbine inspections, and radiation measurement and monitoring

ACTSDRONES LLC believes that we can safely operate UAV’s / UAS’s safely during these missions,

without increased harm to the public or property, at the same safety assumed for the original petition

for exemption docket FAA-2016-4885.

There has been no change in the conditions and reasons relative to public interest and safety that 

were the basis for granting the original exemption.

Please contact the undersigned should you have any question concerning this request for an 

amendment to the exemption request.

Sincerely yours, 

Steven Murray, 

Member ACTSDRONES LLC