G ii g 

KEYSTONE 

AERIAL SURVEYS 

July 6, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Keystone Aerial Surveys, Inc. Petition to Amend 

Section 333 Exemption No. 11472, Docket No. FAA-2015-0301 

Keystone Aerial Surveys, Inc. (Keystone) petitions to amend its small Unmanned Aerial 

Systems (sUAS) Section 333 Exemption (No. 11472) to include the following Vertical 

Takeoff and Landing (VTOL) aircraft: DJI Phantom 3, DJIInspire 1, Altavian Nova 

R8400, 3D Robotics X8-M, and SteadiDrone Mavrick X4. Below are summaries of each 

aircraft: 

• The DJI Phantom 3 is a quadcopter rotor aircraft that has been included in over 

14 exemptions through mid-June, most notably Nos. 11824, 11837 and 11696 

were granted for use in aerial survey missions similar to those requested to be 

conducted by Keystone. 

• The DJI Inspire 1 is a quadcopter rotor aircraft that has been included in over 95 

exemptions through mid-June, most notably Nos. 11843, 11822, 1177 4 and 

117 42 were granted for use in aerial survey missions similar to those requested 

to be conducted by Keystone. 

• The Altavian Nova R8400 is an octocopter rotor aircraft manufactured by the 

same manufacturer as the fixed wing aircraft in Keystone's exemption. The 

R8400 has been approved in Exemption Nos. 11776, 11735 and 11306A. 

• The X8-M from 3D Robotics is their mapping grade octocopter rotor aircraft. This 

aircraft has been included in Exemptions 11824 and 11855. 

• The SteadiDrone Mavrick X4 is a quadcopter rotor aircraft that has been included 

in Exemption Nos. 11825 and 11832. 

All these aircraft will allow Keystone to better serve its clients through greater flexibility 

in airborne capture and sensor type. Keystone will be able to use the aircraft for small 

area collection (less than 10 acres) in a cost effective manner and with a more robust 

image sensor and great image capture angle. 

Keystone proposes that item #1 of the Conditions and Limitations set forth in Exemption 

11472 be amended to read: "Operations authorized by this grant of exemption are 

limited to the Altavian Nova F6500 and R8400, the DJI Phantom 3 and Inspire I, the 3D 

Robotics XB-M and the SteadiDrone Mavrick when weighing less than 55 pounds 

including payload. Proposed operations of any other aircraft will require a new petition 

or a petition to amend this exemption." 

Northeast Philadelphia Airport • P.O. Box 21059 

Philadelphia, PA 19114 • V:215.677.3119 • F:215.464.2889 

www.kasurveys.com • Info@kasurveys.com 
~~~=====~======~~~ KEYSTONE 

AERIAL SURVEYS 

All operations of these aircraft will continue to be in accordance with the exemption 

previously granted, including, but not limited to, operation below 500ft., visual line of 

sight piloting by FAA certificate holders, less than 55 pound weight of system with 

payload and a speed not to exceed 87 knots. Keystone is NOT requesting any change 

in its proposed use. 

Keystone's Flight Operations Manual (submitted with previous exemption request) 

contains special instructions for the operation of rotor craft. These and other pilot 

instructions for all UAS will be followed in order to maintain the safety of the crew and 

ground participants. 

User Manuals can be viewed using these links: 

DJI Phantom3 

Professional User Manual: http://download.djiinnovations.com/downloads/phantom 3/en/Phantom 3 Professional User Man 

ual v1.2 en.pdf 

DJI Battery Safety Guide: http://download.djiinnovations.com/downloads/inspire 1/enllntelligent Flight Battery Safety Guide 

lines en.pdf 

DJIInspire 1 

Inspire 1 User Manual: http://download.djiinnovations.com/downloads/inspire 1/enllnspire 1 User Manual v1.2 en.pdf 

Inspire 1 Safety Guidelines: http://download.djiinnovations.com/downloads/inspire 1/en/lnspire 1 Safety Guidelines en.pdf 

Inspire 1 Maintenance Manual: http://download.djiinnovations.com/downloads/inspire 1/en/lnspire 1 Maintenance ManuaiV1.0 

en.pdf 

30 Robotics X8-M 

X8-M operation Manual: http://3drobotics.com/wpcontent/uploads/20 15/04/X8M-Operation-Manual-v3.pdf 

X8-M Maintenance Manuals: http://3drobotics.com/kb/x8-m-support/ 

SteadiDrone Mavrick X4 

Mavrik Quick Start Guide: 

https://drive.google.com/file/d/OBOEFpqbUh1 KaZOhZZUwvaVJMdWc/view 

In order to protect intellectual property, the Altavian Nova R8400 does not have a 

published operator manual and maintenance manual. The Nova R8400 Maintenance 

and Operator Manuals are included with this amendment request. Additionally, in 

accordance with Item 7 of the Conditions and Limitations section of Exemption No. 

Northeast Philadelphia Airport • P.O. Box 21059 

Philadelphia, PA 19114 • V:215.677.3119 • F:215.464.2889 

www.kasurveys.com • Info@kasurveys.com 
Q iii Q 

KEYSTONE 

AERIAL SURVEYS 

11472, included with this amendment is Keystone's updated Flight Operations Manual 

(FOM). 

The Altavian Nova R8400 Operators Manual and Maintenance Manual and Keystone's 

FOM are submitted as Confidential Documents under 14 CFR 11.35(b) and exempt 

from disclosure under the Freedom of Information Act, 5 USC 552, et seq., and any 

other requirement established by the FAA pursuant to Section 333 of the Reform Act. 

Si "fi~Jy 

David Day 

Executive Vice President 

Keystone Aerial Surveys, Inc. 

Northeast Philadelphia Airport • P.O. Box 21059 

Philadelphia, PA 19114 • V:215.677.3119 • F:215.464.2889 

www.kasurveys.com • Info@kasurveys.com