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# KEYSTONE AERIAL SURVEYS July 6, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., 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 Takeoffand Landing (VTOL) aircraft: DJI Phantom 3, DJIInspire 1, Altavian Nova R8400, 3D Robotics X8-M, and SteadiDrone Mavrick X4. Below are summaries ofeach aircraft:

• The DJI Phantom 3 is a quadcopter rotor aircraftthat has been included in over 14 exemptionsthrough mid-June, most notably Nos. 11824, 11837 and 11696 were granted for use in aerial survey missions similartothose requested to be conducted by Keystone. • The DJI Inspire 1 is a quadcopter rotor aircraftthat has been included in over 95 exemptionsthrough mid-June, most notably Nos. 11843, 11822, 1177 4 and 117 42 were granted for use in aerial survey missions similarto those requested to be conducted by Keystone. • The Altavian Nova R8400 is an octocopter rotor aircraft manufactured by the same manufacturerasthe 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 MavrickX4 is a quadcopter rotor aircraftthat has been included in Exemption Nos. 11825 and 11832. All these aircraftwill allow Keystone to betterserve its clients through greaterflexibility in airborne capture and sensortype. Keystone will be ableto usethe aircraftfor 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 ofthe Conditions and Limitations setforth in Exemption 11472 be amended to read: "Operations authorized bythis grant ofexemption are limited to theAltavian 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 ofany other aircraftwill 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 

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# ~~~=====~======~~~ KEYSTONE AERIAL SURVEYS All operations ofthese aircraftwill continue to be in accordancewith 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 ofsystem with payload and a speed notto 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 instructionsforthe operation of rotor craft. These and other pilot instructions for all UAS will be followed in orderto maintain the safety ofthe 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/2015/04/X8M-Operation-Manual-v3

.pdf X8-M Maintenance Manuals: http://3drobotics

.com/kb/x8-m-support/ SteadiDrone MavrickX4 Mavrik Quick Start Guide: https://drive

.google

.com/file/d/OBOEFpqbUh1 KaZOhZZUwvaVJMdWc/view

In orderto 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 ofthe 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 

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# 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 underthe Freedom of Information Act, 5 USC 552, etseq., and any other requirement established bythe FAA pursuantto Section 333 ofthe Reform Act.



# Si**"fi ~Jy**  David Day ExecutiveVice President Keystone Aerial Surveys, Inc.

Northeast Philadelphia Airport • P.O. Box 21059 Philadelphia, PA 19114 • V:215.677.3119 • F:215.464.2889 

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