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Mark E. McKinnon

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Matthew J. Clark

703.336.8714

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mmckinnonf@mckennalong.com

mclark@mckennalong.com

April 16, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Second Amendment to Exemption No. 11241 Issued to Phoenix Air 

UNMANNED, LLC Pursuant to Section 333 of the FAA Reform Act

(Docket No. FAA-2014-0692)

Dear Gentlemen:

Phoenix Air UNMANNED, LLC ("Phoenix Air UNMANNED") was issued Exemption No. 

11241 on March 26, 2015 (hereinafter "the Exemption"), allowing commercial operation of the Pulse 

Vapor 35 and Vulcan Octo UASs for aerial data collection and filming. On March 31, 2015, 

Phoenix Air UNMANNED filed a petition to amend the Exemption to allow operation of the Pulse 

Aerospace Vapor 55 UAS under the same conditions and limitations contained in the Exemption. 

That petition to amend the Exemption remains pending. 

Phoenix Air UNMANNED hereby requests a second amendment to the Exemption to allow 

UAS operations for the purpose of closed-set motion picture and television filming. Specifically, 

Phoenix Air UNMANNED seeks revision to conditions and limitations number 2 of the Exemption

to state:

"2. Operations for the purpose of closed-set motion picture and television filming 

are permitted."

In all other respects, the closed-set motion picture and television filming will be conducted in 

accordance with the same conditions and limitation contained in the Exemption. 

As required by conditions and limitations number 29 of the Exemption, the Petitioner is 

filing under separate cover the Phoenix Air UNMANNED, LLC Movie Production and Television 
U.S. Department of Transportation

April 16, 2015

Page 2

Operations Manual ("MPTOM"). The MPTOM is submitted as a confidential document pursuant to 

14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary 

information that Phoenix Air UNMANNED has not and will not share with others. Additionally, 

these documents contain operating conditions and procedures that are not generally available to the 

public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq. 

Phoenix Air UNMANNED believes that an amendment allowing UAS operations for the 

purpose of closed-set motion picture and television filming is in the public's interest as it would

reduce hazards and emissions associated with alternate use of helicopters to conduct similar closedset filming operations. Petitioner's UASs are light weight and do not carry any flammable fuel, 

further reducing the risk from any potential accident.

Phoenix Air UNMANNED respectfully submits that this amendment qualifies for summary 

grant approval. The FAA has already granted previous exemptions similar to this amendment 

request, namely; small UAS operations for film/television production. See e.g., Grant of Exemption 

to Ryan K. Koffman, Exemption No. 11314. Given that the proposed operations will fully comply 

with the other conditions of the Exemption, there is no need for the FAA to repeat the analysis 

performed for the original exemption on which this amendment is based. For these same reasons, 

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

requested amendment.

If you have any questions, or need any additional information to process the requested 

amendment to allow UAS operations for the purpose of closed-set motion picture and television 

filming, please do not hesitate to contact the undersigned. 

Very truly yours, 

Matthew J. Clark

Mark E. McKinnon 

 

Counsel for Phoenix Air UNMANNED, LLC

Attachments
U.S. Department of Transportation

April 16, 2015

Page 3

(These attachments are submitted as a Confidential Document under 14 C.F.R. § 11.35(b) and 

exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any 

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

Attachments:

Phoenix Air UNMANNED, LLC Movie Production and Television Operations Manual 

(MPTOM)