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Mark E. McKinnon

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Matthew J. Clark

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mclark@mckennalong.co m

April 2

, 201 5

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: 

### 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 operation of the Pulse

Vapor 35 and Vulcan Octo UASs for filmmaking, precision aer ial surveys and infrastructure

inspections. Phoenix Air UNMANNED hereby requests an amendment to the Exemption to add

an additional model of UAS that fully complies with the conditions of the Exemption.

Phoenix Air UNMANNED seeks to operate the Pulse Aer ospace Vapor 55 UAS under

the same conditions and limitations contained in the Exemption. Phoenix Air UNMANNED will

submit the Pulse Aerospace Vapor 55 Aircraft Flight Manual and a revised version of the

Phoenix Air UNMANNED UAS Operations Manual that inc ludes the Vapor 55. These manuals

are submitted as confidential documents 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. All operations of the

additional UAS will b e in full compliance with the terms of the Exemption.

Phoenix Air UNMANNED believes that an amendment adding the Vapor 55 to the

Exemption is in the public's interest as it would reduce hazards and emissions associated withU.S. Department of Transportation

April 2, 2015

Page 2

alternate use of helicopters to conduct similar inspection operations. Like the other UAS models

authorized for use under the Exemption, the Vapor 55 is light weight and does not carry any

flammable fuel, further reducing the risk from any potential accident. In addition, the Vapor 5 5

is equipped with state of the art safety features, such as a "return to home" capability and an

encrypted digital link to ensure safe operations.

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

UAS model, Pho enix Air UNMANNED respectfully submits that 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 the Exemption, please do not hesitate to contact the undersigned.

Very truly yours,

/s/

Mark E. McKinnon

Matthew J. Clark

Counsel for Phoenix Air UNMANNED, LLCU.S. Department of Transportation

April 2, 2015

Page 3

(These a ttachments 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:

Amended Phoenix Air UNMANNED Operations Manual

Pulse Vapor 55 Aircraft Flight Manual