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Mark E. McKinnon

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Matthew J. Clark

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mclark@mckennalong.com

April 2, 2015

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 aerial 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 Aerospace 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 includes 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 be 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 with 
U.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 55 

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, Phoenix 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, LLC
U.S. Department of Transportation

April 2, 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:

Amended Phoenix Air UNMANNED Operations Manual 

Pulse Vapor 55 Aircraft Flight Manual