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Mark E. McKinnon

703.336.8708

Matthew J. Clark

703.336.8714

Email Address

mmckinnonf@mckennalong.com

mclark@mckennalong.com

April 30, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition to Amend Exemption No. 11293 Issued to Erie Insurance Group

Pursuant to Section 333 of the FAA Reform Act (Docket No. FAA-2014-

0962)

Dear Gentlemen:

Erie Insurance Group (Erie) was issued Exemption No. 11293 on April 8, 2015 

(hereinafter "the Exemption"), allowing operation of the DJI Phantom 2 Vision+ for aerial data 

collection. Erie hereby requests an amendment to the Exemption to add an additional UAS 

vehicle that fully complies with the conditions of the Exemption.

Erie seeks to operate the DJI Phantom 3 Professional and Advanced Models (hereinafter 

“Phantom 3”) under the same conditions and limitations contained in the Exemption. Erie will 

revise its UAS Operations Manual to include the DJI Phantom 3. If requested, Erie will submit a 

revised copy of the UAS Operations Manual to the Administrator under separate cover pursuant 

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

information that Erie has not and will not share with others. Additionally, the document contains

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. 

Erie believes that an amendment adding the DJI Phantom 3 to the Exemption is in the 

public's interest as it would reduce hazards and emissions associated with alternate use of

manned aircraft to conduct similar aerial data collection. Like the DJI Phantom 2 Vision+ 

authorized for use under the Exemption, the DJI Phantom 3 is light weight and does not carry 
U.S. Department of Transportation

April 30, 2015

Page 2

any flammable fuel, further reducing the risk from any potential accident. Moreover, the size, 

weight, design, and performance specifications of the DJI Phantom 3 are substantially similar to 

those of the DJI Phantom 2 Vision+ in all relevant aspects. Below is a side-by-side comparison 

chart of DJI Phantom 2 Vision+ and DJI Phantom 3 specifications1: 

Specifications DJI Phantom 2 Vision+ DJI Phantom 3 

Weight (Battery & Props 

Included) 1242g 1280g

Max Speed 15 m/s 16 m/s

Max Ascent / Max Descent Ascent: 6 m/s, Descent: 3 m/s Ascent: 5 m/s, Descent: 3 m/s

Battery Capacity 5200 mAh - 11.1 V 4480 mAh-15.2 V

Controller Operating 

Frequency 5.728 GHz – 5.85 GHz. 2.4000 GHz -- 2.483 GHz

Diagonal Distance (motormotor) 350mm 350mm

Failsafe Return-to-Home 

(RTH) Function Yes Yes 

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

UAS model that is substantially similar to the one currently authorized for use under the 

Exemption, Erie 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. 

 

1

For additional information on DJI Phantom 3 specifications, see the DJI Phantom 3 Advanced 

User Manual v1.0 included as Attachment A and the DJI Phantom 3 Professional user Manual 

v1.0 included as Attachment B
U.S. Department of Transportation

April 30, 2015

Page 3

Very truly yours, 

Mark E. McKinnon 

Matt Clark

 

Counsel for Erie Insurance Group

Attachments
U.S. Department of Transportation

April 30, 2015

Page 4

Attachment A: DJI Phantom 3 Advanced User Manual v1.0
U.S. Department of Transportation

April 30, 2015

Page 5

Attachment B: DJI Phantom 3 Professional User Manual v1.0