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Mark E. McKinnon

703.336.870 8

Matthew J. Clark

703.336.8714 Email Address

mmckinnonf@mckennalong.com

mc lark@mckennalong.com

April 30

, 201 5

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 mater ials contain confidential commercial and/or proprietary

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

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 carryU.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 D JI Phantom 2 Vision+ in all relevant aspects. Below is a side

- by

- side comparison

chart of DJI Phantom 2 Vision+ and DJI Phantom 3 specifications 1 :

Specifications DJI Phantom 2 Vision+ DJI Phantom 3

Weight (Battery & Props

Inclu ded) 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 GH z

D iagonal Distance (motor

motor) 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 authoriz ed 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 D JI Phantom 3 Advanced

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

v 1.0 included as Attachment BU.S. Department of Transportation

April 30, 2015

Page 3

Very truly yours,

Mark E. McKinnon

Matt Clark

Counsel for E rie Insurance Group

Attachment sU.S. Department of Transportation

April 30, 2015

Page 4

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

April 30, 2015

Page 5

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