www.pillsburylaw.com 405255227v3 Kenneth P. Quinn kquinn@pillsburylaw.com Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW | Washington, DC 20036 | tel 202.663.8000 | fax 202.663.8007

May 26, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition to Amend Exemption 11593, Docket FAA-2015-0477

To whom it may concern:

On May 15, 2015, Freeport-McMoRan, Inc. (“Freeport”) received an exemption
under Section 333 of the FAA Modernizatio n and Reform Act of 2012 to conduct commercial operations with Prioria Robotic s, Inc.’s (“Prioria”) Maveric small unmanned aircraft system (“sUAS”) to provi de surveying and mine -related services at Freeport’s U.S. mines, which are primarily located in remote unpopulated and accesscontrolled areas with minimal air traffic. Freeport submits this petition to amend Exemption 11593 to include an exemption from 14 C.F.R. § 91.119( c)’s prohibition on operating closer than 500 feet to any person, vessel, vehicle, or structure. Freeport requests that the FAA amend Condition Number 26 of Exemption 11593 to allow Freeport to operate the Maveric sUAS as close as 50 feet from nonparticipants without barriers or structures present to protect them. Specifically, Freeport requests
that Condition Number 26 be amended to read:

26. All Flight operations must be c onducted at least 50 feet from all nonparticipating persons, vessels, ve hicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonpartic ipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are
within 50 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safetyMay 26, 2015 Page 2

www.pillsburylaw.com 405255227v3 assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or e ssential persons are not considered nonparticipating persons under this exemption.

In support of this petition, Fr eeport incorporates by referenc e its original petition for exemption, which describes, among other things, the sUAS operating area; the reasons Freeport’s sUAS operations are in th e public interest; the Maveric sUAS and its safety features; and Freeport’s mine sa fety training, required personal protective gear, and coordination with mine safety personnel.

In support of its petition to amend its ex emption, Freeport is enclosing the Freeport Risk Assessment under separate cover w ith a request for c onfidentiality. As explained in the Risk Assessment, an equiva lent level of safety is provided by the Maveric’s light weight, airspeed, 1 and safety features; the very low population density of Freeport’s mines, and the PIC training requirements.

Freeport respectfully submits that the Fr eeport Risk Assessment provides the FAA with sufficient grounds to grant Freeport’ s request for exemp tion from 14 C.F.R. § 91.119(c) to operate the Maveric sUAS as close as 50 feet from nonparticipants without barriers or structures present to protect them. In the event that the FAA requires additional information to grant the requested relief, Freeport requests that the FAA contact me, with a copy to Jennifer Tr ock (jennifer.trock@ pillsburylaw.com), and identify the additional required materials.

Federal Register Summary

Pursuant to 14 C.F.R. § 11.81(f), the follo wing summary is provided for publication in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA-2015-0477 Petitioner: Freeport McMoRan, Inc. Section of 14 CFR: Part 21, § 61.113( a) and (b), § 91.7(a), § 91.119(c), § 91.121, § 91.151(a), § 91.405(a), § 91.407(a )(1), § 91.409(a)(2), § 91.417(a) and (b).

1 As described in the safety assessment, Freeport w ill limit the Maveric’s airspeed to under 41 knots.May 26, 2015 Page 3

www.pillsburylaw.com 405255227v3 Description of Relief Sought: Freeport is seeking to amend Exemption No. 11593, which allows for commerci al mining-support operations using small unmanned aircraft (sUAS), to allo w for sUAS operations as close as 50 feet from nonparticipants.

Sincerely,

Kenneth P. Quinn