Mark E. McKinnon

Matthew J. Clark

Mark.McKinnon@dentons.com

Matthew.Clark@dentons.com

D 703.336.8708

D 703.336.8714

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102

United States

T 703.336.8800

F 703.336.8750

Salans FMC SNR Denton

McKenna Long

dentons.com

July 29, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition for Fourth 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)

To Whom it May Concern:

Phoenix Air UNMANNED, LLC (Phoenix Air) was issued Exemption No. 11241 on March 

26, 2015 (hereinafter "the Exemption"), allowing operation of UAS for aerial data collection. The

Exemption was subsequently amended to allow operation of the Pulse Aerospace Vapor 55 and

permit closed set motion picture and television filming on June 3, 2015. See Exemption 11241A. 

On July 24, 2015 Phoenix Air filed a third petition for amendment to allow operation of the Intuit 

Aerial Aerigon. Phoenix Air now presents this petition seeking an amendment to Exemption 11241 

to permit operation of the Freefly ALTA for both aerial data collection and closed set motion picture 

and television production.

If requested, Phoenix Air will submit a revised copy of the UAS Operations Manual and 

Closed Set Motion Picture and Television Operations Manual under separate cover pursuant to 14 

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

that 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 Exemption. 

Phoenix Air believes that an amendment adding the Freefly ALTA 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 and closed-set filming activities. The Freefly ALTA
July 29, 2015

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has six electric motors configured in a hexacopter formation and measures 1126 mm in diameter 

(without props). The vehicle is composed of carbon fiber and has a balsa core. It has a maximum 

gross take-off weight of 30 pounds, operates at a speed of less than 87 knots, and uses a command 

and control frequency of 2.4 GHz. The aircraft also has advanced safety features such as a lost link 

fail-safe mode and an advanced return to home system. Additional details on the Freefly ALTA's 

specifications and operational capabilities are available in the Freefly ALTA User Manual1and

Setup Guide.

2

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

UAS model, Phoenix Air 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, 

Mark E. McKinnon

Matthew J. Clark

 

Counsel for Phoenix Air UNMANNED, LLC

Attachments

 

1

See Attachment A.

2

See Attachment B.
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dentons.com

Attachment A – Freefly ALTA User Manual
July 29, 2015

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McKenna Long

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Attachment B – Freefly ALTA Setup Guide