Ma rk 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 Refo rm 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. Th e

Exemption was subsequently ame nded 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 mo tion 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 a nd 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 F reefly ALTA to t he 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 ALTAJuly 29, 2015

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

(without props). The vehicle is c omposed of carbon fiber a nd has a balsa core

. It has a maximum

gro ss take

- off weight of 30 pounds

, operates a t a speed of less than 87 knots , and u ses 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 Manual 1 and

Setup Guide

. 2

As thi s is an amendment to an existing exemption seeking the addition of a su pplementary

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.July 29, 2015

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Attachment A

– Freefly ALTA User ManualJuly 29, 2015

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Attachment B

– Freefly ALTA Setup Guide