JimWilliams UAS Integration Office FederalAviationAdministration 800 Independence Avenue SW Washington, DC 20591 March 9, 2015 

# Aki Gum
STRAUSS HAUER & FELD LLP

GREGORY5. WALDEN +1 202.887.4213/fax: +1 202.887.4288 gswalden@akingump.com

Re: Re: DocketFAA2014-0400, Petitionfor Second Amendmentto Exemption No. 11150 Dear Mr. Williams: This firm represents AeroCine, LLC, which received FAAExemption No. 11150 onJanuary 23, 2015 authorizing AeroCine under section 333 of the FAA Modernization and Reform Act of 2012 to operate its unmanned aircraft system ("UAS") for purposes ofcapturinghigh definition feature film quality aerial cinematography. On February 24, 2015, AeroCine submitted a petitionfor an amendmentto thatExemption to operate the same UAS (the Kopterworx Hammer X12) for additional purposes, namely real estate photography and videography, agriculture, inspections ofoil and gas facilities, flare stacks, and bridge infrastructure, wildlife preservation industries, and search and rescue operations. Thatpetitionremainspending. In this present petition for an amendment to Exemption No. 11150, AeroCine seeks to operate two additional types of UASs for the purposes listed above: (1) the DJI SlOOO and (2) the Aerobo UA V, designed and manufactured by AeroCine. Both UASs would be equipped with one oftwo flight controllers: eitherthe DJIWookong-M or the 3D Robotics Pixhawk. The airworthiness of the DJI SlOOO was previously determined by the FAA in Exemption No. 11156 (Total SafetyU.S. Inc.), Exemption No. 11158 (Team 5, LLC), and Exemption No. 11184 (Low Country RC). The airworthiness ofthe DJI Wookong-M flight controllerwas approved by FAAfor use by AeroCine with the Kopterworx Hammer X12 in Exemption No. 11150 granted to AeroCine. The 3D Robotics Pixhawkflight controller has been approved by FAAfor use by VikingUnmanned Aerial Systems inExemptionNo. 11192. AeroCine will comply with all of the conditions and limitations imposed in Exemption 11150 (with the amendment to condition/limitationnumber 2 to reflect additional purposes), exceptthat condition/limitation number 1 will need to be revised to include the DJI SlOOO and Aerobo UASs. The list of "operating documents" will also need to be revised to include AeroCine's

RobertS. Strauss Building 11333 New Hampshire Avenue, N.W.jWashington, D.C. 20036-15641202.887.4000 1 fax 202.887.42881 akingump.comJimWilliams FederalAviationAdministration March 9, 2015 Page 2 

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STRAUSS HAUER & FELD LLP

Technical Manuals for these two UASs equipped with flight controllers. Other than these revisions, there will be no change in the conditions and reasons relative to public safety that were the basisfor the initial grantofexemption. 1 TheAerobo is AeroCine'scustom designed carbon fiber frame to house the electronics and flight controller for its UAVs, as shown in manuals submitted to the FAA. The weight ofthe Aerobo with landing gear and electronics, but excluding gimbal, is about 15 pounds. The Aerobo was designed by several mechanical engineers with a master's degree who put the frame through strength analysis tests with cutting-edge, industry-leading software, confirmingit is significantly stronger, lighter, and more dynamically balanced than off-the-shelf frames. It provides an optimumlevel ofsafety. Because the requested amendment would not set any precedent or otherwise raise any novel issue, and because AeroCine seeks to begin these operations without delay, AeroCine respectfully requests the FAAto determine that good cause exists to dispense withpublication of the summary of this petition in the Federal Register and grant the requested amendment expeditiouslyby summarymeans. Thankyou for your considerationofthis petition. Sincerely,

roCine, LLC
Enclosures (notfiled withwww.regulations.gov)

1 Submitted separately to this amendment petition are several manuals prepared by AeroCine, which contain proprietary and commercially sensitive material, and which are not publicly available. Accordingly, these documents are exempt from required disclosure under the Freedom ofInformation Act, 5 U.S.C. 552(b)(4) and are not to be included in the Federal Docket Management Systemper 14 C.F.R. 11.35(b).