Jim Williams 

UAS Integration Office 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

March 9, 2015 

Aki Gum 

STRAUSS HAUER & FELD LLP 

GREGORY 5. WALDEN 

+1 202.887.4213/fax: +1 202.887.4288 

gswalden@akingump.com 

Re: Re: Docket FAA 2014-0400, Petition for Second Amendment to Exemption No. 

11150 

Dear Mr. Williams: 

This firm represents AeroCine, LLC, which received FAA Exemption No. 11150 on January 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 of capturing high definition 

feature film quality aerial cinematography. On February 24, 2015, AeroCine submitted a 

petition for an amendment to that Exemption to operate the same UAS (the Kopterworx Hammer 

X12) for additional purposes, namely real estate photography and videography, agriculture, 

inspections of oil and gas facilities, flare stacks, and bridge infrastructure, wildlife preservation 

industries, and search and rescue operations. That petition remains pending. 

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 of two flight controllers: either the DJI Wookong-M or the 3D Robotics Pixhawk. 

The airworthiness of the DJI SlOOO was previously determined by the FAA in Exemption No. 

11156 (Total Safety U.S. Inc.), Exemption No. 11158 (Team 5, LLC), and Exemption No. 11184 

(Low Country RC). The airworthiness of the DJI Wookong-M flight controller was approved by 

FAA for use by AeroCine with the Kopterworx Hammer X12 in Exemption No. 11150 granted 

to AeroCine. The 3D Robotics Pixhawk flight controller has been approved by FAA for use by 

Viking Unmanned Aerial Systems in Exemption No. 11192. 

AeroCine will comply with all of the conditions and limitations imposed in Exemption 11150 

(with the amendment to condition/limitation number 2 to reflect additional purposes), except that 

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.j Washington, D.C. 20036-15641202.887.4000 1 fax 202.887.42881 akingump.com 
Jim Williams 

Federal Aviation Administration 

March 9, 2015 

Page 2 

AkinGump 

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 basis for the initial grant of exemption. 1 

The Aerobo is AeroCine's custom designed carbon fiber frame to house the electronics and flight 

controller for its UAVs, as shown in manuals submitted to the FAA. The weight of the 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, confirming it is significantly 

stronger, lighter, and more dynamically balanced than off-the-shelf frames. It provides an 

optimum level of safety. 

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 FAA to determine that good cause exists to dispense with publication of 

the summary of this petition in the Federal Register and grant the requested amendment 

expeditiously by summary means. 

Thank you for your consideration of this petition. 

Sincerely, 

roCine, LLC 

Enclosures (not filed with www.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 of Information Act, 5 U.S.C. 552(b)(4) and are 

not to be included in the Federal Docket Management System per 14 C.F.R. 11.35(b).