Albany 1.1`.'Kellila Lolig NorthernVirginia 

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Miami Seoul 

NewYork Washington, DC 

MARK E. MCKINNON EMAIL ADDRESS 

703.336.8708 mmckinnon@mckennalong.com 

February 13, 2015 

Nia Daniels 

Federal Aviation Administration 

Office of Rulemaking, Airmen & Airspace 

Division 

800 Independence Ave., SW 

Washington, DC 20591 

Re: FAA Docket No. FAA-2014-0962 

Dear Ms. Daniels: 

The following is the response to your request for additional information in support of the 

above referenced Petition for Exemption. For your convenience, this response includes your 

question and the response. 

l. Describe the size of the aircraft for the proposed UAS operation. 

All of the specifications for the proposed UAS can be found on page A-72 of the Erie 

Insurance UAS Operations Manual, which 'is submitted as a confidential and proprietary 

document. The UAS has a maximum operational weight of approximately 4 pounds. 

2. Provide information regarding the radio frequency spectrtun. This information 

can be located in the aircraft manual. 

The operating frequency of the controller is 5.728 GHz — 5.85 GHz. 

3. Provide description of proximity to airports. 

The procedures for operations in the vicinity to airports can be found in section 7.2.5 and 

7.2.6 of the Erie UAS Operations Manual, 
Nia Daniels 

February 13, 2015 

Page 2 

4. Your petition references a pre-flight inspection and/or checklist. Describe the 

process used to determine if the UAS is airworthy and in safe condition for 

operation in the NAS. 

The Preflight procedures can be found in Section 8 of the Erie UAS Operations Manual. 

Additional preflight procedures can be found in the DJI Phantom 2 Vision+ User's Manual 

which is incorporated as Appendix A to the Erie UAS Operations Manual. Finally, procedures 

can be found in the Normal Flight Operations Procedures Checklist which is incorporated as 

Appendix G to the Erie UAS Operations Manual. 

5. Describe the process used to document UAS discrepancies and the corrective 

action taken in the aircraft record. Examples of processes include (1) the petitioner has elected 

to use its own process to maintain its UAS and ensure that only airworthy and safe UAS will be 

allowed to operate in the NAS and (2) the petitioner has elected to maintain its UAS in 

accordance with the manufacturer maintenance and inspection recommendations. 

Documentation processes can be found in Sections 13 and 15 of the Erie UAS Operations 

Manual. In addition, the Aircraft will be maintained in.accordance with the procedures set forth 

in the DJI Phantom 2 Vision+ User's Manual which is incorporated as Appendix A to the Erie 

UAS Operations Manual. Additional documentation requirements can be found in Appendix B, 

C, D, E, and F of the Erie UAS Operations Manual. 

For your convenience, an additional hard copy and electronic copy of the Erie UAS 

Operations Manual and the incorporated DJI Phantom 2 Vision+ Manual are being hand 

delivered as confidential and proprietary documents. If you have any additional questions, 

please do not hesitate to contact me. 

truly yours, 

— 

Mark E. McKinnon