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

 

August 6, 2015

To Whom it May Concern:

On April 15, 2015, Duke University (hereinafter "Duke") filed a Petition for Exemption 

under Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, to

allow commercial operation of small UAS in support of its education and research programs. Duke 

University hereby requests an amendment to its Petition for Exemption to add three additional UAS 

models: 3D Robotics Iris, 3D Robotics Iris+, and 3D Robotics Solo. 

In support of this Amended Petition for Exemption, Duke will also submit The University

UAS Operations Manual. Duke submits this material as a confidential document under separate

cover pursuant to 14 C.F.R. § 11.35(b), as the material contains confidential commercial and

proprietary information that Duke has not and will notshare with others. The information contained

in the material is not generally available to the public and is protected from release under the

Freedom of Information Act, 5 U.S.C. § 552 et seq.

For ease of use, this Amendment sets forth the heading of the applicable section of the April 

15, 2015 Petition for Exemption, followed by a description of the addition or change to the section. 

OVERVIEW CHARACTERISTICS OF PROPOSED UAS

Duke amends this section of its Petition for Exemption to include an overview of the 

characteristics of the 3D Robotics Iris, 3D Robotics Iris+, and 3D Robotics Solo. 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Amendment to Duke University Section 333 Petition for Exemption (Docket No. 

FAA-2015-1679)

3DR Solo 3DR Iris 3DR Iris+

Aircraft Type Multirotor (4 rotors) Multirotor (4 rotors) Multirotor (4 rotors)

Aircraft Weight 1.8kg/3.97lbs 1.3kg/2.83lbs 1.3kg/2.83lbs
U.S. Department of Transportation

August 6, 2015

Page 3

The FAA is familiar with and has already determined that the addition UAS models that 

Duke seeks to add, including the 3D Robotics Iris, 3D Robotics Iris+, and 3D Robotics Solo, 

meet the requirements of Section 333 of the Reform Act due to their weight, speed and operational

capabilities. See e.g.,

 3D Robotics Iris: Exemption No. 11521 to SkyWard IO, Inc.; Exemption No. 11533 to 

AviTronics Integrated Solutions LLC 

 3D Robotics Iris+: Exemption No. 11273 to AIG PC Global Services, Inc.; Exemption 

No. 1141 to Douglas R. Dorrer; and Exemption No. 11204 to Build Imagery, LLC; 

Exemption no. 12036 to Northwest Hydraulic Consultants

 3D Robotics Solo: Exemption No. 11778A to Cloud9Drones; Exemption No. 11832 to 

AUV, LLC; Exemption No. 12009 to Aerial Indigo, LLC; Exemption No. 11204 to Build 

Imagery, LLC; Exemption No. 11954 to Flying Solutions

QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

Duke amends the limitations and conditions in this section of the Petition for Exemption to 

read as follows:

1. Operations authorized by this grant of exemption are limited to the following aircraft: 

SenseFly eBee, Mikrokopter HEX XL, Freefly Cinestar 6, 3D Robotics Solo, 3D 

Robotics Iris, and 3D Robotics Iris+. 

Max Take-off Weight 2.2kg/4.9lbs 1.68 kg/3.7lbs 1.68 kg/3.7lbs

Dimensions 460x460x250mm 500x500x100mm 550x550x100mm

Max Flight time (aprox) 20mins 15mins 20mins

Max airspeed 48kts 25kts 35kts

Propulsion Brushless DC motor Brushless DC motor Brushless DC motor

Power Lithium polymer 5200 

mAh 14.8 Vdc

11.1v 3500 mAh 30 c 5100 mAh 3S 8C 

lithium polymer battery

Payload Digital compact /Video

camera

Digital compact /Video

camera

Digital compact /Video

camera

Airframe material Plastic Nylon/Plastic Nylon/Plastic
U.S. Department of Transportation

August 6, 2015

Page 4

We thank you for your prompt consideration of these amendments. Should you have any

questions, or if you need additional information to process Duke's Petition, please do not hesitate to 

contact us. 

Very truly yours,

Mark E. McKinnon

Matthew J. Clark

Counsel for Duke University 

Attachment
U.S. Department of Transportation

August 6, 2015

Page 5

(The following attached item will be submitted under separate cover as it contains proprietary and

commercial information exempt from disclosure under the Freedom of Information Act, 5 U.S.C. §

522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments:

 The University UAS Operations Manual