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Tel: 703.336.8800 mckennalong. com Northern Virginia

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Mark E. McKinnon

703.336.870 8
Matthew J. Clark

703.336.8714 Email Address mmckinnonf@mckennalong.com mclark@mckennalong.com

June 2

, 201 5

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: 

### Petition to Amend Exemption No. 11304 Issued to Auburn University

Aviation Center (Docket No. FAA

- 2014

- 1014 )

To Whom it May Co ncern :

Auburn University Aviation Center (Auburn ) was issued Exemption No. 11293 on April

8 , 2015 (hereinafter "the Exemption") , allowing operation of the DJI Phantom 2 Vision+ for

aerial data collection. Auburn hereby requests an amendment to the Exempti on to add additional

s UAS vehicle s that fully comply with the conditions of the Exemption.

Auburn seeks to operate the following additional s UAS vehicles under the same conditions and limitations contained in the Exemption: PrecisionHawk Lancaster Hawkeye M k

III, DJI Phantom 2, DJI Inspire 1, 3D Robotics Iris, 3D Robotics Iris+

, Trimble UX5 , Auburn EasyStar sUAS, and Auburn War Eagle Fixed W ing sUAS . In addition to this Petition to Amend Exemption No. 11304 , Auburn will also submit the following additional supporting documents:

 Auburn Lancaster Hawkeye Mk

- III sU AS Aircraft Flight Manual

 Auburn DJI Phantom 2 and Vision+ sUAS Aircraft Flight Manual

 Auburn Trimble UX5 sUAS Aircraft Flight Manual

 Auburn DJI Inspire 1 sUAS Aircraft Flight Manual

 Auburn 3D Robotics IRIS sUAS Aircraft Flight Manual

 Auburn War Eagle Fixed Wing sUAS Aircraft Flight Manual

 Auburn EasyStar sUAS Aircraft Flight Manual

 Auburn sUAS Operati ons Manual v1.1U.S. Department of Transportation

June 2, 2015 Page 2

Auburn submits these manuals as confidential documents under separate cover pursuant to 14
C.F.R. § 11.35(b), as the materials contain confidential commercial and proprietary information that

Auburn has not and will not share with others. The information contained in these documents 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.

Auburn believes that an amendment adding these s UAS vehicles to the Exemptio n 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. Like the DJI Phantom 2 Vision+ authorized for use under the Exemption, the additional vehicl es are light weight and do not carry any flammable fuel, further reducing the risk from any potential accident. Moreover, t he FAA is familiar with and has already determined that six of the eight additional vehicles chosen by Auburn meet the requirements

of Section 333 of the Reform Act due to their weight, speed and operational capabilities: PrecisionHawk Lancaster Hawkeye Mk

- III, DJI Phantom 2, DJI Inspire 1, 3D Robotics Iris, 3D Robotics Iris+, and Trimble UX5. See e.g.,

 PrecisionHawk Hawkeye Lancaster Mk

- III : Exemption No. 11273 to AIG PC Global Services, Inc.; Exemption No. 11573 to Ag Tech Enterprises, Inc.; Exemption No. 11551 to AgWorx Inc; Exemption No. 11345 to PrecisionHawk, Inc.

 DJI Phantom 2 : Exemption No. 11494 to The Travelers Companies, In c.; Exemption No. 11445 to Unmanned Aerial Solutions; Exempti on No. 11442 to Hazon Solutions

 DJI Inspire 1 : Exemption No. 11657 to Fresh Cut Above, Inc.; Exemption No. 11658 to Navigator CS, LLC; Exemption No. 11659 to Fovea Aero Systems LLC

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

AviTronics Integrated Solutions, LLC

 3D Robotics Iris +: Exemption No. 11549 to Thomas' Wildlife Solutions, Inc. ; Exemption No. 11490 to The Travelers Companies, Inc. ; Exemption No. 112 73 to AIG PC Global Services, Inc.

 Trimble UX5: Exemption No. 11432 to CompassData, Inc.; Exemption No. 11329 to Falkirk Mining Company; Exemption No. 11110 to Trimble Navigation, Ltd.

Auburn 's proprietary UAS vehicles

— the War Eagle Fixed Wing sUAS and EasyStar sUAS

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

. A uburn's War Eagle Fixed Wing sUAS and EasyStar sUAS both weigh less than 55 pounds including payload

. They also have the capability to operate safely after experiencing

certain in

- flight contingencies or failures and u se an auto

- pilot system to maintain s UAS stabilityU.S. Department of Transportation

June 2, 2015 Page 3

and control. The War Eagle sUAS and EasyStar sUAS a re also able to respond to a loss of GPS or a

lost

- link event with a pre

- coordinated, predictab le, automated flight maneuver. The radio frequencies used for operations and control of A uburn's War Eagle and EasyStar sUAS also comply

with the Federal Communications Commission (FCC) and other appropriate government oversight agency requirements . Finally, both sUAS vehicles operate at a speed of 87 knots or less.

As this amendment only seeks to add s UAS vehicles that the FAA has either al ready approved for performing aerial data collection, or vehicles which exhib it the same exact
characteristics and operating capabilities w hich would warrant approval under Section 333 of the Reform Act, Auburn respectfully submits that this amendment request is not precedent setting and therefore qualifies for expedited approval via the FAA's summary grant process. For these same reasons, Auburn also belie ves that good cause exists for not publishing a summary of this amendment request in the Federal Register.

If you have any questions, or need any additional information to process the requested amendment to the Exempti on, please do not hesi tate to contact the undersigned, or John McGraw

at:
John McGraw John McGraw Aerospace Consulting, LLC

Phone: 540

- 219

- 1638

Web: www.jmacaerospace.aero Email: john@jmacaerospace.aero

Very truly yours,

Matt hew J. Clark

Mark E. McKinnon

Attachment sU.S. Department of Transportation

June 2, 2015 Page 4

(The following attached items contain 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:

 Auburn Lancaster Hawkeye Mk

- III sUAS Aircraft Flight Manual

 Auburn DJI Phantom 2 and Vision+ sUAS Aircraft Flight Manual

 Auburn Trimble UX5 sUAS Aircraft Flight Manual

 Auburn DJI Inspire 1 sUAS Aircraft Flight Manual

 Auburn 3D Robotics IRIS sUAS Aircraft Flight Manual

 Auburn War Eagle Fixed Wing sUAS Aircraft Flight Manual

 Auburn EasyStar sUAS Aircraft Flight Manual

 Au burn sUAS Operations Manual v1.1