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Mark E. McKinnon

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Matthew J. Clark

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mclark@mckennalong.com

June 2, 2015

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 Concern:

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 Exemption to add additional 

sUAS vehicles that fully comply with the conditions of the Exemption.

Auburn seeks to operate the following additional sUAS vehicles under the same 

conditions and limitations contained in the Exemption: PrecisionHawk Lancaster Hawkeye MkIII, DJI Phantom 2, DJI Inspire 1, 3D Robotics Iris, 3D Robotics Iris+, Trimble UX5, Auburn 

EasyStar sUAS, and Auburn War Eagle Fixed Wing 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 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

 Auburn sUAS Operations Manual v1.1 
U.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 sUAS vehicles to the Exemption 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 vehicles are light weight and do not carry any flammable fuel, 

further reducing the risk from any potential accident. Moreover, the 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, Inc.; Exemption 

No. 11445 to Unmanned Aerial Solutions; Exemption 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. 11273 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. Auburn'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 use an auto-pilot system to maintain sUAS stability 
U.S. Department of Transportation

June 2, 2015

Page 3

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

lost-link event with a pre-coordinated, predictable, automated flight maneuver. The radio 

frequencies used for operations and control of Auburn'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 sUAS vehicles that the FAA has either already 

approved for performing aerial data collection, or vehicles which exhibit the same exact 

characteristics and operating capabilities which 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 believes 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 Exemption, please do not hesitate 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, 

Matthew J. Clark

 Mark E. McKinnon

Attachments
U.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

 Auburn sUAS Operations Manual v1.1