Mark McKinnon

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102-4832

United States

email: mark.mckinnon@dentons.com

T 703.336.8808

F 703.336.8750

Salans FMC SNR 

Denton

McKenna Long

dentons.com

February 3, 2017

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Petition for Sixth Amendment to Exemption 11241 granted to Phoenix Air 

UNMANNED, LLC, (Docket No. FAA–2014–0692)

To Whom it May Concern:

This office represents Phoenix Air UNMANNED, LLC (Phoenix Air) regarding the 

above-referenced Petition for Exemption, which was granted on March 26, 2015. On June 3, 

2015, the FAA granted an amendment to this exemption to permit Phoenix Air to operate the 

Pulse Vapor 35 and Pulse Vapor 55. See Exemption 11241A. Phoenix Air requests that an 

amendment be issued permitting Phoenix Air to operate the Pulse Vapor 65.

14 C.F.R. Part 107 does not permit the operation of unmanned aircraft weighing in excess 

of 55 pounds. The Pulse Vapor 65 has an operational weight of up to 65 pounds. As a result, it 

is not eligible for operation under 14 C.F.R. 107 as it is not a "small UAS." 

The Pulse Vapor 65 is a slightly scaled-up version of the Pulse Vapor 55, which has an 

opartional weight of 55 pounds. The Pulse Vapor 65 uses a rotorcraft configuration with a main 

rotor consisting of a 3 blade semi-rigid flybarless main rotor made of carbon fiber. It has a main 

rotor diameter of 7.5 feet. It is powered by a Hirth 403 (100cc) 8.2 HP fuel injected motor with a

flight endurance of 180 minutes. 

The Pulse Vapor 65 employs the same state of the art redundant safety systems as the 

Vapor 55, including a smart automatic homing system in the event of a lost link. In addition, the 

datalink is encrypted for additional security. It has an automatic flight control system to assist 

the pilot in operating the aircraft. It is capable of both waypoint guidance and joystick control. 

In the event of an in-flight problem, the aircraft is capable of an automatic autorotation. It also 

has an automatic rotor speed setting depending on altitude.

Phoenix Air will operate the Vapor 65 in accordance with all of the guidance provided by 

the manufacturer for its flight and maintenance. In addition, the aircraft will be operated in 

accordance with all of the terms and conditions contained in its existing Exemption. This 

includes operation by a pilot with a manned aircraft pilot's license, limitation to visual line of 

sight, and the altitude and horizontal separation limitations.
February 3, 2017

Page 2

Salans FMC SNR Denton

McKenna Long

dentons.com

Phoenix Air has extensive experience in the safe operation of the Vapor 55. Given that 

the Vapor 65 is only 15% heavier than the Vapor 55 and the aircraft employs the same 

configuration as the Vapor 55, Phoenix Air can operate the Vapor 65 with the same equivalent 

level of safety as it currently has for operation of the Vapor 55

The public interest will be served by granting this amendment. Congress has established a 

national policy that favors integration of UAS into the National Air Space (NAS). Granting this 

Petition for Exemption also helps fulfill Congress' goal in passing Section 333(a) through (c) of 

the Reform Act—the FAA Administrator's assessment of whether certain UAS may operate 

safely in the NAS before completion of the statutorily required rulemaking. Finally, the proposed 

Amendment significantly improves safety and reduces risk by alleviating the public's exposure to 

danger associated with the low level operation of a traditional rotorcraft

As this is an amendment to an existing exemption seeking the addition of supplementary 

UAS model, Phoenix Air UNMANNED respectfully submits that good cause exists so that 

notice does not need to be published in the Federal Register for the requested amendment.

If you have any questions regarding this amendment, or require any additional 

information to process this Petition, please do not hesitate to contact us. 

Very truly yours, 

Mark E. McKinnon

Counsel for Phoenix Air UNMANNED, LLC