Mark McKinnon

Dentons US LLP

1676 International Driv e • 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 S ixth Amendment to Exemption 11241 granted to Phoenix Air UNMANNED, LLC, (Docket No. FAA

– 2014

– 0692 )

To Whom i t 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 P hoenix Air to operate the

Pulse V apor 35 and Pulse Vapor 55. See Exemptio n 11241A. Phoenix Air requests that an

amendment be issued permitting Phoenix Air to ope r ate the Pulse Vapor 65.

14 C.F.R. Part 107 does not permit the operation of unmanned aircraf t weighing in excess of 55 pounds. The Pulse V apor 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 V apor 65 is a slightly scaled

- up version of the Pulse Vapor 55 , which has an opartional weight of 55 pounds. T he Pulse V apor 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

. I t is powered by a Hirth 403 (10 0cc) 8.2 HP fuel injected motor with a flight endurance of 180 minutes.

The Pulse V apor 65 employs the same s tate 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

dat alink 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 manuf

acturer 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 wi th the same equivalent level of safety as it currently has for operation of the Vapor 55

The public interest will be served by granting t h i s a m e n d m e n t . Congress has established a

n ational 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, t he proposed

Amendment significantly improve s safety and reduce s 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 amendm ent.

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