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Mark E. McKinnon

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Matthew J. Clark

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June 15, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition to Amend Exemption No. 11273 Issued to AIG PC Global 

Services, Inc. Pursuant to Section 333 of the FAA Reform Act (Docket No. 

FAA-2014-0913)

Dear Gentlemen:

AIG PC Global Services, Inc. (AIG) was issued Exemption No. 11273 on April 2, 2015 

(hereinafter "the Exemption"), allowing the use of the Hawkeye Lancaster MK-III, IRIS+, 

Phantom 2 Vision, and senseFly eBee for aerial data collection. AIG hereby requests an 

amendment to the Exemption to add two additional UAS vehicles that fully comply with the 

conditions of the Exemption, the DJI Phantom 3 and the 3DR Solo.

I. DJI Phantom 3

AIG believes that an amendment adding the DJI Phantom 3 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. The FAA has already ruled that the 

DJI Phantom 3 meets all of the criteria set forth in Section 333 of the FAA Modernization and 

Reform Act of 2012. See, Exemption No. 11860, Docket No. FAA-2015-1127. Therefore, 

based on the foregoing, AIG requests permission to operate the DJI Phantom 3 subject to the 

same terms and limitations contained in Exemption 11273. 

II. 3DR Solo

AIG believes that an amendment adding the 3DR Solo to the Exemption is in the public's 

interest as it would reduce hazards and emissions associated with alternate use of manned aircraft 
U.S. Department of Transportation

June 15, 2015

Page 2

to conduct similar aerial data collection. The 3DR Solo is a light weight battery powered 

quadcopter which incorporates a number of advanced safety features, including:

 A choice between automatic and manual take-off and landing.

 A sophisticated system of computer assisted navigation and flight management.

 Altitude is determined based on a combination of barometers and inertial navigation.

 The ability to both return to home or return to a predetermined point that has been 

preselected as free from obstructions or hazards.

 The ability to set custom battery charge warning levels and to set either an automatic return 

to home or return to a preset location in the event of a low battery.

 Tactile feedback in the controller when warnings are given to alert the pilot to certain 

conditions such as low battery.

 Programmable geo-fencing capabilities allowing the creation of a virtual “safety fence.”

The following is a side by side comparison between the DJI Phantom 2 Vision+ and the 3DR Solo. 

Specifications DJI Phantom 2 Vision+ 3DR Solo 

Weight (Battery & Props 

Included) 1242g 1496g

Max Speed 15 m/s 25 m/s

Max Ascent / Max Descent

Ascent: 6 m/s 

Descent: 3 m/s

Ascent: 5 m/s

Descent: 2.5 m/s

Battery Capacity 5200 mAh - 11.1 V 5200 mAh-14.8 V

Controller Operating 

Frequency 5.728 GHz – 5.85 GHz. 2.40 GHz -- 2.48 GHz

Diagonal Distance (motormotor) 350 mm 260 mm

Failsafe Return-to-Home 

(RTH) Function Yes Yes 
U.S. Department of Transportation

June 15, 2015

Page 3

The 3DR Solo is, in most respects, substantially similar in terms of its weight and 

performance to the DJI Phantom 2 Vision+, which the FAA has already given AIG permission to 

operate. Therefore, based on the foregoing, AIG requests permission to operate the 3DR Solo 

subject to the same terms and limitations contained in Exemption 11273. 

III. Conclusion

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

UAS model that is substantially similar to the one currently authorized for use under the 

Exemption, AIG respectfully submits that good cause exists so that notice does not need to be 

published in the Federal Register for the requested amendment.
U.S. Department of Transportation

June 15, 2015

Page 4

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. 

Very truly yours, 

Mark E. McKinnon 

Counsel for AIG Insurance Group

Attachment

3DR Solo Operators Manual