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Mark E. McKinnon

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Matthew J. Cl ark

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

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. 11 273 Issued to AIG PC Global

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

FAA

- 2014

- 09 13 )

Dear Gentlemen :

AIG PC Global Services, Inc. ( AIG ) was issued Exemption No. 112 7 3 on April 2 , 2015 (hereinafter "the Exemption") , allowing the use of the Hawkeye Lancaster MK

- III, IRIS+, Phantom 2 Vision, and senseFly eBee for aeri al data collection. AIG hereby requests an amendment to the Exemption to add two additional UAS vehicle s 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 c r i teria 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 aircraftU.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.

 Al titude 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 cha rge 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.

 Progra mmable 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

Inc luded) 1242g 1496 g

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 GH z

Diagonal Distance (motor

motor) 350 mm 260 mm

Failsafe Return

- to

- Home (RTH) Function Yes YesU.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 giv en 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 see king 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,

Mar k E. McKinnon

Counsel for AIG Insurance Group

Attachment

3DR Solo Operators Manual