June	28,	2015

U.	S.	Department	of	Transportation	

Docket	Management	System

1200	New	Jersey	Ave	SE

Washington,	DC	20590

Re:	Exemption	Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation	

Regulations

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14	

C.F.R.	Part	11,	New	Mexico	State	University’s	Physical	Science	Laboratory	(NMSU/PSL),	the	operator	of	

the	3D	Robotics	X8	and	Y6	multi-copter	sUAS,	seeks	an	exemption	from	the	Federal	Aviation	Regulations	

(“FARs”)	listed	below	and	discussed	in	Appendix	A.

Description	of	the	UAS

1. 3D	Robotics	X8

The	3D	Robotics	X8	is	an	8	motor	sUAS	in	a	Standard	X	frame	Quad	formation.

The	3DR	X8	features	the	APM	2.6	autopilot	system	and	GPS	navigation	combined	with	a	powerful	and	

redundant	multi-rotor	design.	As	part	of	the	APM	Copter	family,	the	3DR	X8	uses	the	full	range	of	

autonomous	flight	features	supported	by	APM	Copter,	including	loiter,	circle,	return	to	launch,	follow	

me,	acrobatic	flying	mode,	and	more.	Installation	of	free	mission	planning	software	allows	the	operator	

to	run	programmed	way	point	missions	and	analyze	flight	data.	Geo-fencing,	robust	fail-safes,	and	a	

durable	airframe	provide	preventative	safety	measures	to	give	peace	of	mind.	3DR	X8	is	the	most	

powerful	3DR	multi-copter	solution,	perfect	for	heavy	payloads,	stability	in	high	winds,	and	capturing	

high	quality	video.

2. 3D	Robotics	Y6

The	3D	Robotics	Y6	is	a	6	motor	sUAS	in	a	Y	frame	formation.

The	Y6	only	has	3	"arms"	and	6	motors	compared	to	the	X8.	The	stability	and	flight	characteristics	of	the	

system	are	similar	to	the	X8.	The	Y6	uses	the	same	APM	2.6	Autopilot	as	the	Y8	and	has	the	same	safety	

features	built	in	including	waypoint	navigation,	loiter,	circle,	return	to	launch	and	GEO	fencing.

Physical	Science	Laboratory

New	Mexico	State	University

P.O.	Box	30002

Las	Cruces,	NM	88003-8002
Exemption

The	requested	exemption	would	permit	commercial	operation	of	3DR	X8	and	3DR	Y6,	with	payload	

installed,	weigh	approximately	6	lbs.	and	5	lbs.	respectively.		Both	are	all	capable	of	capturing	still	

imagery,	video,	and	other	sensors	including	IR,	multi-spectral,	etc.

Remote	sensing	applications	for	these	two	sUAS	include	mapping,	structural	inspections,	aerial	imagery,	

and	demonstrations.	Use	of	the	two	sUAS	for	these	purposes,	provide	the	NMSU/PSL	with	high	quality	

data	safely	and	at	a	fraction	of	the	cost	of	using	conventional	aircraft.	They	can	also	operate	in	

conditions	that	conventional	sized	aircraft	could	not	accommodate.	

Operations	under	the	exemption	will	be	subject	to	strict	operating	requirements	and	conditions	to	

ensure	an	equivalent	level	of	safety	to	currently	authorized	operations	using	manned	aircraft.

The	airspace	in	which	the	sUAS	will	operate	will	occur	in	FAA	approved	airspace	as	designated	in	the	

COA.

Safety	and	risk	assessment	evaluations

New	Mexico	State	University	Physical	Science	Laboratory	Flight	Test	Center,	as	part	of	its	safety	

processes,	has	performed	an	airworthiness	assessment	and	hazard	analysis	evaluation	on	the	3D	

Robotics	multi-copter	series	with	FAA	UAS	Integration	Office	oversight.	This	analysis	is	quite	

comprehensive	and	was	FAA	accepted.	These	sUAS	were	deemed	to	be	airworthy	and	the	subsequent	

flights	validated	these	findings	for	the	purposes	requested.

New	Mexico	State	University	Physical	Science	Laboratory	Flight	Test	Center	respectfully	submits	that	

these	small	unmanned	aerial	systems	will	be	used	in	lieu	of	comparatively	hazardous	operations	now	

conducted	with	fixed	wing	and	rotary	conventional	aircraft.	The	FAA	can	have	confidence	that	the	

operations	will	achieve	at	least	an	equivalent	or	greater	level	of	safety.	Approval	of	this	exemption	

would	thereby	enhance	safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	

responsibilities	under	Section	333(c)	of	the	Reform	Act	to	“Establish	requirements	for	the	safe	operation	

of	such	aircraft	systems	in	the	national	airspace	system.”

The	regulations	from	which	the	exemption	is	requested	are	as	follows:

14	C.F.	R.	61.113(a)	&	(b) 14	C.F.	R.	91.7	(a)

14	C.F.	R.	91.119(c) 14	C.F.	R.	91.	121

14	C.F.	R.	91.	151(a)	(1) 14	C.F.	R.	91.	405(a)

14	C.F.	R.	91.	407(a)	(1) 14	C.F.	R.	91.	409(a)	(2)

14	C.F.	R.	91.	417(a)	&	(b)
THE	APPLICABLE	LEGAL	STANDARD	UNDER	SECTION	333	

New	Mexico	State	University	Physical	Science	Laboratory	Flight	Test	Center	submits	that	granting	of	this	

exemption	application	for	use	of	the	sUAS	3DR	X8	and	Y6	for	remote	sensing	with	a	focus	on	mapping,	

aerial	imaging,	industrial/structural	inspections,	and	demonstrations.	This	will	advance	the	

Congressional	mandate	in	Section	333	of	the	Reform	Act	to	accelerate	the	introduction	of	UASs	into	the	

national	airspace	system	(NAS).	In	making	this	determination,	the	Secretary	is	required	to	determine	

which	types	of	UASs	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national	

security	in	light	of	the	following:

• The	UAS’s	size,	weight,	speed,	and	operational	capability

• Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas

• Operation	of	the	UAS	within	visual	line	of	sight	of	the	operator

The	granting	of	the	requested	exemption	is	in	the	public	interest	based	on	the	clear	direction	in	Section	

333	of	the	Reform	Act;	the	additional	authority	in	the	Federal	Aviation	Act,	as	amended;	the	strong	

equivalent	level	of	safety	surrounding	the	proposed	operations;	and	the	significant	public	benefit,	

including	enhanced	safety	and	cost	savings	associated	with	transitioning	to	UASs	for	remote	sensing.	

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	exemption	without	

delay.

The	sUAS

The	sUAS	comply	with	the	requirements	set	forth	by	Section	333	by	its	small	size,	weight,	speed,	and	

operational	proximity	to	airports	and	densely	populated	areas.	As	a	result	under	this	exemption	UAS’

are	not	deemed	airworthy	by	an	airworthiness	certificate,	but	rather	they	are	deemed	airworthy	by	the	

operator	conducting	a	thorough	preflight	of	the	aircraft.	In	this	case,	as	NMSU	is	a	public	entity,	an	FAA	

accepted	airworthiness	process	has	been	conducted	and	a	statement	made	to	and	accepted	by	the	FAA	

UAS	Integration	Office.	These	aircraft	will	also	be	registered	according	to	14	CFR	Part	47,	marked	in	

accordance	to	14	CFR	Part	45	Subpart	C,	and	accompanied	by	a	letter	of	alternative	marking	due	to	the	

unconventional	design.	Markings	will	be	as	large	as	practicable.	These	aircraft	are	of	the	same	size,	

configuration,	and	operational	capabilities	of	the	aircraft	granted	in	exemptions	11138,	11153,	and	

11157.

Aircraft	Performance/Specifications:

•Ground	Control	Station	(GCS):	The	aircraft	will	be	primarily	controlled	through	the	use	of	a	2.4	GHz	RC	

transmitter.	The	aircraft	can	also	be	pre-programmed	to	conduct	a	mission	through	the	use	of	a	laptop	

or	tablet	via	a	915	MHz	telemetry	link.	Whenever	operations	are	conducted	in	this	matter,	the	RC	

Transmitter	will	be	able	to	take	control	of	the	aircraft	if	the	need	arises.

• Video	Downlink:	

o 5.8	GHz	at	200mW

• Lost	Com:	

o Aircraft	will	autonomously	return	to	the	launch	location	and	safely	land.

• Emergency	Procedure:
o Should	the	need	arise	the	aircraft	can	be	commanded	by	a	switch	on	the	RC	transmitter	

to	safely	land	immediately	or	return	and	land	at	the	launch	location.

• Power	Supply:

o 4S	5000	MAH	25C	Lithium	Polymer	Battery

• Dimensions:

o 32	in.	prop	tip	to	prop	tip

• Maximum	Speed:

o <44	knots

• Normal	operating	speed:	

o <	30	knots

• Weight	with	payload:	

o X8=6	lb.

o Y6=5	lb.

Aircraft	manuals	and	operations	checklist	will	be	included	as	additional	information	to	this	petition	for	

exemption.

Operator	Requirements

NMSU	UAS	pilots	will	meet	or	exceed	all	FAA	requirements	for	UAS	operations	as	listed	below.

Minimum	of:

• Private	pilot’s	certificate

• At	least	a	third	class	medical	

• Aircraft	specific	flight	training	as	defined	below

• 25	hours	as	a	UAS	rotorcraft	pilot	including

• 10	hours	logged	as	a	UAS	pilot	with	a	multi-rotor	UAS

• 5	hours	with	the	specific	make	and	model	of	the	UAS

• At	least	3	take-offs	and	landings	within	the	preceding	90	days

Mandatory	Operating	Conditions

Grant	of	the	exemption	to	NMSU	UAS	FTC	will	be	subject	to	the	following	mandatory	conditions	for	

flight	operations.

• Operations	shall	not	occur	over	congested,	actively,	or	densely	populated	areas	as	defined	

by	the	local	FSDO.

• Permission	from	land	owner	is	required	before	commencing	any	flight.

• Operations	will	only	occur	during	Visual	Flight	Rules	Meteorological	Conditions	(VMC).

• Operations	will	not	occur	less	than	500	feet	below	or	less	than	2,000	feet	horizontally	from	a	

cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	operator.

• The	sUAS	will	remain	clear	of	manned	aircraft	and	yield	right	of	way.

• A	flight	test	will	be	conducted	after	any	major	repair	or	alteration.

• A	preflight	check	will	be	conducted	before	each	flight	to	assure	airworthiness.

• Aircraft	will	remain	within	Visual	Line	of	Sight	(VLOS)	of	the	operator.

• All	operations	will	be	conducted	with	a	Visual	Observer	(VO).

• Operations	will	be	limited	to	daylight	hours.
• Operations	will	be	concluded	with	no	less	than	25%	battery	power	remaining.

• Operations	will	not	exceed	400ft	AGL.

• Operations	will	not	occur	within	5nm	of	any	airport	unless	a	letter	of	agreement	with	that	

airport’s	management	is	obtained.

• Operations	will	take	place	under	a	COA.

• Operator	will	file	a	NOTAM	for	each	flight.

• All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	county	or	city	

jurisdictions,	including	local	law	enforcement,	fire,	or	other	appropriate	governmental	

agencies.

• All	non-participants	will	keep	500ft	away	from	operations	unless	there	are	adequate	barriers	

to	protect	them.

• All	operations	will	be	conducted	according	to	the	manufacturer’s	manuals.

• All	documents	that	will	be	kept	at	the	GCS	include	but	are	not	limited	to;	the	aircraft	

manuals,	maintenance	logs,	aircraft	registration,	grant	of	exemption,	and	COA.

Public	Interest

Consistent	with	the	requirements	of	14	C.F.R.	§11.81(d),	Petitioner	offers	the	following	reasons	why	

granting	this	petition	for	exemption	is	in	the	public	interest,	i.e.,	how	granting	it	would	benefit	the	public	

as	a	whole.

Approval	of	this	exemption	allowing	commercial	remote	sensing	operations	of	sUAS	in	mapping,	aerial	

imagery,	structural	inspections,	and	demonstration	will	benefit	the	public	as	a	whole	in	the	following	

ways:

• It	helps	fulfill	Congress'	goal	in	passing	Section	333(a)	through	(c)	of	the	Reform	Act,	namely,	

the	FAA	Administrator's	assessment	of	whether	certain	UAS	may	operate	safely	in	the	

National	Airspace	System	before	completion	of	the	rulemaking	required	under	Section	332	

of	the	Reform	Act.

• The	operation	significantly	improves	safety	and	reduces	risk	by	alleviating	human	exposure	

to	danger	associated	with	current	aerial	remote	sensing	methods,	namely,	full	size	

helicopters.	Reducing	human	exposure	to	death	or	serious	injury	associated	with	manned	

aircraft	performing	these	tasks	furthers	the	public’s	interest.

• Petitioner's	sUAS	are	battery	powered	and	create	no	emissions.	If	Petitioner's	sUAS	crashes,	

there	is	no	fuel	to	ignite	and	explode.	Any	impact	of	Petitioner's	lightweight	sUAS	is	far	less	

than	a	full	size	manned	aircraft.	The	public's	interest	is	furthered	by	minimizing	ecological	

impact	of	an	accident	and	by	reducing	human	exposure	to	potentially	harmful	emissions	

associated	with	manned	aircraft.

• Remote	sensing	is	a	valuable	tool	for	mapping,	structural	inspections,	aerial	imagery,	flight	

testing	and	training.	However,	problems	with	safety,	cost,	statistical	integrity,	and	logistics	

continue	to	impede	remote	sensing	from	conventional	manned	aircraft.	The	use	of	sUAS	

addresses	these	problems	and	is	a	powerful	tool	for	performing	a	wide-range	of	remote	

sensing	applications.	The	public	as	a	whole	will	benefit	from	the	safer	and	more	costeffective	remote	sensing	services that	sUAS	operations	provide.
Privacy

All	flights	will	occur	over	property	with	the	landowner’s	prior	consent.

Conclusion

NMSU/PSL	seeks	an	exemption	from	the	FARs	set	forth	above	and	in	Appendix	A	to	allow	commercial	

operations of	a	sUAS	conducting	remote	sensing	with	a	focus	in	research,	mapping,	aerial	imaging,	

structural	inspections,	flight	testing	and	training.

Approval	of	this	exemption	allowing	commercial	operations	of	the	two	sUAS	for	remote	sensing	will	

enhance	safety	by	reducing	risk.	Conventional	remote	sensing	operations,	using	turbine	or	pistonpowered	aircraft	present	risks	associated	with	vehicles	that	can	weigh	5,000	to	7,000	lbs.,	or	more,	carry	

large	quantities	of	fuel,	passengers,	and,	in	some	cases,	cargo.	In	contrast,	these	two	sUAS	weighing	less	

than	6	lbs.	and	powered	by	batteries	eliminates	a	portion	of	that	risk	given	the	reduced	mass	and	lack	of	

combustible	fuel	carried	on	board.	The	sUAS	will	carry	no	passengers	or	crew	and,	therefore,	will	not	

expose	any	individuals	to	the	risks	associated	with	manned	aircraft	flights.

Additionally,	no	national	security	issue	is	raised	by	the	grant	of	the	requested	exemptions	due	to	all	

pilots	being	certified	through	the	FAA.

The	operation	of	the	two	sUAS	weighing	less	than	6	lbs.,	for	remote	sensing	in	accordance	with	the	strict	

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of	the	

exemptions	requested	herein.

These	sUAS	provide	satisfaction	of	the	criteria	set	forth	in	Section	333	of	the	Reform	Act—size,	weight,	

speed,	operating	capabilities,	lack	of	proximity	to	airports	and	populated	areas,	operation	within	visual	

line	of	sight,	and	national	security—and	its	showing	of	an	equivalent	level	of	safety	provides	more	than	

adequate	justification	for	the	grant	of	the	requested	exemptions	allowing	commercial	operation	of	the

two	sUAS	in	the	remote	sensing	business.

Dennis	Zaklan

Deputy	Director

NMSU/PSL	UAS	Operations

1050	Stewart	St.

Las	Cruces,	NM	88003

Email:	dzaklan@psl.nmsu.edu	
APPENDIX	A:

EXEMPTION	REQUEST	AND	EQUIVALENT	LEVEL	OF	SAFETY	

SHOWINGS

UNDER	APPLICABLE	RULES	SUBJECT	TO	EXEMPTION

NMSU	UAS	FTC	requests	an	exemption	from	the	following	regulations,	all	of	which	have	been	granted	by	

every	approved	Section	333	exemption	at	the	time	of	this	submission.

14	C.F.R.	§	61.113	Private	pilot	privileges	and	limitations:	Pilot	in	command.

The	regulation	provides	that	no	person	that	holds	a	private	pilot	certificate	may	act	as	pilot	in	command	

of	an	aircraft	for	compensation	or	hire.	Subparagraph	(b)	allows	a	private	pilot	to	act	as	pilot	in	

command	of	an	aircraft	in	connection	with	any	business	or	employment	if:	(1)	The	flight	is	only	

incidental	to	that	business	or	employment;	and	(2)

The	aircraft	does	not	carry	passengers	or	property	for	compensation	or	hire.

Equivalent	Level	of	Safety

Currently,	there	are	no	applicable	areas	identified	for	sUAS	in	either	the	private	or	commercial	sector	

and	therefore	an	exemption	is	required	to	conduct	commercial	operations.	As	flight	operations	will	be	

conducted	in	a	restricted	environment	as	described	in	the	operations	section,	these	strict	guidelines	will	

achieve	an	equivalent	level	of	safety	for	each	individual	flight	especially	when	compared	to	commercial	

flights	identified	in	Part	61	when	originally	developed.

14	C.F.R.	§	91.7(a):	Civil	Aircraft	Airworthiness

Petitioner	seeks	an	exemption	from	14	C.F.R.	§	91.7(a),	which	requires	that	a	civil	aircraft	be	in	

airworthy	condition	to	be	operated.	Inasmuch	there	will	be	no	airworthiness	certificate	issued	for	the	

sUAS,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for	determining	

airworthiness.

Equivalent	Level	of	Safety

Given	the	size	of	the	X8	&	Y6	and	the	preflight	procedures	including	the	review	of	maintenance	logs	and	

preflight	check	lists,	an	equivalent	level	of	safety	will	be	provided	to	assure	the	aircraft	is	in	an	airworthy	

condition.

14	C.F.R.	§	91.119(c):	Minimum	Safe	Altitudes

Petitioner	requests	an	exemption	from	the	minimum	safe	altitude	requirements	of	14

C.F.R.	§	91.119(c)	which	states	that	aircraft	may	not	operate	closer	than	500	feet	above	the	surface	and	

away	from	any	person,	vessel,	vehicle,	or	structure	in	non-congested	areas.

To	provide	the	intended	operations,	the	sUAS	is	operated	below	400	feet	AGL.
Equivalent	Level	of	Safety

Compared	to	flight	operations	with	rotorcraft	weighing	far	more	than	the	6	pounds	proposed	herein,	

and	given	the	lack	of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less	than	those	that	

presently	exist	with	conventional	aircraft.	An	equivalent	level	of	safety	will	be	achieved	given	the	size,	

weight,	and	speed	of	the	UAS,	as	well	as	the	location	where	it	is	operated.	As	set	forth	in	the	operations	

section	of	this	exemption,	the	sUAS	will	be	operated	away	from	densely	populated	areas	and	at	least	

5nm	away	from	airports	(unless	a	letter	of	agreement	from	the	airport’s	management	is	obtained),	

where	buildings	and	people	will	not	be	exposed	to	operations	without	their	pre-obtained	consent.	

Because	of	the	advance	notice	to	the	property	owners	and	participants,	all	affected	individuals	will	be	

well	aware	of	the	planned	flight	operations.

14	C.F.R.	§	91.121:	Altimeter	Settings

This	petition	seeks	an	exemption	from	14	C.F.R.	§	91.121,	which	requires	a	person	operating	an	aircraft	

to	maintain	cruising	altitude	or	flight	level	by	reference	to	an	altimeter	that	is	set	to	the	elevation	of	the	

departure	airport	or	barometric	pressure.	An	exemption	is	required	because	the	sUAS	uses	AGL	from	

takeoff	location	and	not	MSL	altitude.

Equivalent	Level	of	Safety

An	equivalent	level	of	safety	will	be	achieved	by	the	operator	confirming	the	altitude	of	the	launch	site	

shown	on	the	altitude	indicator	before	flight.	Moreover,	the	PIC	will	use	the	barometric	altitude	AGL	

indicator	to	constantly	monitor	the	sUAS	height,	thus	ensuring	operation	at	safe	altitudes.

14	C.F.R.	§	91.151(a)	(1):	Fuel	Requirements	for	Flight	in	VFR	Conditions

Petitioner	requests	an	exemption	from	14	C.F.R.	§	91.151(a)	(1)'s	fuel	requirements	for	flight	in	VFR	

conditions	during	the	day.	Section	91.151(a)	(1)	states:

(a) No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless	(considering	wind	and	

forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed	–

(1) During	the	day,	to	fly	after	that	for	at	least	30	minutes;

Here,	the	battery	powering	the	UAS	provides	approximately	12	minutes	of	flight.	To	meet	the	30	

minutes	reserve	requirement	in	14	C.F.R.	§	91.151,	sUAS	flights	could	not	be	conducted.	Given	the	

limitations	on	the	sUAS	proposed	flight	area	and	the	location	of	its	proposed	operations	within	a	

predetermined	area,	a	safety	margin	based	on	a	reserve	amount	of	battery	life	is	needed.

Equivalent	Level	of	Safety

An	equivalent	level	of	safety	will	be	achieved	because	the	operations	will	be	conducted	on-site	without	

significant	transit	time	by	the	sUAS.	All	flights	will	be	planned	to	be	terminated	with	no	less	than	25%	

reserve	battery	power	still	available.	This	restriction	would	be	more	than	adequate	to	return	the	sUAS	

safely	to	the	ground	and	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area	even	in	

the	event	of	an	unexpected	occurrence.	Operation	of	the	sUAS	with	less	than	30	minutes	of	reserve	fuel	

does	not	include	the	type	of	risks	that	Section	91.151(a)(1)	was	intended	to	alleviate	given	the	size	and	

speed	of	the	small	UAS,	and	the	proximity	of	the	flight	operation	to	the	landing	zone.
14	C.F.R.	§	91.405(a),	91.407(a)	(1),	91.409(a)	(2);	91.417(a)	and	(b):	Maintenance Inspections

Petitioner	also	seeks	an	exemption	from	the	maintenance	inspection	requirements	contained	in	14	

C.F.R.	§	91.405(a),	91.407(a)	(1),	91.409(a)	(2);	91.417(a)	and	(b).	These	regulations	specify	maintenance	

and	inspection	standards	in	reference	to	14	C.F.R.	Part

43.	See,	e.g.,	14	C.F.R.	§	91.405(a)	(stating	that	each	owner	or	operator	of	an	aircraft	“shall	have	the	

aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections	...have	

discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter").	An	exemption	to	these	regulations	is	

needed	because	Part	43	and	these	sections	only	apply	to	aircraft	with	an	airworthiness	certificate,	which

the	sUAS	will	not	have.

Equivalent	Level	of	Safety

An	equivalent	level	of	safety	will	be	achieved	because	the	operator	will	ensure	that	the	sUAS	is	in	

working	order	prior	to	initiating	flight	by	following	the	preflight	checklist,	perform	required	

maintenance,	and	keep	a	log	of	any	maintenance	performed.	The	operator	is	the	person	most	familiar	

with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition.
APPENDIX	B:	SUMMARY	OF	NMSU	UAS	FTC	SECTION	333	

EXEMPTION	REQUEST

NMSU	UAS	FTC	hereby	provides	pursuant	to	Part	11	a	summary	of	its	exemption	application	to	allow	

commercial	operation	of	the	3D	Robotics	X8	and	Y6	unmanned	aircraft	in	remote	sensing.	An	exemption	

is	requested	from	the	following	regulations:

	14	C.F.	R.	61.113(a)	&	(b);	

	14	C.F.	R.	91.7	(a);	

	14	C.F.	R.	91.119(c);	

14	C.F.	R.	91. 121;	

14	C.F.	R.	91. 151(a)	(1);	

14	C.F.	R.	91. 405(a);	

14	C.F.	R.	91. 407(a)	(1);	

14	C.F.	R.	91. 409(a)	(2);	

14	C.F.	R.	91. 417(a)	&	(b).