July	10,	2015

US	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue,	SE

Washington,	DC	20590

Dear	Sir	or	Madam:

Pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012,	Public	Law	112-95,	Section	333,	

LeTourneau	University	requests	a	grant	of	exemption	from	Title	14,	Code	of	Federal	Regulations	(CFR)	

parts	21,	27,	45.23(a),	45.27(a),	45.29(b)(iii),	61.23(a),	61.101(e)(4)	and	(5),	61.113(a),	61.315(a),	91.7(a),	

91.9(b)(2)	and	(c),	91.203(a)	and	(b),	91.119(c),	91.121,	91.151,	91.405(a),	91.407(a)(1),	91.409(a)(1)	and	

(2),	and	91.417(a)	and	(b)	in	accordance	with 14	CFR part	11.81.	Under	this	petition,	LeTourneau	

University	seeks	to	offer	Unmanned	Aircraft	Systems	aerial	data	acquisition	training	to	degree-seeking	

students. Please direct	all	communication	to:

LeTourneau	University	

Fred	Ritchey,	Dean,	School	of	Aviation	and	Aeronautical	Science

200	Airpark	Drive

Longview,	TX	75603

(903)	233-4210

FredRitchey@letu.edu

Description	of	Petitioner:

LeTourneau	University	(LETU)	in	Longview,	Texas	is	a private inter-denominational	Christian	university	

offering	more	than	90	programs	that	prepare	students	for	success	in	areas	including	aviation,	business,	

criminal	justice,	education,	engineering,	and	health	sciences.	LETU	is	accredited	by	the	Southern	

Association	of	Colleges	and	Schools Commission	on	Colleges	(SACSCOC)	to	award	associate,	

baccalaureate	and	master’s	degrees.	LETU’s	School	of	Aviation contains	both	a	part-141	flight	training	

school	and	a	part-147	maintenance	training	school that	provide	thousands	of	hours	of	training	each	

year.	Aviation	training	programs	include	pilot certification,	maintenance certification,	air	traffic	control,	

missionary aviation training, dispatch certification, and	remote-piloted	aircraft training.	The	School	of	

Aviation	and	Aeronautical	Science	began	in	1956	as	part	of	the university founder’s	aviation	business	in	

Longview,	TX.	For	nearly	60	years,	LETU	alumni	have	been	working	around	the	world	as	respected	

professionals	in	airline	operations,	engineering, management,	inspections,	military,	air	traffic	control,	

and	maintenance.	They	are	men	and	women	of	faith,	personal	integrity,	and	professional	excellence,	

marking	a	positive	contribution	in	aviation	workplaces	around	the	world.	As	LETU	progresses	into	the

future	of	aviation,	we	are	offering	a	professional	remote-piloted	aircraft	program	of	study	to	students	

wishing	to	obtain	the	skills	and	practical	experience	necessary	to	operate	UAS	safely	in	the	NAS. We	

seek	to	train	students	and	develop	professional	skills	with	practical	application	in	the	UAS	industry.	We	

currently	offer	3	separate	degree	programs	focusing	on	flight	operations,	maintenance	of	small	UAS,	and	

training	in	electronic	systems.	In	order	to	successfully	introduce	students	to	safe	operation	of UAS,	we	
seek	exemption	from	certain	Federal	aviation	regulations to	begin	practical	training courses	to	instruct	

students	in	operation	of	unmanned	aircraft	and	their	systems,	to	include	collection	of	aerial	data.	

Public	interest:

It	is	in	the	public	interest	for	LeTourneau	University	to	provide	standardized	UAS	ground	and	flight	

instruction	to	assist	with	research	and	development	of	performance-based	training	standards	and	

certification	of	UA	crewmembers	to	operate	safety	in	the	NAS	in	accordance	with	current	and	future	

federal	aviation	regulations,	manufacturer	recommendations,	and	industry-based	standards	of	

performance.	According	to	FAA	projections	in	the	Draft	14	CFR	part	107	Economic	Analysis,	more	than	

7,500	small	UAS	will	be	in	operation	in	the	first	five	years	after	the	effective	date	of	the	final	rule.	

Practical	test	standards,	training	syllabi,	and	academic	knowledge	will	be	essential	components	of	

certifying	commercial	UAS	operators.	LeTourneau	University	intends	to	train	pilots,	mechanics,	and	

engineers	to	be	industry	leaders	in	safe	and	responsible	operation	of	UAS.	

Abbreviations:

• FOM	– Flight	Operations	Manual

• PIC	– Pilot-in-Command

• RPA	– Remotely	Piloted	Aircraft

• RPAS	– Remotely	Piloted	Aircraft	System

• UA	– Unmanned	Aircraft

• UAS	– Unmanned	Aircraft	System

• VLOS	– Visual	Line	of	Sight

• VO	– Visual	Observer

Design	and	operational	characteristics	of	the	proposed	UAS:

• Proposed	unmanned	aircraft:	3DRobotics	Aero

o Aircraft	characteristics:	

§ Foam	construction	with	carbon	fiber	reinforcement

§ Single	electric	motor	propulsion	(carries	no	flammable	liquid)

§ Electric	servo	flight	control	

§ Rechargeable	lithium	polymer	battery,	40	minute	endurance

§ Wingspan:	74”

§ Maximum	weight:	6.8	lbs

§ Maximum	airspeed:	50	kts

§ Minimum	airspeed:	20	kts

§ Autopilot	system	with	external	GPS	and	compass

• Ability	to	automatically	fly	to	a	safe	location	in	the	event	of	a	GPS	signal	

loss,	control	signal	loss,	or	depletion	of	battery	capacity	below	minimum

• Ability	to	operate	within	a	defined	secure	area

• Ability	to	re-zero	current	altitude	based	on	local	altimeter	pressure	and	

GPS	altitude

• Proposed	unmanned	rotorcraft:	3DRobotics	IRIS+
o Aircraft	characteristics:	

§ Composite	plastic	construction

§ 4	(“quad-rotor”)	electric	motor	propulsion	(carries	no	flammable	liquid)

§ Rechargeable	lithium	polymer	battery,	22	minute	endurance

§ Dimensions:	21.7	inches	from	center	of	motor	to	opposing	motor	in	quad	

configuration,	31.2	inches	wide	including	installed	propellers

§ Maximum	weight:	3.7	lbs

§ Maximum	airspeed:	50	kts

§ Autopilot	system	with	external	GPS	and	compass

• Ability	to	automatically	fly	to	a	safe	location	in	the	event	of	a	GPS	signal	

loss,	control	signal	loss,	or	depletion	of	battery	capacity	below	minimum

• Ability	to	operate	within	a	defined	secure	area,	automatically	remain	

within	defined	horizontal	and	vertical	parameters,	and	fly	to	a	safe	

location	if	boundary	is	breached

• Ability	to	re-zero	current	altitude	based	on	local	altimeter	pressure	and	

GPS	altitude

14	Code	of	Federal	Regulations	from	which	the	exemption	is	requested	for LeTourneau	University	

(also	referred	to	as	“the	petitioner”	hereafter)	and	the	equivalent	level	of	safety:

• Part	21,	subpart	H,	Certification	Procedures	for	Products	and	Parts,	prescribes	the	procedural	

requirements	for	issuing	and	changing	design	approvals,	production	approvals,	airworthiness	

certificates,	and	airworthiness	approvals.	This	petition	requests	an	exemption	from	14	CFR	part	

21.

o Equivalent	level	of	safety:	in	Exemption	No.	11062	to	Astreus	Aerial,	the	FAA	found	that,	

given the	limited	size,	weight,	operating	conditions,	design	safety	features,	and	imposed	

conditions	and	limitations,	relief	from	14	CFR	part	21	was	not	necessary.	Considering	the	

size,	weight,	speed,	and	operating	limitations associated	with	the	3D	Robotics	Aero	

aircraft,	LeTourneau	University assumes	that	the	aircraft	meets the	conditions	of	

Section	333.

• Part	27,	Airworthiness	Standards:	Normal	Category	Rotorcraft,	prescribes	the	procedural	

requirements	for	airworthiness	certification	of	normal	category	rotorcraft.	This	petition	requests	

an	exemption	from	14	CFR	part	27.	

o Equivalent	level	of	safety:	Considering	the	size,	weight,	speed,	and	operating	limitations	

associated	with	the	3D	Robotics	IRIS+	rotorcraft,	LeTourneau	University	assumes	that	

the	rotorcraft	meets	the	conditions	of Section	333.

• Parts 45.23(a),	45.27(a),	45.29(b)(iii),	and	91.9(c)	prescribe	that	each	operator	of	an	aircraft	and	

rotorcraft	must	display	the	registration	number	of	the	aircraft. This	petition	requests	an	

exemption	from	sections	45.23(a),	45.27(a),	45.29(b)(iii),	and	91.9(c)	because	the	aircraft	and	

rotorcraft	are	too	small	to	comply	with	the	dimensional	requirements.	

o Equivalent	level	of	safety:	LeTourneau	University	will	mark	all	UA as	large	as	practical

with	their	registration	number	on	the	fuselage,	preceded	by	the	Roman	capital	letter	

“N”	denoting	United	States	registration.	
• Part 61.23(a)	prescribes	that	a	person	must	hold	a	medical	certificate	when	exercising	the	

privileges	of	a	pilot	certificate.	This	petition	requests	an	exemption	from	section	61.23(a)

because	the	UA	will	not	be	carrying	passengers	or	cargo	for	hire.	

o Equivalent	level	of	safety:	LeTourneau	University	will	require	the	pilot-in-command	of	

any	UA	to	hold	a	current	and	valid	driver’s	license	to	satisfy	a	minimum	safe	vision	

standard.	All	UA	instructors	will	hold	a	minimum	of	third-class	medical	certificate.	All	

flights	will	be	conducted	within	VLOS,	utilize	a	VO,	and	not	allow	artificial	means	of	

visual	enhancement	beyond	prescription	eyewear.	

• Parts 61.101(e)(4)	and	(5), 61.113(a),	and	61.315(a)	prescribe that	no	person	who	holds	a	sport	

pilot	certificate,	recreational	pilot	certificate,	or	private	pilot	certificate	may,	for	compensation	

or	hire,	act	as	pilot	in	command	of	an	aircraft	carrying	passengers	or	cargo	for	compensation	or	

hire. This	petition	requests	an	exemption	from	sections	61.101(e)(4)	and	(5),	61.113(a),	and	

61.315(a) because	the	UA	will	not	be	carrying	passengers	or	cargo	for	hire.	

o Equivalent	level	of	safety:	pilots-in-command	of	all	LeTourneau	University	UA	will	be	

required	to	have	at	minimum	a	current	sport	pilot’s	certificate,	along	with	a	current	and	

valid	driver’s	license.	In	addition,	restrictions	as	found	in	Appendix	C,	LeTourneau	

University	RPA Flight Operations	Manual will	be	placed	on	all	flight	operations,	to	

include	minimum	safe distances for	persons	not	directly	involved	with	flight	operations,	

maximum	altitudes,	crew	qualifications, and	currency	to	include	written/oral	and	

practical	testing.	All	UA	will	be	flown	below	400	feet	AGL	within	VLOS	and	utilize	a	VO.	

NOTAMs	will	be	filed	with	the	appropriate	ATC	facility	at	least	72	hours	in	advance	of	

flight	operations,	and	contact	with	ATC	will	be	established	prior	to	flight	as	necessary.	

All	flights	will	occur	in	sterile	areas	over	controlled-access	property	to	prevent	personnel	

from	accessing	the	flight	operations	area	who	are	not	directly	involved	with	UA	flight.	

• Section	91.7(a)	prescribes	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	

condition.	This	petition	requests	an	exemption	from section	91.7(a) because	an	exemption	from	

part	21	has	be	requested	and	the	UA	will	not	be	issued	an	airworthiness	certificate.	

o Equivalent	level	of	safety:	as	stated	by	the	FAA	in	previous	exemptions	(nos.	11062,	

11109,	11112,	11213),	relief	from	14	CFR	part	21	was	not	necessary	and	the	UA	would	

not	receive	a	civil	airworthiness	certificate,	therefore	an	exemption	from	section	91.7(a)	

was	not	required.	LeTourneau	University	will	maintain	an	equivalent	level	of	safety	by	

maintaining	all	UA	in	a	manner	consistent	with	a	professional	flight	training	operation,	

to	include	preflight	inspections,	post-flight	inspections,	phase	inspections,	and	

preventative	maintenance.	Reference	Appendix	E,	LeTourneau	University	RPA	Flight	

Operations	Manual.	

• Sections	91.9(b)(2)	and	91.203(a)	and	(b)	prescribe	that	no	person	may	operate	a	U.S.-registered	

civil	aircraft	unless	there	is	a	current,	approved	aircraft	or	rotorcraft	flight	manual,	airworthiness	

certificate,	and	an	effective	U.S.	registration	certificate.	This	petition	requests	an	exemption	

from	sections	91.9(b)(2)	and	91.203(a)	and	(b)	because	the	UA	will	not	be	carrying	passengers	

and	are	too	small	to	carry	the	aircraft	flight	manual	and	registration	certificate.	

o Equivalent	level	of	safety:	as	outlined	in	FAA	exemption nos.	11062	and	11617,	the	

manufacturer’s	operating	manual,	the	LeTourneau	University	UA	operations	manual,	

and	the	aircraft	registration	certificate	(“operating	documents”)	will	be	kept	with	the	

aircraft	ground	control	station,	made	accessible	during	UAS	operations,	and	made	
available	to	the	Administrator	on	request.	The	company	operations	manual	is	a	living	

document,	and	the	petitioner	will	maintain,	revise,	and	update	the	operating	

documents	as	needed	when	manufacturer	revisions	are	published	or	when	safety	

circumstances	warrant	an	update	to	flight	operation	guidelines.	Any	updated	and	

revised	documents	will	be	submitted	with	any	extension	or	amendment	to	this	petition,	

or	if	an	update	or	revision	to	the	documents	would	affect	the	basis	on	which	the	FAA	

grants	an	exemption	to	the	petitioner.	

• Section	91.109	prescribes	that	no	person	may	use	an	aircraft	for	flight	instruction	unless	the	

aircraft	has	fully	functioning	dual	controls.	This	petition	requests	an	exemption	from	section	

91.109	because	dual	controls	are	not	installed	in	UAS.	

o Equivalent	level	of	safety:	The	petitioner	will	require	all	company	pilots-in-command	to	

complete	a	10-hour	simulator-based	training	course	prior	to	operation	of	all	small	UAS.	

In	addition,	the	aircraft	listed	in	this	petition	have	the	ability	to	operate	with	

electronically-linked	controls	in	a	student-instructor	configuration.	All	pilots	of	small	

UAS	under	this	petition	will	be	required	to	complete	5	hours	of	dual-control	training	

with	the	aircraft	they	intend	to	operate	as	PIC,	prior	to	acting	as	PIC.	

• Section	91.119(c)	prescribes	that	no	person	may	operate	an	aircraft	below	500	feet	above	the	

surface	except	over	open	water	and	sparsely	populated	areas	and	within	500	feet	of	any	person,	

vessel,	vehicle,	or	structure.	This	petition	requests	an	exemption	from	section	91.119(c) because	

the	maximum	authorized	altitude	for	UA	is	400	feet	above	the	surface,	and	personnel	involved	

in	flight	operations	will	be	within	500	feet	of	the	aircraft	during	flight.	

o Equivalent	level	of	safety:	Given the	limited	size,	weight,	operating	conditions,	design	

safety	features,	imposed	conditions	and	limitations,	and	lack	of	flammable	fuel	on	

board,	the	UA	listed	in	this	request	for	exemption	pose	a	far	lesser	risk	than	manned	

aircraft.	All	flight	operations	will	be	conducted	less	than	400	feet	above	the	surface	and	

over	sterile	areas	with	controlled	access.	As	prescribed	in	Appendix	E, LeTourneau	

University	RPA	Flight	Operations	Manual,	the	UA	will	not	operate	within	100	feet	of	any	

person	not	directly	involved	with	flight	operations,	or	any	vessel,	vehicle,	or	structure.	

• Section	91.121	prescribes	that	each	person	operating	an	aircraft	shall	maintain	the	cruising	

altitude	of	that	aircraft by	reference	to	an	altimeter	that	is	set,	when	operating,	to	a	current	

reported	altimeter	setting	for	the	airport	of	departure	or	the	current	reported	altimeter	setting	

of	a	station	within	100	miles	of	the	aircraft.	This	petition	requests	an exemption	from	section	

91.121	because	the	UA	does	not	carry	a	typical	barometric	altimeter	onboard	the	aircraft.	

o Equivalent	level	of	safety:	as	referenced	in	FAA	exemption	11062,	an	altitude	reading	is	

a	critical	safety	component	of	all	aspects	of	UA	operation.	Although	LeTourneau	

University’s	UA	will	not	have	a	typical	barometric	altimeter	onboard	the	aircraft,	the	UA	

will	be	operated	within	VLOS,	and	below	400	feet	above	the	surface.	Additionally,	

altitude	information	will	be	provided	to	the	PIC	via	a	digitally	encoded	telemetric	data	

feed	which	downlinks	from	the	aircraft	to	a	ground-based	on-screen	display.	The	

altitude	information	will	be	generated	by	equipment	installed	on	the	aircraft	as	

specified	by	using	GPS	triangulation,	digitally	encoded	barometric	altimeter,	radio	

altimeter;	or	any	combination	thereof.	Prior	to	each	flight,	a	zero	altitude	initiation	point	

will	be	established	and	confirmed	for	accuracy	by	the	PIC.	
• Section	91.151 prescribes	that	no	person	may	begin	a	flight	in	an	airplane	in	VFR	conditions	

unless	there	is	enough	fuel	to	reach	the	first	point	of	intended	landing	with	30	minutes	of	

reserve	fuel	on	board.	Also,	no	person	may	begin	a	flight	in	a	rotorcraft	in	VFR	conditions	unless	

there	is	enough	fuel	to	reach	the	first	point	of	intended	landing	with	20	minutes	of	reserve	fuel	

on	board.	This	petition	requests	an	exemption	from	section	91.151(a)(1)	and	(b),	as	current	

battery	technology	would	prevent	the	petitioner	from	conducting useful	flight	within	the	

manufacturer	stated	battery	capacity	and	a	reserve	capacity	in	accordance	with	section	91.151.	

o Equivalent	level	of	safety:	the	PIC	will	not	begin	a	flight	with	the	Aero	aircraft	or	IRIS+	

rotorcraft	unless	there	is	enough	available	power	for	the	UA	to	conduct	the	intended	

operation	and	to	operate	after	that	for	at	least	5	minutes	or	with	the	reserve	power	

recommended	by	the	manufacturer,	as	previously	granted	by	the	FAA	in	exemption	

11617.	

• Section	91.405(a),	91.407(a)(1),	91.409(a)(1)	and	(2),	and	91.417(a)	and	(b)	prescribe	inspection	

requirements,	qualification	for	return	to	service,	and	records	of	maintenance	and	approved	

inspections	performed	as	required,	including	status	of	life-limited	components.	This	petition	

requests exemption	from	sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	and	(2),	and 91.417(a)	

and	(b)	because	these	inspections,	return-to-service,	and	records-keeping	pertain	to	aircraft	

maintained	under	14	CFR	part	43	and	which	are	issued	an	airworthiness	certificate under	parts	

21	and	27,	in	which	the	petitioner	has	also	requested	an	exemption.

o Equivalent	level	of	safety:	LeTourneau	University	operates	a	professional	FAA-approved	

14	CFR	part	147	maintenance	training	program	and	seeks	to	maintain	its	fleet	of	UA	to	

the	same	standard	of	professional	skill	and	workmanship	as	expected	of	a mechanic	

certificated	under	14	CFR	part	65.	All	maintenance	and	inspections	will	be	performed	in	

accordance	with	manufacturer	maintenance,	overhaul,	replacement,	inspection,	and	life	

limit	requirements	for	the	aircraft	and	aircraft	components.	Any	maintenance	

operations	will	comply	with	manufacturer	safety	bulletins.	Prior	to	each	flight,	the	PIC	

will	be	responsible	for	conducting	a	pre-flight	inspection	to	determine	if	the	UAS	is	in	a	

condition	for	safe	flight.	Appendix	E contains requirements	for	maintenance,	

inspections,	and	recordkeeping	to	be	conducted	on	the	UA	as	part	of	a	professional	

maintenance	program.	

Qualifications	for	approval	under	Section	333:

Operations	in	the	NAS	under	section	333	will	be	conducted	over	rural	private	property	under	permission	

from	the	property	owner	and	lessees.	The	flights	will	be	limited	to	visual	line	of	sight	(VLOS)	and	remain	

below	400’	AGL,	with	aid	by	visual	observer	and	pre-programmed	software	limitations.	Control	of	the	

aircraft	will	be	completed	through	remote	radio	control	link	and	computer	software.	Risk	to	third	parties	

will	be	reduced	through	the	following	means:	1)	use	of	automatic	return-to-home	logic	in	the	event	of	

loss-of-link	2)	geo-fence	programming	to	prevent	loss	of	VLOS	and	3)	maintaining	safe	distance	from	

people	and	equipment	on	the	ground.	The	proposed	UA	weigh	less	than	5	pounds,	so	risk	is	further	

reduced	to	authorized	personnel	in	the	vicinity	of	operations.	Performing	these	flights	with	a	UA	is	

essential	to	building	safe	and	effective	practical	training	for	future	UAS	operators.	The	majority	of	the	

computer-based	training	will	take	place	on,	but	cannot	be	completely	replaced	by,	computer	simulators.
Description	of	proposed	operations:

• All	operations	will	be	performed	with	a	pilot-in-command	and	a	visual	observer	in	accordance	

with	FAA	Policy	N	8900.227	with	the	following	included	restrictions:

o UA	will	be	operated	in	accordance	with	manufacturers	and	operators	manuals

o UA	will	be	operated	during	daytime	VFR	only	

o UA	will	be	operated	within	visual	line	of	sight

o UA	will	be	operated	in	controlled	environments confined	to	sterile	area	inaccessible	to	

public/unauthorized	personnel	

o UA	will	be	operated	within	5	nm	of	an	airport	only	after	coordination	and	approval	from	

airport	operator	and	ATC	authority

o UA	will	remain	below	400	feet	above	the	surface

o UA	will	be	operated	away	from	densely	populated	areas

o UA	will	not	be	operated	above	public	roadways

o UA	will	be	operated	greater	than	100	feet	away	from	persons	not	directly	involved	in	

flight	operations

o UA	will	be	operated	after	a	daily	flight	operations	brief	with	mandatory	attendance	by	

all	personnel	participating	with	flight	operations has	been	conducted	

o UA	will	be	operated	only	after	all	routine	maintenance	has	been	performed

o UA	will	be	operated	within	an	approved	COA	and	after	a	NOTAM	has	been	filed	detailing	

location,	altitude,	and	times	of	expected	flight	operation

Not	a	risk	to	safety	or	national	security	because:

• Proof	of	U.S.	citizenship	will	be	required	

• Pilots-in-command	of	UA	will	hold	a	sport	pilot	certificate	or	greater

• UAS	ground training	course	to	include	a	knowledge	test	and	simulator	time	will	be	completed	

prior	to	commencing	UA	flight	training

Privacy	considerations:

Aerial	data,	including	still	and	video	images,	will	be	collected	as	a	function	of	UAS	flight	training.	

However,	the	intent	to	operate	a	UAS	does	not	include	the	intent	to	capture	images	of	persons	or	

private	property.	Privacy	of	all	persons	on	the	ground	will	be	respected and	all	training	flights	will	be	

conducted	within	the	restrictions	and	provisions	of	Texas	state	law	governing	UAS	data	collection.	If	

operations	are	to	be	conducted	over	private	property,	permission	from	the	landowner	will	be	required.	

If individuals	not	directly	involved	with	flight	operations,	not	a	professor,	employee,	or	student	of	

LeTourneau	University,	or	do	not	wish	to	be	identified	are	captured	in	visual	aerial	data,	their	likeness	

will	not	be	utilized	in	any	marketing	or	publicity materials	used	by	LeTourneau	University.	

RF	Spectrum	Used	for	Control	of	the	UAS:

The	RF	frequency	bands	used	for	control	of	the	3DR	IRIS+	and	3DR	Aero	are	located	within	United	States	

Industrial,	Scientific,	and	Medical	bands:	902-928	MHz	and	2.4-2.5	GHz,	and	do	not	require	a FCC license	

for	operation.	The	ground- and	air-based	transceivers	comply	with	FCC	part	15	requirements.
Summary	to	publish	in	the	Federal	Register:

Pursuant	to	14	C.F.R.	section	11.81(f),	the	following	summary	is	provided	for	publication	in	the	Federal	

Register:	

Petitioner:	LeTourneau	University

Section	of	14	C.F.R:	Parts	21,	27,	45.23(a),	45.27(a),	45.29(b)(iii),	61.23(a),	61.101(e)(4)	and	(5),	

61.113(a),	61.315(a),	91.7(a),	91.9(b)(2)	and	(c),	91.203(a)	and	(b),	91.119(c),	91.121,	91.151,	91.405(a),	

91.407(a)(1),	91.409(a)(1)	and	(2),	and	91.417(a)	and	(b).

Description	of	relief	sought:	Under	this	petition,	LeTourneau	University	seeks	to	offer	Unmanned	

Aircraft	Systems	aerial	data	acquisition	training	to	degree-seeking	students.

Supporting	documentation:

Attached	items	contain	proprietary	and	commercial	information	exempt	from	public	disclosure.	

• Appendix	A:	3D	Robotics	Aero	User	Manual	(version	B)

• Appendix	B:	3D	Robotics	Aero	Checklist	(version	B)

• Appendix	C:	3D	Robotics	IRIS+	Operation	Manual	(version	H)

• Appendix	D:	3D	Robotics	IRIS+	Flight	Checklist	(version	B)

• Appendix	E:	LETU	RPA	Flight	Operations/Safety	Manual