July 30 th , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 14 C.F.R. Part 11, CSRMFoundation ( hereafter CSRM) is applying for a Summary Grant of Exemption from the Federal Aviation Regulations (FARs) identified below, to operate small unmanned aerial systems (sUAS) for the purpose of con ducting aerial data collection, including aerial imaging and remote sensing and surveying, in support of its research, education, and community outreach programs. CSRM respectfully
notes that the Federal Aviation Administration (FAA) has previously issued grants of exemption in circumstances similar in all material respects to those presented in this document.

CSRM will be happy to change any pa rt of this proposal, t he proposed activities

, or requested exemptions as requested by the Federal Aviation Administration.

DESCRIPTION OF sUAS:

 DJI Phantom 3 Professional, a system weighing less than 4 lb gross during flight activities (micro
UAS sub

- category)

 On

- board flight computer with GPS navigation ability for automa ted flight paths and return that receives signals from a 2.400 to 2.483 GHz ground control system.

 On

- board camera capable of b oth high resolution video and stills.

 On

- board telemetry system that records flight data from the flight computer for consistent geolocation, altitude, horizontal and vertical speed, orientation, and direction of optional pre

established flight paths and a utomated return features in the event of signal disruption.

 On

- board 2.400 to 2.483 GHz radio transmitter that sends live video feed from the onboard camera as well as telemetry data.

 Power source is a 6000 mAh LiPo battery that supports approximately 20 m inutes of continual flight time per charge.

DESCRIPTION OF GROUND CONTROL SYSTEM

 A Pilot in Command (PIC) in operational control of a flight from beginning to end who controls
the sUAS while in the air

.

 A 2.400 to 2.483 GHZ radio transmitter/receiver oper ated by the PIC to control the sUAS during flight.

 A radio receiver obtaining live video feed and flight data from the onboard camera and
computer A Visual Observer (VO) who adds redundancy to the PIC’s line of sight control over the flight of

the sUAS

D ESCRIPTION OF THE PETITIONER

CSRMFoundation is a 503(c) non

- profit organization devoted to archaeological research, management and development of heritage sites, and public engagement with historical education and preservation.
C SRM, in collaboration with JPL/NASA, the N ASA Goddard Spaceflight Center, and the Johns Hopkins University, employs sophisticated remote sensing and geospatial analyses to meet these goals. CSRM is a global leader in the application of these technologies to archaeological heritage management, and the
use of small UAS holds enormous promise for facilitating research and management activities. Acquisition of very high resolution aerial imagery from a low

- cost, low

- maintenance, and rapidly deployed platform w ill allow CSRM to fulfill objectives that would otherwise be cost

- and capacity

prohibitive fo r a small research institution. Because of this, CSRM seeks an exemption for operations of small UAS for the purpose of conducting aerial data collect ion as a part of its current and future research portfolio.

The contact information for the Petitioner is as follows:

Douglas Comer, Ph.D. Primary Investigator, CSRMFoundation 2113 St. Paul Street, Baltimore, MD 21218 (410) 244

- 6320 // dcomer@culturalsite.com

DESCRIPTION OF PROPOSED ACTIVITES

CSRM seeks an exemption pursuant to Section 333 of the Reform Act to use a DJI Phantom 3
Professional UAS to meet the above goals. The three primary uses to which this UAS will be put are i) direct research applications, using the integrated 4k camera to collect low

- altitude (sub

- 200 foot) aerial imagery for visual analysis and photogrammetry, ii) education, training other archaeology and heritage management professiona ls in using sUAS in carefully controlled environments , and iii) promotion of CSRM’s mission through video and still images of projects and project locations. The s UAS employed by
CSRM is a new edition of the same chassis/vehicle that has been approved for other FAA exemptions (DJI Phantom 2)

. The FAA has previously determined that these vehicles meet the criteria established in Section 333 of the Reform Act and are suitable platforms for performing aerial data collection. The proposed operations in this Petition for Exemption are consistent with other appl ications made to t h e FAA by research institutions.

The sUAS will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 “Operational Requirements for UAS” with the following additional restrictions:

a) No flight will be made with a s UA S Gross weight exceeding 5 pounds;b) All operations must occur in FAA Class G airspace at no more than 2 00ft AGL, at an airspeed of no

more than 50 knots and no further than 1 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by
voice at all ti mes during a flight operation; d) Operations will be restricted to flights over property with the permission of the property owner;

e ) All required permits will be obtained from state and local government prior to operation;
f ) sUAS System will not be operated over densely populated areas; g) sUAS System will not be operated at air shows; h) sUAS System will not be operated over any open

- air assembly of people;
i ) sUAS System will not be operated over heavily trafficked roads; j ) sUAS System will not be operated within 5 NM of an airport or heliport with a control tower or within 3 NM of an airport without a control tower ; k ) Operations will be restricted to day only and weather conditions equivalent to VFR;
l ) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location;

m ) No flight may be made without a Pre

- Flight Inspection by the PIC before each operation to ascertain
that the s UA S is in a conditi on safe for flight.

PILOT CERTIFICATION

The PIC will operate under the Operator Certificate FAA classification in lieu of a formal piloting license, as the sUAS proposed for use in this document falls within the micro sUAS sub

- category described in
Part 107 of the proposed rules. Aeronautic knowledge is self

- certified under this classification and comprehensive operational and safety training will be conducted at CSRM before any field operations
are undertaken.

RELEVANT STATU T ES

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft syste ms into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the sUAS where it is safe to do so based on the following considerations:

x The s UAS's size, weig ht, speed and operational capability; x Operation of the s UAS away from airports and populated areas; and x Operation of the s UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to g rant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) (permittin g exemptions from §§ 44701(a), (b) and §§ 44702 ± 44716, et seq.). A party requesting anexemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a lev el of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

CORRESPONDENCE BETWEEN PROPOSED sUAS OPERATION AND REQUIREMENTS OF SECTION 333 OF
THE REFORM ACT

CSRM’s proposed operations in this Petition for Exempti on qualify for expedited approval via the summary grant process pursuant to Section 333 of the Reform Act, as each of the statutory criteria and relevant factors are satisfied and the FAA has previously issued grants of exemption in circumstances
similar i n all material respects to those presented in this Petition for Exemption.

A. Approval is Warranted Based on the Low Risk Presented by the s UAS's Size, Weight, Speed, and Operational Capability

The FAA is familiar with and has already determined that previous generations of the vehicle employed by CSRM meet the requirements of Section 333 of the Reform Act due to weight, speed, and operational capabilities. The DJI Phantom 3 is an updated version of the previously exempted DJI Phantom 2 ( Exemption No. 11315 to The Climate Corpor ation and Precision Planting, LLC; Exemption No. 114 45 to Unmanned Aerial Solutions). The DJI Phantom three shares all of the core characteristics that make the DJI Phantom 2 eligible, namely:

 Weighing less than 55 lbs (gross flight weight of sUAS is les s than 4 lbs /micro UAS sub

- category ) ;

 Automated safety features and return capability on disruption of either GPS signal to the vehicle or communication with the ground based controller held by the PIC;

 Limited range (2 km/23 minutes) and speed (16 m/s) capabilities with no mini mum altitude or cruising speed required for operation;

 The radio frequencies used to transfer information between the ground based controller and
the sUAS ful ly comply with FCC requirements

B. Approval is Warranted Based on the Operational Restrictions in CSRM’s Operating Protocols

 Max altitude of 200 m AGL for operational use, limited by preflight programming of the flight
computer;

 Operation of the sUAS in line

- of

- sight visibi lity to both the PIC and the VO

C. A p pro val I s Warranted Based on Precedent in Materially Similar Cases

 Similar vehicle: DJI Phantom 2: Exemption No. 11315 to The Climate Corporation and Precision Planting, LLC; Exemption No. 114 45 to Unmanned Aerial Solutions; Similar purpose: Exemption No. 11552 to Sinclair Community College to conduct educational

research and trai ning (Docket No. FAA

- 2015

- 0374).

CSRM ’ s operation protocols and the manufacturer's manuals for the selected sUAS platfor m contain all the procedures and limitations necessary to safely and successfully perform the proposed operations.

D. Approval Is Warranted Based on Public Good

CSRM Foundation is registered as a 501 (c) (3) nonprofit institution , incorporated to undertak e methodological research in ar chaeological remote sensing, and has won a succession of grants through
the Department of Defense Legacy Program, the NASA R esearch Opportunities in S p ace and Earth
Sciences Program, the Strategic Environmental Research and Development Program , and within the next calendar y ear we expect to a research project that would employ sUAS aerial imagery to be funded by the National Science Foundation. The research undertaken by CSRM is immensely valuable to archaeological heritage management, as it po tentially allows federal institutions to avoid significant cost in complying with archaeological site inventory and evaluation under sections 110 and 106 of the Native
America Graves Pro tection and Repatriation Act (NAGPRA), thereby saving taxpayers money and increasing the operational efficiency of federal land manage ment on military installations, the B ureau of Land Management, and similar institutions.

REGULATIONS FROM WHICH EXEMPTION IS SOUGHT

The Federal Aviation Act expressly g rants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, including UAS, from its safety regulations and minimum standards when the Administr ator decides a requested exemptio n is in the public interest. CSRM seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using s UAS, including:

14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an ai rworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the sUAS System under either or both of the following provisions:

21.191 Experimenta l certificates. Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for airc raft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuanceof type and supplemental type certificates, flights to subst antiate major design changes, and

flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and custome r crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.203 (a) & (b) Civil aircraft: Certifications required

. As the sUAS is by definition uninhabited, there is no interior space available to comply with the display of the airworthiness and registration certificates found in subparagraph (b)

, "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA
will be co

- located with th e crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via chassis painting conta ining the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23 (below) , which follows immediately after the proposed description below:

EXPERIMENTAL
Manufacturer: D JI Innovations, Inc.
950 E Baseline Ave. Ste. 210 Apache Junction AZ 85119

Models: Phantom 3 Professional

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide t hat each aircraft must display “ N'' and the aircraft's registration number in
letters at least 3 inche s high. Additionally, the aircraft must display the word “ EXPERIMENTAL ” in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The s UA S does not have an entrance in which the word 11EXPERIMENTAL11 can be placed, and ma y not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word

“ EXPERIMENTAL ” directly on the chassis of the sUAS , as shown above, where the PIC, VO and others in the vicinity o f the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent inscription on the chassis discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, w e will display at the ground stationa high contrast flag or banner that contains the words “ un manned Aircraft Ground Station ” in letters 3

inches high or greater. Since the aircraft will operate within 2 KM of the ground station, the banner
should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

. This regulation provides that no person may operate an aircraft unless a current, app roved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is no t only too small to carry documentation, the documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

91.103 Preflight Action : 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight

tests The reg ulation states that ‘ ’ No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS ground based control station consists
of a small hand

- held radio transmitter and while it does not offer a second set of “ controls ” , both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having “ hands

- o n ” the controls during flight, we feel that this tec hnique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General

. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft wil l be operating at a maximum of 2 0 0 feet AGL, we cannot comply with this requirement. In order to provide an equivalent level of safety we will only fly over open (i.e. without power lines, heavy tree cover, or other obstructio ns) property plots
with a size of at least two acres wit h the permission of the owner of the property flown over. The aircraft will not be operated over congested areas

, over any open air assembly of persons , or during any emergency operations . The property owner will be briefed on the expected route of flight and the associated risks to person s and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on
the surface. Therefore we maintain that due to the small size of the s UA S , the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings

. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting
available within 100 NM of the aircraft. The s UA S will always fly below 2 00 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Levelaltimeter measurement above the takeoff point is transmitted via radio from the s UA S on

- board

computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

. The regulation provides that no pers on may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve a s a safety buffer for delays to landing. The s UA S is battery operated and the maximum duration of flight from a single battery charge is 20 minutes with a 20°/o reserve. Since the aircraft will never fly more than 2 km from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401

- 91.417)

- Main tenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require
that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to s ervice." As provided in the Pre

- Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and
firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facili ty. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1 ) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second

- class medical certificate issued under part 67 in order to perform as a pilot or observer. The s U S A maximum gross weight is 4 pounds, it
is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the sit e of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. We propose that the minimum medical require ments for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

B. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections
CSRM seeks an exemption from the maintenance inspection requireme nts contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b). These regulations specifymaintenance and inspection standards in reference to 14 C.F.R. Part 43.6 An exemption from these

regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS to be operated under this grant of exemption will not have.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in a ccordance with the operating documents and any required manufacturer Safety or Service Bulletins. Further, as required by the operating documents, the PIC will conduct a pre

- flight inspection of the UAS and all associated equipment to account for all discr epancies and/or inoperable components. Maintenance will be performed and ver ified to address any conditions potentially affecting safe operation of the UAS and no flights will occu r unless, and until, all flight critical components of the
UAS have been fou nd to be airwor thy and in a c ondition safe for operation. A functional test flight will be conducted following the rep lacement of any flight

- critical components. As required by the operating documents, the PIC w ho conducts the functional test flight will m ake an entry in the UAS aircraft records of the flight.

The operating documents also include requirements to follow the sUAS maintenance, overhaul, replacement, inspection, and life limit re quirements for the aircraft and aircraft components. Moreover, the operating documents also inc lude procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, and status of airworthiness

.

C. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Rec reational and Sport Pilot Medical Certificate, Privileges and Limitations The regulation provi des 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 i f: (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. CSRM ’ s intended use of the sUAS fulfills both of these requirements: as a research nonp rofit, sUAS applications will be a part of activities outlined in our research proposals and not of direct commercial consequence; similarly, the DJI Phantom 3 sUAS is incapable of taking either

passengers or a non

- camera payload. We feel that our use meet s the intent of 14 CFR 61.113.

As the PIC of CSRM ’ s sUAS (micro sub

- category) will opera te under an Operator Certification rather than a License, any specific restriction on licensed activity is anticipated by the restrictions alre ady present in the Certification/License distinction.