December 10, 2015

Steve Morris

Vice President for Business Services

University of the Cumberlands

6180 College Station Drive

(606) 539-4597

Dear Sir or Madam,

 University of the Cumberlands is petitioning the Federal Aviation Administration (FAA) for 

an exemption to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

14 CFR part 11. The exemption would allow commercial operation of the DJI Inspire 1 

unmanned aircraft systems (UAS) for the purpose of aerial video and photography of University 

of the Cumberlands’ properties and for other marketing purposes.

 University of the Cumberlands agrees to operate within the boundaries set forth by this 

exemption to provide a professional service in the aerial photography and video field. University 

of the Cumberlands will provide a low cost business alternative to its customers to be more 

efficient and a safer alternative to using a manned aircraft. Please Allow University of the 

Cumberlands to offer UAS operations to its market to promote the safe, efficient and responsible 

use of UAS.

The Aircraft, specifications, and levels of safety and maintenance. 

University of the Cumberlands will operate the DJI Inspire 1 and will provide a professional and 

safe manner of collecting photos and videos.

1. The safe operation of the UAS will be the first priority before, during and after every

operation.

2. University of the Cumberlands UAS operators are required to complete the FLYSAFE 

UAV certification program.

3. University of the Cumberlands carries an insurance policy covering $2,000,000 general 

aggregate liability with a $1,000,000 per occurrence maximum, also including $5,000 

medical payments with a $1,000 property damage deductible. The policy is with Aerial 

Pak.

4. Operations utilizing the DJI Inspire 1 will provide a benefit to the general public and 

serve the public interest by providing the service of aerial photographic images and video

to colleges and universities for considerably less than the previously only available option 

of utilizing manned aircraft at an equivalent level of safety.

5. The device utilizes GPS to establish its home points for takeoff and return to home when 

battery levels reach 20%. 

6. The device is also equipped with a failsafe should something go wrong, will go to its 

designated home point set before each flight at the maximum altitude set to avoid 

obstacles.
7. The weight of the DJI Phantom is 6.4 pounds and is powered by a 5700mah battery 

which is used to power the 4 electric motors. The batteries enable a flight time of 15 to 20

minutes. 

8. All UAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 

400 feet AGL.

9. No UAS operations will be conducted within 5 NM of an airport.

10. No UAS operations shall occur over densely populated areas, large assemblies of people, 

stadiums, government buildings, power lines, or major roads.

11. All nonparticipating persons shall be a minimum of 500 feet from the UAS.

12. If a nonparticipating person comes within 500 feet of the UAS, flight operations will 

cease immediately or the UAS will be rerouted to avoid such a situation.

13. All UAS operations shall take place during daylight hours under conditions

equivalent to Visual Flight Rules (VFR) with the UAS no more than 3/4 NM from the

PIC.

14. The UAS will yield to all manned aircraft at all times.

15. A pre-flight inspection by the PIC will be performed prior to each flight to assure that

the UAS is safe for flight. A post-flight inspection will also be performed as an added

level of safety. An aircraft check will also occur after every two hours of flight.

16. At no time shall the UAS be operated with missing or manufacturer unapproved parts,

or in any condition that could pose a hazard to any other aircraft or structure or person on 

the ground.

17. The DJI Inspire 1 has a weight of less than 6 pounds, dimensions of 17.24 x 17.75 x 

11.85 inches, and has a max speed of 22m/s.

18. The DJI Inspire 1 has numerous safety features such as Failsafe mode, automatic landing

should signal between PIC and UAS be interrupted, GPS based altitude and distance 

locks, Flight Limits function and low battery warnings at 30% that automatically returns 

to home.

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b)

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b)
Flight Profiles

University of the Cumberlands flight profile varies per project, and because the campus owns a 

gross square acreage of over 12,500 acres, not every flight path will be the same. Operations 

utilizing the DJI Inspire 1 will provide a benefit to the general public and serve the public 

interest by providing the service of aerial photographic images of University of the Cumberlands, 

as well as other marketing efforts, with a high level of safety.

Conclusion

University of the Cumberlands is requesting an exemption for the purpose of aerial video and 

photography of its various property. This exemption would allow University of the Cumberlands 

to provide the aerial footage necessary for prospective students to see campus visually when they 

are not able to visit the campus in advance of applying, or excite alumni about happenings on 

campus so that they stay connected with their alma mater. With the market in high demand for 

individuals in need of this service, University of the Cumberlands will provide this service with 

safety and quality in mind. With over 20 hours of logged flight time with the DJI Inspire 1, and 

successful completion of the FLYSAFE UAV certification program, we are qualified and 

prepared to provide this service. 

Appendix

Section Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on vehicle 

Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification 

requirements and procedures 

Designed for manned aircraft; 

not suitable for off-the-shelf 

UAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements designed 

for manned aircraft, not UAS; 

petition describes training for 

UAS operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; 

not suitable for off-the-shelf 

UAS 

14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls 

during flight instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 
14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read