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

o f 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 o f University of the Cumberlands’ properties and for other marketing purposes. University

o f 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

o f 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

o f the Cumberlands UAS operators are required to complete the FLYSAFE UAV certification program. 3. University

o f 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 pay

ments with a $1,00 0 property damage deductible. The policy i s 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 i s 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 5 700mah 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 op erations 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 3 0% 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

o f the Cumberlands flight profile varies per project, and because the campus owns a gross square acreage of over 12,500 acres, not every f light 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

o f 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 nece ssary f or 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 o f 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

**S ection**  **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 altitudes14 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