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BEFORE THE

FEDERAL AVIATION ADMINISTRATION

___________________________________________________

PRINCETON UNIVERSITY,

Petitioner.

Docket No. FAA-2015-_____

PETITION OF PRINCETON UNIVERSITY

FOR AN EXEMPTION FROM CERTAIN FEDERAL AVIATION REGULATIONS

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS

Pablo Debenedetti

Dean for Research

Princeton University

107 91 Prospect Avenue

Princeton, NJ 08544

E. Tazewell Ellett

Patrick R. Rizzi

Hogan Lovells US LLP

555 13th Street, N.W.

Washington, DC 20004

Phone: 202-637-8644/ -5659

Fax: 202-637-5910

tazewell.ellett@hoganlovells.com

patrick.rizzi@hoganlovells.com

COUNSEL FOR PRINCETON UNIVERSITY

DATE: November 10, 2015
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TABLE OF CONTENTS Page

1. BACKGROUND INFORMATION: THE PETITIONER ..................................................................................- 1 -

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST ...............................................................- 1 -

3. PROPOSED CONDITIONS AND LIMITATIONS ...........................................................................................- 2 -

3.1 Conditions and limitations regarding the proposed UAS...........................................................- 3 -

3.2 Conditions and limitations regarding the proposed UAS operations .......................................- 4 -

3.3 Conditions and limitations regarding the Pilot in Command and other

crewmember qualifications and training......................................................................................- 8 -

3.4 Conditions and limitations regarding Princeton manuals related to UAS

operations.......................................................................................................................................- 9 -

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA ........................................................- 11 -

5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR

EXEMPTION ..................................................................................................................................................- 12 -

5.1 Contact information .......................................................................................................................- 12 -

5.2 The specific section or sections of the FAR from which Princeton seeks an

exemption .......................................................................................................................................- 12 -

5.3 The extent of relief sought and the reason relief is sought........................................................- 13 -

5.4 Reasons why granting the request would be in the public interest ..........................................- 27 -

5.5 Reasons why granting the exemption would not adversely affect safety, or how

the exemption would provide a level of safety at least equal to that provided by

the rule from which exemption is sought ....................................................................................- 28 -

5.6 Summary that can be published in Federal Register, including the rule from

which exemption is sought, and a brief description of the nature of the

exemption sought. .........................................................................................................................- 30 -

5.7 Additional information that supports request .............................................................................- 31 -

5.8 Request to exercise the privileges of the exemption outside the U.S.......................................- 31 -

5.9 Attachments ...................................................................................................................................- 31 -

6. CONCLUSION ...............................................................................................................................................- 32 -
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1. BACKGROUND INFORMATION: THE PETITIONER

Princeton University (“Princeton”) is a non-profit institution of higher education and one of

the leading universities in the world. In addition to educating students, Princeton conducts

research on a wide variety of subjects.

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST

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

14 C.F.R. (“FAR”) §§ 11.61(b), 11.63(a), and 11.81, Princeton requests that the FAA grant

Princeton an exemption from certain sections of the FAR (detailed below in Sections 5.2 and 5.3)

so that it may operate one or more small UAS to conduct aerial data collection for various

purposes, including research and development (“R&D”), education, facility inspections,

photography, and videography. These proposed operations involve aerial data collection,

consistent with grants like Exemption No. 11213 (March 24, 2015; Docket FAA-2014-0642)

(“Aeryon Labs Exemption”), as well as previously granted summary grant exemptions. As

explained below, Princeton’s proposed UAS operations, as conditioned and limited herein, will

not adversely affect safety, but rather will provide a level of safety equivalent to or greater than

that provided by the current rules, large manned aircraft operations, and other current data

collection methods. See FAR § 11.81.

Princeton respectfully requests that the FAA grant the requested exemption on an

expedited basis. To that end, as detailed below, Princeton agrees to comply with the conditions

and limitations imposed in recent summary grant exemptions, including ones involving aerial
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data collection for purposes of inspections, photography/videography, and R&D. See, e.g.,

Aeryon Labs Exemption; Exemption No. 11822 (June 15, 2015; Docket FAA−2015−1093)

(“HYSight Technologies Exemption”); Exemption No. 11290 (April 8, 2015; Docket FAA-2014-

0474) (“Amazon Exemption”). These are the same conditions and limitations imposed on

Section 333 exemptions recently granted to other universities for aerial data collection. See,

e.g., Exemption No. 11304 (April 8, 2015; Docket FAA-2014-1014) (“Auburn Exemption”).

Given Princeton’s agreement to comply with these conditions and limitations, and given

that this Petition is similar in all material respects to those petitions for which summary grant

exemptions have been granted, and that the proposed UAS use falls within the “aerial data

collection” category of uses permitted by numerous summary grant exemptions, no new

precedent would be set by granting the requested exemption, and any delay in the FAA’s acting

on this Petition would be detrimental to Princeton and delay its implementation of these use

cases. Accordingly, as with the HYSight Technologies Exemption, at 1, and Auburn Exemption,

at 1, good cause exists for the FAA to move forward with consideration of this Petition and the

grant of this exemption without publishing a summary of the Petition in the Federal Register.

3. PROPOSED CONDITIONS AND LIMITATIONS

The small UAS operations proposed in this Petition will be subject to the following

conditions and limitations. As noted above, these conditions and limitations are the same

conditions and limitations as those contained in previously granted small UAS Section 333

exemptions, including recent summary grant exemptions. To facilitate the FAA’s review of this

Petition, Princeton provides a chart at the end of this Section 3 cross-referencing the conditions

and limitations from the HYSight Technologies Exemption, the Aeryon Labs Exemption, the

Auburn Exemption, and the Measure Exemption (cited below) with the corresponding conditions

and limitations outlined below. Collectively, these conditions and limitations ensure that the
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proposed small UAS operations will not adversely affect safety and will provide at least an

equivalent level of safety to that provided by the current rules, large manned aircraft operations,

and other data collection methods.

3.1 Conditions and limitations regarding the proposed UAS

Princeton intends to operate a variety of small, lightweight, battery-operated UAS models

under the requested exemption, all of which are models approved by the Secretary of the

Department of Transportation for operation under Section 333 and designated by the FAA in

previously granted Section 333 exemptions. These models are listed in Attachment 1 to the

Measure Exemption (appended to this Petition as Exhibit 1). See, e.g., Exemption No. 12646

(August 28, 2015; Docket FAA-2015-1602) (“Measure Exemption”) (granting an exemption

covering 324 UAS models). In addition, Princeton requests that its exemption also cover

operations by: (i) the Parrott AR Drone 2.0, the Cropcam UAS, and the Syma X11;1and (ii)

single propeller or multi-rotor, battery-powered, small UAS models developed by Princeton, its

professors, or its enrolled students, see Amazon Exemption (granting exemption covering

“Amazon-manufactured multi-rotor small UAS”).

Each UAS operated under the exemption will be subject to the following conditions and

limitations:

3.1.1 Operations under the exemption will be limited to the UA approved

by the Secretary of the Department of Transportation for operation

under Section 333 and designated by the FAA in previously granted

Section 333 exemptions (Exhibit 1 hereto), the Parrott AR Drone 2.0,

the Cropcam UAS, the Syma X11 UAS, and single-propeller or multirotor, battery-powered, small UAS models developed by Princeton,

its professors, or its enrolled students, in each case when weighing

less than 55 pounds including payload.2 Proposed operations of any

other UAS will require a new exemption or an amendment to the

1

Although it does not appear that these three models of UAS have previously been designated in Section 333

exemptions, there are pending petitions seeking to operate the Parrott AR Drone 2.0 and the Cropcam UAS.

2

The UAS models which Princeton seeks to have covered in the requested exemption are collectively referred

to in this Petition as “these UAS”.
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previously granted exemption. [Measure Exemption Limitation No. 1;

Amazon Exemption Limitation No. 1.] 3

3.1.2 The UA will not be operated at airspeeds greater than the maximum

UA operating speed recommended by the UA manufacturer, and in

no event will it be operated at a speed exceeding 87 knots (100 miles

per hour). Princeton may use either groundspeed or calibrated

airspeed to determine compliance with the maximum speed

restriction. [Aeryon Labs Exemption Limitation No. 3; HYSight

Technologies Exemption Limitation No. 3.]

3.1.3 Each UA will be identified by its serial number and registered with the

FAA in accordance with FAR Part 47 or any alternative method of

registration for UA adopted by the FAA. [Aeryon Labs Exemption

Limitation No. 22; HYSight Technologies Exemption Limitation No.

22.]

3.1.4 Each UA will have identification markings in accordance with FAR

Part 45, with the markings being as large as practicable. [Aeryon

Labs Exemption Limitation No. 22; HYSight Technologies Exemption

Limitation No. 22.]

3.2 Conditions and limitations regarding the proposed UAS operations

All UAS operations under the exemption will be subject to the following conditions and

limitations:

3.2.1 All UAS operations will be covered by an Air Traffic Organization

(“ATO”)-issued Certificate of Waiver or Authorization (“COA”). All

UAS operations will be conducted in accordance with the airspace

requirements in the ATO-issued COA. Should Princeton want to

conduct operations that cannot be conducted under the terms of the

blanket COA accompanying this exemption, Princeton will apply for a

new or amended COA. [Aeryon Labs Exemption Limitation No. 21;

HYSight Technologies Exemption Limitation No. 21.]

3.2.2 Operations for the purpose of closed-set motion picture and

television filming are not permitted under this exemption. [Aeryon

3

To the extent processing and consideration of this Petition may be slowed or delayed by the request for

authority to operate the Parrott AR Drone 2.0, the Cropcam UAS, the Syma X11 UAS, and/or single-propeller or multirotor, battery-powered, small UAS models developed by Princeton, its professors, or its enrolled students, Princeton

respectfully requests that the FAA move expeditiously to grant the Petition with respect to the UAS models listed in

Exhibit 1, all of which previously have been designated approved by the Secretary of the Department of Transportation

for operation under Section 333 and designated by the FAA in previously granted Section 333 exemptions. The FAA

has previously followed this procedure. See, e.g., Exemption No. 12714 (July 27, 2015; Docket FAA-2015-1851)

(granting Section 333 exemption as to several UAS makes/models, but not others for which the FAA had not

completed its review).
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Labs Exemption Limitation No. 2; HYSight Technologies Exemption

Limitation No. 2.]

3.2.3 The UA will not operate within 5 nautical miles of an airport’s

reference point (“ARP”) as denoted in the current FAA Airport/Facility

Directory, or for airports not denoted with an ARP, the center of the

airport symbol as denoted on the current FAA-published aeronautical

chart, unless a letter agreement with that airport’s management is

obtained or such an operation is otherwise permitted by a COA

issued to Princeton. Princeton will make the letter agreement

available to the FAA or any law enforcement official upon request.

[Aeryon Labs Exemption Limitation No. 16; HYSight Technologies

Exemption Limitation No. 16.]

3.2.4 The minimum crew for each UAS operation will consist of one Pilot in

Command (“PIC”) and one Visual Observer (“VO”). The PIC will be

designated before the flight, and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that

the VO can perform the functions prescribed for the VO. [Aeryon

Labs Exemption Limitation No. 6; HYSight Technologies Exemption

Limitation No. 6.]

3.2.5 The UA will be operated within the visual line of sight (“VLOS”) of the

PIC and VO at all times. The PIC will maintain VLOS with human

vision unaided by any device other than corrective lenses as

specified on the PIC’s FAA-issued airman medical certificate or U.S.

driver’s license. [Aeryon Labs Exemption Limitations Nos. 5 and 6;

HYSight Technologies Exemption Limitations Nos. 5 and 6.] The VO

may be used to satisfy the VLOS requirement as long as the PIC

always maintains VLOS capability. [Aeryon Labs Exemption

Limitation No. 6; HYSight Technologies Exemption Limitation No. 6.]

3.2.6 During each UAS operation, the PIC and the VO must be able to

communicate verbally with each other at all times. Electronic

messaging or texting by the PIC and the VO is not permitted during

UAS flight operations. [Aeryon Labs Exemption Limitation No. 6;

HYSight Technologies Exemption Limitation No. 6.]

3.2.7 The PIC is prohibited from beginning a UAS flight unless

(considering wind and forecast weather conditions) there is enough

available power for the UA to conduct the intended operation and to

operate after that for at least five minutes or, if greater, with the

reserve power recommended by the UA manufacturer. [Aeryon Labs

Exemption Limitation No. 20; HYSight Technologies Exemption

Limitation No. 20.]

3.2.8 Prior to each UA flight, the PIC will conduct a pre-flight inspection

and determine that the UAS (including the Ground Control Station) is

in a condition for safe flight. The pre-flight inspection will account for

all potential discrepancies, e.g., non-functioning components, items
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or equipment. If the inspection reveals a condition that affects the

safe operation of the UAS, the UA is prohibited from operating until

the necessary maintenance has been performed, and the UAS is

found to be in a condition for safe flight. [Aeryon Labs Exemption

Limitation No. 10; HYSight Technologies Exemption Limitation No.

10.]

3.2.9 The operator is responsible for maintaining and inspecting the UAS

to ensure that it is in a condition for safe operation. [Aeryon Labs

Exemption Limitation No. 9; HYSight Technologies Exemption

Limitation No. 9.]

3.2.10 During each UAS operation, the UA will remain at or below 400 feet

above ground level (“AGL”). [Aeryon Labs Exemption Limitation No.

4; HYSight Technologies Exemption Limitation No. 4.]

3.2.11 Altitude reports made to ATC or other persons must be reported in

feet AGL. [Aeryon Labs Exemption Limitation No. 4; HYSight

Technologies Exemption Limitation No. 4.]

3.2.12 All UAS operations will be conducted over private or controlledaccess property with permission from the property owner/controller or

authorized representative. Permission from the property

owner/controller or authorized representative will be obtained for

each flight to be conducted. [Aeryon Labs Exemption Limitation No.

27; HYSight Technologies Exemption Limitation No. 27.]

3.2.13 The UA will operate at least 500 feet from all non-participating

persons, vessels, vehicles, and structures unless:

(a) Barriers or structures are present that sufficiently protect

non-participating persons from the UA and/or debris in the

event of an accident. Princeton must ensure that nonparticipating persons remain under such protection; and if a

situation arises where non-participating persons leave such

protection and are within 500 feet of the UA, flight

operations must cease immediately in a manner ensuring

the safety of the non-participating persons; and/or

(b) The owner/controller of any vessels, vehicles or structures

has granted permission for operating closer to those objects

and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it

does not present an undue hazard.

The PIC, VO, operator trainees, and essential persons are not

considered non-participating persons under this exemption.

[Aeryon Labs Exemption Limitation No. 26; HYSight Technologies

Exemption Limitation No. 26.]

3.2.14 All UAS operations will take place during visual meteorological

conditions (VMC) only. [Aeryon Labs Exemption Limitation No. 15;

HYSight Technologies Exemption Limitation No. 15.]
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3.2.15 Princeton will not operate UAS flights under Special Visual Flight

Rules (SVFR). [Aeryon Labs Exemption Limitation No. 15; HYSight

Technologies Exemption Limitation No. 15.]

3.2.16 All UAS operations will take place during daylight hours. UAS

operations will not be conducted during night, as defined in 14 C.F.R.

§ 1.1. [Aeryon Labs Exemption Limitation No. 15; HYSight

Technologies Exemption Limitation No. 15.]

3.2.17 During each UAS operation, the UA will avoid, remain clear of, and

yield right-of-way to all manned aviation operations and activities at

all times. [Aeryon Labs Exemption Limitation No. 24; HYSight

Technologies Exemption Limitation No. 24.]

3.2.18 The UA will not be operated 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 PIC. [Aeryon Labs Exemption Limitation No.

17; HYSight Technologies Exemption Limitation No. 17.]

3.2.19 The UAS will not be operated by the PIC from any moving device or

vehicle. [Aeryon Labs Exemption Limitation No. 25; HYSight

Technologies Exemption Limitation No. 25.]

3.2.20 Any UAS that has undergone maintenance or alterations that affect

the UAS operation or UA flight characteristics (e.g., replacement of a

flight critical component) must undergo a functional test flight prior to

conducting further operations under this exemption. Functional test

flights will only be conducted by a PIC with a VO, and must remain at

least 500 feet from other people. The functional test flight must be

conducted in such a manner so as to not pose an undue hazard to

persons and property. [Aeryon Labs Exemption Limitation No. 8;

HYSight Technologies Exemption Limitation No. 8.]

3.2.21 If the UAS loses communications or its GPS signal during any

operation, the UA must return to a pre-determined location within the

private or controlled-access property. [Aeryon Labs Exemption

Limitation No. 18; HYSight Technologies Exemption Limitation No.

18.]

3.2.22 The PIC will abort the UAS operation and UA flight in the event of

unpredicted obstacles or emergencies. [Aeryon Labs Exemption

Limitation No. 19; HYSight Technologies Exemption Limitation No.

19.]

3.2.23 The documents used by the operator to ensure the safe operation

and flight of the UAS and any documents required under 14 C.F.R.

§§ 91.9 and 91.203 will be available to the PIC at the Ground Control

Station of the UAS at any time the UA is operating, and will be made

available to the FAA or any law enforcement official upon request.
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[Aeryon Labs Exemption Limitation No. 23; HYSight Technologies

Exemption Limitation No. 23.]

3.2.24 Any incident, accident or flight operation that transgresses the lateral

or vertical boundaries of the operational area as defined by the

applicable COA will be reported to the FAA’s UAS Integration Office

(AFS-80) within 24 hours. Accidents will be reported to the National

Transportation Safety Board (“NTSB”) per instructions contained on

the NTSB website: www.ntsb.gov. [Aeryon Labs Exemption

Limitation No. 28; HYSight Technologies Exemption Limitation No.

28.]

3.3 Conditions and limitations regarding the Pilot in Command and other

crewmember qualifications and training

The PIC and other crewmembers for each UAS operation under the requested exemption

will be subject to the following conditions and limitations:

3.3.1 The PIC must hold (i) either an ATP, commercial, private,

recreational or sport pilot certificate; and (ii) a current FAA airman

medical certificate or a valid driver’s license issued by a State, the

District of Columbia, Puerto Rico, a U.S. territory/possession, or the

Federal Government. The PIC must satisfy the flight review

requirements of 14 C.F.R. § 61.56 in an aircraft for which the PIC is

rated on his or her pilot certificate. [Aeryon Labs Exemption

Limitation No. 13; HYSight Technologies Exemption Limitation No.

13.]

3.3.2 The operator will not permit any PIC to operate the UAS unless the

PIC demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under this exemption,

including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles, and

structures. PIC qualification flight hours and currency must be

logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for

the purposes of training Princeton’s PICs and VOs (training,

proficiency, and experience-building) and determining the PIC’s

ability to safely operate the UAS in a manner consistent with how the

UAS will be operated under this exemption are permitted under the

terms of this exemption. These training operations, however, may

only be conducted during dedicated training sessions. [Aeryon Labs

Exemption Limitation No. 14; HYSight Technologies Exemption

Limitation No. 14.]

3.3.3 During training, proficiency, and experience-building flights, all

persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate
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distance from non-participants in accordance with 14 C.F.R. §

91.119. [Aeryon Labs Exemption Limitation No. 14; HYSight

Technologies Exemption Limitation No. 14.]

3.4 Conditions and limitations regarding Princeton manuals related to UAS

operations

Princeton will have manuals and checklists for each of these UAS models it plans to

operate under the requested exemption (collectively, the “Manuals”). The Manuals will be

subject to the following conditions and limitations:

3.4.1 The Operating Documents4 must be accessible during UAS

operations and made available to the FAA upon request. If a

discrepancy exists between the conditions and limitations in the

exemption and the procedures outlined in the other Operating

Documents, the conditions and limitations in the exemption take

precedence and must be followed. Otherwise, Princeton must follow

the procedures as outlined in the Operating Documents. [Aeryon

Labs Exemption Limitation No. 7; HYSight Technologies Exemption

Limitation No. 7.]

3.4.2 Princeton may update or revise its Operating Documents, and it is

Princeton’s responsibility to track such revisions and present updated

and revised documents to the FAA or any law enforcement official

upon request. Princeton must also present updated and revised

documents if it petitions for an extension or amendment of the

exemption. If Princeton determines that any update or revision

would affect the basis upon which the FAA granted the requested

exemption, then Princeton must petition for an amendment to the

exemption. Princeton will contact the FAA’s UAS Integration Office

(AFS-80) if questions arise regarding updates or revisions to the

Operating Documents. [Aeryon Labs Exemption Limitation No. 7;

HYSight Technologies Exemption Limitation No. 7.]

3.4.3 Each UAS operated under the exemption will comply with all

manufacturer safety bulletins. [Aeryon Labs Exemption Limitation

No. 12; HYSight Technologies Exemption Limitation No. 12.]

3.4.4 Princeton will follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the UAS and

UAS components. [Aeryon Labs Exemption Limitation No. 11;

HYSight Technologies Exemption Limitation No. 11.]

4

The “Operating Documents” means this exemption, the Manuals, and all other documents needed by

Princeton to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in

this grant of exemption. [Aeryon Labs Exemption Limitation No. 7; HYSight Technologies Exemption Limitation No. 7.]
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In sum, Princeton’s operations under this exemption will be subject to the same

conditions and limitations imposed in the Measure Exemption, the Aeryon Labs Exemption, the

Auburn Exemption, and the HYSight Technologies Exemption.

CROSS-REFERENCES

Aeryon Labs Exemption Limitation No.

HYSight Technologies Exemption Limitation No.

Auburn Exemption Limitation No.

Measure Exemption Limitation No.

Petition Limitation No.

1

Plus Amazon Exemption Limitation No. 1

3.1.1

2 3.2.2

3 3.1.2

4 3.2.10, 3.2.11

5 3.2.5

6 3.2.4, 3.2.5, 3.2.6

7 3.4.1, 3.4.2

8 3.2.20

9 3.2.9

10 3.2.8

11 3.4.4

12 3.4.3

13 3.3.1
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14 3.3.2, 3.3.3

15 3.2.14, 3.2.15, 3.2.16

16 3.2.3

17 3.2.18

18 3.2.21

19 3.2.22

20 3.2.7

21 3.2.1

22 3.1.3, 3.1.4

23 3.2.23

24 3.2.17

25 3.2.19

26 3.2.13

27 3.2.12

28 3.2.24

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA

In accordance with FMRA Section 333, Princeton requests that the Secretary of

Transportation determine that Princeton’s proposed small UAS operations (i) do not create a

hazard to users of the National Airspace System or the public, and (ii) do not pose a threat to

national security.
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Princeton further requests that, based on the Secretary’s determination, the FAA

determine – as it did in the Aeryon Labs Exemption, the HYSight Technologies Exemption, the

Auburn Exemption, and the Measure Exemption – that relief from FAR Part 21 and any

associated noise certification and testing requirements of FAR Part 36 is not necessary for the

UAS operations proposed in this Petition.5

5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR

EXEMPTION

As required by FAR § 11.81, Princeton provides the following information in support of

this Petition:

5.1 Contact information:

Name: Princeton University submits this Petition for Exemption, through counsel,

E. Tazewell Ellett and Patrick Rizzi.

Mailing address: E. Tazewell Ellett, Patrick R. Rizzi

Counsel for Princeton University

Hogan Lovells US LLP

555 13th Street, NW

Washington, DC 20004

Telephone/Facsimile number:

(T) 202-637-8644 (Ellett) / 202-637-5659 (Rizzi)

(F) 202-637-5910

E-mail addresses:

tazewell.ellett@hoganlovells.com

patrick.rizzi@hoganlovells.com

5.2 The specific section or sections of the FAR from which Princeton seeks an

exemption:

FAR § 61.23(a) and (c) – Medical certificates: Requirement and Duration.

FAR § 61.101(e)(4) and (5) – Recreational pilot privileges and limitations.

5

Aeryon Labs Exemption, at 7; HYSight Technologies Exemption, at 2; Auburn Exemption, at 2; Measure

Exemption, at 2. If the FAA concludes that the UAS operations proposed in this Petition require an exemption from

FAR Parts 21 and/or 36, then Princeton requests that the FAA include that relief in the exemption.
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FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in

command.

FAR § 61.315(a), (c)(2), and (c)(3) – What are the privileges and limitations of my

sport pilot certificate?

FAR § 91.7(a) – Civil aircraft airworthiness.

FAR § 91.119(c) and (d)(1) – Minimum safe altitudes: General.

FAR § 91.121 – Altimeter settings.

FAR § 91.151 – Fuel requirements for flight in VFR conditions.

FAR § 91.405(a) – Maintenance required.

FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance,

rebuilding, and inspections.

FAR § 91.409(a)(1) and (2) – Inspections.

FAR § 91.417(a) and (b) – Maintenance records.

5.3 The extent of relief sought and the reason relief is sought:

Princeton proposes to conduct small UAS operations, as described herein, for aerial data

collection for various purposes, including aerial surveying, photography, videography, and R&D.

In order to be able to conduct these UAS operations, Princeton petitions the FAA, pursuant to

FAR §§ 11.61(b), 11.63(a), and 11.81(b), for an exemption from the following sections of the

FAR for the reasons noted:

FAR § 61.23(a) and (c) -– Medical certificates: Requirement and Duration.

FAR § 61.101(e)(4) and (5) – Recreational pilot privileges and limitations.

The regulation states, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a

recreational pilot may not act as pilot in command of an aircraft— .

. .

(4) For compensation or hire;

(5) In furtherance of a business; . . . .

FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in command.

The regulation states, in relevant part:

(a) Except as provided in paragraphs (b) through (h) of this section,

no person who holds a private pilot certificate may act as pilot in

command of an aircraft that is carrying passengers or property for

compensation or hire; nor may that person, for compensation or

hire, act as pilot in command of an aircraft.
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(b) A private pilot may, for compensation or hire, 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.

(c) ****.

FAR § 61.315(a) and (c)(2), (c)(3) – What are the privileges and limitations of my

sport pilot certificate?

The regulation states, in relevant part:

(a) If you hold a sport pilot certificate you may act as pilot in

command of a light-sport aircraft, except as specified in paragraph

(c) of this section. . . .

. . . .

(c) You may not act as pilot in command of a light-sport aircraft: . . .

(2) For compensation or hire.

(3) In furtherance of a business. . . .

Princeton requests an exemption from these regulations to the extent necessary to permit

Princeton to conduct UAS operations using PICs who hold (i) an FAA private pilot, recreational

pilot or a sport pilot certificate, and (ii) an FAA airman medical certificate or a state driver’s

license. While Princeton recognizes that the FAA normally requires a PIC to hold a commercial

pilot certificate where there is compensation either to the pilot or for the operation, Princeton

requests that the FAA exempt Princeton and its PICs from this requirement since the use of at

least a sport pilot as the PIC for the UAS operations under this exemption will be more safe than

the use of a commercial pilot for manned aircraft operations. Unlike conventional aircraft, these

small UAS [see Limitation No. 3.1.1] are lightweight, remotely controlled, and battery-powered

(not fuel/gas), and they have no crew or passengers. The fulfillment of the additional

requirements for a sport, recreational or private pilot to become qualified as a commercial pilot

would not lead to any additional safety benefits when UAS operations are involved.
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The differences between the aeronautical knowledge and aeronautical experience

requirements for sport pilots and for commercial pilots are significant in the traditional world of

manned aircraft. However, no aspect of this incremental additional knowledge or aeronautical

experience is significant for the daytime, VMC, low-altitude, visual-line-of-sight, small UAS

operations over private or controlled-access properties with property owner/controller permission

as proposed in this Petition. Put another way, there are stark and fundamental differences

between the type of experience and aeronautical knowledge that the PIC of a commercial

manned aircraft with passengers and property should have, versus the type of experience and

aeronautical knowledge that the PIC of a small UAS should have, in order to avoid imperiling

passengers or property. In the case of Princeton, the small amount of property carried aboard

the UA will be Princeton’s property. While the PIC may, or will, be compensated, all risk of

damage to the property (in fact to the UAS itself) will be borne by Princeton. There is no

expectation or need for the PIC of the small UA to have the type of experience or aeronautical

knowledge that a commercial pilot for a manned aircraft would have. Similarly, the differences

between the flight proficiency requirements for sport pilots and commercial pilots are not

substantively significant here where the operations will be conducted strictly during daylight VMC

conditions, within VLOS, at altitudes no higher than 400 feet AGL. In addition, Princeton will

implement a training program to ensure that the experience, knowledge, and flight proficiency

needed to operate its small UAS safely are achieved for its PICs. Accordingly, there is no

reason to require the UAS PIC to have more aeronautical knowledge, experience, and flight

proficiency than that required for a sport pilot certificate.

Given that Princeton plans to operate these small UAS over private or controlled-access

property and at low altitudes during daytime in VMC, the parallel nature of sport pilot aeronautical

knowledge requirements to those of commercial pilot requirements, the limited airmanship skills

necessary to operate these small UAS, and the lack of additional safety benefits for the proposed
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UAS operations here resulting from commercial pilot experience, the PIC under this exemption

should only be required to hold, at most, a sport pilot certificate. Such a condition would be

consistent with the certificate requirements imposed on the PIC in the Aeryon Labs Exemption,

the HYSight Technologies Exemption, and the Auburn Exemption.

For these reasons, and consistent with recent summary grant exemptions, Princeton

requests that the FAA grant an exemption to permit Princeton to use as PIC of its proposed UAS

operations pilots who hold at least a sport pilot certificate and either an FAA third-class airman

medical certificate or a state driver’s license, so long as they satisfy the conditions and limitations

proposed in this Petition, including the PIC qualification and training requirements.

FAR § 91.7(a) – Civil aircraft airworthiness.

The regulation states in relevant part:

(a) No person may operate a civil aircraft unless it is in an airworthy

condition. . . .

Princeton requests an exemption from this provision to the extent necessary to permit

Princeton to conduct the small UAS operations proposed in this Petition. These small UAS will

not require an airworthiness certificate under FAR Part 21, Subpart H, and thus Princeton

requests relief from this regulation. See Exemption No. 11110 (December 10, 2014; Docket

FAA-2014-0367) (“Trimble Exemption”), at 16. An exemption is warranted because Princeton

understands that, notwithstanding the lack of an airworthiness certificate, the FAA will consider

its “compliance with [Princeton’s Manuals] to be sufficient means for determining an airworthy

condition” and that Princeton must still determine the UA’s airworthiness prior to each flight

based on compliance with such Manuals. Trimble Exemption, at 16; see also HYSight

Technologies Exemption at 2 (granting exemption from this section).

FAR § 91.119(c) and (d)(1) – Minimum safe altitudes: General.

The regulation states:
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Except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an

emergency landing without undue hazard to persons or property on

the surface.

(b) Over congested areas. Over any congested area of a city, town,

or settlement, or over any open air assembly of persons, an altitude

of 1,000 feet above the highest obstacle within a horizontal radius

of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above

the surface, except over open water or sparsely populated areas.

In those cases, the aircraft may not be operated closer than 500

feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control

aircraft. If the operation is conducted without hazard to persons or

property on the surface—

(1) A helicopter may be operated at less than the minimums

prescribed in paragraph (b) or (c) of this section, provided

each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by

the FAA; and

(2) A powered parachute or weight-shift-control aircraft may

be operated at less than the minimums prescribed in

paragraph (c) of this section.

Princeton requests an exemption from this regulation to the extent necessary to permit

Princeton to conduct its UAS operations at altitudes lower than those permitted by FAR §

91.119(c) and (d)(1), since the ability to operate at such altitudes is one of the key benefits of

using small UAS for these flights. Even at these low altitudes, Princeton’s UAS operations will

be conducted at a level of safety at least equal to that which would be achieved if larger manned

aircraft were to be used at the altitudes required by FAR § 91.119.

With respect to paragraph (a), Princeton intends to comply with this requirement to the

same extent as would a manned aircraft operation, meaning that the UA must operate at an

altitude such that the loss of a single power unit aboard the UA or used by the UAS would still

permit an emergency landing “without undue hazard to persons or property on the surface.”
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Princeton agrees with the FAA’s reasoning on this issue in the Astraeus Exemption, at 20,6and

therefore does not believe that relief is required from paragraph (a).

With respect to paragraph (b), Princeton plans to operate these small UAS over private or

controlled-access properties (with owner/controller permission), and thus Princeton does not

believe that an exemption is necessary from this paragraph (b).

With respect to paragraph (c), Princeton requests an exemption to allow UAS operations

down to the surface, both in sparsely populated areas and in “other than congested” areas.

Princeton’s UAS operations require lower-level flying, but have a number of self-imposed

restrictions to ensure at least an equivalent level of safety. For example,

 All operations will be conducted over private or controlled-access property.

 Permission from the property owner/controller will be obtained prior to the

beginning of each UA flight.

 The UA will operate at least 500 feet from all non-participating persons, vessels,

vehicles, and structures unless:

o Barriers or structures are present that sufficiently protect non-participating

persons from the UA and/or debris in the event of an accident. Princeton

will ensure that non-participating persons remain under such protection;

and if a situation arises where non-participating persons leave such

protection and are within 500 feet of the UA, flight operations will cease

immediately in a manner ensuring the safety of the non-participating

persons; and/or

o The UA is operated near vessels, vehicles or structures where the property

owner/controller has granted permission, and the PIC has made a safety

6

Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352).
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assessment of the risk of operating closer to those objects and determined

that it does not present an undue hazard.

Even with a grant of this exemption, the UAS operations will be at least as safe as

operations by manned aircraft that comply with this paragraph. Flying a manned aircraft, given

its weight, size, speed, and fuel load, would pose a significant risk compared to the use of a

small UA, with a much smaller size and lighter weight, operating at much slower speeds, with

batteries rather than a significant fuel load, at all times within VLOS of the PIC on the ground

who has a wide view. Accordingly, as the FAA determined in the Trimble Exemption, at 17-18,

relief is warranted here provided that Princeton adheres to its Manuals and the additional

conditions and limitations outlined above and in the exemption. For these reasons, Princeton

requests relief from the entirety of paragraph (c), as was recently granted in the Measure

Exemption, the Aeryon Labs Exemption, the HYSight Technologies Exemption, and the Auburn

Exemption.

To the extent necessary, Princeton also requests relief from paragraph (d)(1), which

applies only to helicopters and allows operation at lower altitudes only if on a prescribed

helicopter route. Flying a manned helicopter would pose a significantly greater risk than using a

small, helicopter-type UA for the proposed operations, even if the helicopter is on a specific route

or at a specific low height prescribed by the FAA. A manned helicopter is much heavier, larger,

and faster than a small UA. Moreover, unlike an unmanned, battery-powered small UA, the

helicopter has people on-board and a fuel load. The operation of a small UA at all times within

the VLOS of the PIC on the ground would be at least as safe as a manned helicopter operation

operating in conformity with the requirements of paragraph (d)(1), and therefore an exemption

from Section 91.119(d)(1) is warranted.

FAR § 91.121 – Altimeter settings.

The regulation states, in relevant part:
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(a) Each person operating an aircraft shall maintain the cruising

altitude or flight level of that aircraft, as the case may be, by

reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station

along the route and within 100 nautical miles of the

aircraft;

(ii) If there is no station within the area prescribed in

paragraph (a)(1)(i) of this section, the current reported

altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio,

the elevation of the departure airport or an appropriate

altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b)  .

Princeton requests an exemption from FAR § 91.121 to the extent necessary7to permit

Princeton to conduct the small UAS operations proposed in this Petition. See, e.g., Aeryon Labs

Exemption, at 12; HYSight Technologies Exemption, at 2; Astraeus Exemption, at 21-22.

Princeton recognizes the critical importance of ensuring that any UAS operated by Princeton

maintains altitude to an accurate reference such that other aircraft and the FAA may rely on

Princeton’s UAS to be operating as proposed. The PIC will check the UA altitude reading prior to

each takeoff, and will effectively zero the UA’s altitude at the point of takeoff, to ensure that

measurements of the UA’s altitude are as accurate as possible relative to the local elevation. To

the extent that this methodology does not satisfy FAR § 91.121 or any other regulation, Princeton

requests an exemption to permit UAS operations using this methodology.

7

It is not clear to Princeton that an exemption from this section is required, because, although the regulation

expressly applies only to aircraft maintaining a “cruising altitude” and dictates the altimeter setting that must be used

while at that cruising altitude, cruising altitudes for VFR flights do not begin – according to FAR § 91.159 – until “more

than 3,000 feet above the surface.” FAR § 91.159; see also Aeronautical Information Manual, at Chpt. 3, Sec. 1, Tbl.

3-1-1, para. 3-1-2. (July 24, 2014).
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FAR § 91.151 – Fuel requirements for flight in VFR conditions.

The regulation 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; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at

least 20 minutes.

Princeton requests an exemption from FAR § 91.151 to permit Princeton to plan its UAS

operations as described above. The proposed small UAS operations in this Petition will (i)

involve operations in which one or more UAS is transported by means other than its own power

to the operational location, and (ii) begin and end at the operational site, with the takeoff, entire

flight, and landing all taking place within the immediate proximity of each other while remaining at

all times within the VLOS of the PIC.

The goal of FAR § 91.151 is to ensure that pilots plan for an extra 20 or 30 minutes of

fuel at their first intended point of landing in order to account for unexpected possible delays en

route and at the first planned destination. Many of these delays that plague manned aircraft are

simply not an issue with the proposed small UAS operations over private or controlled-access

property, because there is virtually no “en route” portion of the flight, and any problems at the

point of landing are extremely unlikely to cause delays, since a UA can always land just a few

feet away if the intended point of landing becomes unusable.

Given the relatively short operating time of these small UAS, requiring a full 30 minutes of

reserve “fuel” (battery power) could take up much, if not all, of the time available for these small
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UAS operations. Princeton believes that using a smaller reserve for UAS flight planning

purposes will be at least as safe as using the reserves required by FAR § 91.151 for manned

aircraft. To that end, and consistent with Measure Exemption Limitation No. 20, Aeryon Labs

Exemption Limitation No. 20, and HYSight Technologies Exemption Limitation No. 20, the PIC

under the requested exemption will be prohibited from beginning a UAS flight unless (considering

wind and forecast weather conditions) there is enough power available for the UA to conduct the

intended operation and to operate after that for at least five minutes or, if greater, with the

reserve power recommended by the UA manufacturer. See Proposed Limitation 3.2.7. Such a

battery reserve is more than sufficient, particularly in light of the FAA’s acceptance of a 5-minute

reserve in the Measure Exemption, the Aeryon Labs Exemption, and the HYSight Technologies

Exemption. Princeton believes that these limitations will further ensure that the proposed

reserve planning and operational requirements that Princeton is requesting to use under this

exemption will provide at least an equivalent level of safety.

For these reasons, Princeton requests an exemption from FAR § 91.151 to permit it to

plan and conduct UAS operations subject to the reserve power limitation explained above.

FAR § 91.405(a) – Maintenance required.

The regulation states, in relevant part:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of

this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter;

(b) ** **.

Princeton requests an exemption from FAR § 91.405(a) to permit Princeton to conduct

the UAS operations proposed in this Petition without having to perform the inspections and

discrepancy repairs required by FAR § 91.405(a). In the Astraeus Exemption and the Trimble
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Exemption, the FAA determined that the proposed UAS operations required exemption from FAR

§ 91.405(a), and that the achievement of an adequate level of safety required certain conditions

and limitations. Princeton has proposed in Section 3 of this Petition several conditions and

limitations related to maintenance and inspections which it believes provide a level of safety at

least equivalent to that provided by FAR § 91.405(a). For this reason, and consistent with the

exemptions granted from this section in the Aeryon Labs Exemption and the HYSight

Technologies Exemption, Princeton requests an exemption from FAR § 91.405(a) to permit

Princeton to conduct UAS operations as proposed in this Petition, subject to the conditions and

limitations proposed above, without having to perform the inspections and discrepancy repairs

required by FAR § 91.405(a).

Princeton does not believe that an exemption from the remaining paragraphs of FAR §

91.405 is required, since Princeton will make appropriate logbook entries in aircraft maintenance

records in accordance with paragraph (b), appropriately mark any inoperative instrument or item

of equipment for which maintenance has been properly deferred in compliance with paragraph

(c), and appropriately placard listed discrepancies that include inoperative instruments or

equipment in compliance with paragraph (d).

FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance,

rebuilding or alteration.

The regulation states:

(a) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration

unless—

(1) It has been approved for return to service by a person

authorized under §43.7 of this chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as

applicable, of this chapter has been made.

. . . .
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Princeton requests an exemption from FAR § 91.407(a)(1) to permit Princeton to conduct

UAS operations as proposed in this Petition without having to have the UAS approved for return

to service by a person authorized under FAR § 43.7. In the Astraeus Exemption, the FAA

determined that the proposed UAS operations required exemption from FAR § 91.407(a)(1),

subject to certain conditions and limitations. Princeton has proposed in this Petition

maintenance-related conditions and limitations which it believes provide a level of safety at least

equivalent to that provided by FAR § 91.407(a)(1). For this reason, and consistent with the

exemptions granted from this section in the Aeryon Labs Exemption and the HYSight

Technologies Exemption, Princeton requests an exemption from FAR § 91.407(a)(1) to permit

Princeton to conduct UAS operations as proposed in this Petition, subject to the proposed

conditions and limitations, without having to have the UAS approved for return to service by a

person authorized under FAR § 43.7.

Princeton does not believe that an exemption from the remaining paragraphs of FAR §

91.407 is required, since Princeton will require that maintenance record entries are made as

required, in compliance with paragraph (a)(2), and since no persons will be carried following

maintenance performed on the UAS, making paragraphs (b) and (c) moot.

FAR § 91.409(a)(1) and (2) – Inspections.

The regulation states, in relevant part:

(a) Except as provided in paragraph (c) of this section, no person

may operate an aircraft unless, within the preceding 12 calendar

months, it has had—

(1) An annual inspection in accordance with part 43 of this

chapter and has been approved for return to service by a person

authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate

in accordance with part 21 of this chapter.

No inspection performed under paragraph (b) of this section may

be substituted for any inspection required by this paragraph unless
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it is performed by a person authorized to perform annual

inspections and is entered as an “annual” inspection in the required

maintenance records.

(b)  .

Princeton requests an exemption from FAR § 91.409(a)(1) and (2) to permit Princeton to

conduct UAS operations as proposed in this Petition without having to obtain the annual

inspection and airworthiness certificate inspection required by FAR § 91.409(a)(1) and (2). In the

Astraeus Exemption, the FAA determined that the proposed UAS operations required exemption

from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of safety required certain

conditions and limitations. Princeton has proposed in this Petition maintenance and inspectionrelated conditions and limitations which it believes provide a level of safety at least equivalent to

that provided by FAR § 91.409(a)(1) and (2). For this reason, and consistent with the

exemptions granted from this section in the Aeryon Labs Exemption and the HYSight

Technologies Exemption, Princeton requests an exemption from FAR § 91.409(a)(1) and (2) to

permit Princeton to conduct UAS operations as proposed in this Petition, subject to the proposed

conditions and limitations, without having to obtain the annual inspection and airworthiness

certificate inspection required by FAR § 91.409(a)(1) and (2).

FAR § 91.417(a) and (b) – Maintenance records.

The regulation states, in relevant part:

(a) Except for work performed in accordance with §§91.411 and

91.413, each registered owner or operator shall keep the following

records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance,

and alteration and records of the 100-hour, annual,

progressive, and other required or approved inspections, as

appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft.

The records must include—

(i) A description (or reference to data acceptable to the

Administrator) of the work performed; and
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(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person

approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine,

each propeller, and each rotor.

(ii) The current status of life-limited parts of each

airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on

the aircraft which are required to be overhauled on a

specified time basis.

(iv) The current inspection status of the aircraft,

including the time since the last inspection required by

the inspection program under which the aircraft and its

appliances are maintained.

(v) The current status of applicable airworthiness

directives (AD) and safety directives including, for each,

the method of compliance, the AD or safety directive

number and revision date. If the AD or safety directive

involves recurring action, the time and date when the

next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this

chapter for each major alteration to the airframe and

currently installed engines, rotors, propellers, and

appliances.

(b) The owner or operator shall retain the following records for the

periods prescribed:

(1) The records specified in paragraph (a)(1) of this section

shall be retained until the work is repeated or superseded

by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section

shall be retained and transferred with the aircraft at the time

the aircraft is sold.

(3) A list of defects furnished to a registered owner or

operator under §43.11 of this chapter shall be retained until

the defects are repaired and the aircraft is approved for

return to service.
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(c) ** **.

Princeton requests an exemption from FAR § 91.417(a) and (b) to permit Princeton to conduct

UAS operations as proposed in this Petition without having to keep the records described in FAR

§ 91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS

operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of

safety required certain conditions and limitations. Princeton has proposed in this Petition

maintenance, inspection, and records-related conditions and limitations which it believes provide

a level of safety at least equivalent to that provided by FAR § 91.417(a) and (b). For this reason,

and consistent with the exemptions granted from this section in the Aeryon Labs Exemption and

the HYSight Technologies Exemption, Princeton requests an exemption from FAR § 91.417(a)

and (b) to permit Princeton to conduct UAS operations as proposed in this Petition, subject to the

proposed conditions and limitations, without having to keep the records described in FAR §

91.417(a) and (b).

5.4 Reasons why granting the request would be in the public interest:

A grant of the requested exemption to allow Princeton to operate these small UAS for

aerial data collection for various purposes, including aerial inspections, photography,

videography, and R&D, would be in the public interest for several reasons.

First, the use of these small UAS by Princeton for these aerial data collection purposes

will enhance R&D related to UAS and various “use cases” and applications for UAS.

Second, its use of these small UAS will provide significant new educational opportunities.

Third, Princeton’s use of these small UAS for aerial inspections, videography, and

photography would substantially mitigate, if not eliminate, any risks to personnel or manned

aircraft currently used to perform these same activities. As the FAA acknowledged in the context

of aerial surveying/inspections of infrastructure:
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“Tower and structure inspections are hazardous and present unique difficulties for

persons conducting inspections and maintenance of this infrastructure. The

inspections are normally conducted utilizing personnel to physically inspect the

tower and structure. Manned helicopters may also be used to transport inspection

personnel to the top of the tower so that a physical inspection may be conducted.

The petitioner plans to utilize a UAS to . . . minimize the need for inspectors to

personally climb such structures. Manned helicopters assisting in tower and

structure inspections can weigh 6,000 pounds or more and are operated by an

onboard pilot, in addition to other onboard crewmembers, as necessary. . . .

[U]tilizing UAS to conduct tower inspections will reduce the need for inspection

personnel to perform this hazardous activity. . . .”

LowCountryRC Exemption,8at 2-3. In sum, the aerial data collection operations proposed in this

Petition would be far less risky, and more efficient, than if conducted with larger, faster, heavier,

combustible fuel-powered manned aircraft.

Fourth, the use of small UAS under this exemption would assist, facilitate, and enhance

Princeton’s ability to gather better data, video, and photography, and thereby enable Princeton to

make more informed decisions.

Fifth, Princeton’s aerial data collection with battery-powered UAS would likely have a net

positive impact on the environment by replacing aerial surveying conducted by larger, fuelpowered, and noisier manned aircraft.

5.5 Reasons why granting the exemption would not adversely affect safety, or

how the exemption would provide a level of safety at least equal to that

provided by the rule from which exemption is sought:

Throughout this Petition, Princeton has discussed many reasons why granting an

exemption from each section of the FAR from which relief is sought would result in UAS

operations that provide a level of safety equal to, or greater than, that provided by the rule from

which exemption is sought. Moreover, the many conditions and limitations proposed in this

Petition, coupled with the operational protocols for these small UAS, also would ensure at least

an equivalent level of safety, as the FAA concluded in the Aeryon Labs Exemption, the HYSight

8

Exemption No. 11184 (February 23, 2015; Docket FAA-2014-0803).
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Technologies Exemption, the Measure Exemption, the Astraeus Exemption, the Auburn

Exemption, and the Trimble Exemption, among others.

In general, the risks of any small UAS operation proposed in this Petition interfering with

a manned aircraft would be minimized by numerous factors, including but not limited to:

 the low altitude at which the UAS would operate;

 the locations at which the UAS would operate (e.g., private or controlled-access

property; away from airports);

 the small size, light weight, and relatively slow speed of these small UAS;

 the restriction on UAS operations to VMC and daytime conditions; and

 the requirement for the UA to be operated within the VLOS of the PIC and VO at all

times.

Importantly, these small UAS have several other safety-related protocols. For example,

depending on the specific model, these UAS have lost link safety failsafe procedures; return-tohome (pilot initiated or automatically-initiated in cases of lost links or low battery power); autolanding; low-battery warning; a flight pause feature; pre- and post-flight checks; defined flight

boundaries; GPS Geofencing; and/or remote pilot features. Princeton believes that the FAA is

very familiar with the UAS models listed on attached Exhibit 1 given that these UAS models have

been the UAS designated for operations in a large number of Section 333 exemptions granted to

date, including the Measure Exemption. With respect to the Parrott AR Drone 2.0, the FAA is

familiar with Parrott-make UAS as other Parrott models have previously been designated in

Section 333 Exemptions (see, e.g., Measure Exemption). In addition, with respect to single

propeller or multi-rotor, battery-powered, small UAS developed by Princeton, its professors or its

enrolled students, the FAA has previously granted an exemption to Amazon providing similar

authority. See Amazon Exemption (granting exemption covering “Amazon-manufactured multirotor small UAS”).
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The risks to persons or property on the ground would be substantially mitigated – if not

eliminated – by these same factors, as well as the 500-foot set-off from non-participating

persons, vehicles, and structures absent additional safeguards. Per the conditions and

limitations proposed in this Petition, (i) the PIC will suspend/abort the UAS operation and UA

flight in the event of unpredicted obstacles or emergencies; and (ii) Princeton will coordinate

extensively, as warranted, with the FAA, with local airports, and with property owners to ensure

that all of its UAS operations under the exemption are at least as safe as would be manned

aircraft operations used for similar purposes.

The conditions and limitations proposed in this Petition (which have been found by the

FAA to be acceptable for other summary grant exemptions) and the operational safety features

of these small UAS provide substantial protection against interference with manned aircraft

operations and with the safety of persons or property on the ground. For these reasons, granting

an exemption from each section of the FAR from which relief is sought would not adversely affect

safety, and would provide a level of safety at least equal to, or greater than, that provided by the

rule from which exemption is sought.

5.6 Summary that can be published in Federal Register, including the rule from

which exemption is sought, and a brief description of the nature of the

exemption sought:

As explained above in Section 2, Princeton believes that good cause exists for not

publishing this Petition in the Federal Register. Nonetheless, if such publication is deemed

necessary, Princeton proposes that the FAA use the following as the summary:

Docket No.: FAA-2015-______

Petitioner: Princeton University

Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b),

61.315(a), (c)(2), and (c)(3), 91.7(a), 91.119(c) and (d)(1), 91.121, 91.151,

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).
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Description of Relief Sought: Petitioner seeks an exemption to operate small UAS

for aerial data collection, including for the purpose of aerial inspections,

videography, photography, and R&D.

5.7 Additional information that supports request:

Princeton is prepared to provide additional information that the FAA might find helpful, or

to answer questions in response to any FAA requests.

5.8 Request to exercise the privileges of the exemption outside the U.S.:

Princeton does not request to exercise the privileges of this exemption outside the United

States.

5.9 Attachments:

There are no attachments accompanying this Petition (except for Exhibit 1, list of UAS).

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EXHIBIT 1

List of Previously Approved Small UAS from the Measure Exemption
10

Attachment 1

1. 2AgEagle

2. 3D Robotics Aero-M 

3. 3D Robotics Iris 

4. 3D Robotics Iris+ 

5. 3D Robotics X8 

6. 3DRobotics Fixed Wing

7. 3DRobotics Multirotor

8. 3DRobotics Quadrotor

9. 3DR Solo

10. 3DR Spektre

11. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle

12. 3D Robotics Solo

13. 3DRobotics X8+ 

14. 3D Robotics X8-M

15. 3D Robotics Y6

16. Aerial Mob Heavy Lifter

17. Aerial Mob Light Lifter 

18. Aerial Remote Mineral Detection System (ARMDS)

19. Aerialtronics Zenith with intergrated Airware system

20. Aerialtronics Altura Zenith ATX8

21. Aerigon

22. Aerobo

23. AeroCine Kopterworx Hammer X12

24. Aeromao AeroMapper 300 25. Aeromao Talon

26. Aeromao Aeromapper 300

27. Aeromao Aeromapper EV-2

28. AeroVironment Shrike 

29. AeroVironment Puma

30. Aeronavics X4 Titanium

31. Aeryon Sky Ranger

32. Aervonics Sky Jib frame with a DJI A2 flight system 

33. Aero-M

34. Aeryon Scout

35. Aeryon SkyRanger

36. AgEagle 

37. AgEagle Robotic

38. AgScout

39. AgScout Mini

40. Agribotix Hornet Drone

41. Agribotix Enduro Quad

42. AgriView VK Ranger EX
11

43. Aibot

44. Aibotix X-6 

45. Air Rover AR-3000

46. AirCover QR-425s

47. AirRobot AR 180

48. AirRobot AR 100

49. AirRobot AR200

50. Air-X

51. Align M690

52. Altavian Nova

53. Altavian Nova F6500 

54. Altavian Nova R8400 

55. Altus X-4

56. Altus X-8

57. American Drones, LLC Eagle 

58. Apprentice

59. Arch Aerial OCTO multi-rotor UAS

60. Arris hexacoper

61. AR-960 Hex Rotor

62. AR-540 Quad Rotor

63. ARF-MikroKopter OktoXL

64. ARF-MikroKopter OktoXL + 

65. ArrowLite

66. AscTec Falcon

67. AscTec Falcon 8

68. Astraeus Aerial Cinema System V.3CS

69. Atlantic RC Aircraft LC04

70. Auburn Trimble UX5

71. Auburn War Eagle

72. Auburn EasyStar

73. Auburn

74. AV44

75. Bixler 3DR Plane

76. Blade 350QX

77. Bixler 2 

78. Boomerang Carbon Fiber Frame (The Identified System) 

79. Bormatec Maja UAV

80. BOSH Technologies Super Swiper

81. Bumblebee-S

82.C-Astral Bramor gEO

83. CarbonCore Octocopter 1000

84. Carbon Core Cortex Quadcopter

85. CCO w/Wkm M 

86. Chameleon Pro
12

87. CinesStar 

88. Cinestar 6

89. Cinestar X8

90. Cinestar 8

91. Cinestar 8 HL

92. Cinestar 8 Okto XL 

93. Coaxial Quad Multirotor VAO1-V1

94. Coaxial Quad Multirotor VAO2-V2

95. CopelandRED LLC Delta Wing Aircraft

96. CyberQuad Maxi

97. DJI Flame Wheel F450

98. DJI Flame Wheel F550

99. DAx8

100. DJI Inspire

101. DJI Inspire 1

102. DJI Inspire 2

103. DJI M P330z 

104. DJI Phantom

105. DJI Phantom 1

106. DJI Phantom 2 

107. DJI Phantom 2+

108. DJI Phantom 2 Vision

109. DJI Phantom 2 Vision+ 

110. DJI Phantom Vision + 

111. DJI Phantom 3 

112. DJI Phantom FC40 

113. DJI Spreading Wings S900 

114. DJI Spreading Wings S1000 

115. DJI Spreading Wings S1000+

116. DJI S800

117. DJI S800 EVO

118. DJI T600

119. Draganflyer Guardian

120. Draganflyer X4ES

121. Draganflyer X4P

122. Draganflyer X6

123. DT-18 

124. DYS D800-X8

125. Eagle VTOL

126. Eagle V2

127.E-Flite Apprentice

128. Event 38 E384

129.F-450

130. Falcon VTOL
13

131. Fire Fly 6

132. First Aerial Responder UAV

133. Flame Wheel G4 7.8 Skycrane 

134. Flying-Cam 3.0 SARAH

135. Foxtech Kraken 130 V2

136. FreeFly Systems ALTA RTF

137. FreeFly Systems Octocopter Airframe (Legacy)

138. G4

139. G4 models

140. GeoStar 

141. GerMAP G220

142. GerMAP G180

143. goFarm GF-1 

144. Gryphon Dynamics X8 

145. GT80X 

146. Harris 18 HL

147. HEFF

148. Helicopters West DJI Inspire

149. Helicopters West SkyJib 8 

150. Helios 960

151. Hawkeye Mk-III 

152. HexaCrafter HC-1100 85.

153. HexaCrafter HO-1250

154. HH Blade 350QX2 AP

155. Hobbyking “Bixler” Fixed Wing Trainer

156. HoneyComb AgDrone

157. Horizon Hobby Blade 350 Qx2 quadcopter

158. Hoverfly LiveSky, BigSky 60 and H-Frame

159. Hubsan X4 micro drone 

160. HVP 14301 Multi Rotor

161. Identified System

162. IMT Global xFold Cinema

163. Indago

164. InovalDrone:Inova One

165. InstantEye Mk-2

166. InstantEye Mk-2 Gen2

167. Intuitive Aerial Aeragon

168. K130 Octocopter

169. KongCopter X8

170. Kopterworx Hammer X12

171. Latitude HQ-4 Hybrid Multirotor

172. LB700 

173. Leading Edge Precision Vision 10

174. Leptron Avenger
14

175. Lewis Realty Associates Hexacopter 650

176. Liberty 1

177. Lockheed Martin Desert Hawk III

178. Lockheed Martin Indago 

179. Matrix quad copter

180. MaxFlight

181. MD4-200

182. MD4-1000

183. Mikrokopter 2.5

184. MLB Company Super Bat

185. MU-1H 

186. Multirotor G4 7.8 Skycrane

187. Nighthawk

188. Nighthawk VTOL

189. OktoXL 6S12

190. PAG X4

191. Parksone Radian RTF

192. Parrot Bebop drone

193. Parrot PF 725100 Bebop Drone 14MP

194. Parrot Skycontroller

195. Patriot X4

196. Patriot X8

197. Finwing Penguin V2

198. Birdseyeview FireFly 6

199. Phoenix

200. Phoenix VTOL 

201. Phoenix 60

202. Phoenix 60LE

203. Pixhawk

204. Precision Drone Pacesetter 205. PrecisionHawk

206. PrecisionHawk Hawkeye Mk-III

207. PrecisionHawk Lancaster

208. Precision Lancaster MK3

209. Prioria Hex

210. Prioria’s Maveric

211. Pulse Aerospace, PA 01 Vapor

212. Pulse Aerospace Pulse Vapor 35 

213. Pulse Vapor

214. Puma AE DDL

215. PV 14817 Multi Rotor

216. PV HL1

217. PV HL2

218. Q1 
15

219. Quadcopter LLC MikroKopter 

220. Quiet UAV

221. Qube

222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof. 

Multi Rotor

223. Frame Ronin Edition Microdrones:MD4-1000

224. RCTimer Hexacopter

225. RDASS

226. REHawk 500

227. REHawk 680

228. RF-70

229. Riegl RiCopter

230. RITEWING Z3 Spade 47”

231. Ritewing Drake 60”

232. RITEWING Z3 Spade 70”

233. RITEWING Z4 Spade 52”

234. RMAX

235. Roboflight

236. Rotomotion SR-15 

237. RV Jet

238. Scout X4

239. SD02

240. Seahawk 1.2 

241. SelectTech Geospacial’s EH-4

242. SenseFly eBee 

243. SenseFly eBee RTK

244. SenseFly eXom

245. Sensurion Magpie MP-1

246. Service-Drone Recon One

247. Service-Drone Blackbird

248. SH 900

249. ShadowHawk 

250. Shrike 

251. Sirius 

252. SkyCatch

253. SkyJib 8 v.2 Heavy Lifter

254. SkyPhilly MI

255. Skywalker Aero

256. Skywalker Flying Wing X8

257. SnapRoll Media SUAS

258. Solutions Phoenix 30

259. SteadiDrone

260. Steadidrone Quad 

261. Steadydrone QU4D 
16

262. Steadidrone Mavik

263. SuperX/P2 Multirotor

264. Swift Radioplanes Lynx

265. Tali 500

266. Talon 120LE

267. Tarot FY690S Hexacopter

268. Tarot quadcopter

269. Tarot 680pro

270. Tarot 690 

271. Tarot 900

272. Tarot 960

273. Tarot T-15

274. Tarot T15 C/F Folding Octocopter

275. Tarot T18 UAV 

276. Tarot T690

277. Tarot T810 

278. Tarot T960

279. Tarsier Systems MoAC

280. Tayzu Robotics Titan X8

281. TBS Discovery Pro

282. Team Black Sheep Discovery Pro Tarot T15

283.T-Rex 700E F3C 

284. TREX 800E DFC PRO

285. Trimble UX5

286. Trimble UX5 hp

287. Trimble ZX5

288. Turningy Talon 500

289. TUP X8-800

290. Turbo Ace CINEWING 6

291. TurboAce Matrix-G quadcopter

292. Turbo Ace matrix-E

293. Turbo Ace MATRIX-1

294. UAV Solutions Phoenix 60

295. Universeye Penguin 

296. Unmanned Flying Rolling Orb “UFRO”

297. US2 GreenHawk 

298. UtiliCopter ITX8

299. VA03-v1 

300. VA04-v1 

301. VA07-v1

302. Viking UAS Multicopter (VTOL)

303. Viking UAS FF-X4/X8

304. VK-Patriot X4/X8

305. Viking UAS Patriot X4/X8 Multirotor
17

306. Viking UAS X6 Model 800

307. Viking UAS Viking ONE

308. VK-450

309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX 

310. Viking VK-FF-X4

311. VK- Ranger EX- SAR Fixed Wing UAS

312. Volantex Raptor Tarot T-18

313. Volt Aerial Robotics Octane

314. Vulcan frame controlled by a DJI A2 flight controller

315. Vulcan Mantis

316. Vulcan Octocopter

317. Vulcan Raven

318. Vulcan UAV 

319. Walkera TALI H500

320. Walkera Scout X4

321. Wookong DJI 5800 

322. xCel Drones XD550CDR

323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 

Copter

324. X8-M