# October 30, 2015 Vice

Chancellor for Research and Economic Development 

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

# RE: University
of Missouri-Kansas City Petition for Exemption Pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012 Dear Sir or Madam: Pursuant
to Section 333 of the FAA Modernization and Reform Act of2012 and 14 C.F.R

. Pa1t 11, the University
of Missouri-Kansas City ("UMKC"
or "Petitioner") hereby applies for an exemption from the Federal Aviation Regulations identified below, to the extent necessary
to allow UMKC
to operate small u1m1anned aircraft systems (UAS) for aerial data collection

in support of its research and educational operations. UMKC seeks to operate the following vehicles: UMKC 800mm X8 Octocopter, UMKC 500mm Quadcopter

, DJI Inspire Series

, DJI Phantom Series, DJI Spreading Wings Series, and the 3D Robotics X8 Octocopter. UMKC submits this petition for exemption from 14 C.F.R.

§ 45.23(b)

, 14 C .F.R

. § 45.27, 14 C

. F

. R. 

# § 61.113, etc. INTkODUCTION The University
of Missouri-Kansas City is a public institution
of higher education located
in Kansas City, Missouri. The university

is made up of approximately 16,000 students, and has over 50 majors or programs and over 125 academic areas. For three years in a row the Princeton Review has named UMKC as a Best Value College, and is currently the only Best Value College in Kansas City. As UMKC continues

to improve both its education and research,

it seeks to take advantage
of urunmmed aircraft systems (UAS) to support both education and research activities. From structural inspection
to improved flight control development, these systems will enable UMKC to provide groundbreaking research, top quality education, and cost-effective UAS applications for the community. PROPOSED FLIGHT OPERATIONS AND CONDIT

I ONS This pel.ition seeks authority
to conduct flight operations with
e ach of UMKC's small unmanned **~ircr~ft.** 

# subject to the follO\Ying proposed conditions: o 

# None of the Petitioner's uEm:>.nned airc
r a ft (UA). inclu
d ing p::l) load.

\ \ ill exceed 55 lbs.

5211 Rockhill Road



# I Kansas City, MO 64110 

# Universit
of Missouri-Kansas

Cit2 • The Petitioner will not operate any UA at speeds exceeding
87 knots (1 00 mph). • The petitioner will not operate
at night. • The petitioner will not operate any UA at altitudes exceeding 400 feet AGL. • The petitioner's flight operations will be such that the aircraft remains within visual line of site of the pilot-in-command (PIC) at all times. • The Petitioner's small UAS will be operated only by a PIC who holds at least
a sport pilot, recreational pilot, or private pilot airman certificate and a corresponding airman medical certificate
or U.S. driver's license. • The Petitioner's small UAS operations will employ

a visual observer, who will be able to communicate orally with the PIC at all times during operations. • All of the Petitioner's small unmanned aircraft systems will be maintained and inspected
to ensure proper condition. Additionally, prior to each flight operation,

a pre-flight inspection will be conducted. • Petitioner will operate within

5 nautical miles of an airport only with an altitude ceiling equal to the specific structure
to be inspected. • All of the Petitioner's flight operations will be recorded into aircraft specific logbooks. The primary objective of the Petitioner's proposed flight operations

is for inspection
ofmanmade structures. Inspection operations will be primarily conducted on closed (with Department of Transportation personnel) bridges
in rural Missouri. Inspections consist of collected aerial imaging
in real-time and identifying areas in need of further inspection.

In pursuit of this objective, many flight operations will be conducted with
a powered tether. The tether provides both increased flight duration
as well as increased operational safety by anchoring the vehicle near the structure
to be inspected.

1 UMKC AIRCRAFTS AND SECTION 333 APPLICABILITY UMKC's proposed operations

in this petition qualify for 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 similar circumstances

in all aspects of those presented
in this petition. The vehicles UMKC intends to use for the proposed operations
all meet the requirements

of Section 333 of the Reform Act due to their weight, speed, and operational capabilities. UMKC intends to operate the following proprietary vehicles: • UMKC 800mm X8 Octocopter. The UMKC X8 is a battery powered multirotor UAS with eight motors configured

in a quadrotor shape (four motors on top, four motors on bottom). The leightweight frame measures approximately 800mm
in diameter and is composed
of carbon fiber. The vehicle utilizes an off-the-shelf autopilot (DJI NAZA M V2 and DJI NAZA A2) capable of return-to-home
and autonomous landing functions
in the presence of loss of communication. The vehicle has a maximum takeoff weight of 20 lbs, and has
a maximum operating speed of approximately

35 mph. The vehicle
is capable of flying with
a 6S 16.000mAh Lithium polymer battery (provides
15 minutes of flight time) or \Yith
a 300 ft ground tether (provides

8 hours of flight time). The UAS operates on a control frequency of2.4 GHz.

### 3 • UMKC 500mm Quadcopter. The UMKC 500mm quadcopter

is a battery powered multirotor UAS with four motors. The lightweight frame measures 500mm
in diameter, and is composed
of aluminum, carbon fiber, and plastic. Similar
to the UMKC X8 vehicle, the 500mm quadcopter utilizes the off-the-shelf autopilot (DJI NAZA M V2) capable of autonomous return-to-home
and landing functions

in the presence of loss of communication. Additionally,

a custom autopilot will be used with the 500mm quadcopter; however, during any custom autopilot flight operations the vehicle will be tethered
to the ground with
a tether length not exceeding 1OOft. The custom autopilot will be used for the development and testing of higher performance control and guidance algorithms.

If any unexpected anomaly occurs in flight, the abort sequence will be initiated, thereby disabling

all motors. UMKC intends to operate the following commercial off-the-shelf vehicles for the proposed operations:
• DJI Inspire Series, DJI Phantom Series, and DJI Spreading Wing Series. The FAA has previously issued grants of exemption authorizing use of the DJI Inspire series, DJI Phantom series, and the DJI Spreading Wings series UAS to perform aerial data collection. For example, see Exemption No. 11804 issued to Orbic Air, LLC (Docket No. FAA-2015-0413). • 3D Robotics X8. The FAA has previously issued grants of exemption authorizing use of this vehicle for aerial data collection. For example, see Exemption NO. 11446 to Trumbull Unmanned, LLC (Docket No. FAA-2015-0890)
and Exemption No. 11433 to Cape Productions, Inc. (Docket No. FAA-2015-0223). 

# I REGULATIONS FROM WHICH EXEMPTION

IS BEING SOUGHT UMKC seeks an exemption from several interrelated provisions
of 14 C.F.R. Parts 45, 61, and 91 for purposes of conducting the requested operations using small unmanned aircraft systems, including: FAR Description 91.9(c), 45.23(b), and Aircraft Marking and Identification Requirements 45.27(a) 91.405(a), 91.407(a)(1), Maintenance and Inspection Requirements 91.409(a)(1) and (2), 91.417(a) and (b) 61.23(a) and (c), 61.113, Private, Recreational, and Sport Pilot Privileges, Limitations, 61.101(e)(4) and (5), and Medical Certificate 61.315 91.7(a)

Civil Aircraft Airworthiness 91.9(b)(2),

91

. 203(3)



# I C3rrying Aircraft Flight Manual, Certification, and 311d (b) Re2:istration

in the Aircraft 91.119(c)



## I Minimum Safe Altitudes OYer Other Than Con2:ested Areas 91.121



## I Altimeter Setting:s4 

### 91.151(a)

Fuel Requirements
for Flight in VFR Conditions Listed below are the specific regulations and the operating procedures and safeguards that UMKC has established which will ensure

a level of safety better than or equal to the rules from which exemption

is sought. 1. 91.9(c), 45.23(b), and 45.27: Aircraft Marking and Identification Requirements • 14 C.F.R.

§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard Requirements, states that: No person may operate

a U.S.-registered civil aircraft unless that aircraft

1s identified

in accordance with Part 45 of this chapter. • 14 C.F.R

§ 45.23(b), Markings ofthe Aircraft, states: When marks include only Roman capital letter "N" and the registration number

is displayed on limited, restricted
or light-sport category aircraft or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance
to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than
6 inches high, the words "limited," "restricted," "light-sport," "experimental,"

or "provisional,"

as **appl~cable.** 

### • 14 C.F.R

§ 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally
on both surfaces of the cabin, fuselage, boom, or tail the marks required by§ 45.23. In prior grants of exemption under Section 333 of the Reform Act, the FAA determined that exemption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings

in accordance with 14 C.F.R. Part 34, Subpart
C if the markings are as large as practicable." All UAS flown by UMKC will bear N-number markings that are as large as practicable

in accordance with 14 C.F.R Part 45, Subpart C. 2. 91.405(a), 91.407(a), 91.409(a)(1) and (2), 91.417(a) and (b): Inspections and Maintenance UMKC seeks an exemption from the maintenance and inspection requirements contained

in 14 C.F.R.

§ 91.405(a), 91.407(a)(1), 91.409(a)(l) and (2), 91.417(a) and (b). An exemption from these regulations

is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, \Yhich the UAS to be operated under this petition \Yill not have. An cquiYalent leYel of **s::~f~ty** 

### \Yill be :::chieved by:5 • performing preventative and required maintenance
on each aircraft
as per the owner's manuals. • inspection
of all UAS before and after each flight, to ensure that the UAS is in a condition for safe flight. • performing functional test flights following the replacement

of any flight-critical components. • noting any and all maintenance

in the UAS aircraft maintenance log. 3. 61.23(a) and (c), 61.113, 61.101 (e)( 4) and (5), 61.315: Private, Recreational, and Sport Pilot Privileges, Limitations, and Medical Certificate UMKC seeks exemption from these sections, which restrict private, recreational

or sport pilot certificate holders from flying aircraft for compensation

or hire, and would also require

asecondclass medical certificate.
In the Grant of Exemption No. 11062 to Astraeus Aerial (FAA Docket No. FAA-2014-0352),

the FAA determined that the unique characteristics

of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have

a Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment
of the additional requirements
for a commercial pilot to be considered qualified for UAS operations would not lead to any benefits compared
to a private pilot. The restrictions the Petitioner has placed on its UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial and other operations

in more recently granted exemptions. UMKC will operate away from persons and property that are not the subjects of the flight **operatio~.** Research and educational flight operations will only be conducted with
a PIC who has logged flight time in the specific make and model UAS.



# I 4. 91.7(a): Civil Aircraft Airworthiness UMKC seeks exemption from 14 C.F.R

§ 91.7(a), which requires that
a civil aircraft be in an airworthy condition

to be operated. The FAA has determined that for the purposes of this exemption, the pilot may determine whether the aircraft
is in a condition safe for flight. 5. 91.9(b)(2), 91.203(a) and (b): Carrying Civil Aircraft Flight Manual, Certification, and Registration

in the Aircraft Title 14 C.F.R.

§ 91.9(b)(2) and § 91.203(a) and (b) require the operator
to carry airworthiness documents and other aircraft manuals onboard the aircraft. Given the small size and configuration

of the UAS,
it would be impossible

to keep airworthiness documents and other aircraft manuals on board the UAS. In a FAA officer of Chief Counsel's Opinion dated August
8, 2014, and prepared by Dean E. Griffith,

it was ackJ10\Yledged that the intent of 14 C.F

. R. 

### § 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmam1ed aircraft has access to the UAS flight manual. registration. certificate, and other required docunLntation from the gr0t:!1d controls st::tion (see FAA Docket No.FAA2014-0352). An cqui"l·:llcnt le\-cl of satcty \Vill be **~,chiewd** by ensuring the PIC has access to o.ll documentation

at the :;round contml station for the **p:~rticular** UAS he or she is operating.6 6. 91.119(c): Minimum Safe Altitudes Over Other Than Congested Areas 14 C.F .R. § 91.119( c) establishes minimum altitudes for operation of civil aircraft. UMKC seeks exemption from this regulation, because flight operations under this exemption will be conducted below 400 feet AGL. Additionally, due to the nature of the proposed operations, the PIC and/or Observers may need to be less than 500 feet away from the UAS. Given the size, weight, speed, and lack of fuel on board the U AS, the level of safety for flight operations will meet exceed those resulting from 91.119( c)
. 7. 91.121

: Altimeter Settings UMKC seeks exemption from 14 C.F.R.



### § 91.121, which requires

a person operating an aircraft to maintain cruising altitude

or flight level by reference
to an altimeter that is set to the elevation of the departure airport or barometric pressure. The FAA has stated that an equivalent level of safety to the requirements

of 14 C.F .R. 

### § 91.121 can be achieved
in circumstances where: the UAS will be operated
at or below 400 feet AGL, within visual line of sight, where GPS based altitude information

is relayed in real time to the operator
at the ground control station, and where prior to each flight,

a zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS (see Exemption No. 11062 to Astraeus Aerial, FAA Docket No. FAA-2014-0352).
The vehicles proposed
in this exemption relay GPS based information

to the PIC and will be operated below 400 feet AGL within visual line of sight. Prior to takeoff, the home location will be zero for the current altitude, in order to ensure ftC Curacy of the on board sensors. 

# I 8. 91.151(a): Fuel Requirements
for Flight in VFR Conditions 14 C.F.R.



### § 91.151(a) 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. UMKC seeks exemption from this regulation
as battery limitations typically do not provide even a 30 minute flight time with fully charged batteries (for multirotor UAS). The FAA has previously granted relief from the fuel requirements

in daytime VFR operations
in circumstances similar to those presented
in this petition (Exemption No. 8811, 10673, and 10808). In Exemption No. 11213 to Aeryon Labs, Inc (FAA Docket No. FAA-2014-0642),

the FAA dete;·mined th:1t for a given flight opci:ation.

it is recommended

to have enough available power to conduct the operation \Yith at least five **i~1inutes** or more of reserve pO\YCL If this condition were met, an equal level of safety to the fuel requirements of§ 91.151(a)

\\

· auld be satisfied

. P U BUC INTEREST7 The flight operations proposed
in this petition will have significant impact on society. First, safety for a variety of applications will be substantially increased. Particularly forinspectionrelated operations, the proposed exemption will reduce the necessity for inspection crews to be in harms way. Additionally,
the methodology and techniques developed

at UMKC will enable inspection
of more structures, increasing the overall infrastructure safety throughout the nation. Beyond increasing crew safety and infrastructure integrity, the public will benefit from the educational and research programs supported by the proposed operations

in this petition. This includes guidance strategies, proven inspection techniques, and aircraft research and development. The hands-on training students will acquire will also greatly increase the number of qualified unmanned aircraft personnel who can continue the safe UAS transition into the National Airspace. FEDERAL REGISTER SUMMARY UMKC seeks exemption from the following rules in Title 14 of the Code of Federal Regulations: 91.9( c), 45.23(b

), 45.27(a), 91.405(a), 91.407(a)(l

), 91.409(a)(l) and (2), 91.417(a) and (b), 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315, 91.7(a), 91.9(b)(2), 91.203(a) and (b), 91.119(c), 91.121, 91.151(a). The exemption will enhance safety by reducing risk to the general public and inspection workers associated with traditional inspection techniques (via both manned aircraft!rotorcraft
and human 

### ~isual inspection). Additionally,
the exemption will! permit both university education and research programs
to maintain safe airspace during the UAS transition into the National Airspace. This petition will grant UMKC the capability

to perform research and educational flight operations with small, lightweight unmanned aircraft systems
to improve both the safety and capabilities
of aerial data collection activities. Should you have any question, please do not hesitate to contact me.