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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 CONDITIONS 

This pel.ition seeks authority to conduct flight operations with each of UMKC's small unmanned 

~ircr~ft. subject to the follO\Ying proposed conditions: 

o None of the Petitioner's uEm:>.nned airc raft (UA). including p::l) load. \\ ill exceed 55 

lbs. 

5211 Rockhill Road I Kansas City, MO 64110 

Universit of Missouri-Kansas Cit 
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 of manmade 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. 
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:s 
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: 
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 a secondclass 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. 
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. 

PUBUC INTEREST 
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.