Michael Wing AIS Lab Director Peavy Hall280 Oregon State University Corvallis, OR 97331 Michael.Wing@OregonState.edu 541.737.4009

October26, 2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590 Dear U.S. Department ofTransportation, 

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This petition is fortheAerial Information System (AIS) Lab at Oregon State University (OSU) for a Summary Grantof Exemption Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012. The Exemptions sought are in reference to CFRs and will be identified in a section below. The AIS Lab seeks to operate small unmanned aircraft systems (UAS) for collecting remotely sensed imagery in support of its research, education, and outreach missions. The FAA has already issued Exemption Grants to otheracademic institutionsforthese same objectives and forthe proposed platforms described in this request. AIS Lab Description The AIS Lab is housed within OSU. OSU is a public research university in Corvallis, Oregon. OSU has over 200 undergraduate and graduate degree programs and is classified bythe Carnegie Foundation as a research university, with very high research activity. The AIS Lab conducts UAS research in avariety ofdisciplines including project and construction '!'anagement inspections and monitoring, environmental review projects, aerial surveying, agricultural projects, educational and research projects, remote sensing projects, wildlife and forestry monitoring projects, search and rescue, and otherfields. Proposed Operations The AIS Lab proposes to use thefollowing platforms in seeking an Exemption Pursuantto Section 333: Aerialtronics Altura Zenith (ATX8 and STR8), DJI Phantom 2Vision, DJI S900, DJI S1000, DJI Phantom 3, and 3DR Solo. The FAA has granted Exemptions to otheracademic entities for UAS operations: Exemption No. 13157to the University ofWyoming to conduct educational research; Exemption No. 11552 to Sinclair Community College to conduct educational research and training (Docket No. FAA-2015-0374); and

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Exemption No. 11304to Auburn UniversityAviation Centerto conducttraining courses to instruct students in the operation of unmanned aircraftand theirassociated systems. (Docket No. FAA-2014-1014); '

Previous FAA Exemptions Each ofthe platforms proposed in this Exemption request have been granted previous Exemptions Pursuant to Section 333 bythe FAA based on the platform weight, speed, and operational characteristics: AerialtronicsAltura ZenithATXS, STRS: Exemption 12655toJonathan Adams DJI Phantom 2**Vision-~:-:** Exemption No. 11228to Steven Zeets DJI Phantom 3: Exemption No. 13203to Matthew D. Gambill DJI 5900: Exemption No.11305to Scott Hess DJI 51000: Exemption No. 11305 to Scott Hess 3DR Solo: Exemption No. 11935to Patricia A. Lines

In grantingthese previous Exemptions, the FAA has found that each ofthese platforms shared the following characteristics:
• Weight is less than 55 pounds including payload. • The ability ofthe UAS to operate safely after experiencing in-flight contingencies orfailures, and the presence ofan auto-pilotto maintainflight stability and control. The UAS is also ableto respond to a loss ofGPS ora lost-link event with a pre-coordinated, predictable, automated flight maneuver. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation and mitigate the risk of command and control link failures. • Communication and control radio frequencies comply with the Federal Communications Commission (FCC} and other appropriate government oversight agency requirements. • The maximum speed ofthe platforms is 87 knots or less.

Public Benefit The AIS Lab conducts research in avariety ofdisciplines. Public benefit ofthe UAS operations proposed in this Exemption request includes the following societal benefits:
• Worker safety is emphasized as UAS operations can reduce or eliminate field measurements. There are significant risks to workers in the construction and structural inspection industries that can be alleviated by UAS. • Manned flights pose risks to pilots. • Greater image resolution can be obtained from UAS mounted sensors in comparison to manned aircraftas UAS are able to fly slower and

### ciO'S~rtothe ground. Increased image resolution allows for more robust analysis which can lead to increases in agricultural and forest productivity. • Search and rescue operations can be conducted in areas that might be ordinarily be inaccessible. • UAS are more cost effective than manned aerial platforms.


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### Reasons why the exemption would notadversely affect safety or howthe exemption would provide a level ofsafetyat leastequaltothe existing rules. 

### 1. The UAS platforms weigh less than 25 pounds, including payload; 2. Flights will be operated within the visual line ofsight ofthe pilot; 3. Maximum total flight time for each operational flight will be (45) minutes. Flight times may**~e** 

### less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return tothe ground station with at least 10% battery power reserved; 4. Flights will be operated at an altitude not greater than 400 feet AGL; 5. Minimum crewfor each operation will consist ofthe UAS pilot and aVisual Observer; 6. A briefingwill be conducted daily by all personnel working with said UAS; 7. Written and/ororal permission from relative property owners will be obtained prior to operatingthe UAS; 8. All permits, permissions, etc. will be obtained from local government offices as required; 9. The UAS will operate at speeds less than 

### 8 7 knots, hover and simultaneously move verticallyand horizontally; 

### 10. The UAS will have the capability to return and land at the pre-determined location with the Security Perimeter should the UAS lose communication or GPS signal during any operations; 

### 11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 

### 12. Operations will not be conducted over densely populated areas or heavily traffic highways; and 

### 13. Operationswill notbe conductedwithinfive (5) NM ofan airportorheliport without permission ofthe airportor heliport.

Exemptions Soughtfrom CFRs The AIS Lab requests Exemptionsfrom the following CFRs: 1. 91.9(b)(2), 91.203(a) and (b): Carrying Aircraft Flight Manual, Certification and Registration in the Aircraft Given the small size ofthe proposed UAS platforms, OSU requests thatthese materials be kept in the vicinityofthe ground control station duringflight. 2. 91.7(a): Civil Aircraft Airworthiness The AIS Lab requests that no Airworthiness Certificate be required. 3. 91.9(c), 45.23(b), and 45.27(a): Aircraft Marking and Identification Requirements



### 3The AIS Lab requests that proposed platforms bear registration numbersthatare as large as practical in accordance with platform size. 4. 61.23{a) and (c), 61.113, 61.101(e){4) and (5), 61.315: Private, Recreational and Sport Pilot Medical Certificate, Privileges and Limitations The AIS labseeks an exemption from these CFRs as they prevent private, recreational orsportpilot certificate holders from receiving payfor piloting duties. The UAS platforms in this petition will not carry passengers orcargo, and the FAA has previously ruled (Exemption No. 11062) thata Commercial Pilot Certificate is not required for UAS operations outside ofcontrolled airspace. 5. 91.405{a), 91.407(a){l), 91.409{a)(1) and {2); 91.417(a) and (b): Maintenance Inspections r The AIS Lab seeks exemptions to these CFRs as they are intended for aircraftthat have an airworthiness certificate. The AIS Lab will ensure that all UAS platforms and components have an adequate maintenance and inspection schedule. 6. 91.121: AltimeterSettings The AIS labseeks an exemption from the requirement thata pilot maintains aflight level through reference to an altimeter. The FAA has previously stated that equivalentfunctionality can be achieved when flights occur ator below400feet AGL and when GPS elevation data can be transmitted in real timeto a ground control station, given that a PIC establishes GPS elevation accuracy on-the-ground prior to every flight. 7. 91.151(a): Fuel Requirements for Flight in VFR Conditions The AIS Lab seeks an exemption from the requirement thatfuel reserves duringVFR require that no less than 30 minutes offuel be maintained duringthe day and 45 minutes during the night. Given that the platforms in this petition generally have a 30 minute or less flight time, no meaningful flights would occur under 91.151(a). Exemption No. 11213 determined that an equivalent level ofsafety is evident in UAS flights where the operational flighttime can be achieved with an additionalfive minutes offlight time being available in fuel reserves.

Please feel free to contact ouroffice should you have any additional questionsorcomments. Thankyou foryourcooperation withthis matter. Sincerely,



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Michael Wing AIS lab Director



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