Michael Wing 

AIS Lab Director 

Peavy Hall280 

Oregon State University 

Corvallis, OR 97331 

Michael.Wing@OregonState.edu 

541.737.4009 

October 26, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear U.S. Department of Transportation, 

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This petition is for the Aerial Information System (AIS) Lab at Oregon State University (OSU) for a 

Summary Grant of Exemption Pursuant to Section 333 of the 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 other academic institutions for these same objectives 

and for the 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 by the Carnegie Foundation as a 

research university, with very high research activity. 

The AIS Lab conducts UAS research in a variety of disciplines 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 other fields. 

Proposed Operations 

The AIS Lab proposes to use the following platforms in seeking an Exemption Pursuant to Section 333: 

Aerialtronics Altura Zenith (ATX8 and STR8), DJI Phantom 2 Vision, DJI S900, DJI S1000, DJI Phantom 3, 

and 3DR Solo. The FAA has granted Exemptions to other academic entities for UAS operations: 

Exemption No. 13157 to the University of Wyoming 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. 11304 to Auburn University Aviation Center to conduct training courses to 

instruct students in the operation of unmanned aircraft and their associated systems. (Docket 

No. FAA-2014-1014); ' 

Previous FAA Exemptions 

Each of the platforms proposed in this Exemption request have been granted previous Exemptions 

Pursuant to Section 333 by the FAA based on the platform weight, speed, and operational 

characteristics: 

Aerialtronics Altura Zenith ATXS, STRS: Exemption 12655 to Jonathan Adams 

DJI Phantom 2 Vision-~:-: Exemption No. 11228 to Steven Zeets 

DJI Phantom 3: Exemption No. 13203 to Matthew D. Gambill 

DJI 5900: Exemption No.11305 to Scott Hess 

DJI 51000: Exemption No. 11305 to Scott Hess 

3DR Solo: Exemption No. 11935 to Patricia A. Lines 

In granting these previous Exemptions, the FAA has found that each of these platforms shared the 

following characteristics: 

• Weight is less than 55 pounds including payload. 

• The ability of the UAS to operate safely after experiencing in-flight contingencies or failures, and 

the presence of an auto-pilot to maintain flight stability and control. The UAS is also able to 

respond to a loss of GPS or a lost-link event with a pre-coordinated, predictable, automated 

flight maneuver. These safety features provide an equivalent level of safety 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 of the platforms is 87 knots or less. 

Public Benefit 

The AIS Lab conducts research in a variety of disciplines. Public benefit of the 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 

aircraft as UAS are able to fly slower and ciO'S~r to the 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 not adversely affect safety or how the exemption would 

provide a level of safety at least equal to the existing rules. 

1. The UAS platforms weigh less than 25 pounds, including payload; 

2. Flights will be operated within the visual line of sight of the 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 to the 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 crew for each operation will consist of the UAS pilot and a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said UAS; 

7. Written and/or oral permission from relative property owners will be obtained 

prior to operating the 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 vertically and 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. Operations will not be conducted within five (5) NM of an airport or heliport 

without permission of the airport or heliport. 

Exemptions Sought from CFRs 

The AIS Lab requests Exemptions from 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 of the proposed UAS platforms, OSU requests that these materials be kept in the 

vicinity of the ground control station during flight. 

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 

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The AIS Lab requests that proposed platforms bear registration numbers that are 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 lab seeks an exemption from these CFRs as they prevent private, recreational or sport pilot 

certificate holders from receiving pay for piloting duties. The UAS platforms in this petition will not carry 

passengers or cargo, and the FAA has previously ruled (Exemption No. 11062) that a Commercial Pilot 

Certificate is not required for UAS operations outside of controlled 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 aircraft that 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: Altimeter Settings 

The AIS lab seeks an exemption from the requirement that a pilot maintains a flight level through 

reference to an altimeter. The FAA has previously stated that equivalent functionality can be achieved 

when flights occur at or below 400 feet AGL and when GPS elevation data can be transmitted in real 

time to 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 that fuel reserves during VFR require that no less 

than 30 minutes of fuel be maintained during the 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 of safety is evident in 

UAS flights where the operational flight time can be achieved with an additional five minutes offlight 

time being available in fuel reserves. 

Please feel free to contact our office should you have any additional questions or comments. Thank you 

for your cooperation with this matter. 

Sincerely, 

%M~ Michael Wing 

AIS lab Director 

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