Michael Wing 

AIS !-ab Director 

Peavy Hall 280 

Oregon State University 

Corvallis, OR 97331· 

Michaei.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 

~- --- --wasfiln~on, oc 2os9o 

Dear U.s .. Department of Tra~sportation, 

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 ~ab 0£lSCription 

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 

management, 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 51000, 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. F.I\A-2015-0374); and ·· ' · · · · !:.: 

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Exemption No. 11304 to Aub~•rn University Aviation Center 'to :conduct training courses tb 

instruct students in the operation of unmanned afrcraft and ~heir assriciat~d systems. (D'otket 

No. FAA-2014-1014); ... · . . i·: . .; · · · · ,: .. · 

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Previous FAA E~emptiohs· · .•. ,· .; ,··:; 

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, STR8: Exemption .12655 to Jonathan Adams 

DJI Phantom 2 Vision+: E)(emption .No. 11228 to Steven Zeets · '· 

DJI Phantom 3: Exemption No. 13203 to Matthew D. G~mbill 

-~---· . -----·-·-· __ DJI S9PO;,J~_!jon N.J>__,.J1JOS_ic;>_S_!:.9tLHess ~ _ ...... . 

DJJ SiOOO:Exemption No. 11305 to Scott H~s'$ ~ --.. 

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 .ss pounds including payload. . . . .. 

• The ability ot'the UAS t6 operate safely afterexperiencing ;~~flight contingenCies or fail~res,'and 

the presence of an auto-pilot to maintain flight stability and control. The 'uAS is.alst> able to 

•: 'respond to a loss ofGPS or a Jbst-link 'event with a pre-coordinated, predittable, autotl1ated 

flight maneuver. These safety features provide an equivalent level of safet'{corripared to a 

manned aircraft performing a similar operation and mitigat!Hhe risk ofcommand 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 Jess. 

Public Benefit 

Th~_A.IS_I,.aJ:u;pndu.ctsre.s.earch iQa variety _Qf discipljnes.--PJ.!Qii£ bertefit_Qf.thl:! t.J.AS Qpe~:_ati_gns prqposed 

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 constr'uction 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 ~omparison t~ manned 

aircraft as UAS are able to fly slower and closer.tothe ground. Increased 1mage resolu:•~n allows 

for more robust analysis which can lead to increases in agricult~ral and ~o~~~t ~ro:uc~IVIty;. - . . . . 

Search and rescue operations can be conducted in areas that m1ght be or manly e 

inaccessible. 

UAS are more cost effective than manned aerial platforms . • 

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Reasons why the exemptipn would not adversely affe,ct safe~y or how the exemption would 

providea level of safety at least equafto tlje existing rules. . . . 

. r \The UASpiatforms V>leigh 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 be 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 pe'rsonnelworking with said UAS; 

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

prior to operating the UAS; 

8. P:lt permits, permissions, etc. will be ob~ain~d from h;>ca) government offices a~ 

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 atthe pr;e-determined location 

with the Security Perimeter should the UAS lose communication on GPS. signal 

during any operations; . . 

11. The UAS will have the capability to abort a flight iri: case of -~np:re'ditted, obstacles - .• ': : \ ' " . ' • <' : : ',, ; . ··: . ~.'' '. .'· ... : ; . : . ·- :. J j ' :· . ' •'.' <' :_. • ... '- I '"' ; ~ I " ,j ' 

_.or.emergenc1es; .... ... . ·.· ,•,.;,,,,,._., .. .•. · 

12. Operations will not be cor:td.ucted over denseJy poplJI~t~d areas or heavily traffic ..... • •. ... .• ' [ .· .. • ., . •'· l' .• . . • 

highways;and , . . .. · ..... 

· 13. Operations will not be conduc~ed within five.(S) NM.of an qirport 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 U,l\5 platforms, OSU requests thaqhese materials be kept in the 

vicinity of the ground control statior:1 during flight. • .· .. , . 

2. 91.7(a): Civil Aircraft.Airworthiness 

: I~ "j • ... , -.' :: ' \!. ' l ' ' ' 

The AIS ~ab requeststhat no Airwqrthiness Certificate be requirE:ld. :,· .... ' 

3. 91.9(c}, 45.23(b), a~d 45.27(a): Aircraft Marking an~}pentification Reqyirements. 

' ,. !.:: 

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.. '•',) ( 

The AIS lab requests that proposed piatformsbear registration numbers that a~e as large a~ 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. 91.40S(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections 

The AIS Lab seeks exemptions to these CFRs as they are intended for aircraft that have an airworthiness 

~"'==~__,~=-~~~~rl;:;'fi~m-~ ·wilf e~fUAS pratt~~n:Js aridcomponents ha~e an ·adequate . ··cc·· ~~~ ~'~~~=··~~- . 

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 .l!nder 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 of flight 

time being available in fuel reserves. 

__ _RleaseJeeLfr~e tQ_CQ.J:!li!~J:J.~have_any~U:iQnaLques:ti.aJls.-gr~omments. Ihank you-- ">~:' -'~ - .... --__ ...:, 

for your cooperation with this matter. 

Sincerely, 

~~ Michael Wing ,. J 

AIS Lab Director 

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