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 ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE**~-** 

# ----**-wasfiln~on,** 

# oc 2os9o
Dear 

### U.s

.. Departmentof**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 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 insupport ofits 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 tothe University of Wyoming to conduct educational research;

.. Exemption No. 11552 to Sinclair Community College to conduct educational researchand
· training (Docket No. F.I\A-2015-0374); and ·· ' · · · · !:.:



### 1Exemption No. 11304to

### Aub~•rn UniversityAviation Center

## 'to :conduct training courses 

## tb instruct students in the operation of unmanned afrcraftand

### ~heir**assriciat~d** systems. (D'otket No. FAA-2014-1014);

...· . . 

### i·:
. .; · · · · ,: .. · 1!' 

### Previous FAA**E~emptiohs·** 

### · .•. ,· .; ,··:; Each ofthe platformsproposed 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 toSteven 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 ofthese 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 ofan auto-pilot to maintain flight stability and control. The

### 'uAS is.alst> able to •: 'respondto

# a loss ofGPS ora Jbst-link 'event with a pre-coordinated, predittable, autotl1ated flight maneuver. These safety features provide an equivalent level ofsafet'{corripared to a manned aircraft performing a similar operation and mitigat!Hhe 

## risk ofcommandand control linkfailures. · · .•. ; • 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 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 mountedsensorsin

## ~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 effectivethan manned aerial platforms

. 

# • 2

### Reasons why the exemptipn would not adversely affe,ct**safe~y** 

### or how the exemption would providealevel ofsafety atleast equaftotlje existing rules.
. . .


# . r \The UASpiatforms V>leigh less than 25 pounds, including payload; 

### 2. Flights will be operated within the visual line of sight ofthe 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 stationwith 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 ofthe UAS pilot and a Visual Observer; 6. A briefing will be conducted daily by all pe'rsonnelworking withsaid 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 

# aflight 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** 

### withinfive.(S) 

## NM.ofan qirportor heliport without permission ofthe airport or heliport.**-~** } . ,' '' ·, ', 

### Exemptions Soughtfrom CFRs The AIS lab requests Exemptions from thefollowing 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 ofthe 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): AircraftMarking

## an~}pentification Reqyirements.

' ,. !.:: 

### 3.. '•',) (

The AIS lab requeststhat 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 ofcontrolled 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 intendedfor aircraft that have an airworthiness**1~"'==~__,~=-~~~~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 aflight 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 thatfuel reserves during VFR require that no less than 30 minutes offuel be maintained during the dayand 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 ofsafety is evident in UAS flights where the operational flight time can be achieved with an additional five minutes offlight timebeing available in fuel reserves.

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

### - ....--__ ...:, foryour cooperation with this matter.
Sincerely,

# ~~ Michael Wing ,. 

# J AIS Lab Director

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