LA Tech UAS Operational Intentions : Aerial Data Collection Research and Education

L a Tech is expanding to include UAS aerial data imaging

, sensing, and surveying in support of

its education al and research operations

. These operations would take place with express written permission from the owner of the property for the purpose of obtaining detailed terrain and topographic imagery of land features. No operations will be conducted within five miles of any airport and t hese operations would be conducted in airspace at or below 400’ AGL . Additionally,

th e sUAS will remain within Visual Line of Sight of the Pilot in Command at all times.

We can i nsure that the combination of each platform’s lightweight, historically demonstrated flight performan ce, on board GPS system, fully qualified flight personnel, and strict operation

under the guidelines established, the FAA can have confidence that La Tech ’s operation will

have an equivalent or greater level of safety of manned aircraft performing the same missions.

Also, given the small size of the sUAS involved and the restricted controlled environment within which they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA mu st, by exemption, allow research and

educational operations of sUAS to commence immediately. D ue to the size of the sUAS and the controlled areas in which the relevant sUAS will operate, approval of the application presents no national security issue.

Th ere is a notable absence of UAS research existing throughout the south central region of the United States. Louisiana Tech recognizes this gap in national research continuity and is committed to improving the region’s contributions to this national UAS ini tiative through a multidisciplinary approach. This collaboration includes various academic areas within the College of Engineering and Science, College of Liberal Arts, and the College of Applied and Natural Sciences. With FAA support, these nationally rec ognized and award

- winning academic programs would be better equipped to promote regional and national UAS innovation.

Additionally, the Department of Professional Aviation has a strong relationship with the FAA. This relationship was created through flight training curriculum design, pilot testing, quarterly safety seminars and pilot evaluation at all levels of airmen cer tification. Therefore, department personnel will prove extremely valuable in this time of regional academic expansion. Both aviation faculty and students can learn from different academic disciplines while at the same time providing informative guidance re garding local airspace requirements, NAS operations and aviation safety.

Given the following, the grant of the requested exemptions is clearly in the public interest.The sUAS

Model 1: 3DR IRIS + The IRIS+ is a small quadcopter produced by 3D Rob otics Inc. The IRIS+ is a reliable sUAS which is controlled with the onboard Pixhawk flight controller. Flight can be guided and stabilized using GPS technology. The IRIS+ complies with the requirements set forth by Section 333 by its small size, weight, s peed, and operational proximity to airports and densely populated areas. As a result under this exemption the IRIS+ is not deemed airworthy by an airworthiness certificate, but rather it is deemed airworthy by the operator conducting a thorough preflight

i nspection of the aircraft. This aircraft will also be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of alternative marking due to the unconventional design of a quadcopter. Markings will be as large as practicable.

Aircraft Make and Model: 3D Robotics IRIS+ Configuration: Quad copter

Aircraft Performance/Specifications:

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use of a typical 2.4 GHz RC transmitter. The aircraft can also be pre

- programmed to conduct a mission through the use of a laptop or tablet via a 915 MHz telemetry link. Wh enever operations are conducted in this matter, the RC Transmitter will be able to take control of

the aircraft if the need arises.

● Lost Com: Aircraft will autonomously return to the launch location and safely land.

● Emergency Procedure: Should the need a rise the aircraft can be commanded by a switch on the RC transmitter to safely land immediately or return and land at the launch location.

● Power Supply: 3S 5.1Ah 8C Lithium Polymer Battery

● Dimensions: 550mm motor to motor

● Maximum Speed: 44 knots

● Normal operating speed: Less than 30 knots

● Weight without payload: 1282g (2.8lb)

● Weight with payload: 1656g (3.7lb)

Model 2 : Pixhawk Hexa

- copter

Aircraft Make and Model: 3D Robotics Pixhawk Hexacopter Configuration: Hexa copter

The Pixhawk Hexacopter is a six rotor hexacopter equipped with the 3D Robotics Pixhawk flight

controller. The hexacopter has upgraded Aimdroix aluminum arms and is equipped with the DJI

e8 00 tuned propulsion system. The system is equipped with GPS navigation capabilities and 2.4

GHz datalink for ground station communication. The Pixhawk Hexacopter complies with the requirements set forth by Section 333 by its small size, weight, speed, and operational proximity to airports and densely populated areas. As a result under this exemption the Pixhawk Hexacopter is not deemed airworthy by an airworthiness certificate, but rather it is deemed airworthy by the operator conducting a thorough preflight inspection of the aircraft. This aircraft will also be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFR Part 45Subpart C, and accompanied by a letter of alternative marking due to the unconventional design of a quadcopter. Markings will be as large as practicable.

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use of a typical 2.4 GHz RC transmitter. The aircraft can also be pre

- programmed to conduct a mission through the use of a laptop or tablet via a 915 MHz telemetry link . Whenever operations are conducted in this matter, the RC Transmitter will be able to take control of

the aircraft if the need arises.

● Lost Com: Aircraft will autonomously return to the launch location and safely land.

● Emergency Procedure: Should the need arise the aircraft can be commanded by a switch on the RC transmitter to safely land immediately or return and land at the launch location.

● Power Supply: 6S 2 0000mAh Lithium Polymer Battery

● Dimensions: 7 00mm motor to motor

● Ma ximum Speed: 35 knots

● Normal operating speed: Less than 30 knots

● Weight without payload: 4574 g ( 10.1 lbs)

● Weight with payload: 5254 g ( 11.5 lbs)

Model 3 : DJI Inspire 1 Aircraft Make and Model: DJI Inspire 1 Configuration: Quad copter

The DJI Inspire 1 is a four rotor quad copter equipped with an advanced flight controller and optic flow system making it extreamly safe and stable. The system is equipped with GPS navigation capabilities and 2.4 GHz datalink for ground station communicati on. The Inspire 1 complies with the requirements set forth by Section 333 by its small size, weight, speed, and operational proximity to airports and densely populated areas. As a result under this exemption

the Inspire 1 is not deemed airworthy by an airw orthiness certificate, but rather it is deemed airworthy by the operator conducting a thorough preflight inspection of the aircraft. This aircraft will also be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFR Part 45 Subpart C, an d accompanied by a letter of alternative marking due to the unconventional design of a quadcopter. Markings will be as large as practicable.

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use of a typical 2.4 GHz RC transmitter. The aircraft status and telemetry can be monitored using the DJI go app on the GCS tablet.

● Lost Com: Aircraft will autonomously return to the launch location and safely land.

● Emergency Procedure: Should the need arise the aircraft can be c ommanded by a switch on the RC transmitter to safely land immediately or return and land at the launch location.

● Power Supply: 6S 5700 mAh Lithium Polymer Battery

● Dimensions: 450 mm motor to motor

● Maximum Speed: 40 knots

● Normal operating speed: Less than 30 knots

● Weight with payload: 2935g (6.5 lbs)Model 4 : DJI Phantom 2

Aircraft Make and Model: DJI Phantom 2 Configuration: Quad copter

The DJI Phantom 2 is a four rotor quad copter equipped with the DJI Naza

- M V2 flight controller. The system is equipped with GPS navigation capabilities and 2.4 GHz datalink for ground station communication. The Phantom 2 complies with the requirements set forth by Section 333 by its small size, weight, speed, and operational proximity to airports and densely populated areas. As a result under this exemption the Phantom 2 is not deemed airworthy by an airworthiness certificate, but rather it is deemed airworthy by the operator conducting a thorough preflight inspection of the aircraft. Thi s aircraft will also be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of alternative marking due to the unconventional design of a quadcopter. Markings will be as large as practica ble.

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use of a typical 2.4 GHz RC transmitter. The aircraft can also be pre

- programmed to conduct a mission through the use of a laptop or tablet via a 2.4 GHz data link . Whenever operations are conducted in this matter, the RC Transmitter will be able to take control of

the aircraft if the need arises.

● Lost Com: Aircraft will autonomously return to the launch location and safely land.

● Emergency Procedure: Should the n eed arise the aircraft can be commanded by a switch on the RC transmitter to safely land immediately or return and land at the launch location.

● Power Supply: 3S 52 00mAh Lithium Polymer Battery

● Dimensions: 3 50mm motor to motor

● Maximum Speed: 35 knots

● No rmal operating speed: Less than 30 knots

● Weight with payload: 1242g (2.7 lbs)

Aircraft manuals and operations checklist will be included as additional information to this petition for exemption.

Mandatory Operating Conditions, Limitations, and Procedures

La Tech proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations and procedures provide for an exceptional level of safety to oper ations. These limitations and

conditions to which La Tech agrees to be bound when conducting research and educational operations under an FAA issued exemption including:

1. The sUAS will weigh less than 55 lbs.

2. The sUAS, depending on the model in operation, will have a maximum operating speed
of no more than 50mph.

3. Flights will be operated within Visual Line of Sight (VLOS) f operator.4. Maximum total flight time for each operational flight will be 30 minutes or less

. 5. Flights will be terminated at 20% battery p ower reserve.

6. Flights will be operated at an altitude of no more than 400 feet AGL

7. sUAS operator will be trained and certified in the proper safety and operations of the

sUAS.

8. Minimum crew for each operation will consist of the sUAS Pilot and at least one Visual
Observer (VO), and may include a third, but separate, Camera Operator (CO).

9. The operator will post an advisory notice at the controlled area.

10. The operator will have been trained in operation of sUAS generally and received up

- to

date information on t he particular sUAS to be operated as required.

11. A safety briefing will be performed prior to each day’s flights consisting of all the days’
flight activities.

12. The flights will occur in Class G airspace no closer than a 5 mile radius of the geographic
center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

13. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate
governmental agencies as appropriate to flight operations.

14. If the sUAS loses communications with the remote controller or loses GPS signal, the

sUAS will have the c apability to return to a predetermined location within a designated
location and land autonomously.

15. The sUAS will have the capability to abort a flight in case of emergencies with an

automated “Return Home and Land” function.

16. The sUAS will have the capabil ity to abort a flight in case of unpredicted obstacles,
weather, or emergencies such as low battery.

17. Operations shall not occur over congested, activ ely, or densely populated areas

. 18. Permission from land owner is required before commencing any flight.

19. Ope rations will only occur during Visual Flight Rules Meteorological Conditions
(VMC).

20. The sUAS will remain clear of manned aircraft and yield right of way.

21. A flight test will be conducted after any major repair or alteration.

22. A preflight check will be con ducted before each flight to assure airworthiness.

23. Operations will be limited to daylight hours.

Public Interest

The proposed sUAS operations in this petition provide an “equivalent level of safety” if not a safer alternative to manned remote sensing operations. The sUAS do not carry persons onboard, they do not contain combustible fuel sources, and are less expensive to operate than manned platforms. Because they are battery powered, the sUAS do not contribute harmful emissions to the atmosphere. These sUAS attributes will benefit the public as a whole when performing remote sensing operations.The name and contact information of t he applicant:

Wesley Palmer Louisiana Tech University

P.O. Box 10138 Ruston, LA 71272 (318) 257

- 4985 wpalmer@latech.edu

Regulations from which the exemption is requested are as follows and described fully in Appendix A:

14 CFR Part 21 14 CFR 45.23(b)

14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103(b)(2)

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a) (1) 14 CFR 409(a) (2) 14 CFR 417(a) & (b)

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and is prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if

additional informati on or clarifications are needed.

Sincerely,

Wesley Palmer Louisiana Tech University

Attachments: 3DR_ IRIS_Plus_Operations_Manual.pdf 3DR_Pixhawk_Hexacopter_Operations_Manual.pdf DJI_Inspire_ 1

_ Operations_Manual .pdf DJI_Phantom_2_Operations_Manual.pdf

Appendices: A. Exemption Request and Equivalent Level of SafetyAppendix A EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

La Tech requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of its sUAS.

14 CFR Part 21, Subpart H: Airworthiness Certificates Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airwor thiness certificates as required by FAR §91.203(a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety unde r Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, w eight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder i s less than 55 lbs fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a controlled area as set out in the Procedures. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Procedures requirements. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its si ze, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry

a substantial external load.

14 CFR § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the Roma n capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, c ockpit, 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 applicable. Even though the sUAS will have no airworthiness certificate, an exem ption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29(f). The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29(f) where the operator working with the sUAS will see the identification of the sUAS as "Experimental." Th e FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and

10167 A14 CFR §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Pr ocedures for maintenance and use of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9(b) (2) provides: No person may operate a U.S.

- reg istered civil aircraft ... (2) for which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings , and placards, or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry suc h an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the operator flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this r egulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103(b): Preflight action This regulation requires that each pilot in command shall, before beginning a flight, become

familiar with all available information concerning that flight. This information must include

— (b) for any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information.

As FAA approved rotorcraft flight manuals will no t be provided for the aircraft and because runways are not needed for takeoff and landing operations, an exemption will be needed. An equivalent level of safety will be provided as set forth in Procedures. The operator will take all actions including revie wing weather, flight battery requirements, landing and takeoff locations and aircraft performance data before initiation of flight.

14 CFR §91.109: Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned fr ee balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use o f a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemp tion Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.14 CFR §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Procedures, the sUAS will never operate at higher than 400 AGL. The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. In addition, the low

- altitude operations of the sUAS will ensure separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altime ter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Procedures and Operation Manual , confirming

the altitude of the launch site shown on the GPS altitude indi cator before flight.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from beginning "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." The battery powering the sUAS pr ovides approximately 40 minutes of powered flight or less depending on the model . To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of pr ior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the sUAS, in a tightly controlled area, with less than 30 minutes of reserve fuel, does not engender the type of risks th at Section 91.151(a) was intended to alleviate given the size and speed of the sUAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 20 % of battery

power whichever happens first. This restriction would be more than adequate to return the sUAS

to its planned landing zone from anywhere in its limited operating area. Similar exemp tions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR §91.203(a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in § 91 .7 15, no person may operate a civil aircraft unless it has within itthe following: (1) an appropriate and current airworthiness certificate ... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than

55 lbs and is operated without an on board pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground cont rol point where the operator flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9 565, 9665, 9789, 9789A, 9797, 9797A, 9816A,

and 10700.

14 CFR §91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpa rt E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter... ," and others shall inspect or maintain the aircraft in compliance with P art 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Procedures. An equivalent level of safety will be achieved because these sUAS are very limited in size and will carry a small payload and operate only in controlled areas for limited periods of time. If

mechanical issues arise the sUAS ca n land immediately and will be operating from no higher than 400 feet AGL. As provided in the Procedures, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H; 14 CFR 45.23(b); 14 CFR §§ 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.409(a) (2) & 91.417(a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) for the purpose of inspection, monitoring, mapping and photographing attac hed equipment and engineering studies involving communication towers, wind turbine tower facilities and power transmission tower operations. Approval of exemptions allowing commercial operations of sUASs will create a level of safety by reducing risk. Conv entional aerial imaging and associated tasks involve risks to personnel and/or utilizing low flying manned aircraft both of which create potential risks to such personnel. In contrast, a sUAS weighing fewer than 55 lbs and powered by batteries eliminates v irtually all of that risk. The sUAS will carry no passengers or crew and, therefore, will not expose personnel to any of the risks described above. The operation of a sUAS, weighing less than 55 lbs, conducted in the strict conditions outlined above, will provide a level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground , and in a controlled environment.