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University of Kentucky 

Dr. Suzanne Weaver Smith 

Department of Mechanical Engineering 

151 RG Anderson Bldg 

Lexington, KY 40506-0503 

 

U.S. Department of Transportation 

Docket Operations 

1200 New Jersey Ave., SE 

Washington, DC 20590 

 

Re: Petition for Exemption and Relief from Specific Regulations of Title 14 of the Code 

of Federal Regulations pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (Public Law 112-95) Regarding Commercial Employment of 

Unmanned Aircraft Systems (UAS). 

Appendix A. “UAS Descriptions” (manuals available upon request) 

Appendix B. “Procedural and Flight Operational Standards” 

 

Dear Sir/Madam, 

 

Pursuant to Section 333 of Public Law 112-95 commonly known as the “FAA Modernization and 

Reform Act of 2012” or “The Reform Act,” the University of Kentucky hereby applies for 

authorization to conduct commercial unmanned aerial systems (UAS) operations within the United 

States National Airspace System (NAS) for the purpose of research, education, and UAS platform 

development. 

 

Federal Register Summary 

Pursuance to 14 CFR § 11.81, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

 

The University of Kentucky seeks exemption from 14 CFR Part 21, Subpart H; 14 CFR Part 

27; 14 CFR 45.23(a)(b); 14 CFR 61.113(a)(b); 14 CFR 61.133(a)(i)(ii); 14 CFR 91.7(a); 14 CFR 

91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (a)(2); 14 CFR 

91.417(a)(b) to allow commercial employment of Unmanned Aerial Systems (UAS) in 

support of research, education and UAS platform development in the areas of agricultural, 

transportation, natural resources and atmospheric sciences, among others. These 

exemptions will enhance safety by reducing risk to the general public and property owners 

from the substantial hazards associated with performing equivalent work with conventional 

aircraft and rotorcraft. 

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INTRODUCTION AND INTEREST OF THE PETTIONER 

 The use of Unmanned Aircraft Systems (UAS) in the United States is increasing at an 

exponential rate. These small, unmanned aircraft are being employed for a variety of purposes 

including agricultural research and assessment, natural resource research and surveying, disaster 

prevention and response, and environmental assessment and compliance. UAS have the potential to 

be an indispensable tool for aerial data collection.1 The use of UAS for these tasks is highly cost 

efficient and environmentally friendly, also reducing the risk to human pilots, crew, and observers. 

The University of Kentucky (UK) is seeking to use UAS to further develop new and existing UAS 

platforms and advance the tools for aerial data collection and analysis. To achieve its goals, UK 

must engage in domestic UAS operations for research, education, and training purposes. The UAS 

will be operating in areas owned, controlled, or operated by UK and other areas where UK has the 

owner/operator’s permission provided that all regulations are met. The use of UAS has provided a 

cost effective and time efficient way of collecting information that has previously only been available 

through manned flight. UK’s goals can be achieved through the use of UAS providing reduced cost, 

risk, and environmental impact. 

 This Petition is entirely in accordance with exemptions previously granted by the FAA, most 

notably Duke University Marine Laboratory, Exemption No. 12656 and the University of Maine, 

Exemption No. 14279. 

 

OVERVIEW CHARACTERISTICS OF PROPOSED UAS 

 The University of Kentucky will operate a variety of UAS as listed in “UAS Description” 

(see Appendix A). All UAS listed in Appendix A. have been previously approved for use by the FAA 

in similar exemptions. The principle construction materials for these UAS airframes are EPO foam, 

carbon fiber, aluminum and/or plastic, or equivalent lightweight materials with an all up weight 

(AUW) no greater than 55lbs. The listed UAS are powered by a lithium polymer batteries that drive 

brushless electric motors. The listed UAS will limit maximum flight time to no greater than 100 

minutes with operating speed no greater than 100 miles per hour. The pilot in command (PIC) will 

typically communicate with the UAS with a 2.4 ghz remote control radio and a 915mhz data 

telemetry radio connected to a ground control (GC) computer, or similar. 

 

As an added level of safety the UAS aircraft will have several failsafe systems in place: 

• In the event of the loss of remote control (unlikely due to visual line of sight (VLOS) 

operations under 400ft) the UAS will perform a “return to home” command. 

• In the event of the loss of ground control connection (unlikely due to VLOS operations 

under 400ft) the UAS will perform “return to home” command. 

• In the event of a low battery (less than 20%) the UAS will perform a “return to home” 

command. 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UAS. Examples 

include imagery (photo, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical 

measurement (particulate measurement), or any other gathering of data by instrument(s) aboard the UAS. See approved 

exemptions with similar UAS: #11845, #11804, #11823, #11837, #12084, #12457, #12696, #13288, #11755, #12646 
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QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

 The proposed operations of this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors 

are satisfied. 

 

 The proposed operations in “Procedural and Flight Operational Standards” (Appendix B) 

would permit the use of small and relatively inexpensive UAS under controlled conditions in 

airspace that is: (1) limited; (2) predetermined; (3) away from populated areas; (4) would provide an 

increased level of safety beyond that existing when fixed or rotor wing aircraft are used to 

accomplish the same purpose. 

 

 Operations will be performed by a qualified UAS Pilot in Command (PIC), to insure that the 

UAS will “not create a hazard to users of the national airspace system or the public.” Given the 

small size of the UAS involved and the pre-planned environment within which they will operate, the 

applicant believes that these operations fall squarely within that zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UAS to commence immediately. Also, due to the size of the UAS and the predefined, 

restricted area in which the UAS will operate, approval of the application presents no national 

security issue. The operation of UAS by knowledgeable professionals will serve to enhance safety, 

add to the public benefit, and reduce environmental impacts related to current methods of manned 

aircraft flight operations. 

 

 Research and training in UAS platform and operations development provides the public 

with educational and informative tools to assist them in moving forward in an increasingly 

technological society. 

 

SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS 

EXEMPTION OR RELIEF

14 CFR Part 21, Subpart H – Airworthiness Certificates 

The FAA has stated that no exemption is needed from this section if a finding is made under Part 11 

and Section 333 of the Reform Act that the UAS selected provides an equivalent level of safety 

when compared to civil aircraft normally used for the same application. The petitioner submits that 

given the small size of the UAS, the limited operating areas and procedures defined within the 

training and operations section of the petition, an equivalent level of safety is obtained and 

exemption is not required (see Grant of Exemption to Astraeus Aerial, Docket No. FAA-20140352). 

If however, the FAA determines that there are some characteristics of the chosen UAS that fail to 

meet the requirements of the Reform Act, an exemption is requested. 

14 CFR Part 27 – Airworthiness Standards: Normal Category Rotorcraft 

14 CFR Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent petitioner’s UAS would otherwise require certification under Part 
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27, petitioner seeks exemption for the same reasons identified in the request for exemption from 14 

CFR Part 21, Subpart H. 

14 CFR § 45.23 (a)(b) and 91.9(c) – Marking of the Aircraft 

Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the 

Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. 

Each suffix letting used in the marks displayed must also be a Roman capital letter. (b) When marks include only 

the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-sport category 

aircraft or experimental or provisionally certified aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, 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. 

 

Regulation 91.9(c) provides: No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with part 45 of this chapter. 

 

The UAS has no entrance to the cabin, cockpit, or pilot station on which to place markings. The 

size of the UAS prevents the two-inch lettering from being possible. The FAA has previously 

granted exemption to these requirements provided that the aircraft “have identification (N-Number) 

markings in accordance with 14 CFR Part 45, Subpart C if the markings are as large as practicable.” 

Petitioner additionally proposes to keep required markings, flight envelope restrictions, cautionary 

notices, and other documents easily visible at the UAS Ground Control Station. The FAA has 

issued several exemptions to this regulation: see Duke University Exemption No. 12656, and see 

Exemptions Nos. 8738, 10167, 10167A, 10700, and 14279. 

 

14 CFR § 91.9(b)(2) – Aircraft Flight Manual in the Aircraft 

Regulation 91.9 stipulates (b) No person may operate a U.S.-registered 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 Aircraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof. 

The size of the UAS prevents the ability to carry a flight manual on board the aircraft. However, 

keeping a flight manual on at the Ground Control Station will provide a parallel level of safety. The 

pilot will have immediate access to the flight manual. The FAA has issued several exemptions to 

this regulation: see Duke University Exemption No. 12656, and see Exemptions Nos. 8607, 8737, 

8738, 9299, 9565, 10167, 10602, 32827, 10700, and 14279. 

 

14 CFR § 61.113 (a)(b) and 61.133(a)(i)(ii) – Private and Commercial Pilot Privilege and 

Limitations 

Regulation 61.113 stipulates (a) Except as provided in paragraphs (b) through (h) of this section, no person who 

holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for 
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compensation or hire; nor may that persons, for compensation or hire, act as pilot in command of an aircraft. (b) A 

private pilot may, for compensation or hire, act as a pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. 

Regulation 61.133 stipulates (a) Privileges—(1) General. A person who holds a commercial pilot certificate may 

act as pilot in command of an aircraft—(i) carrying persons or property for compensation or hire, provided that the 

person is qualified in accordance with this part and with the applicable parts of this chapter that apply to the 

operation; and (ii) For compensation or hire, provided the person is qualified in accordance with this party and with 

the applicable parts of this chapter that apply to the operation. 

The UAS does not carry a pilot, passengers, or cargo. Due to the size, weight, speed, operating 

environment, and operating capabilities of the UAS, an equivalent level of safety will be obtained by 

stipulating that the UAS PIC hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, 

or the Federal Government. The PIC must also meet the flight review requirements specified in 14 

CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. The FAA has 

issued several exemptions to this regulation: see Duke University Exemption No. 12656, and see 

Exemptions Nos. 11284, 11281, 11282, 11296, 14279, and 14279. 

 

14 CFR § 91.7(a) – Civil Aircraft Airworthiness 

Regulation 91.7 stipulates (a) No person may operate a civil aircraft unless it is an airworthy condition. 

With no current regulatory standard for the airworthiness of a UAS, a parallel level of safety will be 

obtained by ensuring compliance with UAS operator and maintenance manuals and safety checklists 

prior to each flight. 

 

14 CFR § 91.121 – Altimeter Settings 

Regulation 91.121 requires that (a) each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating – (1) below 18,000 

feet MSL, to – (i) the current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; (ii) if there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or (iii) in the case of an aircraft not equipped with a 

radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 

Typically, conventional aircraft use a local barometric pressure to set the barometric altimeter, which 

gives a reading in accordance with the MSL (Mean Sea Level). Since UAS operations are performed 

in reference to ground level calculations (no greater than 400 feet above ground level (AGL)), a 

more accurate reading would require the barometric altimeter set to zero prior to takeoff, thus 

providing the AGL altitude readout. If the UAS does not have a barometric sensor, a GPS derived 

altitude similarly set to zero at the takeoff point will provide an equivalent level of safety. The FAA 

has granted several exemptions to this regulation: see Duke University Exemption No. 12656, and 

see Exemptions Nos. 11066, 11065, 11062, 11063, and 14279. 
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14 CFR § 91.151 (a) – Fuel Requirements for Flight in VFR Conditions 

Regulation 91.151 stipulates that (a) No person may begin 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 after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, and assuming normal cruising speed to fly after that for at least 20 minutes. 

This regulation, based on the capabilities of traditional civil aircraft, would effectively deny any 

ability for the UAS to operate. With typical flight times of an hour or less, Petitioner submits that an 

equivalent level of safety would be provided by requiring that no UAS flight will begin unless there 

is enough fuel (battery) to fly the planned route to the first point of intended landing and land with 

25% of battery capacity in reserve. This would allow for more than enough battery life for the UAS 

to return to its planned landing zone from anywhere in its limited operating area. The FAA has 

issued several exemptions to this regulation: see Duke University Exemption No. 12656, and see 

Exemptions Nos. 2689F, 5745, 10673, 10808, and 14279. 

 

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) – Maintenance Inspections 

Regulation 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in 

Subpart 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...” Regulation 91.407(a)(1) similarly makes 

reference to requirements in Part 43. Regulation 91.409(a)(2) requires an annual inspection for the issuance of an 

airworthiness certificate. Regulation 91.417(a) and (b) requires the owner or operator to keep records showing 

certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

 

Exemption from these sections is required because Part 43 and these sections apply only to aircraft 

with an airworthiness certificate. Requiring that each UAS have a flight log and standard operating 

procedures will achieve an equivalent level of safety insuring that inspections will be accomplished in 

accordance with manufacturer recommendations. The FAA has issued several exemptions to this 

regulation: see Duke University Exemption No. 12656, and see Exemption Nos. 11066, 11062, 

11067A, 11065, and 14279. 

 

14 CFR § 91.103 – Preflight Action 

Regulation 91.103 stipulates Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include—(a) for a flight under IFR or a flight not 

in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight 

cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; (b) For 

any flight, runaway lengths at airports of intended use, and the following takeoff and landing distance information: (1) 

For civil aircraft for which an approval Airplane or Rotorcraft Flight Manual containing takeoff and landing distance 

data is required, takeoff and landing distance data contained therein; and (2) For civil aircraft other than those 

specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft 
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performance under expected values of airport elevations and runaway slope, aircraft gross weight, and wind and 

temperature. 

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. Because FAA-approved UAS flight manuals will not be provided for the aircraft, an 

exemption will be needed. An equivalent level of safety will be achieved as the PIC will take separate 

preflight actions, including checking the condition of the UAS, flight battery requirements, weather 

conditions, takeoff and landing distances, as specified in Appendix B “Procedural and Flight 

Operational Standards”. 

 

 

14 CFR § 91.109 – Flight Instruction 

Regulation 91.109 stipulates, in part, that (a) No person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

By their design, UAS do not have fully functioning dual controls. Flight control is accomplished 

through the use of a control interface that communicates with the aircraft via radio. Given the size, 

speed, and limited operational parameters of the UAS, an equivalent level of safe training can be 

performed without dual controls. The FAA has issued several exemptions to this regulation: see 

Duke University Exemption No. 12656, and see Exemptions Nos. 11066, 11062, 11067A, 11065, 

and 14279. 

14 CFR § 91.119 – Minimum Safe Altitudes 

Regulation 91.119 stipulates, in part, that Except when necessary for takeoff or landing, no person may operate 

an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area 

of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 

500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. 

An exemption from this regulation is required because UAS operations will be conducted at altitudes 

no higher than 400 feet above ground level. The size, speed, weight, and limited operational 

parameters of the UAS allow for an equivalent level of safety. 
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WHY GRANTING THIS PETITION IS IN THE PUBLIC INTEREST 

 As stated above, the requested exemption would authorize the Applicant to perform 

commercial operations with UAS that will provide significant benefits to the public interest: 

 

1. The commercial use of UAS at the University of Kentucky – in support of government 

entities, private institutions, scientific studies and resource monitoring – to perform research 

in areas including agriculture, transportation, natural resources, atmospheric sciences and 

educational activities, all of which are critical to the well-being of the general public. 

2. A significant reduction in costs to conduct research, training, and education programs. At 

present, our agricultural research programs that use aerial surveys can cost tens of thousands 

of dollars per day. By incorporating UAS into these programs we can incur significant 

savings and more efficiently conduct research in the public interest. 

3. The use of UAS will decrease congestion in the National Airspace System along with 

reducing noise and air pollution generated during traditional manned aircraft flight 

operations. 

4. When using UAS to complement field personnel, they reduce safety concerns when 

gathering data from inaccessible or unstable/unsafe areas and in extreme weather or terrain.

5. Operation of UAS will substantially reduce the risk to life and property in the air, and on the 

ground, which is commonly associated with traditional manned aircraft flight operations for 

agricultural science missions. 

6. Similar to the current manned aircraft flight operations in agricultural sciences, geography 

and transportation that have been conducted for many decades, UAS used for similar tasks 

will not generate any new privacy issues.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform 

Act to “establish requirements for the safe operation of such aircraft systems in the national 

airspace system.” Approval of this exemption will allow for safe, more efficient and less costly 

agriculture science missions, and produce much higher data quality. 

 

PRIVACY 

 

The proposed operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. The University of Kentucky will not conduct flight operations over 

property that it does not own or control without the prior consent and knowledge of the 

property owner. 
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SUMMARY OF REGULATIONS FORM WHICH PETITIONER SEEKS EXEMPTION 

OR RELIEF 

14 CFR Part 21, Subpart H 

14 CFR Part 27 

14 CFR 45.23(a)(b) 

14 CFR 61.113(a)(b) 

14 CFR 61.133(a)(i)(ii) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2)(c) 

14 CFR 91.103 

14 CFR 91.109(a) 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.405(a) 

14 CFR 91.407(a)(1) 

14 CFR 91.409(a)(1) and (a)(2) 

14 CFR 91.417(a)(b) 
Appendix A 

 UAS Descriptions 

UAS Name * UAS Type UAS approved 

Exemptions 

DJI S1000+ Rotorcraft #13039 

DJI Phantom 3 Pro Rotorcraft #13024 

DJI Phantom 2 Rotorcraft #13030 

DJI Inspire 1 Rotorcraft #12905 

3DR SOLO Rotorcraft #11935 

3DR X8 Rotorcraft #12084 

Tarot X6 W/DJI Rotorcraft #13288 

Trimble UX5 Fixed Wing #12457 

Skywalker X8/Pixhawk Fixed Wing #11755 

Aeryon Scout Rotorcraft #11447B 

* Manuals available upon request. 

  

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Appendix B. 

Procedural and Flight Operational Standards 

As the operator of these aircraft, the University of Kentucky is committed to the following 

procedural and flight operational conditions and limitations. 

1. Operations are limited to the UAS listed in the Appendix when weighing less than 55 pounds 

including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are not permitted. 

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case 

will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed 

recommended by the aircraft manufacturer. 

4. The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UAS will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) at all 

times. This will require the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s U.S. driver’s license. 

6. All operations will utilize a visual observer (VO). The aircraft will be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. 

7. All operating documents needed to operate the UAS and will be accessible during UAS 

operations and made available to the Administrator upon request. The operator will also present 

updated and revised documents if it petitions for extension or amendment. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight 

prior to conducting further operations. Flight tests will be conducted by a PIC with VO and will 

remain 500 feet from non-participating parties. 

9. The University of Kentucky is responsible for maintaining and inspecting the UAS to ensure that 

it is in a condition for safe operation. 

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. 

11. The University of Kentucky will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption will comply with all manufacturer safety bulletins. 

13. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. 

driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, 

or the Federal government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
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14. The University of Kentucky will not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated to 

acquire aerial data, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency will be logged in a manner consistent with 14 CFR § 61.51(b). The University of 

Kentucky will operate flights for the purposes of training PICs and VOs (training, proficiency, 

and experience building) and determining the PIC’s ability to safely operate the UAS. 

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). 

16. The UAS will not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, 

the center of the airport symbol as denoted on the current FAA-published aeronautical chart, 

unless a letter of agreement with that airport’s management is obtained or otherwise permitted by 

a COA. 

17. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UAS will return to a predetermined 

location. 

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power or fuel for the aircraft to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power or fuel 

recommended by the manufacturer if greater. 

21. All operations shall be conducted in accordance with an ATO-issued COA if the blanket COA 

does not cover the intended operation. 

22. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR 

part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings will be as large as practicable. 

23. Documents used by the University of Kentucky to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC 

at the Ground Control Station of the UAS any time the aircraft is operating. 

24. The aircraft will remain clear and give way to all manned aviation operations and activities at all 

times. 

25. The UAS will not be operated by the PIC from any moving device or vehicle. 

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the aircraft or debris in the event of an accident; or 
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b. The owner/controller/operator of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made an assessment of the 

risk of operating closer to those objects and determined that it does not present an undue 

hazard. 

27. The PIC, VO, operator trainees or essential persons will not be considered nonparticipating 

persons under this exemption. 

28. All operations conducted over private or controlled-access property will be conducted with the 

permission from the property owner/controller or authorized representative. Permission from 

property owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.