1

Cyber Communications and Technology College of Agriculture and Life Sciences

1140 E South Campus Dr

. University of Arizona 85721

U.S. Department of Transportation Docket Operations 1200 New Jersey Ave., SE Washington, DC 20590 Dec 2

, 2015

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 1012 (Public Law 112

- ­­95) Regarding Commercial Employment of Unmanned Aircraft Systems (UAS)

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

Arizona hereby applies for authorizatio n 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

Pursuant to 14 CFR §11.81, the followin g summary is provided for publication in the Federal Register, should it be determined that publication is needed:

The University of Arizona seeks exemption from 14 CFR Part 21, Subpart H; 14 CFR Part 27;

14 CFR 45.23(b); 14 CFR 61.113(a)(b); 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 91.203(a)(b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 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 agriculture, water management, and

environmental science.

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

from the substant ial hazards associated with performing equivalent work with conventional

aircraft and rotorcraft.2

The name and address of the applicant is:

Cody Sheehy Cyber Communications and Technology College of Agriculture and Life

Sciences

1140 E South Campus Dr

. University of Arizona 85721

Signed:3 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airmen

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012, Section 333 SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer4 INTRODUCTION AND INTEREST OF THE PETITIONER

The use of small unmanned aerial systems (sUAS) in terrestrial commercial and science applications is now widespread and transforming agricultural assessments, environmental compliance regimes and spatial ecological science. These devices are used regularl y to reduce costs, increase safety and boost knowledge of key agricultural parameters, to assess progress and environmental compliance in mining operations and occasionally to study the terrestrial habitats and aggregations of wildlife [3]. The use of these aerial platforms to capture images for educational us e is also growing.

The University of Arizona, Cyber Communications and Technology Department is developing a UAS program to 1) help meet the growing educational needs of agricultural and environmental scientists seeking to use sUAS in agricultural and

wildland areas and; 2) to support sUAS

- ­­based research in agricultural and wildland areas nationally and interna tionally. To achieve these goals, our research program must engage in domestic sUAS operations for research, education and training purposes. Due to the nature of our work, these flights will occur predominantly in remote areas, away from human act ivities and often exclusively over desert s, grassland s, or forests . UAS are developing as a legitimate and robust means of conducting research that heretofore have been possible only from manned aircraft. Such traditional survey techniques are expensive, incur substantial risk to p ersonnel and produce lower quality data. Our work addresses these issues through agricultural science UAS applications to the benefit of society at large.

OVERVIEW CHARACTERISTICS OF PROPOSED UAS

United States Registration : T0056331

UA Manufacturer or Builder : DJI sUA Model Designation : M odel T600

sUA Serial Number W13DCC30030503

Class Rotorcraft sUA Maximum Takeoff Weight 2935 g Category Land

Name of Engine Manufacturer DJI Engine Model Designation DJI 3510 Engine Serial

- Numbers none Number of Engines 4 Engine Power Output 1600 g/axis Engine Type Electric5 QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations in 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 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 sa fety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

The UAS's planned to be operated are roto rcraft a nd always less than 55 lbs., includin g payload. They would operate, under normal conditions, at a speed of no more than 50 knots. The principal construction material of the UAS aircraft would typically be foam, carbon fiber, aluminum and/or plastic. Operations will be performed by a qualifie d UAS Pilot in Command (PIC), as outlined below, 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 ope rate, 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 pre

- ­­defined, 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. These limitations and conditions to which the operator, or its employees, acting as UAS PIC agrees to be bound when conducting commercial operations under a FAA issued exemption:

1. Operations authorized by this grant of exemption are limited to the following

aircraft: DJI Inspire 1

2. UA (aircraft and payload) will weigh less than 55lbs.

3. UA will be operated at altitudes not greater than 2 00 feet AGL. Altitudes reported to ATC will be in feet AGL.

4. UA will be flown at ground speeds not greater than 50 knots.6

5. The UAS PIC will hold either an airline transport, commercial, priva te, 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 recent flight experience requirement stated in 14 CFR § 61.57 and flight review requirements stated in 14 CFR § 61.56.

The University of Arizona employs a full

- ­­time instrument rated co mmercial pilot.

6. In addition to holding an FAA issued airman certificate, UAS PIC must complete a University of Arizona UAS Training Program. This training will include detailed review of manufacturer operating manuals and practical de monstration of ability to safely operate UAS in a manner consistent with how the UAS will be operated under this exemption (to include evasive and emergency maneuvers and maintaining appropriate distances from persons, vehicles, vessels and structures). PI C qualification will have a currency requirement of at least three

take

- ­­offs and landings within the preceding 90 days. PIC qualification flight hours will be logged in a manner consistent with 14 CFR § 61.51.

7. UA will not be operated within 5 nautical mi les (NM) of an airport having an operational control tower, or 3 NM of an airport with a published instrument flight procedure but not an operational control tower, or 2 NM of an airport without a published instrument flight procedure or operational contro l tower, or 2 NM of a heliport with a published instrument flight procedure. Flights will be operated in Class G airspace whenever possible. If operation in other airspace is required, the relevant controlling agency will be notified at least 24 hours prio r to the operation and, if required, any necessary permission obtained

8. UAS flights will operate within visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR).

9. UAS operations will not be conducted during night, as defined within 14 CFR §

1.1.

10. UA flights over land will not be operated by the PIC from any moving vehicle or device. UA flights conducted entirely over water may be operated from a

suitable vessel.

11. UA will not be operated from a raised platform.

12. The UA will remain clear of and yield right of way to manned aviation operations.

13. UA will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use human vision unaided by device other than corrective lenses as specified on P IC’s FAA medical certificate.

14. UAS operations will employ a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC maintains VLOS capability. The7 VO and PIC must be able to communicate verbally for the duration of the flight. Electronic messaging or texting is not allowed during flight operations.

15. The VO will perform no duties other than assisting the PIC see and avoid other aircraft, obstacles, per sons or property.

16. UAS will be equipped with an autopilot system which will be at least equivalent

to a DJI Inspire system. The UAS will utilize GPS navigation, failsafe’s, return

- ­­to

- ­­ home (RTH) and flight abort safety features.

17. Prior to ea ch flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. Checklists developed from manufacturer operating documents will be the basis for this inspection. If the inspection reveals a condition that affects safe operation of t he UAS, the aircraft is prohibited from operating until necessary maintenance has been performed and the UAS is found to be in a safe condition for flight. The Ground Control Station must be included in the preflight inspection.

18. All UAS operations will be conducted over remote and sparsely populated property or over open waters. Permission for flight will be obtained in advance from property owners or controlling agency. A Ground Station will be connected, by radio communication, to the UAS during the entire flight, which will give the PIC flight information such as GPS Position, Altitude, Air speed, Battery Remaining, and other telemetry information.

19. Flight boundaries will be established for each flight and such boundaries will be designed such that the UA will pass no closer than 500 feet from nonparticipating persons, vehicles or structures.

20. If the UAS loses communications or loses GPS signal, the UA will return to a predetermined location within the established flight boundary a nd land or be recovered in accordance with manufacturer operations documents.

21. The PIC will abort any flight in the event of unpredicted obstacles, occurrence of adverse weather or loss of UAS flight control capability in accordance with manufacturer operat ions documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast conditions) there is enough power to fly the planned route to the intended landing point and land the UAS with 25% of battery capacity remaining.

23. Documents required by 14 CFR § 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS whenever the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

24. Before conducting flight operations, the radio frequency spectrum used for operation and control of the UA must comply with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.8

25. A Flight Operations and Maintenance Log will be maintained for each UAS. Cumulative flight hours, maintenance activities, repairs, alterations and inspections will be noted.

26. Any UAS maintenance or alterations that affect UAS operation or flight

characteris tics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the Flight Operations and Maintenance Log.

SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS EXEMPTION OR RELEIF

14 CFR Part 21, Subpart H

– Airworthiness Certificates and 14 CFR § 91.203(a)(1)

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 are as 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

- ­­2014

- ­­0352). If however, the FAA

det ermines 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 r equirements for airworthiness certification of normal category rotorcraft. To the extent petitioner’s UAS would otherwise require certification under Part 27, petitioner seeks exemption for the same reasons identified in the request for exemption from 14 C FR 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 letter used in the marks displayed must a lso 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 certificated 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 w ords “limited,” “restricted,” “light

- ­­sport,” “experimental,” or “provisional,” as applicable.9

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 markings can be placed. Given the small size of the UAS, two

- ­­inch lettering will not be possible. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted 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 practic able.” The petitioner additionally proposes to place all required markings, placards, flight envelope restrictions, cautionary notices in an easily visible location at the UAS Ground Control Station. The FAA has issued several exemptions to this regulation : see Exemptions Nos. 8738, 10167, 10167A and 10700.

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 Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combinat ion thereof.

Given the size of the UAS, they have no place or ability to carry a flight manual aboard the aircraft. An equivalent level of safety will be achieved by keeping the flight manual at the Ground Control Station where the pilot operating the UAS will have immediate access to it. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 10167, 10602, 32827 and 10700.

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 propert y for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as 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

—10

(i) Carrying persons or property for compensation or hire, provided 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 i n accordance with this part and with the applicable parts of this chapter that apply to the operation.

Unlike a conventional aircraft that carry pilot, passengers and cargo, the proposed UAS are remotely controlled and carry no persons or cargo. The UAS a re capable of a high degree of flight automation and employ technical capabilities that limit the potential for operation in an unintended manner. It is the petitioner’s belief that given the size, weight, speed, operating environment and operating capabil ities of the UAS, an equivalent level of safety may be obtained by stipulating the UAS PIC must 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 Colombia, 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 Exemptions Nos. 11284, 11281, 11282 and 11296.

14 CFR § 91.7(a)

– Civil Aircraft Airworthiness

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

Should this exemption be granted allowing commercial operation of UAS without an airworthiness certificate, no FAA regulatory standard will exist for airworthiness of the UAS. An equivalent 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 set ting 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) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.11

Conventional aircraft are provided altitude data by a barometric altimeter that is m ost commonly set to a local barometric pressure and therefore reports altitude relative to MSL (Mean Sea Level). UAS operations are restricted to altitudes no greater than 400 feet AGL (Above Ground Level). For those UAS with a barometric sensor, greater u tility and an equivalent level of safety will be obtained by setting the altimeter to read “zero altitude” when the UAS is on the ground prior to takeoff thus providing an AGL altitude readout. If no barometric sensor is aboard the UAS, a GPS derived altit ude similarly set to zero at the takeoff point will provide an equivalent level of safety. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11066, 11065, 11062

and 11063.

14 CFR § 91.151

– Fuel Requirements for Flight in VFR C onditions

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 nor mal 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. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weathe r conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

This regulation is written based on the capabilities of traditional civil aircraft which typically have flight times with full fuel of several hours. For the majority of UAS which have flight times of an hour, or much less, this regulation would effectivel y deny an ability for the UAS to operate. The petitioner submits that an equivalent level of safety will be obtained by requiring that no UAS flight will begin unless (considering wind and forecast conditions) there is enough fuel (battery) to fly the plan ned route to the first point of intended landing and land with 25% of battery capacity in reserve

. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

The FAA has issued s everal exemptions to this regulation: see Exemptions Nos. 2689F, 5745, 10673 and 10808.

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 prescri bed in Part 43 of this chapter...” Regulation 91.407 (a)(1) similarly makes12

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 fro m these regulations is needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate. An equivalent level of safety will be obtained by requirement that each UAS will have a flight and maintenance log.

Maintenance and i nspections will be accomplished in accordance with manufacturer recommendations. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065.

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 fore casts, 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, runway lengths at airports of intended use, and the followin g takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civ il aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and win d and temperature.

The petitioner seeks exemption to the extent that an FAA

- ­­approved Flight Manual is required. An equivalent level of safety will be provided by following the Operations Manual provided by the manufacturer. Additionally, the PIC will co nduct preflight actions, to include performing all required checklists, reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, before initiation of flight.

14 CFR § 9 1.109

– 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.13

UAS by their design do not have fully functional 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 Exemptions Nos. 11066, 11062,

11067A and 11065.

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 o r 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

airc raft. (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.

A n exemption to 91.119(c) is required because UAS operations will be conducted at altitudes no greater than 400 feet above the surface. The size, speed, weight and limited operational parameters of the UAS allow for an equivalent level of safety.

WHY GRANT ING THIS PETITION IS IN THE PUBLIC INTEREST

As introduced above, the requested exemption would authorize the Applicant to perform commercial operations with sUAS that will provide significant benefits to the public interest:

1. The commercial use of sUAS to perform agriculture and water management

related research and educational activities at University of Arizona in support of government entities, private research institutions, scientific studies and wildlife monitoring, all of which are critical to the well

- ­­being of the general public. This includes rapid studies of coastal geomorphology crucial to storm assessments and sea level rise, water quality studies, wildlife population assessments and critical habitat mapping.

2. A significant reduction in costs to conduct re search, training and education

programs . At present, our agriculture research programs that use aerial surveys can cost tens of thousands of dollars per day. By incorporating sUAS into these programs we can incur significant savings and more efficiently condu ct research in the public interest14

3. The use of sUAS will decrease congestion in the National Airspace System along with reducing the noise and air pollution generated during traditional manned aircraft flight operations.

4. When using UAS to co mplement field personnel, they reduce safety concerns when gathering data from inaccessible or unstable/unsafe areas and in extreme

weather or terrain.

5. Operation of sUAS 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 science that have been conducted for many decades, sUAS 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 fo r the safe operation of such aircraft systems in the national airspace system." Approval of this exemption will allow for safer, more efficient and less costly agricultural science missions, and produce much higher data quality.

SUMMARY OF REGULATIONS FROM WHI CH PETITIONER SEEKS EXEMPTION OR RELIEF

14 CFR Part 21, Subpart H

14 CFR Part 27

14 CFR 45.23(b)

14 CFR 61.113(a)(b)

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 91.203(a)(b)

14 CFR 91.405(a)

14 CFR 91.407(a)(1) CFR 91.409(a)(1) and (a)(2)

14 CFR 91.417(a)(b)

SUPPORTING AND TECHNICAL DOCUMENTS15

To be delivered under separate attachment

University of Arizona DJI In s pire Maintenance manual University of Arizona DJI In s pire User Manual