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Michael Wing

AIS Lab Director

Peavy Hall 280

Oregon State University

Corvallis, OR 97331

Michael.Wing@OregonState.edu

541.737.4009

October 26, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12‐140

1200 New Jersey Avenue, SE

Washington, DC 20590

Dear U.S. Department of Transportation,

This petition is for the Aerial Information System (AIS) Lab at Oregon State University (OSU) for a

Summary Grant of Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of

2012. The Exemptions sought are in reference to CFRs and will be identified in a section below.

The AIS Lab seeks to operate small unmanned aircraft systems (UAS) for collecting remotely sensed

imagery in support of its research, education, and outreach missions.

The FAA has already issued Exemption Grants to other academic institutions for these same objectives

and for the proposed platforms described in this request.

AIS Lab Description

The AIS Lab is housed within OSU. OSU is a public research university in Corvallis, Oregon. OSU has over

200 undergraduate and graduate degree programs and is classified by the Carnegie Foundation as a

research university, with very high research activity.

The AIS Lab conducts UAS research in a variety of disciplines including project and construction

management, inspections and monitoring, environmental review projects, aerial surveying, agricultural

projects, educational and research projects, remote sensing projects, wildlife and forestry monitoring

projects, search and rescue, and other fields.  

Proposed Operations

The AIS Lab proposes to use the following platforms in seeking an Exemption Pursuant to Section 333:

Aerialtronics Altura Zenith (ATX8 and STR8), DJI Phantom 2 Vision, DJI S900, DJI S1000, DJI Phantom 3,

and 3DR Solo. The FAA has granted Exemptions to other academic entities for UAS operations:

Exemption No. 13157 to the University of Wyoming to conduct educational research;

Exemption No. 11552 to Sinclair Community College to conduct educational research and

training (Docket No. FAA‐2015‐0374); and
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Exemption No. 11304 to Auburn University Aviation Center to conduct training courses to

instruct students in the operation of unmanned aircraft and their associated systems. (Docket

No. FAA‐2014‐1014);

Previous FAA Exemptions

Each of the platforms proposed in this Exemption request have been granted previous Exemptions

Pursuant to Section 333 by the FAA based on the platform weight, speed, and operational

characteristics:

Aerialtronics Altura Zenith ATX8, STR8: Exemption 12655 to Jonathan Adams

DJI Phantom 2 Vision+: Exemption No. 11228 to Steven Zeets

DJI Phantom 3: Exemption No. 13203 to Matthew D. Gambill

DJI S900: Exemption No. 11305 to Scott Hess

DJI S1000: Exemption No. 11305 to Scott Hess

3DR Solo: Exemption No. 11935 to Patricia A. Lines

In granting these previous Exemptions, the FAA has found that each of these platforms shared the

following characteristics:

 Weight is less than 55 pounds including payload.

 The ability of the UAS to operate safely after experiencing in‐flight contingencies or failures, and

the presence of an auto‐pilot to maintain flight stability and control. The UAS is also able to

respond to a loss of GPS or a lost‐link event with a pre‐coordinated, predictable, automated

flight maneuver. These safety features provide an equivalent level of safety compared to a

manned aircraft performing a similar operation and mitigate the risk of command and control

link failures.

 Communication and control radio frequencies comply with the Federal Communications

Commission (FCC) and other appropriate government oversight agency requirements.

 The maximum speed of the platforms is 87 knots or less.

Public Benefit

The AIS Lab conducts research in a variety of disciplines. Public benefit of the UAS operations proposed

in this Exemption request includes the following societal benefits:

 Worker safety is emphasized as UAS operations can reduce or eliminate field measurements.

There are significant risks to workers in the construction and structural inspection industries

that can be alleviated by UAS.

 Manned flights pose risks to pilots.

 Greater image resolution can be obtained from UAS mounted sensors in comparison to manned

aircraft as UAS are able to fly slower and closer to the ground. Increased image resolution allows

for more robust analysis which can lead to increases in agricultural and forest productivity.

 Search and rescue operations can be conducted in areas that might be ordinarily be

inaccessible.

 UAS are more cost effective than manned aerial platforms.
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Reasons why the exemption would not adversely affect safety or how the exemption would

provide a level of safety at least equal to the existing rules.

1. The UAS platforms weigh less than 25 pounds, including payload;  

2. Flights will be operated within the visual line of sight of the pilot;

3. Maximum total flight time for each operational flight will be (45) minutes. Flight

times may be less than thirty (30) minutes as the UAS will continuously monitor

battery reserve and return to the ground station with at least 10% battery power

reserved;

4. Flights will be operated at an altitude not greater than 400 feet AGL;

5. Minimum crew for each operation will consist of the UAS pilot and a Visual Observer;

6. A briefing will be conducted daily by all personnel working with said UAS;

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

prior to operating the UAS;

8. All permits, permissions, etc. will be obtained from local government offices as

required;

9. The UAS will operate at speeds less than 8 7 knots, hover and simultaneously

move vertically and horizontally;

10. The UAS will have the capability to return and land at the pre‐determined location

with the Security Perimeter should the UAS lose communication or GPS signal

during any operations;

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles

or emergencies;

12. Operations will not be conducted over densely populated areas or heavily traffic

highways; and

13. Operations will not be conducted within five (5) NM of an airport or heliport         

without permission of the airport or heliport.

Exemptions Sought from CFRs

The AIS Lab requests Exemptions from the following CFRs:

1. 91.9(b)(2), 91.203(a) and (b): Carrying Aircraft Flight Manual, Certification and Registration in the

Aircraft

Given the small size of the proposed UAS platforms, OSU requests that these materials be kept in the

vicinity of the ground control station during flight.  

2. 91.7(a): Civil Aircraft Airworthiness

The AIS Lab requests that no Airworthiness Certificate be required.

3. 91.9(c), 45.23(b), and 45.27(a): Aircraft Marking and Identification Requirements
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The AIS Lab requests that proposed platforms bear registration numbers that are as large as practical in

accordance with platform size.

4. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport Pilot Medical

Certificate, Privileges and Limitations

The AIS Lab seeks an exemption from these CFRs as they prevent private,recreational or sport pilot

certificate holders from receiving pay for piloting duties. The UAS platforms in this petition will not carry

passengers or cargo, and the FAA has previously ruled (Exemption No. 11062) that a Commercial Pilot

Certificate is not required for UAS operations outside of controlled airspace.

5. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

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

certificate. The AIS Lab will ensure that all UAS platforms and components have an adequate

maintenance and inspection schedule.   

6. 91.121: Altimeter Settings

The AIS Lab seeks an exemption from the requirement that a pilot maintains a flight level through

reference to an altimeter. The FAA has previously stated that equivalent functionality can be achieved

when flights occur at or below 400 feet AGL and when GPS elevation data can be transmitted in real

time to a ground control station, given that a PIC establishes GPS elevation accuracy on‐the‐ground prior

to every flight.

7. 91.151(a): Fuel Requirements for Flight in VFR Conditions  

The AIS Lab seeks an exemption from the requirement that fuel reserves during VFR require that no less

than 30 minutes of fuel be maintained during the day and 45 minutes during the night. Given that the

platforms in this petition generally have a 30 minute or less flight time, no meaningful flights would

occur under 91.151(a). Exemption No. 11213 determined that an equivalent level of safety is evident in

UAS flights where the operational flight time can be achieved with an additional five minutes of flight

time being available in fuel reserves.

Please feel free to contact our office should you have any additional questions or comments. Thank you

for your cooperation with this matter.

Sincerely,

Michael Wing

AIS Lab Director