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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 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

Pursuant 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 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 substantial hazards associated with performing equivalent work with conventional 

aircraft androtorcraft.
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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:
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air TrafficOrganization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal AviationAdministration

FAR Federal AviationRegulation

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 OperatingProcedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer
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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 regularly 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 use 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 internationally. 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 activities and often exclusively over deserts, grasslands, 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 personnel 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 : Model 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 Electric
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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 safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

The UAS's planned to be operated are rotorcraft and always less than 55 lbs., including 

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 qualified 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 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 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 200 feet AGL. Altitudes 

reported to ATC will be in feet AGL.

4. UA will be flown at ground speeds not greater than 50 knots.
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5. The UAS 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 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 commercial 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 demonstration 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). PIC 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 miles (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 control 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 prior 

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 PIC’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. The
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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, persons 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 each 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 the 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 and 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 operations 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.
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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 

characteristics, 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 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-­­2014-­­0352). 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 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 letter 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 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 words “limited,” 

“restricted,” “light-­­sport,” “experimental,” or “provisional,” as applicable.
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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 

practicable.” 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 

combination 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 Privilegeand 

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 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—
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(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 in 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 are 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 capabilities 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 operate 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 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.
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Conventional aircraft are provided altitude data by a barometric altimeter that is most 

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 utility 

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 altitude 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 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 

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 weather 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 effectively 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 planned 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 several 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 

prescribed in Part 43 of this chapter...” Regulation 91.407(a)(1) similarly makes
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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 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 inspections 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 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, runway lengths at airports of intended use, 

and the following 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 civil 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 wind 

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 conduct 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 § 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.
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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 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 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 GRANTING 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 research, 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 conduct research 

in the public interest
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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 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 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 for 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 WHICH 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 DOCUMENTS
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To be delivered under separate attachment 

University of Arizona DJI Inspire Maintenance manual

University of Arizona DJI Inspire User Manual