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August 28, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SC 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and 14 C.F.R. Part 11, Kansas State University, the operator of the DJI Phantom 2 Vision Plus, 

DJI Inspire 1, DJI S800, DJI S800 EVO, DJI S900, DJI S1000, DJI S1000+, 3D Robotics Aero, 

3D Robotics X8+, Aeryon Scout, and Altus X8 ("sUAS"), seeks an exemption from the Federal 

Aviation Regulations ("FARs") listed below and discussed in Appendix A. 

The requested exemption would permit Kansas State University to conduct commercial 

operations of sUAS, all weighing less than 27 lbs. including payload and capable of capturing 

still imagery and video. The application for our sUAS will be for tlight training, aerial data 

collection and commercial i•esearch purposes. 

Operations under the cxemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft. 

As described more fully below, the requested exemption would authorize commercial operations 

using these sUAS, which at 271bs. are small in size. The sUAS will be operated under controlled 

conditions at low altitude in airspace that is limited in scope, as described more fully herein; it 

will have automated control features, as described below. The sUAS also will be operated by an 

individual who has at least a sport or recreational pilot's certification, a valid driver's license and 

sUAS flight training. Finally, the airspace in which the sUAS will operate will be disclosed to the 

FAA in advance through the use of a COA and NOTAMs. 

Kansas State University respectfully submits that because these small unmanned aerial 

systems—the DJI Phantom 2 Vision Plus, DJI Inspire 1, DJI S800, DJI S800 EVO, DJI S900, 

DJI S 1000, DJI S 1000+, 3D Robotics Aero, 3D Robotics X8+, Aeryon Scout, and Altus X8 — 

will be used in lieu of comparatively hazardous operations now conducted with fixed wing and 

rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least 

an equivalent or greater level of safery. Approval of this exemption would thereby enhance safety 

and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities uiicler 
Section 333(c) ol'the Reform Act to "establish requirements for the safe operation of such 

aircrafi systems in the national airspace systein." 

The name and address of the applicant are: 

Kansas State University 

Attn: Kurt J. Carraway, Acting UAS Program Manager 

Address: 2310 Centennial Rd, Salina, KS 67401 

Ph: 785-826-2624 

Cmail: kcarraway@ksu.edu 

The regulations froiirn w}hich the exeniption is requested arc as ('OIlows: 

14 C.F.R. 61.113(a)&(b); 

14 C.F.R. 91.7(a); 

14 C.F.R. 91.119(c); 

14 C.F.R. 91.121: 

14 C.F.R. 91.151(a)(1); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a) (1); 

14 C.F.R. 91.409(a) (2); 

14 C.F.R. 91.417(a)&(b). 

Appendix A discusses each rule listed above and explains why exemptions pursuant to tlie 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in 

the public interest. These are the same rules that have been granted in every Section 333 

Cxemption to date. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Kaiisas State University submits that grant of this exemption application for use of sUAS for 

flight training, aerial data collection and commercial research will advance the Congressional 

mandate in Section 333 of the Reform Act to accelerate the introduction of UASs into the 

natioiial airspace system ("NAS") if it can be accomplislled safely. This law directs the Secretary 

of Transpoi•tation to consider whetlier certain UASs may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard 

to users of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS' size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and poptilated areas; and 

• Operation of the UAS within visual line of sigllt of the operator. 

T'he grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; 

the strong equivalent level of safety surrounding the proposed operations; and the significant 

public beneiit, including enhanced safety and cost savings associated with transitioning to UASs 

for coinmercial purposes. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. 
The sUAS 

The sUAS requested in this exemption comply with the requirements set forth by Section 333 by 

their small size, weight, speed, and operational proximity to airports and densely populated 

areas. As a result under this excmption the sUAS are not deemed airworthy by an airworthiness 

certifcate, but rather they are deemed airworthy by the operator conducting a thorough preflight 

of the aircraft. There aircraft will also be registered in accordance to 14 CFR Part 47, marked in 

accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of alternative marking due 

to the unconventional design of the UAS requested. Markings will be as large as practicable. All 

requested aircraft have been previously approved by the FAA uiider other Section 333 

exemptions. 

Aircraft Make and Model: DJI Phantom 2 Vision Plus 

Configuration: Quadcopter 

Aircraft Performance/Specitications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled tlirough the use 

of a handheld console at 2.4 GHz and 5.8GI-Iz. 

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

• Emergency Procedure: Should the need arise the aircraft can be commanded by the hand 

held console to safely land immediately or return and land at the launch location. 

• Power Supply: 5200mA1i litllium polymer batteries. 

• Dimensions: 350min motor diagonal length 

• Maximum Speed: 15 m/s (30 knots) 

• Normal operating speed: Less than 25 knots 

• Weight without payload: 1242g. 

• Maximum weiglit witli payload: 1350g 

• Approximate Flight Tiine: 25 minutes 

Aircraft Make and Model: DJI Inspire 1 

Configuration: Quadcopter 

Aircraft Performance/Specifications: 

• Ground Control Station (GCS): The aireraft will be primarily controlled through the use 

of a handheld console at 2.4 GHz and 5.8GI-Iz. 

• Lost Com: Aircraft will autonomously return to the launcii location and safely land. 

• Emergency Procedure: Should the need arise the aircraft can be comnlanded by the hand 

lield console to safely land immediately or return and land at the launch location. 

• Power Supply: 4500mAh or 5700mAh lithium polymer batteries 

• Dimensions: 559 to 581 mm motor diagonal length 

• Maximum Speed: 22111/s (43 knots) 

• Normal operating speed: Less than 30 knots 

• Weiglit witliout payload: 2935g 

• Maximum weiglit witli payload: 3151g 
• Approximate Flight Time: 18 tninutes 

Aircratt Make and Model: DJI S800 

Contiguration: Hexacopter 

Aircraft Performance/Specifications: 

• Ground Control Station (GCS): The aireraft will be primarily controlled through the use 

of a handheld console or laptop via 900 MHz, 2.4 GHz, or 5.8GHz. 

• Lost Com: Aircraft will autonoinously return to the launch location and safely land. 

• Emergency Procedure: Should the iieed arise the aircraft can be commanded the tablet 

GCS to safely land iniinediately or returii and land at the launch location. 

• Power Supply: Lithiuin polymer batteries 

• Dimensions: frame arm 350mm, center frame diameter 240mm, landing geac• height 

320mm 

• Maximum Speed: 8 m/s (15.5 knots) 

• Normal operating speed: 5 m/s (10 knots) 

• Weight witllout payload or battery: 2.6kg 

• Maximum weight witli payload: 7.Okg 

• Approximate Flight Time: 20 minutes 

Aircraft Make and Model: DJI S800 EVO 

Configuration: Hexacopter 

Aircraft Performanee/Specifications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled through the use 

of a handheld console or laptop via 900 MHz, 2.4 GHz, or 5.8GHz. 

• Lost Com: Aireraft will autonomously return to the launch location aiid sal'ely land. 

• Emergency Procedure: Should the need arise the aircraft can be commanded the tablet 

GCS to safely land immediately or rettirn and land at the launch location. 

• Power Supply: Lithium polymer batteries 

• Dimensions: frame arm 350min, center fratne diameter 240mm, landing gear height 

320mm 

• Maxiinum Speed: 8 m/s (15.5 knots) 

• Normal operating speed: 5 m/s (10 knots) 

• Weight without payload or battery: 3.7kg 

• Maxiinum weight with payload: 8.Okg 

• Approximate Flight Time: 12 minutes 

Aircraft Make and Model: DJI S900 

Configuration: Hexacopter 

Aircraft Performance/Specifications: 
• Ground Control Station (GCS): The aireraft will be primarily controlled through the use 

of a handheld console or laptop via 900 Ml-lz, 2.4 GI-Iz, or 5.8GI-Iz. 

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

• Emergency Procedure: Should the need arise the aircraft can be comtnanded the tablet 

GCS to safely land iinmediately or return and land at the launch locatioil. 

• Power Supply: Litliiuni polymer batteries 

• Dimensions: franie arm 358mm, center fratrte diaineter 2721nm, landing gear height 

305mm 

• Maximum Speed: 8 m/s (15.5 knots) 

• Normal operating speed: 5 m/s (10 knots) 

• Weigllt witliout payload or battery: 3.3kg 

• Maximtun weight with payload: 8.2kg 

• Approximate rlight Time: 18 tninutes 

Aircraft Make and Model: DJI S 1000 

Configuration: Octocopter 

Aircraft Performance/Specifications: 

• Ground Control Station (GCS): The aircratt will be primarily controlled through the use 

of a handlield console or laptop via 900 MHz, 2.4 GI-Iz, or 5.8GHz. 

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

• Emergency Procedure: Should the need arise the aircraft can be commanded the tablet 

GCS to safely land immediately or return and land at the launch location. 

• Power Supply: Lithium polymer batteries 

• Dimensions: frame arm 386mm, center frame diameter 337.5mtn, landing gear height 

305mtn 

• Maximum Speed: 22 m/s (43 knots) 

• Normal operating speed: 5 m/s (10 knots) 

• Weight witllout payload or battery: 4.2kg 

• Maxinium weight with payload: 11.Okg 

• Approximate Pligllt Time: 15 minutes 

Aircraft Make and Model: DJI S 1000+ 

Configuration: Octocopter 

Aircraft Performance/SpeciCcations: 

• Ground Control Station (GCS): The aircrait will be primarily eontrolled through the use 

of a handlield console or laptop via 900 MHz, 2.4 GHz, or 5.8GHz. 

• Lost Com: Aircraft will autonomously returii to the launch location and safely land. 

• Emergency Procedure: Should the need arise the aireraft can be cotnmanded the tablet 

GCS to safely land imtnediately or return and land at the launch location. 

• Power Supply: Lithiutn polymer batteries 
• Dimensions: frame arin 386mm, center frame diaineter 3371lim, landing gear height 

305mm 

• Maximum Speed: 22 m/s (43 knots) 

• Normal operating speed: 5 m/s (10 knots) 

• Weight without payload or battery: 4.4kg 

• Maximum weight with hayload: 11.Okg 

• Approxiinate Flight Timc: 15 minutes 

Aircraft Make and Model: 3 D Robotics Aero 

Configuration: Fixed wing 

Aircraft Perforinance/Specitications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled through the use 

of a handheld console or laptop via 900 MHz, 2.4 GHz, or 5.8GHz. 

• Lost Coiii: Aircraft will autonomously return to the launch location and safely land. 

• Emergency Procedure: Should the need arise the aircraft can be commandeci the tablet 

GCS to safely land immediately or return and land at the launch location. 

• Power Supply: Lithium polymer batteries 

• Dimensions: 188cm wingspan, 129 cm length 

• Maximum Speed: 20 in/s (39 knots) 

• Normal operating speed: 15 m/s (30 knots) 

• Weiglit witliout payload: 6.81bs. 

• Maximum weight with payload: 7.91bs. 

• Approximate flight time: 40 minutes 

Aircraft Make and Model: 3D Robotics X8+ 

Contiguration: Quadcopter 

Aircraft Perforinaiice/Specifications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled through the use 

of a handheld console or laptop via 900 MI-Iz, 2.4 Gl-Iz, or 5.8GHz. 

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

• Emergency Procedure: Should the need arise the aircraft can be commanded the tablet 

GCS to safely land inlinediately or return and land at the launch location. 

• Power Supply: Lithium polymer batteries 

• Dimensions: 565mm motor diagonal length 

• Maximuin Speed: 17 m/s (33 knots) 

• Normal operating speed: 5 m/s (10 knots) 

• Weight witliout payload: 5.61bs. 

• Maximum weight with payload: 7.3 lbs. 

• Approximate flight time: 15 minutes 
Aircraft Make and Model: Aeiyon Scout 

Configuration: Quadcopter 

Aircraft Performance/Specifications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled througlt the use 

of a tablet via 900 MHz and 2.4 GHz. 

• Lost Com: Aircraft will autonomously return to the launch locatioti and safely land. 

• Emergeiicy Procedure: Should the need arise the aircraft can be comnlanded tlle tablet 

GCS to safely land immediately or return and land at the launch location. 

• Power Supply: Lithium polymer batteries 

• Diniensions: 500mm inotor diagonal length 

• Maxinium Speed: 15 nz/s (30 knots) 

• Normal operatiiig speed: 5 m/s (10 knots) 

• Weight without payload: 3 lbs. 

• Maximtim weight with payload: 41bs. 

• Approxiniate Fliglit Titne: 25 minutcs 

Aircraft Make and Model: Altus X8 

Configuration: Quadcopter 

Aircraft Performance/Specitications: 

• Ground Control Station (GCS): The aircraft will be primarily controlled via 2.4 GHz and 

915MHz. 

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

• Emergency Procedure: Should the need arise the aircraft can be commanded the tablet 

GCS to safely land immediately or return and land at the launch location. 

• Power Supply: Litliium polymer batteries 

• Dimensions: 106 tnotor diagonal length 

• Maximum Speed: 10 m/s 

• Normal operating speed: 5 m/s (10 knots) 

• Weight without payload: 9.5kg 

• Maximuni weight with payload: 12 kg 

• Approximate Flight Time: 15 minutes 

Aircraft manuals, operations checklist, and Kansas State University's Standarcl Operating 

Procedures will be included as additional proprietary inforniation to this petition 1'or excmption 

that will be subinitted upon reduest. 

Operator Requirements 

'I'o operate the sUAS under this exemption an operator will be required to have at least a sport or 

recreational pilot's certification, a valid driver's license and aircraft specific tlight training so as 
to operate the UAS in a inanner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, veliicles and structures. 

Mandatory Operating Conditions 

Grant of the exemption to Kansas State Univcrsitv Nvill be subject to the following mandatory 

conditions for flight operations. 

• Permission from the landowner will be obtained before commencing any flight. 

• Operations will only occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Operations will not occur less than 500 feet below or less than 2,000 feet horizontally 

froin a cloud or when visibility is less than 3 statute miles from the operator. 

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

• A flight test will be condticted after any major repair or alteration. 

• A preflight check will be conducted before each flight to assure airworthiness. 

• Aircraft will reinain witllin Visual Line of Sight (VLOS) of the operator. 

• All operations will be conducted with a Visual Observer (VO). 

• Operations will bc limited to daylight hours. 

• Operations will be concluded with no less than 25% battery power remaining. 

• Operations will iiot exceed 400ft AGL. 

• Operations will not occur within Snm of any airport unless a letter of agreement witli tllat 

airport's managemcnt is obtained. 

• Operations will take place under a COA. 

• Operator will file a NOTAM for each flight. 

• All required permissions and perinits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

• All non-participants will keep 500ft away t'rom operations unless there are adequate 

barriers to protect them. 

• All operations will be conducted according to the manufacturer's manuals. 

• All documents that will be kept at the GCS include but are not limited to; the aircraft 

manuals, maintenance logs, aircraft registration, grant of exemption, and COA. 

Public Interest 

Consistent with the requirements of 14 C.F.R. § 11.81(d), Petitioner offers the following reasons 

wliy granting this petition f'or exemption is in the public interest, i.e., liow granting it would 

benefit the public as a whole. 

Approval of this exemption allowing commercial operations of sUAS for flight trainitig, aerial 

data collection and coinmercial research benefits the public as a whole in the following ways: 

• It helps fulfill Congress' goal in passing Section 333(a) tlhrough (c) of the Relorm Act, 

naniely, the FAA Administrator's assessment of whether certain UAS may operate safely 
in the National Airspace System before completion of the rulemaking required under 

Section 332 of the Reform Act. 

• The operation significantly improves safety aiid reduces risk by alleviating hucnan 

exposure to danger associated with current aerial remote sensing methods, namely, ftill 

size helicopters. Reducing human exposure to death or serious injury associated with 

manned aircraft performing these tasks furthers the public's interest. 

Petitioner's sUASs are battery powered and create no emissions. If Petitioner's sUAS 

crashes, there is no fuel to ignite and explode. Any impact of Petitioner's liglitweight 

sUASs is far less than a tull size manned aircraft. The public's interest is furthered by 

ininimizing ecological impact of an accident and by reducing human exposure to 

potentially harmful etnissions associated with manned aircraft. 

Remote sensing is as valuable tool for mapping, real estate, insurance evaluations, and 

industrial inspection. However, problems with safety, cost, statistical integrity, and 

logistics continue to impede remote sensing from conventional manned aircraft. The use 

of sUAS addresses these probleins and is a powerful tool for perforining a wide-range of 

remote sensing applications. The public as a whole will benefit froin the safer and moi•e 

cost-effective remote sensing services that sUAS operations provide. 

As the UAS industry continues to expand into the commercial market, so too does the 

demand for structured, professional training. Approval of this exeinption will enable 

Kansas State University to continue its tradition of providing excellent training in thc 

development of pilots, now in the unmanned side of aviation. This will enhance safe, 

efficient operations by operators. 

Privacy 

Kansas State University will not operate sUAS in any way that may invade personal privacy and 

will comply with any federal, state, or local privacy laws that may apply in areas where Kansas 

State University operates sUAS. In addition, as a practical matter, flights will occur over 

property only with land owner permission, so privacy is unlikely to be a concern in relation to 

Kansas State University's proposed use. 

Conclusion 

Kansas State University seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of a sUAS to conduct fliglit training, aerial data collection, aiid 

commercial research. 

Approval of this exemption allowing cominercial operations of the DJI Pliantom 2 Vision Plus, 

DJI Inspire 1, DJI S800, DJI S800 EVO, DJI S900, DJI S1000, DJI S1000+, 3D Robotics Acro, 

3D Robotics X8+, Aeryon Scout, and Altus X8 for flight training, aerial data collection and 

commercial research will enliance safety by reducing risk. Conventional remote sensing 

operations, using turbine or piston-powered aircraft present risks associatcd witli vchicles that 
can weigh 5,000 to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in some 

cases, cargo. In contrast, sUAS weighing less than 27 lbs. and powered by batteries eliininates a 

portion of that risk given the reduced inass and lack of combustible fuel carried on board. The 

sUAS will carry no passengers or crew and, tlierefore, will not expose any individuals to the 

risks associated with manned aircraft flights. 

Additionally, no national security issue is raised by the grant of the requested exemptions due to 

all pilots being certified tiu•ough the FAA. 

The operation of the sUAS, weighing less than 27 lbs., for flight training, aerial data collection 

and eommercial research in accordance with the strict conditions outlined above, will provide an 

equivalent level of safety supporting the grant of the exemptiotis requested herein. 

The DJI Phantom 2 Vision 13 lus, DJI lnspire 1, DJI S800, DJI S800 EVO, DJI S900, DJl S1000, 

DJI S1000+, 3D Robotics Aero, 3D Robotics X8+, Aeryon Scout, and Altus X8's satisfaction of 

the criteria set forth in Sectioti 333 of the Reform Act—size, weight, speed, operating 

capabilities, lack of proximity to airports, operation within visual line of siglit, aiid national 

security—and its showing of an equivalent level of safety provides more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of the 

sUAS for fliglit training, aerial data collectioti and for commercial researcll purposes. 

Best Regards, 

~~ --- 

~ --- _ 

Kurt J. Carraway 

Acting UAS Program Manager 

Applied Aviation Research Center 

Kansas State University 

2310 Centennial Road 

Salina, KS 67401 

785.826.2624 (Office) 

kcarraway(,ksu.edu 
APPENDIX A: 

EXEMPTION REQUEST AND E UIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION 

Kansas State University requests an exemption from the following regulations, all of which have 

been granted by every approved Section 333 exemption at the time of this submission. 

14 C.F.R. § 61.113 Private pilot privileges and limitations: Pilot in command. 

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in cominand 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. 

Equivalent Level of Safety 

Currently, there are no applicable areas identified for sUAS in either tlie private or commercial 

sector and tlierefore an exeniption is required to conduct cotnmercial operations. As flight 

operations will be conducted in a restricted environment as described in the operations section, 

these strict guidelines will achieve an equivalent level of safety for each individual flight 

especially when compared to commercial flights identified in Part 61 when originally developed. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for 

the sUAS, should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. 

Equivalent Level of Safety 

Given the size of the DJI Phantom 2 Vision Plus, DJI Inspire 1, DJI S800, DJI S800 EVO, DJl 

S900, DJI S1000, DJI S1000+, 3D Robotics Aero, 3D Robotics X8+, and Aeryon Scout and the 

preflight procedures including the review of maintenance logs and preflight check lists, an 

equivalent level of safety will be provided to assure the aircraft is in an airworthy condition. 

14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

Petitioner requests an exemption froin the minimum safe altitude requirements of 14 C.F.R. § 

91.119(e) whieh states that aireraft may not operate closer thati 500 feet above the surface ancl 

away fi•om any person, vessel, vehicle, or structure in non-congested areas. 

`I'o provide the intended operations, the sUAS is operated below 400 feet AGL. 

Equivalent Level of Safety 

Compared to flight operations with rotoreraft weighing far more than the 271bs. pj•oposed lierein, 

and given the lack of flammable fuel, any risk associated with these operations is far less than 
those that presently exist with conventional aircraft. An equivalent level of satety will be 

achieved given the size, weight, and speed of the UAS, as well as the location where it is 

operated. As set fortlt in the operations section of this exeinption, the sUAS will be operated at 

least 5nin away from airports (unless a letter of agreement from the airport's inanagement is 

obtained), wliere buildings and people will not be exposed to operations without theii• preobtained consent. Because of the advance notice to the property owners and participants, all 

affected individuals will be well aware of the planned flight operations. 

14 C.F.R. § 91.121: Altiineter Settings 

Petitioner requests an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is requireci because the 

sUAS does not have a barometric altiineter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by the operator contirining the altitude of'the 

launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the 

GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe 

altitudes. 

14 C.F.R. § 91.151(a)(1): F uel IZcquirements for Flight in VFR Conditions 

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)(1)'s fuel requireinents for flight in 

VFR conditions dtiring the day. Section 91.151(a)(1) states: 

(a) No person inay begin a flight in an airplaiie under VFR conditions unless (consiciering wind 

and forecast weather conditions) there is enough fuel to tly to the tirst point of intended latiding 

and, assuming normal cruising speed — 

(1) During the day, to fly after tliat for at least 30 ininutes; 

Here, the batteries powering the DJI Phantom 2 Vision Plus, DJI Inspire 1, DJI S800, DJl S800 

EVO, DJI S900, DJI S1000, DJI S1000+, 3D Robotics Aero, 3D Robotics X8+, and Aeryon 

Scout provide approximately 40 minutes or less. To ineet the 30 minutes reserve requireinent in 

14 C.F.R. § 91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's 

proposed flight area and the location of its proposed operations within a predetermined area, a 

safety margin based on a reserve amotint of battery life is needed. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved becatise the operations will be conciticted on-site 

without signifieant transit time by the sUAS. All flights will be planneci to be terminatecl with no 

less than 25% reserve battery power still available. This restriction wotild be more than aclequate 

to return the sUAS safely to the ground and its planned landing zone from anywhere in its 

limited operating area even in the event of an tinexpected occurrence. Operation of the sUAS 

witli less than 30 ininutes of reserve fiiel does not include the type of risks that Section 

91.151(a)(1) was intended to alleviate given the size and speed of'the small UAS, and the 

proximity of the flight operation to the landing zone. 
14 C.F.R. 5 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections 

Petitioner also seeks an exemption from the inaintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that eaeh owner or operator of an aireraft "[s]hall have the aircraft inspected as 

prescribed in subpart E ofthis part and shall between required inspections ...have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certifcate, which 

the sUAS will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operator will ensure that the sUAS is 

in working order prior to initiating flight by following the preflight cliecklist, perform required 

maintenance, aiid keep a log of any maintenaiice perfonned. The operator is the person rnost 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition. 

APPENDIX I3: S11 ~ 1MAIZY OF KANSAS STATE UNIVFRSI'I'Y SECTION 333 

I?XIi.NIPTION REOUEST 

Kansas State University hereby provides pursuant to Part 11 a summary of lts excllptiotl 

application to allow comniercial operation of the DJI Phantom 2 Vision Plus, DJI lnspire 1, DJI 

S800, DJI S800 EVO, DJI S900, DJI S 1000, DJI S 1000+, 3D Robotics Aero, 3D Robotics X8+, 

Aeryon Scout, and Altus X8 unmanned aircraft in remote sensing. An exemption is requested 

from the following regulations: 

14 C.F.R. 61.113(a)&(b)-, 

14 C.F.R. 91.7(a); 

14 C.F.R. 91.119(c); 

14 C.F.R. 91.121; 

14 C.F.R. 91.151(a)(1); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a) (1); 

14 C.F.R. 91.409(a) (2); 

14 C.F.R. 91.417(a)&(b).