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n (D 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 uiiclerSection 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 minutesAircraft 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 asto 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 safelyin 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 thatcan 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 1 3 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,

~~ ---

~ 

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_ 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.eduAPPENDIX 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 thanthose 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 isobtained), 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).