California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	1

Dr. Sean Anderson, Mr. Paul Spaur and Mr. Todd Van Epps

California State University Channel Islands

Environmental Science and Resource Management

1 University Dr.

Camarillo, CA 93003

sean.anderson@csuci.edu

paul.spaur@csuci.edu

t.vanepps@yahoo.com

January 20, 2016

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

California State University Channel Islands

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

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Table	of	Contents

GLOSSARY OF ABBREVIATIONS....................................................................................................................... 3

INTRODUCTION AND INTERESTS OF THE PETITIONER ................................................................................... 4

Executive Summary ........................................................................................................................................ 5

Description of Type, Make and Models of sUAV/UAS Requested:................... Error! Bookmark not defined.

Commercial (Mission, Operation) Purpose: ................................................................................................... 5

Regulations from which the Exemption Relief is requested: ......................................................................... 6

The name and address of the Petitioner:....................................................................................................... 6

Background:.................................................................................................................................................... 7

Dr. Sean Anderson's Career Summary: ............................................................ Error! Bookmark not defined.

Mr. Paul Spaur's Career Summary:................................................................................................................. 8

Mr. Todd Van Epps' Career Summary:.......................................................................................................................9

Project Experience: ....................................................................................................................................... 10

Education:..................................................................................................................................................... 11

Commitment to Safety ................................................................................................................................. 11

Expertise & Experience................................................................................................................................. 11

The Exemption Request................................................................................................................................ 12

Operator Requirements ............................................................................................................................... 14

Aircraft and Equivalent Level of Safety ........................................................................................................ 16

Specific Uses Public Benefits ........................................................................................................................ 19

Equivalent Level of Safety ............................................................................................................................ 21

14 C.F.R. § 91.7(a): Civil aircraft airworthiness............................................................................................. 22

14 C.F.R. §91.119: Minimum safe altitudes.................................................................................................. 22

14 C.F.R. §91.121 Altimeter Settings............................................................................................................ 22

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions........................................................ 23

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance Inspections.................. 24

Federal Register Publication......................................................................................................................... 26

Privacy and National Security....................................................................................................................... 26

Summary ...................................................................................................................................................... 27

APPENDIX A - EXEMPTION PATTERN............................................................................................................ 29

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS......................................................................... 30

APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA PREVIOUS APPROVED EXEMPTION 

NUMBERS ..................................................................................................................................................... 31

APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION NUMBERS........................................ 32

APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED EXEMPTION NUMBERS........................... 33

APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG ......................................................................... 34

APPENDIX G - FLIGHT OPERATIONS MANUAL .............................................................................................. 35
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

ROV Remotely Operated Vehicle (submarine)

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	4

INTRODUCTION AND INTERESTS OF THE PETITIONER

To Whom It May Concern:

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

14 C.F.R. Part 11, California State University Channel Islands, (“CSUCI”) Operator of Small Unmanned 

Aircraft Systems (“sUASs”) equipped to offer on-demand commercial UAS operations for a host of 

industries and applications and to perform the purposes listed below, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of 

its sUAVs/UAS’s, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA in an exemption granted under either Section 333 or

Section 49 U.S.C. §44701(f) 

As described more fully below, the requested exemption would permit the operation of a UAS 

under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide 

safety enhancements in the fields in which it will operate, which now depend upon conventional 

aircraft or humans climbing high on dangerous structures, walking in insect laden swamps, and 

working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...

establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” Section 333(c) of the Reform Act.1

																																																							

1		California	State	University	Channel	Islands	relies	upon	the	following	exemptions	where	specific	reference	to	an	

exemption	is	not	provided:	Exemptions	11062	thru	11067,	11080,	11109	through	11112,	11114,	11213,	11062	

and	as	recent	as	11857.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

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Executive Summary

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAV makes and models as follows: 

AeroVironment	Puma, AeroVironment Qube,	AgEagle,	3DRobotics	Aero-M,	3DRobotics	Iris,	

3DRobotics	Solo,	DJI	Phantom	2,	DJI	Phantom	3,	DJI Inspire	1,	DJI	Spreading	Wings	S800,	DJI

Spreading	Wings	S900,	DJI	Spreading	Wings	S1000,	DJI	Matrice 100,	Microdrones	MD4 - 1000,	

SenseFly	eBee, SenseFly	eXom,	Skyhunter, Skywalker X8,	Trimble	UX5 and	Yuneec	Q500.

Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment.

Equipment operation manuals for each sUAV are included for your reference and are considered 

confidential information for each respective company’s UAS and are affixed separately in these 

documents labeled Appendix.

Commercial (Mission, Operation) Purpose: 

This exemption request, once granted would allow the petitioner to operate a small unmanned 

aerial vehicle (sUAV), or unmanned aircraft system (UAS), to conduct bridge Inspections, flare stack 

inspection, utility-power generation system inspections and patrolling, aerial inspection, 

photography and videography of residential and commercial real estate, weddings, aerial mapping, 

photography and videography of utility infrastructure including but not limited to electrical power 

lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, 

and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and monitoring, public 

entity support operations, aerial imaging for research, safety, monitoring and comparing work 

efforts and completion percentages, and security of controlled environment of various sites, aerial 

video and live video feed to assist with search and rescue operations under the authority and 

support of local authority officials, aerial video and photography for public and private use including 

television, public events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase awareness and 

improve safety for current and future UAS operations within the NAS, special events: including high 

schools, colleges, professional sports, open air events and fairs, research, risk management and 

assessment, motion picture production 2, surface mining, closed set filming 3, disaster and 

catastrophe event response and finally UAS pilot training.

																																																							

2 Motion	Picture	and	Television	Flight	Operations	Manual	is	herein	attached	as	Appendix	G.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	6

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

See Appendix E

The name and address of the Petitioner:

Dr. Sean Anderson, Mr. Paul Spaur and Mr. Todd Van Epps

California State University Channel Islands

Environmental Science and Resource Management

1 University Dr.

Camarillo, CA 93003

805-732-2732

																																																																																																																																																																																										

3 Motion	Picture	and	Television	Flight	Operations	Manual	for	closed	set	filming	is	herein	

attached	as	Appendix	G.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	7

Background

The Petitioner is California State University Channel Islands Environmental 

Science and Resource Management (“ESRM”) Department. Dr. Sean Anderson is the 

director of the Aerial and Aquatic Robot Research (“AARR”) team. He is a highly 

accomplished, capable and experienced Professor, Marine Biologist, Environmental 

Scientist, and Technology Aficionado. Dr. Anderson runs a number of research projects

around the world, which often use cutting edge technologies to perform field 

assessments and explore or document fundamental dynamics of our environment. He 

teaches UAS-utilizing classes at CSUCI titled, “ESRM 370: Introduction to Remotely 

Piloted Systems” which covers the basics of unmanned systems used in the air and 

under the water and “ESRM 371: Coastal Monitoring With Remotely Piloted Systems” 

focused on developing piloting and data collection proficiency with students operating 

UAVs for >40 hours in field settings. Mr. Paul Spaur is Dr. Anderson’s Lead Technician, 

and Project Manager for the AARR. Paul has many years of experience using unmanned 

systems for the hobby perspective, and has performed several research projects 

internationally and domestically using both UAS and underwater ROVs. In addition to his 

work in unmanned systems, Paul is a licensed Paramedic, and has a vast amount of 

experience in public safety and emergency management. ESRM partners with several 

public agencies, and provides research and characterization of many landscapes, parks, 

wilderness sites as well as coastal hazard assessments, wildlife surveys and related 

work. These agencies include the National Park Service, California Department of Fish 

and Wildlife, and the National Oceanic and Atmospheric Administration. CSUCI has an 

official Memorandum of Understanding (“MOU”) with the National Oceanic and 

Atmospheric Administration (“NOAA”) Center of Excellence for Unmanned Technology

which specifies that CSUCI and NOAA will share resources, equipment and training using 

UASs and ROVs for research and resource protection under NOAA’s existing FAA 

permits/airspace. The overarching goal of the program is to instruct and train a new 

generation of scientists and workforce technicians in the safe and responsible use of 

unmanned technology for both the public (research) and private (commercial) sectors.

Career Summaries

Dr. Sean Anderson’s Career Summary

Dr. Anderson has over 30 years of field research experience running national and 

international research projects at various scales at several universities including: UC 

Santa Barbara, UC Los Angeles, Stanford and (for the past 11 years) California State 

University Channel Islands (CSUCI). He has notable work in ecological assessments and 

management of the coastal zone including natural disaster response and impact 
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	8

assessments of the Deepwater Horizon oil spill, Santa Barbara Refugio Beach oil spill, 

and Hurricane Katrina. His current research projects include the use of submarine ROVs

to assess near-shore marine communities, fixed and multi-rotor UAS for international 

humanitarian and mapping work using UAS, and UAS-based photogrammetric and LIDAR 

mapping of coastal landscapes. Dr. Anderson is an elected or appointed member to 

numerous technical advisory committees at local, state, federal and international levels. 

His teaching efforts often emphasize practical fieldwork and community service with 

cutting edge technology and have garnered both local and national awards. He recently 

created both a new division in his lab (AARR) at CSUCI to support his own, new research 

projects and a broader, campus-wide consortium (CORSaiRS) to professionalize and 

improve the training of UAV operators. He has also spearheaded the landmark policy 

for oversight of UAS use at CSUCI (the so-called Unmanned Systems Board) that is now 

being adopted across the 23-campus CSU system and emulated by universities across 

California. Dr. Anderson has secured Memoranda of Understanding with numerous 

federal agencies (NOAA, US Navy) to participate in UAS operation in their airspace.

Dr. Sean Anderson’s Certifications and Degrees: 

Bachelor of Arts in Ecology and Evolution – UC Santa Barbara 1993

Bachelor of Arts in Environmental Studies – UC Santa Barbara 1993

PhD in Marine Population Biology – UC Los Angeles 2001

Postdoctoral Fellow – Stanford University Center for Conservation Biology – 2003

California Safe Boating Certificate

California State University Fire Certification

California State University Defensive Driver Certification

American Academy of Underwater Science Research Diver

Wilderness First Aid Certified

Boy Scouts of America Adult Leader Training including Wilderness Survival

State of California Disaster Response Certified

City of Thousand Oaks Disaster Response Team Certified

Aeronautical Modeling Association Member

Mr. Paul Spaur’s Career Summary

Mr. Spaur is a public servant and environmental robotics professional. He has 

been building and piloting fixed and rotor wing aircraft as a hobbyist for 15 years, and 

has over 2000 hours of recreational flight time. In addition to his flight experience, he 

has served the public as a Paramedic and Public Safety Instructor. After 10 years of 

public service, he returned to school to obtain a degree in Biology. He worked on several 

research projects, specializing in using robotic and unmanned systems for use in

environmental research. For the past two years, he has been leading the AARR research 

team under Dr. Anderson. This includes the building, modifying, repairing and piloting 

sUAVs (simulators and indoors currently) and ROVs. Paul also serves as a co-instructor 

for Dr. Anderson’s class, “Introduction to Remotely Piloted Systems.” This class instructs 

students on proficient use the technology within the workforce.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	9

Mr. Paul Spaur’s Certifications and Degrees:

Bachelor of Science in Biology – CSUCI 2015

Technical Diploma in Paramedicine – NCTI 2015

California Licensed Paramedic – P25945

California Safe Boating Certificate

California State University Fire Certification

California State University Defensive Driver Certification

Emergency Vehicle Operator’s Course (EVOC) Certification

Hazardous Waste Operations and Emergency Response (HAZWOPER 24hr)

FEMA Incident Command System 100, 200 and 700

American Heart Association Instructor 

Aeronautical Modeling Association Member

Mr. Todd Van Epps’ Career Summary

Todd Van Epps is an accomplished sUAV pilot and engineer with over 10 years of 

experience in the field. During this time he has safely instructed hundreds of new sUAV 

operators and flown over 2000 hours recreationally. His passion for sUAVs, science and 

the environment has led him to work with multiple governmental agencies and research 

entities, including NOAA, the US Navy, Coast Guard and local Sheriff Departments. He is 

currently employed by the California Department of Fish and Wildlife where he serves 

as a fully sworn peace officer managing the States diverse and unique resources. He is 

very active in the sUAV community and regularly presents to students and industry 

professionals on the safe and efficient use of the technology. He holds a wide variety of 

professional qualifications and degrees (listed below). He is a co-instructor for Dr. Sean 

Anderson’s class, “Introduction to Remotely Piloted Systems.” This class includes the 

building, modifying, repairing and piloting sUAVs (simulators and indoors currently). 

Todd Van Epps Certifications and Degrees:

Game Warden for the State of California Department of Fish and Wildlife –

2011 to present

Bachelor of Science in Environmental Science - CSUCI 2007

Federal Law Enforcement Training Center Graduate, Marine Law 

Enforcement Training – 2013

US Coast Guard 100 Ton Master License – 2015

NOAA MD4-1000 UAV Operator Training – 2015

InterDrone presenter “Safe and Efficient sUAV Operations” – 2015, 2016

Law Enforcement and Scientific Research Diver Qualified – 2014

- PADI Basic Scuba Certified – 2013

- PADI Advanced Scuba Certified – 2013

- PADI Rescue Diver Certified – 2013

- PADI Master Diver Certified – 2014

40 hour Hazardous Waste Operations and Emergency Response – 2014
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	10

Project Experience

Dates: 09-2015 to 10-2015

Project Description: NOAA AeroVironment Puma Evaluation

Duties: Dr. Sean Anderson, Mr. Paul Spaur, Mr. Todd Van Epps and the 

NOAA Center of Excellence for Unmanned Technologies, went aboard the NOAA 

research vessel the R/V Shearwater for several evaluation test flights in the Santa 

Barbara Channel using the AeroVironment UAS. NOAA pilots operated the UAS, and the 

team provided consultation and observation on the operations, and feasibility of the use 

of the UAS for oceanic, wildlife and maritime enforcement operations.

Dates: 08-2015 to 09-2015 

Project Description: Humanitarian Environmental Research and Mapping

Duties: Dr. Sean Anderson, Mr. Paul Spaur, three PhD faculty and 20 

students travelled to the Cook Islands, a group of very remote tropical Pacific Islands to 

initiate several long term environmental monitoring projects. These projects include the 

characterization and monitoring of coral reefs, agriculture, fresh water supply and sandy 

beaches. A Skyhunter UAS and DJI Inspire 1 rotor wing was used with permission of the 

country’s government to map several sites of agriculture, fresh water, and beach to 

assess for coastal erosion and effects from climate change.

Dates: 06-2015 to 09-2015 

Project Description: NOAA Liquid Robotics Waveglider Evaluation

Duties: Dr. Sean Anderson, Mr. Paul Spaur, and the NOAA Center of 

Excellence for Unmanned Technologies, went aboard the NOAA research vessel the R/V 

Shearwater for several evaluation missions with the Liquid Robotics Waveglider 

Autonomous Surface Vehicle (“ASV”) in Santa Barbara Channel. The team provided 

consultation and observation on the operations, and feasibility of the use of the ASV for 

oceanic, wildlife and maritime enforcement operations. The program also evaluated the 

ability for the Waveglider ASV to communicate with UAS platforms. 

Dates: 09-2014 to 01-2016

Project Description: Santa Rosa Island Marine Protected Area ROV Research Project

Duties: Dr. Sean Anderson, Mr. Paul Spaur, and CSUCI ESRM senior 

students made several week long research trips to Santa Rosa Island, off the coast of 

Santa Barbara, CA, to CSUCI’s research station with the National Park Service. In this

project, several students built and modified submarine ROVs and performed data 

collection transects inside and outside of the Carrington Point Marine Protected Area to 

assess the efficacy of the Marine Protected Area, and to determine whether there was 

more abundance and diversity of wildlife inside or outside of the area.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	11

Education:

Dr. Sean Anderson has been a professor for over 10 years, teaching, mentoring and 

helping cultivate students from diverse backgrounds. Mr. Paul Spaur with over 10 years 

of experience as a first responder and safety manager has taught many public first aid 

and safety training courses, and trained people to fly recreational sUAVs for many years. 

Mr. Todd Van Epps has several years of sUAV piloting and instruction experience, along 

with a wealth of field science and law enforcement knowledge. With the collective 

experience and knowledge, this group teaches the university course, “Introduction to 

Remotely Piloted Systems” in which students learn the basics of UAS and underwater 

ROVs.

CSUCI, under Dr. Sean Anderson’s, Mr. Paul Spaur’s and Mr. Todd Van Epps’ vast 

training and safety experience, is preparing trainers whose mission is to educate and 

train personnel on this new technology to be used at various locations across the nation.

Commitment to Safety

As part of its commitment to safety and innovation, CSUCI is asking for this exemption in 

part, to reduce the risk of injury to its employees and contractors who participate in the

proposed activities the petitioner requests, including but not limited to damage to 

agriculture, natural habitat, buildings and other structures within the United States. 

Expertise & Experience

CSUCI, Dr. Sean Anderson and Paul Spaur, due to their experience are extremely 

qualified and are considered as up and coming subject matter experts in the southern 

California area for sUAVs and UASs of all types, models and makes. 
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	12

The Exemption Request

CSUCI proposes the use of the sUAVs will be for capture of high resolution imagery and 

video of residential or commercial applications and purposes to a level of quality that 

allows the Petitioner to use the imagery to identify, record, memorialize events and 

objects according to the purposes noted. 

The imagery and video will be used to identify the condition of landscapes, agriculture, 

events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, 

utility-power generation system inspections and patrolling, aerial inspection, 

photography and videography of residential and commercial real estate, weddings, 

aerial inspection, photography and videography of utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers, pipeline inspection 

and patrolling, filmmaking, cinematography, and videography, precision agriculture with 

on board sensors, wildlife and forestry monitoring and mosquito and insect control, 

aerial surveying, construction site inspection and monitoring, public entity support 

operations, aerial imaging for safety, monitoring and comparing work efforts and 

completion percentages, and security of controlled environment of various sites, aerial 

video and live video feed to assist with search and rescue operations under the 

authority and support of local authority officials, aerial video and photography for public 

and private use including television, public events, and cinematography live feed and 

live newsgathering, training to persons individually or belonging to both private and 

public organizations to increase awareness and improve safety for current and future 

UAS operations within the NAS, special events: including high schools, colleges, 

professional sports, open air events and fairs research, risk management and 

assessment, motion picture production, surface mining, closed set filming, disaster and 

catastrophe events.

The UAS will be operated by CSUCI and or contracting operators on occasion to capture 

high-resolution imagery/video of large structures (wide and tall) such as warehouses, 

high rise buildings, bridges, and construction sites, as well as “bird’s eye” views of fire 

and explosion sites. Given the small size of the sUAVs involved, no more than 55 lbs., 

majority of the speed of operation be between 5-15 mph and the restricted 

environment within which they will operate, the Petitioner falls 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 UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	13

safely in the national airspace system (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’s size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate

safely in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis 

added).4

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is 

defined under §40101 of the Act: The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or any 

of sections 44702-44716 of this title if the Administrator finds the exemption is in the

public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203(a)(1) This authority to grant exemptions reaches such issues as authorization of 

commercial operation of aircraft without an FAA issued pilot’s license.

CSUCI in filing this application is requesting that the FAA combine the grant of the 

Section 333 exemption with a standard Certificate of Operation (COA) that will allow

commercial operations of its CSUCI’s sUAV without the necessity of filing for a COA for 

each flight, unless such flight is to be conducted in an area not approved in the 

exemption. Compliance with the conditions agreed to herein and that may be imposed 

by the FAA, as set forth in prior Section 333 exemptions, provide the separation needed 

from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer

than 5 nautical miles of the geographic center of an airport as denoted on a current FAA

published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained, CSUCI requests that operations over congested or densely 

populated areas be allowed. The new Phantom 3 and Inspire 1 sUAVs do have GPS geofencing, it will operate at a very low altitude, within confined areas, at low speed and 

weighs no more than 55 lbs. Such operations will only be under-taken with the approval 

of the land or home owner, as set forth herein, and will comply with the requirements 

																																																							

5 Applicant	interprets	this	provision	to	place	a	duty	on	the	Administrator	to	not	only	

process	applications	for	exemptions	under	section	333,	but	for	the	Administrator	to	

craft	conditions	for	the	safe	operation	of	the	UAS,	if	it	should	be	determined	that	the	

conditions	set	forth	herein	do	not	fulfill	the	statutory	requirements	for	approval.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	14

that operations be no closer than 500 feet to the adjacent building unless the land 

owner has provided permission, and the Operator has made a safety assessment of the 

risk from such operations. 

Operator Requirements

Given the sUAVs proposed by CSUCI, Operators should not be required to hold a private 

pilot license. CSUCI believes that 1) the operator, instead of understanding how to 

operate a passenger carrying aircraft, should have knowledge and experience that 

enables the safe operation of a small, remotely piloted sUAV should understand 

airspace restrictions and know how to ensure separation from other aircraft as well as 

non-participants and property; 2) the sUAV has built-in technical capabilities that limit 

the potential for unsafe operation and 3) there are other security screening mechanisms 

already in existence (such as our Unmanned Systems Board that approves all flights) 

that CSUCI will utilize to ensure the operators are acting consistently with national 

security interests. 

Given the sUAV safety features outlined below, CSUCI proposes that its operations 

under this Exemption request should not be required to hold a commercial or private

pilot certification. Instead, Operators should be required to: have successfully 

completed, at a minimum, FAA private pilot ground instruction and passed the FAA 

Private Pilot written examination or FAA-recognized equivalents; have completed 

CSUCI’s training program for operation of the UAS.

CSUCI notes that 1) the FAA has found that safety factors permitted operation of sUAVs 

by Operators with these qualifications in the case of operations pursuant to public COAs

when the mandatory operating conditions specified above were present; and 2) that the 

Notice of Proposed Rulemaking entitled Operation and Certification of Small Unmanned 

Aircraft Systems, 80 F.R. 9544 (February 23, 2015) (“NPRM”), does not require the 

operator to hold a private pilot license or a third class medical.

Advanced sUAVs has a navigation and control system and auto-pilot that allows it to

execute very accurate pre-programmed flights. Flights are pre-programmed with GPS 

waypoint to establish perimeters beyond which the aircraft will not operate. Flights 

under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto-pilot. In the case of 

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the 

control unit, and the autopilot executes those maneuvers. Pre-programmed Operator 

interventions include: initiation of holding at present position; suspension of mission; fly 

back to launch point; abort mission and land immediately; and emergency power cut off 

and land (flight termination system). Additional automated safety functions and safety 

enhancing features of the Advanced sUAVs may include the following:
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1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low 

power below 10% triggers an immediate landing, 

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold position at 

its current location for 5 seconds and if the signal is not restored, execute a return to 

home and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down in flight in

the event of a loss of control or un-commanded deviation from the flight path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) The motors are driven by pulse width modulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor

above 200 feet above the structure (imaging altitude) or a maximum of 400 feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems 

(UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has determined in 

Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the 

requirements for private pilot knowledge and the knowledge required for a commercial 

pilot, that knowledge associated with a private pilot license, and therefore private pilot 

ground school, was sufficient to allow private pilots to operate sUAVs under those 

exemptions. 

Based upon that analysis, CSUCI believes successful completion of FAA private pilot 

ground school is a suitable predicate to operating the sUAV under this exemption. CSUCI

proposes that the Operator accumulate required sUAV flight training hours through the 

operation of sUAVs rather than flight hours in conventional aircraft. Those hours are 

more relevant to the operations proposed herein than hours gained in obtaining a

private pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders of 

magnitude heavier than the sUAS and carry not only the pilot himself, but also 

passengers and fuel, none of which is carried in the sUAS. These conventional aircraft fly 

over all sorts of airspace without the permission or knowledge of the landowner. 

A handheld radio controller controls the sUAV and the vehicle is operated within the 

line of sight. The requirements of Part 61.127 (commercial flight proficiency) and 

§61.107 (private flight proficiency), to the extent they are relevant to UAS operations, 

can be taught in the training proposed herein. As a review of the requirements of part 

61.127 and 107 demonstrate, the issues presented as they relate to a 55 pound aircraft,

operating at less than 30 mph during filming operations are those taught in ground 

school and in flight training with the particular UAS and not gained from accumulating

flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross 

country flights and take offs and landings at controlled and uncontrolled airports.

As to national security review of pilots, each of CSUCI’s pilots/operators will obtain 

internally provided certified training (Ground and Practical) from CSUCI to operate the 
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sUAV. This review and certification could reasonably vet the Operators against any 

known terrorist or no fly listings that are relevant and publically available.

CSUCI additionally asks that the exemption be issued without the requirement for a 

visual observer. As set forth herein, an equivalent level of safety is provided by the size,

speed and control capabilities of the aircraft, as well as the operational procedures that 

will be applicable to all flight hereunder. These obviate the need for the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she will 

walk and follow the aircraft around the inspection area so that while it is flying it’s preprogrammed and at times, manual flight path, the UAS will always be directly in his or 

her line of sight. The Operator will not be distracted by viewing the pictures taken 

during the flight. Rather, once the sUAV is launched, the Operator’s only duty will be to 

watch the flight of the UAS over the structure and intervene to address flight path

deviations or other issues that arise during the flight. The functions that an observer 

performs where the aircraft is flown at long distances from the launch area will not be 

necessary as the Operator will always have the aircraft in his or her direct sight. The 

observer also will not be necessary because the Operator will conduct a pre-flight 

inspection of the area, will and if needed, cordon off the area and will perform frequent 

visual scans of the area while the vehicle is operating.

CSUCI again notes that the NPRM does not require the use of a visual observer. Given 

the clear direction in Section 333 of the Reform Act; the authority contained in the

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the

proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with 

allowing battery powered sUAVs for these functions instead of turbine or gas power 

aircraft/rotorcraft and operations with pilots having at least a private pilot license, the 

grant of the requested exemptions is in the public interest. 5

Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

																																																							

5 Should	the	FAA	determine	that	it	cannot	grant	such	an	exemption	for	operations	

without	 a	FAA	licensed	private	pilot,	despite	the	 showing	made	herein,	under	the	

statutory	authority	the	FAA	already	has,	California	State	University	Channel	Islands	

will	operate	its	aircraft	with	pilots	holding	at	least	a	private	pilot	certificate	issued	

by	the	FAA.	In	that	event,	California	State	University	Channel	Islands	requests	that	

the	exemption	be	granted	with	conditions	similar	to	those	contained	in	numbered	

paragraphs	14-15	in	Exemption	11136
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under the current regulatory structure because the proposed operations represent a 

safety enhancement to the operations conducted with conventional aircraft or with 

humans climbing up and around structures. These conditions are drawn from 

Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112, and 11213 

and as recent as 11857.

These limitations and conditions to which CSUCI (referred to as “Operator”) agrees to be 

bound when conducting commercial operations under an FAA issued exemption include:

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

aircraft described in the Operator’s manual, which is a multi-rotor weighing up to 55

pounds: Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 30

mph (10 mph during inspections).

3) The UA must be operated at an altitude of no more than 400 feet 

above ground level (AGL), as indicated by the procedures specified in the Operator’s 

manual. All altitudes reported to ATC must be in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the 

Aircraft Operator at all times. This requires the Aircraft Operator to be able to use 

human vision unaided by any device other than corrective lenses..

5) The Exemption Holder’s Manuals must be amended to include all 

conditions and limitations required by the FAA. The Manuals must be maintained and 

made available to the Administrator upon request. If a discrepancy exists between the

conditions and limitations in the exemption and the procedures outlined in the

Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption 

take precedence and must be followed. Otherwise, the Aircraft Operator must follow 

the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or 

revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

Exemption Holder must also present updated and revised documents if it petitions for 

an extension or amendment of this exemption. If the Exemption Holder determines that 

any update or revision would affect the basis upon which the FAA granted this

exemption, then the Exemption Holder must petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to 

ensure it is in a condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed, and the UAS is found to be in a condition 

for safe flight. The Ground Control Station must be included in the preflight inspection. 

All maintenance and alterations must be properly documented in the aircraft records.
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7) Any UAS that has undergone maintenance or alterations that affect 

the UAS operation or flight characteristics, e.g., replacement of a flight critical 

component, must undergo a functional test flight in accordance with the Exemption 

holder’s Manuals. The Aircraft Operator who conducts the functional test flight must 

make an entry in the UAS aircraft records of the flight. The requirements and

procedures for a functional test flight and aircraft record entry must be added to the 

Exemption Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit 

requirements, with particular attention to flight critical components that may not be 

addressed in the manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, inspections, 

and record keeping requirements in accordance with the Operator’s Manuals. 

Maintenance, inspection, and alterations must be noted in the aircraft logbook, 

including total flight hours, description of work accomplished, and the signature of the

authorized technician returning the UAS to service.

10) The authorized technicians must receive and document training 

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a 

record entry in the UAS logbook or equivalent document of the corrective action taken 

against discrepancies discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have 

logged at least 25 hours of total time as a UA rotorcraft pilot and at least ten hours 

logged as a UA pilot with a similar UA type and 5 hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the UA 

must return to a pre-determined location within the private or controlled-access 

property and land or be recovered in accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of 

unpredicted obstacles or emergencies, including unauthorized people entering the flight 

area, in accordance with the Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight 

unless (considering wind and forecast weather conditions) there is enough power to fly

to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 10 minutes.
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17) All aircraft operated in accordance with the exemption must be 

identified by serial number, registered in accordance with 14 CFR part 47, and have

identification (N- Number) markings in accordance with 14 CFR part 45, Subpart C. 

Markings must be as large as practicable.

18) Before conducting operations, the radio frequency spectrum used 

for operation and control of the UA must comply with the Federal Communications 

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

19) The documents required under 14 CFR 91.9 and 91.203 must be 

available to the Operator at the Ground Control Station of the UAS any time the aircraft 

is operating. These documents must be made available to the Administrator or any law 

enforcement official upon request. 

20) The UA must remain clear and yield the right of way to all other 

manned operations and activities at all times (including, but not limited to, ultra-light

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any 

moving device or vehicle.

22) UAS operations may not be conducted during night, as defined in 14 

CFR 1.1.

23) All operations must be conducted under visual meteorological 

conditions (VMC). The UA may not be operated less than 500 feet below or less than 

2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from 

the Operator.

24) During operations the UA may not operate within 5 nautical miles 

of the geographic center of an airport as denoted on a current FAA-published

aeronautical chart unless a letter of agreement with that airport’s management is

obtained, and the operation is conducted in accordance with a NOTAM, if as required by 

the Operator’s COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request.

25) The UA may not be operated over congested or densely populated 

areas unless the conditions set for in #26 are satisfied. These populated areas include 

but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), 

Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, 

aeronautical charts may not reflect pertinent local information. Ultimately, it is the 

Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 

(d) (1).
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26) Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from debris in the event of an accident. The Aircraft Operator 

must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 30 feet of 

the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where

the land owner/controller has granted permission and/or the Aircraft Operator has 

made a safety assessment of the risk of operating closer to those objects and;

c. Operations near the Aircraft Operator do not present an undue 

hazard to the Operator per § 91.119(a).

27) All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be obtained for 

each flight to be conducted.

28) Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours.

Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov.

Specific Uses Public Benefits 

CSUCI proposes use of its sUAV provided equivalent or augmented levels of safety for 

each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting the 

roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, 

mosquito and insect control are now conducted by either humans wading through 

swamps, climbing on the roofs and structures that are steep, tall, slippery, weakened or 

otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must climb 

on the roofs or require the use of aircraft that are orders of magnitude greater in size

than the sUAV. Either method, manual inspection or large conventional aircraft, results 

in increased risk of injury due to personnel falling off roofs or ladders, carrying heavy 

ladders and dealing with confined and dangerous spaces, or increased risk from low 
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altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage 

from storms or other disasters, such as earthquakes or fires. Such flights are, of course, 

significantly more expensive than those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, but 

those who are along the path of flight associated with the arrival and departure of the 

conventional aircraft at the inspection site because the aircraft must be flown to and 

from the site. By contrast, the sUAV is carried to the site and transits no other property. 

Conventional aircraft carry flammable fuels that are not carried by the UAS and emit

pollutants associated with internal combustion engines. The sUAVs proposed herein are

battery powered and have no emissions.

Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command; 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the CSUCI’s sUAV is 

remotely controlled with no passengers or property of others on board. Section 

61.133(a) requires an individual with a commercial pilot’s license to be pilot in 

command of an aircraft for compensation or hire. 

CSUCI respectfully proposes that Operator requirements should take into account the

characteristics of the particular UAS. CSUCI’s sUAV has a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the 

potential for operation outside of the operating conditions set forth in the exemption 

application. The CSUCI’s sUAV has navigation and control system comprised of a Ground 

Control Station (GCS) and auto-pilot system that can be pre-programmed to set 

operational boundaries. All flights are pre-programmed with precision GPS guidance.. In 

the case of unplanned events, the Operator may input pre-programmed evasive 

maneuvers from the control unit, and the onboard autopilot executes those maneuvers.

Pre-programmed Operator interventions include initiation of holding at present 

position; suspension of mission; fly back to launch point; abort mission and land 

immediately; and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the CSUCI’s 

sUAVs may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate

landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low 

power below 10% triggers an immediate landing.
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1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will hold position at 

its current location for 5 seconds and if the signal is not restored, execute a return to 

home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in 

the event of a loss of control or un-commanded deviation from the flight path.

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor 

above 200 feet above the structure (imaging altitude) or a maximum of 400 AGL.

Given these safety features, CSUCI proposes that Operators of the CSUCI’s sUAV should

not be required to hold a commercial or private pilot certification. 

Instead, Operators should be required to: have successfully completed, at a minimum, 

FAA private pilot ground instruction and passed the FAA Private Pilot written 

examination or FAA-recognized equivalents; have completed the manufacturer’s or 

CSUCI’s training program for operation of the UAS.

CSUCI notes that the FAA has found that safety factors permitted operation of UASs by 

Operators with these qualifications in the case of operations pursuant to public COAs 

where the mandatory operating conditions specified above were present. See, Federal 

Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) 

Operational Approval, at 20-21 (July 30, 2013). Likewise, CSUCI notes that the NPRM 

does not require that the Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the CSUCI’s sUAV without a private pilot’s certificate or a 

commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the CSUCI’s sUAV (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level 

of risk associated with private pilot operations or commercial operations contemplated 

by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations 

of the UAS as set forth above meets or exceeds the present level of safety provided 

under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial 

pilot to operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation 

of the UAS without an airworthiness certificate, no standard will exist for airworthiness 

of the UA. Given the size of the aircraft and the requirements that the Operator has 
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agreed to as it relates to airworthiness, as contained in the manual, an equivalent level 

of safety will be achieved by insuring compliance with the manuals prior to each flight. 

The FAA has granted exemptions to conduct similar operations in Exemptions 11062 

through 11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, an exemption may 

be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner, facility owner, and/or local officials. Because of the 

advance notice to the property owner and participants, all affected individuals will be 

aware of the planned flight operations as set forth in the Manuals. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and 

the lack of flammable fuel, any risk associated with these operations is far less than 

those presently presented by conventional aircraft operating at or below 500 AGL in the 

aerial photography industry. In addition, the low-altitude operations of the sUAS will 

ensure separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. The FAA has granted

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 

and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the CSUCI’s sUAV, in 

manual or emergency mode, will not have a barometric altimeter display, but instead a 

GPS altitude display, an exemption will be needed. The Operator, pursuant to the 

procedures set forth in the Manuals as indicated before flight, will achieve an equivalent 

level of safety. The FAA has granted exemptions to conduct similar operations in 

Exemptions 11062 through 11067, 11080 and 11110.
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14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “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.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limited to approximately 10 minutes in length. Given the limitations on the UAS’s 

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

area, a longer time frame for flight is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly 

controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights 

to 30 minutes or 25% of remaining battery power whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned landing zone 

from anywhere in its limited operating area. Similar exemptions have been granted to 

other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 

11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

These regulations require 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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the Petitioner. Maintenance will be 

accomplished by the Operator or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits an
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equivalent level of safety will be achieved because these small UASs are very limited in 

size and will carry a small payload and operate only in defined areas for limited periods 

of time. If mechanical issues arise, the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual 

the Operator will ensure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the Operator and manufacturer are most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level 

of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 

through 11067, 11080 and 11110.

*********
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Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site 

inspection and monitoring, public entity support operations, aerial video and live video 

feed to assist with search and rescue operations under the authority and support of 

local authority officials, aerial video and photography for public and private use 

including television, public events, and cinematography live feed and live 

newsgathering, training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events: including high schools, colleges, professional 

sports, open air events and fairs, research, risk management and assessment, motion 

picture production, surface mining, closed set filming, disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Inspection will be of inanimate objects in areas where the 

owners will have consented to the inspections or otherwise have agreed to allow the 

UAS and the Operator to be in the area where operations will take place. 

The size of the UAS, its speed and restricted area of operation do not raise national

security issues.
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Summary

Approval of exemptions allowing commercial operations of sUAVs for petitioner to 

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack 

inspection, utility-power generation system inspections and patrolling, aerial inspection 

and photography of residential and commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers, pipeline inspection and 

patrolling, filmmaking, cinematography, and videography, precision agriculture with on 

board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, public entity support operations, 

aerial video and live video feed to assist with search and rescue operations under the 

authority and support of local authority officials, aerial video and photography for public 

and private use including television, public events, and cinematography live feed and 

live newsgathering, training to persons individually or belonging to both private and 

public organizations to increase awareness and improve safety for current and future 

UAS operations within the NAS, special events: including high schools. colleges, 

professional sports, open air events and fairs, research, risk management and 

assessment, motion picture production, surface mining, closed set filming, disaster and 

catastrophe events, and training of students on UAS and piloting will enhance safety by 

reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing people 

in swamps, on roofs or tall, hazardous or weakened structures, exposes them to higher 

risks than those created by use of a sUAVs. Conventional aircraft that operate at 

extremely low altitudes just feet from the subject being inspected and in extreme 

proximity to people and structures present the risks associated with vehicles that weigh 

in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet 

helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV

weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lack of combustible fuel carried on board. The sUAV is 

carried to the target area and not flown. The sUAV will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein. These lightweight aircraft operate at slow 

speeds, close to the ground, and in areas that are under the control of the customer for 

the operations and, as a result, are far safer than conventional operations conducted 

with turbine helicopters operating in close proximity to the ground and people or the 

use of individuals to climb the structures to conduct the operations.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	28

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation 

of Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions 

already granted, including Exemptions number 11171 through 11174, 11176, 11177, 

11062, 11109, 11112, and 11213 and as recent as 11857.

Sincerely,

Dr. Sean Anderson, Mr. Paul Spaur and Mr. Todd Van Epps

California State University Channel Islands

Environmental Science and Resource Management

1 University Dr.

Camarillo, CA 93003

805-732-2732
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	29

APPENDIX A - EXEMPTION PATTERN

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act 

Section 333 (b). 

Submitted under separate cover.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	30

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is protected 

under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b). 

Submitted under separate cover.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	31

APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA 

PREVIOUS APPROVED EXEMPTION NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act 

Section 333 (b). 

Submitted under separate cover.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	32

APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION 

NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act 

Section 333 (b). 

Submitted under separate cover.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	33

APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED 

EXEMPTION NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act 

Section 333 (b). 

Submitted under separate cover.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	34

APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act 

Section 333 (b). 

Submitted under separate cover.
California State University Channel Islands 

Environmental Science and Resource Management

1 University dr. Camarillo, CA 93012 – (805)732-2732

Page	35

APPENDIX G –FLIGHT OPERATIONS MANUAL VERSION 1.0

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act 

Section 333 (b). 

Submitted under separate cover.