Executive Technology

Services & UAS

Operations

Georgia Southern

University

P. O. Box 8136

Statesboro, GA 30460

December 7, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave SE

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, Georgia Southern University’s Executive Technology Services & UAS Operations, the operator of the

3D Robotics X8 and DJI Phantom 3 Professional sUAS, seeks an exemption from the Federal Aviation

Regulations (“FARs”) listed below and discussed in Appendix A.

Description of the UAS

1. 3D Robotics X8

The 3D Robotics X8 (3DR X8) is an 8 motor small UAS (sUAS) in a Standard X frame Quad formation.

The 3DR X8 features the APM 2.6 autopilot system and GPS navigation combined with a powerful and

redundant multirotor design. As part of the APM Copter family, the 3DR X8 uses the full range of autonomous

flight features supported by APM Copter, including loiter, circle, return to launch, follow me, acrobatic flying

mode, and more. Installation of free mission planning software allows the operator to run programmed

waypoint missions and analyze flight data. Geofencing, robust failsafes, and a durable airframe provide

preventative safety measures to give peace of mind. 3DR X8 is the most powerful 3DR multi‐‐copter solution,

perfect for heavy payloads, stability in high winds, and capturing high quality video.

2. DJI Phantom 3 Professional

The DJI Phantom 3 Professional is a 4 motor sUAS quad copter.

The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross

weight of approximately 2.8 lb. while having a diagonal dimension of 23.2 inches, a maximum speed of

approximately 37 knots and a set maximum flying height of 400 feet. The DJI Phantom 3 is equipped with four

main rotors; driven by lithium polymer (LiPo) battery powered electric motors.
Exemption

The requested exemption would permit commercial operation of 3DR X8 and DJI Phantom 3 Professional,

with payload installed, weights are approximately 6 lbs. and 2.8 lbs. respectively. Both are all capable of

capturing still imagery, and video.

Remote data acquisition for these two sUAS include remote sensing, mapping, structural inspections, aerial

imagery, and demonstrations. Use of the two sUAS for these purposes, provide GEORGIA SOUTHERN

UNIVERSITY with high quality data, safely, and at a fraction of the cost of using conventional aircraft. They can

also operate in conditions that conventionally sized aircraft could not accommodate.

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

ensure an equivalent level of safety to currently authorized operations using manned aircraft.

The airspace in which the sUAS will operate will occur in FAA approved airspace as designated in the blanket

COA or other COA.

Safety and risk assessment evaluations

Georgia Southern University Executive Technology Services and UAS Operations, as part of its safety

processes, has extensive checklists and operational procedures to minimize risk. These two small unmanned

aircraft systems have been approved in many other Section 333 exemption requests submitted by other

operators to the FAA.

Georgia Southern University Executive Technology Services and UAS Operations respectfully submits that

these small unmanned aircraft systems 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 safety. Approval of this exemption would

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s)

responsibilities under Section 333(c) of the Reform Act to “Establish requirements for the safe operation

of such aircraft systems in the national airspace system.”

The regulations from which the exemption is requested are as follows:

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)
THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Georgia Southern University Executive Technology Services and UAS Operations submits that granting of this

exemption application for use of the sUAS 3DR X8 and DJI Phantom 3 Professional for remote data acquisition

with a focus on aerial imaging, industrial/structural inspections, and demonstrations. This will advance the

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

national airspace system (NAS). 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

• Operation of the UAS within visual line of sight of the operator

The granting 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 benefit,

including enhanced safety and cost savings associated with transitioning to UASs for remote sensing.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without

delay.

The sUAS

The two sUAS models 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 exemption

UAS’ are not deemed airworthy by an airworthiness certificate, but rather they are deemed airworthy by the

operator conducting a thorough preflight of the aircraft. In this case, as Georgia Southern University is a

public entity, an FAA accepted airworthiness process has been conducted and a statement made to and

accepted by the FAA UAS Integration Office. These aircraft will also be registered according 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. Markings will be as large as practicable. These aircraft are of the same

size, configuration, and operational capabilities of the aircraft granted in exemptions 11138, 11153, 13793,

and 11157.

Aircraft Performance/Specifications:

•Ground Control Station (GCS): Both aircraft will be primarily controlled through the use of a 2.4 GHz RC

transmitter. The 3DR X8 aircraft can also be preprogrammed to conduct a mission through the use of a

laptop or tablet via a 915 MHz telemetry link. Whenever operations are conducted in this matter, the RC

Transmitter will be able to take control of the aircraft if the need arises.

• Video Downlink:

3DR X8

5.8 GHz at 200mW

Phantom 3 Professional

2.4GHz ISM at 100 mW

• Lost Comm/Failsafe:

Both aircraft will autonomously return to the launch location and safely land.

• Emergency Procedures:
Should the need arise the aircraft can be commanded by a switch or a button on the RC

transmitter to safely land immediately or return and land at the launch location. Both aircraft also

have a failsafe that will have it return to home and land if communications are lost.

• Power Supply:

3DR X8

4S 5000 mAh 25C LiPo Battery

Phantom 3 Professional

4S 4480 mAh 25C LiPo Intelligent Flight Battery

• Dimensions:

3DR X8

32 inches prop tip to prop tip

Phantom 3 Professional

23.2 inches prop tip to prop tip

• Maximum Speed:

3DR X8

<44 knots

Phantom 3 Professional

37 knots

• Normal operating speed:

< 30 knots

• Weight with payload:

X8 = 6 lbs.

Phantom 3 = 2.8 lbs.

Aircraft manuals and operations checklist will be included as additional information to this petition for

exemption.

Operator Requirements

Georgia Southern University UAS pilots will meet or exceed all FAA requirements for UAS

operations as listed below. Minimum of:

• Private pilot’s certificate

• At least a third class medical

• Aircraft specific flight training as defined below

• 10 hours logged as a UAS pilot with a multirotor UAS

• 5 hours with the specific make and model of the UAS

• At least 3 takeoffs and landings within the preceding 90 days

Mandatory Operating Conditions

Grant of the exemption to Georgia Southern University Executive Technology Services & UAS Operations

will be subject to the following mandatory conditions for flight operations.

• Operations shall not occur over congested, actively, or densely populated areas as defined by

the local FSDO.

• Permission from the landowner is required 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 from 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 conducted after any major repair or alteration.
• A preflight check will be conducted before each flight to assure airworthiness.

• Aircraft will remain within Visual Line of Sight (VLOS) of the operator.

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

• Operations will be limited to daylight hours.

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

• Operations will not exceed 400ft AGL.

• Operations will not occur within 5nm of any airport unless a letter of agreement with that

airport’s management is obtained.

• Operator will file a NOTAM for each flight.

• All required permissions and permits 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 from 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 Ground Control Station 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 why granting

this petition for exemption is in the public interest, i.e., how granting it would benefit the public as a whole.

Approval of this exemption allowing commercial remote sensing operations of sUAS in mapping, aerial

imagery, structural inspections, and demonstration will benefit the public as a whole in the following ways:

• It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act, namely, the

FAA Administrator's assessment of whether certain UAS may operate safely in the National

Airspace System before completion of the rulemaking required under Section 332 of the Reform

Act.

• The operation significantly improves safety and reduces risk by alleviating human exposure to

danger associated with current aerial remote sensing methods, namely, full size helicopters.

Reducing human exposure to death or serious injury associated with manned aircraft performing

these tasks furthers the public’s interest.

• Petitioner's sUAS 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 lightweight sUAS is far less than

a full size manned aircraft. The public's interest is furthered by minimizing ecological impact of

an accident and by reducing human exposure to potentially harmful emissions associated with

manned aircraft.

• Remote aerial data acquisition is valuable for aerial imagery, structural inspections, flight testing

and training. However, problems with safety, cost, statistical integrity, and logistics continue to

impede remote aerial data acquisition from conventional manned aircraft. The use of sUAS

addresses these problems and is a powerful tool for performing a wide‐‐range of remote sensing

applications. The public as a whole will benefit from the safer and more cost‐‐ effective remote

sensing services that sUAS operations provide.
Privacy

All flights will occur over public property or private property with the landowner’s prior consent.

Conclusion

Georgia Southern University’s Executive Technology Services and UAS Operations seeks an exemption

from the FARs set forth above and in Appendix A to allow commercial operations of a sUAS conducting

remote aerial data acquisition with a focus in aerial imaging, structural inspections, flight testing and

training.

Approval of this exemption allowing commercial operations of the two sUAS for aerial data acquisition will

enhance safety by reducing risk. Conventional aerial data acquisition operations, using turbine or piston‐‐

powered full scale aircraft present risks associated with vehicles that can weigh 5,000 to 7,000 lbs., or more,

carry large quantities of fuel, passengers, and, in some cases, cargo. In contrast, these two sUAS weighing less

than 6 lbs. and powered by batteries eliminates a portion of that risk given the reduced mass and lack of

combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose

any individuals to the risks associated with manned aircraft flights.

Additionally, no national security issue is being raised by the grant of the requested exemptions because

all pilot in command personnel will be certified through the FAA.

The operation of the two sUAS models weighing less than 6 lbs., for aerial data acquisition in accordance with

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

exemptions requested herein.

These sUAS provide satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight,

speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual line

of sight, and 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 two

sUAS in the remote sensing business.

Joseph Reeves

Director

Executive Technology Services & UAS Operations

Georgia Southern University

P.O. Box 8136

Statesboro, GA 30460

jreeves@georgiasouthern.edu
APPENDIX A:

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

GEORGIA SOUTHERN UNIVERSITY EXECUTIVE TECHNOLOGY SERVICES & UAS OPERATIONS 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 command of an

aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or

employment; and (2)

The aircraft does not carry passengers or property for compensation or hire.

Equivalent Level of Safety

Currently, there are no applicable areas identified for sUAS in either the private or commercial sector and

therefore an exemption is required to conduct commercial 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 X8 & Y6 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 from the minimum safe altitude requirements of 14

C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above the surface and

away from any person, vessel, vehicle, or structure in non‐‐congested areas.

To provide the intended operations, the sUAS is operated below 400 feet AGL.
Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the 6 pounds proposed herein,

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

presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight,

and speed of the UAS, as well as the location where it is operated. As set forth in the operations section of

this exemption, the sUAS will be operated away from densely populated areas and at least

5nm away from airports (unless a letter of agreement from the airport’s management is obtained), where

buildings and people will not be exposed to operations without their pre‐‐obtained 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: Altimeter Settings

This petition seeks 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 required because the sUAS uses AGL from takeoff

location and not MSL altitude.

Equivalent Level of Safety

An equivalent level of safety will be achieved by the operator confirming the altitude of the launch site

shown on the altitude indicator before flight. Moreover, the PIC will use the barometric altitude AGL

indicator to constantly monitor the sUAS height, thus ensuring operation at safe altitudes.

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

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

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

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming

normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes;

Here, the battery powering the UAS provides approximately 12 minutes of flight. To meet the 30

minutes reserve requirement in 14 C.F.R. § 91.151, sUAS flights could not be conducted. Given the

limitations on the sUAS proposed flight area and the location of its proposed operations within a

predetermined area, a safety margin based on a reserve amount of battery life is needed.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on‐‐site without

significant transit time by the sUAS. All flights will be planned to be terminated with no less than 25% reserve

battery power still available. This restriction would be more than adequate 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

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel 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. § 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 maintenance 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 each owner or operator of an aircraft “shall have the aircraft

inspected as prescribed in subpart E of this 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 certificate, 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 checklist, perform required maintenance, and keep

a log of any maintenance performed. The operator is the person most familiar with the aircraft and best

suited to maintain the aircraft in an airworthy condition.
APPENDIX B: SUMMARY OF Georgia Southern University Executive

Technology Services and UAS Operations’ SECTION 333

EXEMPTION REQUEST

Georgia Southern University Executive Technology Services and UAS Operations hereby provides pursuant to

Part 11 a summary of its exemption application to allow commercial operation of the 3D Robotics X8 and DJI

Phantom 3 Professional unmanned aircraft in remote aerial data acquisition. 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).