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The University of Georgia ------------------9 

O tfo:c o f rh.: Vu:.: Pre,id.:nt for Research 

November 30, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of the University of Georgia for an Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (" Reform Act") and 14 C.F.R. 

Part 11, the Board of Regents of the University System of Georgia by and on behalf of the University of 

Georgia (" UGA") hereby requests and applies for an exemption from the Federal Aviation Regulations 

("FARs") identified herein to allow for commercial operation of small Unmanned Aerial Systems ("sUAS") 

for research, precision agriculture, and aerial data collection1 so long as such operations are conducted 

under the restrictions outlined herein. 

UGA requests this exemption based on the information contained in this Petition along with the 

accompanying User Manuals and other attachments. The exemption would permit UGA to utilize sUAS 

within the National Airspace ("NAS") in a safe, efficient, and economically feasible manner and to 

conduct research, precision agriculture, and aerial data collection, which provide important benefits to 

the public including improving agricultural crops, conducting fundamental research, improving the 

accuracy of mapping, and assisting in agricultural and natural resources planning. 

As a land-grant and sea-grant institution and the state's most comprehensive research institution, UGA 

conducts a wide range of research activities that benefits Georgia, the United States, and the globe. 

Examples of these activities that could be enhanced by sUAS use include: imagery of vegetation changes 

in response to ecological restoration, determining the effectiveness of fungicide applications, water 

resource monitoring, measuring drought stress on agricultural plots, three-dimensional mapping of 

landscapes and cultural features, monitoring of fish spawning, meteorological research, plant 

phenotyping, entomology research, rock structure mapping and identification, and research into the 

applicabil ity of sUAS into new and developing fields such as telemedicine. 

The ability to fly sUAS in the NAS in furtherance of these research activities, and the aerial data 

collection and precision agriculture uses the research necessarily involves, is one key element to 

growing UGA's research mission and propelling the United States into a new era of technological 

innovation. Without the use of a sUAS, precision agriculture, research, and aerial data collection are 

1 Aerial data collection includes, but is not limited to, imagery (photography, videography, infrared, etc.), electronic 

measurement (precision surveying, RF analysis, LIDAR, etc.), chemical measurement (particulate measurement, 

etc.), or any other gathering of data by instruments on board the sUAS, but not including closed-set motion picture 

and television filming and producing. 

150 Paul 0. Coverdell Center fo3.Biomedical and Health Sciences 

Athens, Gcorgi.i 30602 • Telephone 706-542-5969 • Fax 706-542 -5978 

An F.qu.1l Opportunity/ Alllrmatin: Action Institution 
either impossible or labor intensive and expensive, requiring both on-the-ground, physical work and the 

use of a small airplane to provide the level of detail required. A sUAS can provide information at a 

higher level of detail than traditional methods and do it in a fraction of the time and at a fraction of the 

cost. The FAA has previously granted 333 Exemptions for research, precision agriculture, and aerial data 

collection uses substantially similar to those requested herein; for example, see Exemptions 11710, 

11795, 11784, 11787, and 11769. 

Aircraft 

This application covers the following makes and models of sUAS: 

DJI Series of sUAS including: 

DJI Spreading Wings S900 

DJI Spreading Wings 51000 

DJI Spreading Wings 51000+ 

DJI Inspire 

DJI Phantom 2 

DJI Phantom 2 Vision 

DJI Phantom 2 Vision+ 

DJI Phantom 3 

3D Robotics XS 

Precisionhawk Hawkeye Lancaster 

All of the above-identified makes and models are commercially available small unmanned aircraft 

systems manufactured by leaders in sUA5 technology. The identified sUASs also include the entire 

package of the flight platform; camera, or other data-recording instrument; gimbal; flight control 

system; remote control; and/or Wi-Fi communication system as outlined in the attached Owner's 

Manuals. All identified sUA5s have a flight speed of less than 87 knots, have a takeoff weight of less 

than 55 pounds, and have a maximum flight time of less than 60 minutes. (For full operational 

capabilities see attached documentation.} The FAA has previously granted 333 Exemptions to all of 

these commercially available aircraft in accordance with the statutory criteria provided in Section 333 of 

Public Law 112-95 in reference to 49 U.S.C. § 44704. For example, see Exemptions 11160A, 11191, 

11694, 11305, 11364, 11326, 11240, 11710, 11648, 11956, 11883, 11345, 11508,and 11558. 

Proposed Limitations on Flight 

UGA proposes the following flight limitations in connection with any granted 333 Exemption: 

1. Operations of the sUAS will always be in accordance with any manufacturer operating and 

technical manuals. 

2. The sUAS will have a weight of less than 55 pounds including payload. 

3. The sUAS will not be operated at a speed exceeding 87 knots. 

4. The sUAS is incapable of carrying pilot or passenger and shall not carry pilot or passenger. 

5. The sUAS will not carry explosive, hazardous, or flammable materials. 

6. The sUAS will be identified by serial number, registered in accordance with 14 CFR part 47, 

and have identification markings in a size as large as practicable and in accordance with 14 

CFR part 45, Subpart C to the extent possible. 

7. The sUAS will not be operated at heights exceeding 400 feet AGL. 

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8. The sUAS will be operated only under visual flight rules and under visual meteorological 

conditions. 

9. The sUAS will be operated by the Pilot in Command ("PIC") using only unaided human 

vision or corrective lenses as specified on the Pie's FAA-issued airman medical certificate or 

U.S. driver's license. 

10. The PIC will have, at a minimum, a valid private pilot, sport pilot, or recreational pilot 

certificate. 

11. The PIC will demonstrate the ability to safely operate the sUAS in a manner consistent with 

any exemption that may be issued by the FAA. 

12. All sUAS operations will utilize a Visual Observer ("VO"). 

13. The sUAS will be operated only within Visual Line of Sight ("VLOS") of the VO and PIC. 

14. The sUAS will not be operated within five nautical miles of an airport reference point or the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart 

unless a letter of agreement is obtained from the airport's management. 

15. All operations will be conducted in accordance with an Air Traffic Organization Certificate 

of Waiver or Authorization. 

16. Prior to any sUAS operation the PIC will perform preflight checks in accordance with 14 CFR 

§ 91.103. Based on these preflight checks the PIC will determine whether the sUAS is in an 

airworthy condition and whether the operation can be conducted in a safe manner. The 

PIC is responsible for maintaining and inspecting the sUAS to ensure that it is in a safe 

operating condition prior to flight. 

17. The sUAS will not be operated over congested or densely populated areas. 

18. If the sUAS loses communication or its GPS signal, the sUAS will be programmed to return 

to a pre-determined location within the controlled-access property. 

19. In the event of an unpredicted obstacle or emergency the PIC will abort the operation. 

20. No operation will be attempted unless, considering wind and weather conditions, there is 

enough power for the sUAS to operate for the intended operational time and for five 

minutes thereafter or with the reserve power recommended by the manufacturer, 

whichever is greater. 

Exemption Request Summary 

UGA requests exemption from the following regulations when the aforementioned aircraft operate 

within the limitations listed herein: 

14 CFR §§ 61.23{a) and {c); 

14 CFR §§ 61.101(e)(4) and {S); 

14 CFR § 61.113(a); 

14 C.F.R. § 61.315(a); 

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); 

14 C.F.R. § 91.405(a); 

14 C.F.R. § 91.407(a){l); 

14 C.F.R. §§ 91.409(a)(l) and {a)(2); 

14 C.F.R. §§ 91.417(a) and {b). 

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The identified limitations provide for a level of safety that is equivalent to or higher than that of manned 

aircraft operations made under the current regulations as outlined below. 

14 CFR § 61 .23(a) and (c); 61.101(e}{4} and {5}; 61 .113{a); 61.315(a} 

The PIC for the sUAS will hold either a private pilot's certificate with corresponding FAA-issued medical 

certificate, a sport pilot's certificate with corresponding U.S. issued driver's license, or a recreational 

pilot's certificate with corresponding FAA-issued medical certificate. As noted in Exemption No. 11213, 

the requirement of a sport, recreational, or private pilot's certificate ensures that the PIC has the 

requisite aeronautical knowledge to safely operate a sUAS when operations are in accordance with this 

Section 333 Exemption. The FAA has previously granted relief to conduct operations in a similar 

manner; for example, see Exemptions 11213, 11783. 

14 CFR § 91. l(a) 

Given that there is neither an airworthiness certificate for the sUAS nor a standard for airworthiness 

that exists, an equivalent level of safety can be attained by allowing the PIC to certify airworthiness prior 

to each operation along with the operational guidelines noted above. The PIC will make this 

determination prior to flight and will ensure that the sUAS is operating within the parameters set forth 

by the sUAS operating and technical manuals as published by the manufacturer. The FAA has previously 

granted relief to conduct operations in a similar manner; for example, see Exemptions 11062 through 

11067, 11080, 11109, 11110, 11345, and 11213. 

14 CFR § 91.119{c) 

Section 91.119(c) requires operations of an aircraft be at an altitude greater than 500 feet AGL Given 

the operational restrictions listed in this Petition that limit any such operation to sparsely populated 

areas below 400 feet AGL, relief from§ 91.119(c) is warranted. Equivalent levels of safety are provided 

by the operational guidelines outlined herein combined with the nature of the sUAS itself. The small 

size, weight, and limited flight speed and altitude of the sUAS create minimal hazards to property or 

persons. The risk associated with such a sUAS operation is nominal when compared to traditional 

aircraft operations at this height. The FAA has previously granted relief to conduct operations in a 

similar manner; for example see Exemptions 11138, 11136, 11109 through 11112, 11062, 11063, and 

11067. 

14 CFR § 91.121 

The sUAS does not have a barometric pressure altimeter as required by§ 91.121. Utilizing an 

alternative method for measuring altitude based upon the sUAS GPS combined with the limited altitude 

of the operations conducted as outlined herein will maintain an equivalent level of safety. The FAA has 

previously granted relief to conduct operations in a similar manner; for example see Exemptions 11153, 

11150, 11138, 11136, 11159, and 11213. 

14 CFR § 91.151(a) 

Since the sUAS may not have the capability to fly for the durations outlined in§ 91.151(a), an exemption 

from§ 91.151(a) is requested. Given the operational requirements above, especially the identified 

battery-power limitation to operations, the sUAS is able to operate with an equivalent level of safety. 

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The FAA has previously granted relief to conduct operations in a similar manner; for example, see 

Exemptions 11213, 2689F, 5745, 10159, and 10650. 

14 CFR § 91.405(a); 407{a)(1); 409{a)(1) and (2); 91.417(a) and (b) 

The maintenance, inspection, and pre-flight inspection requirements mentioned herein, when combined 

with the size and operational limitations of the sUAS, ensure comparable levels of safety to the 

maintenance requirements of 14 CFR Subpart E (91.401-417). The FAA has previously granted relief to 

conduct operations in a similar manner; for example, see Exemption 11489, 11159, 11138, 11109, and 

11213. 

Conclusion 

The operational parameters outlined in this Petition satisfy the standards of Section 333 of the Reform 

Act and the FAA's subsequent guidance. In consideration of that fact, along with the substantial benefit 

to the public that granting this Petition provides, UGA respectfully requests approval of our requested 

exemptions. 

Should you have any questions regarding this Petition please do not hesitate to contact us. 

David Lee, PhD 

Vice President for Research 

University of Georgia 

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