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September 25, 2015

University of Nebraska at Kearney

Aviation Systems Management Program

905 W 25th St

Kearney, NE 68849

U.S. Department of Transportation 

Docket Operations

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Petition for Exemption and Relief from Specific Regulations of Title 14 of 

the Code of Federal Regulations Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 1012 (Public Law 112‐95) Regarding 

Commercial Employment of Unmanned Aircraft Systems (UAS)

Dear Sir/Madam,

Pursuant to Section 333 of Public Law 112‐95 commonly known as the “FAA

Modernization and Reform Act of 2012” or “The Reform Act”, The University of

Nebraska at Kearney, UNK, hereby applies for authorization to conduct civil unmanned 

aerial systems (UAS) operations within the United States National Airspace System 

(NAS) for the purpose of Research, Education and Constituent Service.

Because the Petitioner will accept the conditions of previously granted 

exemptions related to similar UASs and proposed uses, as outlined in 

detail herein below, and, given all operations will be conducted in 

accordance with blanket CoA announced March 25, 2015, we seek a

summary approval of this exemption request. 

Federal Register Summary

Pursuant to 14 CFR §11.81, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:
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The University of Nebraska at Kearney seeks exemption from 14 CFR Part 21,

Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR 61.113(a)(b); 14 CFR

91.7(a); 14 CFR 91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 

14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a)(b); 14 CFR 91.405(a); 14

CFR 91.407(a)(1); CFR 91.409(a)(1) and (a)(2); 14 CFR 91.417(a)(b) to allow

commercial employment of Unmanned Aerial Systems (UAS) utilizing optical, 

infrared, and other sensors in support of research, education and constituent service. 

This exemption will enhance safety by reducing risk to the general public and

property owners from the substantial hazards associated with performing equivalent 

work with conventional aircraft and rotorcraft.

The name and address of the applicant is:

Mr. Terry Gibbs

Aviation Systems Management Program 

University of Nebraska at Kearney

905 W 25th St.

Kearney, NE 68849

gibbst@unk.edu

308.865.8309
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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 AviationAdministration

FAR Federal AviationRegulation

GCS Ground Control Station

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airmen

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012,Section

333 SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight
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VMC Visual MeteorologicalConditions

VO Visual Observer
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Description of Petitioner 

The University of Nebraska at Kearney has a rich aviation history. Established in 1981, the UNK 

Aviation Systems Management program was the first in the nation to be designated by FAA as an 

Airway Science Program and today, almost 35 years later, UNK continues to serve the citizens of 

Nebraska and surrounding region with out-standing aviation expertise. Building upon this 

experience, UNK seeks to extend and expand its aviation teaching and outreach efforts to include 

UAS operations. 

Description of Proposed Operation

The use of unmanned aerial systems (UAS) in terrestrial commercial and science applications is 

now widespread and transforming. These devices are used regularly to: reduce costs; increase 

safety; boost knowledge of key agricultural parameters; assess progress and environmental

compliance; and study the terrestrial habitats and aggregations of wildlife. The use of UAS by

researchers can provide significant benefits including reduced costs, greater survey efficiency, 

reduced wildlife disturbance, reduced risk to human pilots and observers and higher data quality 

and quantity. However, today there are relatively few universities exploring these opportunities. 

The University of Nebraska at Kearney is seeking to develop a UAS program to help meet the 

needs of our institution in undergraduate and graduate education, research, and service. 

Examples of specific utilization include, but are not limited to:

UAS Specific Flight Training;

Environmental / Biological Survey;

Public Safety;

Construction Management;

Facilities Management; and

University Operations.

To achieve these goals, our academic and administrative programs need to engage in domestic 

UAS operations. Due to the nature of our work, these flights will occur primarily over rural 

Nebraska, but we do not wish to limit operations to an extent greater than that currently offered 

in the blanket CoA. 

OVERVIEW CHARACTERISTICS OF PROPOSED UAS

DJI Phantom 3 DJI Inspire 3D Robotics Solo

Aircraft Type Multirotor (4 Rotor) Multirotor (4 Rotor) Multirotor (6 Rotor)

Aircraft Weight 1.2kg/2.68lbs 2.9kg/6.5lbs 1.8kg/3.9lbs

Dimensions 438x451x301mm 438x451x301mm 460x460x250mm

Max Flight time (aprox) 23min 18min 25min

Max airspeed 31kts 43kts 47kts
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Propulsion Brushless DC motor Brushless DC motor Brushless DC motor

Power 15.2 v Lithium 

Polymer battery

22.4v Lithium 

Polymer battery

14.8v Lithium 

Polymer battery

Payload Still/Video/IR/MultiSensor

Still/Video/IR/MultiSensorStill/Video/IR/MultiSensor

QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE 

REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other potentially

relevant factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive UAS 

under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) away 

from populated areas; and (4) would provide an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

The UAS's planned to be operated are rotorcraft each weighing typically less than 15 lbs., 

and always less than 55 lbs., including payload. They would operate, under normal 

conditions, at a speed of no more than 50 knots. The principal construction material of the 

UAS aircraft would typically be foam, carbon fiber, aluminum and/or plastic. A 

certificated Pilot in Command (PIC) will perform operations, as outlined below, to ensure 

that the UAS will "not create a hazard to users of the national airspace system or the 

public." Given the small size of the UAS involved and the environment within which they 

will operate, the applicant believes that these operations fall 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 UAS to commence immediately. Also, due to 

the size of the UAS and the restricted area in which the UAS will operate, approval of the 

application presents no national security issue. The operation of UAS by knowledgeable 

professionals will serve to enhance safety, add to the public benefit, and reduce 

environmental impacts related to current methods of manned aircraft flight operations. 

These limitations and conditions to which the operator, or its employees, acting as UAS 

PIC agrees to be bound when conducting commercial operations under a FAA issued 

exemption:

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

aircraft: DJI Phantom 3, DJI Inspire, and 3D Robotics Solo.

2. UAS (aircraft and payload) will weigh less than 55lbs.

3. UAS will be operated at altitudes not greater than 200 feet AGL. Altitudes 

reported to ATC will be in feet AGL.

4. UAS will be flown at ground speeds not greater than 87 knots.

5. The UAS PIC will hold an airline transport, commercial, private, recreational or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or,

for holders of the sport pilot certificate, a valid U.S driver’s license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the recent flight experience requirement stated in 
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14 CFR § 61.57 and flight review requirements stated in 14 CFR § 61.56. 

6. PIC qualification will have a currency requirement of at least three take‐offs and landings 

within the preceding 90 days. PIC qualification flight hours will be logged in a manner 

consistent with 14 CFR § 61.51.

7. UAS will not be operated within 5 nautical miles (NM) of an airport having an 

operational control tower, or 3 NM of an airport with a published instrument flight 

procedure but not an operational control tower, or 2 NM of an airport without a 

published instrument flight procedure or operational control tower, or 2 NM of a 

heliport with a published instrument flight procedure. Flights will be operated in Class 

G airspace whenever possible. If operation in other airspace is required, the relevant 

controlling agency will be notified at least 24 hours prior to the operation and, if 

required, any necessary permission obtained

8. UAS flights will operate within visibility and cloud clearance requirements equivalent 

to Visual Flight Rules (VFR).

9. UAS operations will not be conducted during night, as defined within 14 CFR § 1.1.

10. UAS flights over land will not be operated by the PIC from any moving vehicle or 

device. 

11. UAS will not be operated from a raised platform.

12. The UAS will remain clear of and yield right of way to manned aviation operations.

13. UAS will be operated within visual line of sight (VLOS) of the PIC at all times. The 

PIC will use human vision unaided by device other than corrective lenses as specified 

on PIC’s FAA medical certificate.

14. UAS operations may employ a visual observer (VO). The VO may be used to satisfy

the VLOS requirement as long as the PIC maintains VLOS capability. TheVO and PIC 

must be able to communicate verbally for the duration of the flight. Electronic 

messaging or texting is not allowed during flight operations.

15. The VO will perform no duties other than assisting the PIC see and avoid other aircraft, 

obstacles, persons or property.

16. UAS will be equipped with an autopilot system. The UAS will utilize GPS navigation, 

failsafe’s, return to home (RTH) and flight abort safety features.

17. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe 

flight. Checklists developed from manufacturer operating documents will be the basis 

for this inspection. If the inspection reveals a condition that affects safe operation of the 

UAS, the aircraft is prohibited from operating until necessary maintenance has been 

performed and the UAS is found to be in a safe condition for flight. The Ground 

Control Station must be included in the preflight inspection.

18. Permission for flight will be obtained in advance from property owners or controlling 

agency. A Ground Station will be connected, by radio communication, to the UAS 

during the entire flight, which will give the PIC flight information such as GPS 

Position, Altitude, Air speed, Battery Remaining, and other telemetry information.

19. Flight boundaries will be established for each flight and such boundaries will be 

designed such that the UA will pass no closer than 500 feet from nonparticipating 

persons, vehicles or structures.

20. If the UAS loses communications or loses GPS signal, the UAS will return to a 

predetermined location within the established flight boundary and land or be recovered 

in accordance with manufacturer operations documents.

21. The PIC will abort any flight in the event of unpredicted obstacles, occurrence of 
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adverse weather or loss of UAS flight control capability in accordance with 

manufacturer operations documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

conditions) there is enough power to fly the planned route to the intended landing point 

and land the UAS with 25% of battery capacity remaining.

23. Documents required by 14 CFR § 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the UAS whenever the aircraft is operating. These 

documents will be made available to the Administrator or any law enforcement official 

upon request.

24. Before conducting flight operations, the radio frequency spectrum used for operation 

and control of the UA must comply with Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

25. A Flight Operations and Maintenance Log will be maintained for each UAS. 

Cumulative flight hours, maintenance activities, repairs, alterations and inspections will 

be noted.

26. Any UAS maintenance or alterations that affect UAS operation or flight characteristics, 

e.g. replacement of a flight critical component, must undergo a functional test flight. 

The PIC who conducts the functional test flight must make an entry in the Flight 

Operations and Maintenance Log.

REGULATIONS FROM WHICH EXEMPTION IS SOUGHT

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, including UASs, from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public interest.1

UNK seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 

and 91 for purposes of conducting the requested operations using UAS. Listed below are: 

(1) the specific sections of 14 C.F.R. for which exemption is sought, and; (2) the operating 

procedures and safeguards that Petitioner has established which will ensure a level of 

safety better than or equal to the rules from which exemption is sought.2

1

See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of 

regulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

2

See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek exemption.
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14 C. F.R. Part 21, Subpart H - Airworthiness Certificates and 14 C. F.R. § 

91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to aircraft normally used for the same application. These criteria are met, and 

therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. 

FAA- 2014-0352 at 13-14, 22. If, however, the FAA determines that there are some 

characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an 

exemption is requested.

Equivalent Level of Safety

The UASs selected by UNK are safe when taking into account their size, weight, speed, 

and operational capability. The UAS weighs less than 55 pounds and will be flown at less 

than 87 nm/h and completely outside controlled airspace. Additionally, the UASs carry

neither pilots nor passengers, carry no explosive materials and or flammable liquid fuels, 

and operate exclusively within the parameters stated in Manufacture’s Manuals.

Operations conducted under this exemption will be closely controlled and monitored by

the operator and will be conducted in compliance with local public safety requirements, to 

provide security for the area of operation. In all cases, the UAS operated under the

proposed conditions, will be at least as safe as, or safer than conventional rotorcraft 

operating with an airworthiness certificate without the restrictions and conditions of the 

proposed UAS operations.

Further, the UAS does not need a means to communicate with other aircraft or ATC, 

because those capabilities will be possessed by the PIC and Observer, who are not onboard 

the UAS. See Grant of Exemption, Docket FAA-2014-0352 at 13. In addition, the UAS 

will be operated at all times in visual line-of-sight and in VFR conditions. 

14 C. F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. To the extent the Petitioner's UAS would 

otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's 

airworthiness standards for the same reasons identified in the request for exemption from 

14 C.F.R. Part 21, Subpart H, supra.

14 C. F.R. Part 61, 14 C. F.R. § 61.113 and 14 C. F.R. § 61.133: Private and 

Commercial Pilot Privileges And L imitations

Regulation 61.113 stipulates:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 
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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.

Regulation 61.133 stipulates 

(a) Privileges—(1) General. A person who holds a commercial pilot certificate may act as 

pilot in command of an aircraft—Carrying persons or property for compensation or hire, 

provided the person is qualified in accordance with this part and with the applicable parts 

of this chapter that apply to the operation; and For compensation or hire, provided the 

person is qualified in accordance with this part and with the applicable parts of this chapter 

that apply to the operation.

Equivalent Level of Safety

Unlike a conventional aircraft that carry pilot, passengers and cargo, the proposed UAS are 

remotely controlled and carry no persons or cargo. The UAS are capable of a high degree 

of flight automation and employ technical capabilities that limit the potential for operation 

in an unintended manner. It is the petitioner’s belief that given the size, weight, speed, 

operating environment and operating capabilities of the UAS, an equivalent level of safety 

may be obtained by stipulating the UAS PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or, for the sport pilot certificate, a valid U.S. 

driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or 

her pilot certificate. The FAA has issued several exemptions to this regulation: see 

Exemptions Nos. 11284, 11281, 11282 and 11296.

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

Inasmuch as there will be no airworthiness certificate issued for the UAS Petitioner 

intends to use, UNK seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a 

civil aircraft be in airworthy condition to be operated. The FAA has stated that no 

exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 

are waived or found inapplicable. See Grant of Exemption to Astraeus Aerial, Docket No. 

FAA- 2014-0352 at 13-14, 22. Accordingly, Petitioner requests that the requirements for § 

91.7(a) be treated in accordance with 14 C. F.R. Part 21, Subpart H - Airworthiness 

Certificates and 14 C. F.R. § 91.203(a)(1) exemption requests.

14 C. F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C. F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft - For which an Airplane or 

Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless there is available in 
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the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

Except as provided in § 91.715, no person may operate a civil aircraft unless it has within 

it the following:

An appropriate and current airworthiness certificate 

No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Given the small size and configuration of the UAS, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the UAS because there is 

simply no room. Also the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean 

E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) 

and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS 

flight manual, registration certificate, and other required documents from the ground 

control station from which he or she is operating the aircraft. As this FAA Office of Chief 

Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these 

key documents during flight. Therefore, an equivalent level of safety will be achieved be 

ensuring that the pilot has access to the documents at the ground control station from 

which he or she is piloting the UAS.

14 C. F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

UNK seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter.

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include only the 

Roman capital letter "N" and the registration number is displayed on limited, restricted or 

light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot
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station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable.

14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that 

rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by

§ 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) 

markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as 

practicable." FAA Docket No. FAA-2014-0352.

Equivalent Level of Safety

UNK will mark all UASs with their N-Number on the fuselage. The markings will be 

made as large as practicable.

14 C. F.R. § 91.103: Preflight Action

UNK seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar 

with all information necessary to safely conduct the flight, an exemption is requested to 

the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

Following the Manufacturer’s Manuals will provide an equivalent level of safety. The PIC 

will perform a series of checklists in accordance with the Manufacturer’s Manuals. The 

PIC will also be required to review weather, flight requirements, battery charge, landing 

and takeoff distance, aircraft performance data, and contingency landing areas - before 

initiation of flight. The Manufacturer's Manuals will be kept at the ground control station 

and will be accessible to the PIC at all times while operating the UAS.
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14 C. F.R. § 91.109(a): Flight Instruction

UNK seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o person 

may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely

piloted aircraft, by their design, do not have functional dual controls. Instead, flight 

control is accomplished through the use of a device that communicates with the aircraft 

via radio communications. Accordingly, an exemption will be required for the flight 

instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UAS that UNK intends to use, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers 

are aboard the UAS, and all persons will be a safe distance away in the event that the 

UAS experiences any difficulties during flight instruction. Moreover, Petitioner will 

conduct training in a controlled and sterile environment. 

14 C. F.R. § 91.119: Minimum Safe Altitudes

UNK requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

§ 91.119. Section 91.119(c) prescribes the minimum safe altitudes under which aircraft 

may not operate, including 500 feet above the surface and away from any person, 

vessel, vehicle, or structure in non-congested areas. Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated 

"without hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically prescribed 

for helicopters by the FAA."

An exemption is required because the proposed UAS operations will need to occur 

below 400 feet AGL. Further, due to the nature of the proposed operations, the PIC, 

Observer(s), Instructor and/or Student may at times be less than 500 feet away from the 

UAS.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel with the UASs, 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 UASs, as well the controlled and sterile location where the 

operations will occur. In order to avoid any risk to manned aircraft, flight operations 

will be restricted to 400 feet AGL or below. These restrictions will ensure that the 

proposed UAS operations are performed in a manner that protects the safety of 

participants, non- participants, the UAS and other property.

14 C. F.R. § 91.121: Altimeter Settings
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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 to the extent that the UASs do not have a barometric altimeter, 

but rather a GPS altitude read out.

WHY GRANTING THIS PETITION IS IN THE PUBLIC INTEREST

As introduced above, the requested exemption would authorize the Applicant to 

perform civil operations with UAS that will provide significant benefits to the public 

interest:

1. The civil use of UAS to perform undergraduate and graduate education, research, 

and service in support of government entities, private research institutions, 

scientific studies and wildlife monitoring, all of which are critical to the well 

being of the general public. This includes rapid studies wildlife population 

assessments and critical habitat mapping.

2. A significant reduction in costs to conduct research, training and education 

programs. At present, our research programs have to use aerial surveys which 

can cost tens of thousands of dollars per day. By incorporating UAS into these 

programs we can incur significant savings and more efficiently conduct research 

in the public interest. The use of UAS will decrease congestion in the National 

Airspace System along with reducing the noise and air pollution generated during 

traditional manned aircraft flight operations.

Using UAS to complement field personnel, they reduce safety concerns when 

gathering data from inaccessible or unstable/unsafe areas and in extreme weather or 

terrain.

Operation of UAS will substantially reduce the risk to life and property in the air, and 

on the ground, which is commonly associated with traditional manned aircraft flight 

operations for marine science missions.

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." Approval of this exemption will allow for 

safer, more efficient and less costly science missions, and produce much higher data 

quality.

SUMMARY OF REGULATIONS FROM WHICH PETITIONER SEEKS 

EXEMPTION OR RELIEF

14 CFR Part 21, Subpart H

14 CFR Part 27

14 CFR 45.23(b)

14 CFR 61.113(a)(b)

14 CFR 91.7(a)
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14 CFR 91.9(b)(2)(c)

14 CFR 91.103

14 CFR 91.109(a)

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a)(b)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

CFR 91.409(a)(1) and (a)(2) 14 CFR 91.417(a)(b)

SUPPORTING AND TECHNICAL DOCUMENTS
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To be delivered under separate attachment 

DJI Phantom 3 Operating Manual

DJI Inspire Operating Manual

3D Robotics Solo Operating Manual