1

September 25, 2015
University

of Nebraska at Kearney Aviation Sy stems Management Program 905 W 25 th 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 L aw 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 s ys tems (UAS) operations within the United States National Airspace Sy stem (NAS) for the purpose of Research, Education and Constituent Service.
Because the Petiti oner 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:2

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 25 th St. Kearney , NE 68849 gibbst@unk.edu 308.865.83093 **GLOSSARY OF ABBREVIATIONS** 
AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
CF R Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FA R Federal Aviation Regulation
GCS Ground Control Station
LO L Loss of Link
NAS National Airspace System
NOTAM Notice to Airmen
PI C 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
VF R Visual Flight Rules
VL OS Visual Line of Sight4

VMC Visual Meteorological Conditions
VO Visual Observer5

**Description of Petitioner** 
The University of Nebraska at Kearne y has a rich aviation history. Established in 1981, the UNK Aviation Sy stems Management program was the first in the nation to be designated b y FAA as an Airway Scie nce 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 it s aviation teaching and outreach efforts to include UAS ope rations.

**Description of Proposed Operation** The use of unmanned aerial sy stems (UAS) in terrestrial commercial and science applications is now widespread and transforming. These devices are used regularly to : reduce costs; increase safety ; boost knowled ge 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 efficie ncy , reduced wildlife disturbance, reduced risk to human pilots and observers and h igher data quality and quantity . However, today there are relativel y few universities exploring these opportunities. The University of Nebraska at Kearney i s seeking to deve lop 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 p rogram s 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**  1.2 kg/2.68 lbs 2.9 kg/6.5lbs 1.8kg/3.9 lbs **Dimensions** 438x451x301mm 438x451x301 mm 460x460x2 50mm **Max Flight time** (aprox) 23 min 18 min 25 min **Max airspeed**  31 kts 43 kts 47 kts6

**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/Multi

Sensor Still/Video/IR/Multi

Sensor Still/Video/IR/Multi

Sensor
**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 relativel y 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 typicall y less than 15 lbs., and alway s less than 55 lbs., including payload. They woul d 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 (PI C) will perform operations, as outlined below, to e nsure that the UAS will "not create a hazard to users of the national airspace s ys tem or the public." Given the small size of the UAS involved and the environment within which they will operate, the applicant believes that these oper ations fall squarel y within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, b y exemption, allow commercial operations of UAS to commence immediately. Also, due to the size of the UAS and the restricted ar ea 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 curr ent methods of manned aircraft flight operations. These limitations and conditions to which the operator, or its emplo yees, acting as UAS PI C agrees to be bound when conducting commercial operations under a FAA issued exemption:
1. Operations authorized b y this grant of exemption are limited to the following aircraft: DJ I Phantom 3, DJIInspire, and 3D Robotics Solo. 2. UA S (aircraft and payload) will weigh less than 55lbs. 3. UA S will be operated at altitudes not greater than 2 00 feet AGL. Altitudes reported to ATC will be in feet AGL. 4. UA S will be flown at ground speeds not greater than 87 knots. 5. The UAS PI C will hold an airline transport, commercial, private, recreational or sport pilot certificate. The PI C 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 st ated in7 14 CFR § 61.57 and flight review requirements stated in 14 CFR § 61.56. 6. PI C qualification will have a currency requirement of at least three take

‐ offs and landings within the preceding 90 day s. PIC qualification flight hours will be logged in a manner consistent with 14 CFR § 61.51. 7. UA S 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 instrum ent 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. I f operation in other airspace is required, the relevant controlling agen cy

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. UA S flights over land will not be operated b y the PI C from an y moving vehicle or device. 11. UA S will not be operated from a raised platform. 12. The UA S will remain clear of and yi eld right of way to manne d aviation operations. 13. UA S will be operated within visual line of sight (VLOS) of the PIC at all times. The PI C will use human vision unaided by device other than corrective lenses as specified on PI C’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 VL OS capability . Th e VO and PIC must be able to communicate verball y for the duration of the flight. Electronic messaging or texting is not allo wed 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 equippe d with an autopilot sy stem . 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 inspec tion 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, b y radio communication, to the UAS during the entire flight, which will give the PIC flight info rmation 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 nonpar ticipating persons, vehicles or structures. 20. If the UAS loses communications or loses GPS signal, the UA S will return to a predetermined location within the established flight boundary and land or be recovered in accordance with manufacturer operations documents. 21. The PI C will abort any flight in the event of unpredicted obstacles, occurrence of8 adverse weather or loss of UAS flight control capability in accordance with manufacturer operations documents. 22. The PI C is prohibited from beginning a flight unless (c onsidering wind and forecast conditions) there is enough power to fl y the planned route to the intended landing point and land the UAS with 25% of battery capacity remaining. 23. Documents required b y 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 l aw 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 Lo g will be maintained for each UAS. Cumulative flight hours, maint enance 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 PI C 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 s eeks 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. L isted 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: T he reasons wh y granting the exemption would not adversel y 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.9

**14 C. F.R. Part 21, Subpart H**
**- Airworthiness Cert** **ificates 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 me t, 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 Refo rm Act, an exemption is requested. Equivalent Level of Safety The UASs selected b y UNK are safe when taking into account their size, weight, speed, and operational capability

. T he UAS weighs less than 55 pounds and w ill 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 condu cted under this exemption will be closel y 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 c onditions, 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 PI C and Observer, who are not onboard the UAS. See Grant of Exemption, Docket FAA

- 2014

- 0352 at 13. In addition, the UAS wi ll 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. §**  **61.1 33**  **: 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 m ay , for compensation or hire, act as pilot in command of an aircraft in10

connection with any business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; 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 appl y 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 th e 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 obtai ned b y 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 PI C 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**
In asmuch 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 requi rements of Part 21 are waived or found inapplicable. See Grant of Exemption to Astraeus Aerial, Docket No. FAA

- 2014

- 0352 at 13

- 14, 22. Accordingl y, Petitioner requests that the requirements for § 91.7(a) be treated in acco rdance with 14 C. F.R. Part 21, S ubpart 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 b y § 21.5 of this chapter, unless there is available in11

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 foll owing: 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 b y 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 C ounsel 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 certifi cated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot12

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 b y § 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 prac ticable." 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 PI C will be familiar with all information necessary to safel y 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 PI C 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. T he Manufacturer's Manuals will be kept at the ground control station and will be accessible to the PI C at all times while operating the UAS.13

**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. Accordingl y, 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 re quests 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, vehi cle, 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 hel icopter complies with any routes or altitudes specifically prescribed for helicopters b y 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 PI C, 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 o f flammable fuel with the UASs, any risk associated with these operations is far less than those that presentl y 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 ma nner that protects the safety of participants, non

- participants, the UAS and other property. **14 C. F.R. § 91.121: Altimeter Settings**14

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 perf orm 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 program s. At present, our research programs have to use aerial survey s which can cost tens of thousands of dol lars per day . By incorporating UAS into these programs we can incur significant savings and more efficientl y conduct research in the public interest

. The use of UAS will decrease congestion in the National Airspace S ys tem along with reducing the noise and air pollution generated during traditional manned aircraft flight operations. U sing UAS to complement field personnel, they reduce safety concerns when gathering data from inaccessible or unstable/unsafe areas and in extreme we ather 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 exempti on would thereb y 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 sy stems in the national airsp ace s ys tem." 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 PETI TI ONER 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)15

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**16

To be delivered under separate attachment DJI Phantom 3 Operating Manual DJI Inspire Operating Manual 3D Robotics Solo Operating Manual