U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 ofthe FAA Reform Act of2012 and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. § 21, Subpart Hand 14 C.F.R. § 91.203(a)(1); 14 C.F.R. § 

91.9 (b); 14 C.F.R. § 45 .23(b); 14 C.F.R. § 91.203(a) and 91.203(b); 14 C.F.R. § 91.109(a); 14 

C.F.R. § 91.103; 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 

C.F.R. 91.151(a) 14 C.F.R. § 91.405(a), 407(a)(l), 409(a)(2), 417(a) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act), 

The Minnesota State College and Universities System, dba Northland Community and Technical 

College (the petitioner), hereby applies for an exemption from the listed Federal Aviation 

Regulations ("F ARs") to allow commercial operation of its sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333 . 

Northland is part ofthe Minnesota State Colleges and Universities System (MnSCU). The 

MnSCU system is the largest single provider of higher education in the state of Minnesota and 

the fifth largest system of colleges and universities in the United States. The system includes 31 

institutions (24 technical and community colleges and seven state universities) spanning 54 

campuses across 47 Minnesota communities serving more than 435,000 students annually. 

Northland provides innovative training programs and high-quality technical education. 

Northland currently offers over 110 programs, which lead to Associate's in Science (AS), 

Associate's in Arts (AA), and Associate's of Applied Science (AAS), degrees, diplomas and 

certificates. Northland's aviation programs have a rich history of excellence, quality and 

innovation. More than 20 individuals staffNorthland Aerospace, with hundreds of years in 

combined experience in aviation education and industry applications. Northland has been 

offering the Aviation Maintenance Technology program since 1959. 

The program, which is a Federal Aviation Administration (FAA) Part 14 7 certified program, 

concentrates training in all facets of repair and inspection in electrical, pressurization, hydraulics, 

instruments, navigation, and engine systems. 

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and their functionality within UAS. 

In 2011, Northland developed a unique Imagery and Geospatial Analysis program as a result of 

growing demand for technicians educated in collection, processing and product development of 

imagery and information data for diverse industries. 

On April 11, 2014 Northland received a Certificate of Authorization 2013-CSA-107 to operate 

the proposed aircraft in Roseau County, MN to research applications ofUAS in precision 

agriculture practices. Operations were conducted over the 2014 and 2015 growing season under 

this COA without any incidents or accidents. As a result of these operations and the continued 

interest by other programs in the Minnesota State Colleges and Universities System, Northland is 

requesting an exemption to continue building education, training and awareness for UAS 

operations and applications. 

Northland also has a pending National Science Foundation Advanced Technological Education 

Project Grant, which would be greatly enhanced as it focuses on developing education and 

pathways around UAS technology. 

With this exemption Northland is seeking to: 

Conduct UAS flight operations for education and training purposes. 

Conduct UAS flights to develop marketing and career pathways materials. 

Conduct UAS flights in support of research projects. 

Approving these exemptions for Northland will create a great benefit in increasing access to 

UAS education and training, leading to safe operating environments and discoveries in many 

industries that will benefit from the technology, ultimately in the public interest. 

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

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of sUAS by 

the applicant for commercial use under controlled conditions in airspace that is (1) limited; (2) 

predetermined; (3) controlled as to access; and ( 4) would provide an increased level of safety 

beyond that existing when fixed or rotor wing manned aircraft are used to accomplish the same 

purpose. 

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While Northland is filing this exemption request on its own behalf, it anticipates that its industry 

partners and other MNSCU institution, in the future, will file exemption applications to allow 

them to operate the multirotor sUAS in commercial operations as well . Northland will work 

with these entities to ensure similarity to this exemption application. 

Northland is submitting the following documents in support ofthis exemption application: 

(Exhibit 1) Currently approved FAA COA granted to Northland vetting the systems operations. 

(Exhibit 2) Vireo-Phoenix Manual 

(Exhibit 3) DJI Phantom Vision 2 Manual 

(Exhibit 4) DJI Phantom Vision 3 Manual 

(Exhibit 5) DJI Inspire Manual 

(Exhibit 6) 3DR Multirotor Manual 

(Exhibit 7) Lockheed Martin Indigo Manual 

Consistent with the requirements of 14 C.F.R. § 11.81, Northland provides the following 

information in support of its petition for exemption: 

The name and address of petitioner is: 

Minnesota State Colleges and Universities 

dba Northland Community and Technical College 

Attn: Curtis Zoller 

13892 Airport Drive 

ThiefRiver Falls, MN 56701 

Phone: (218) 683-8829 

Fax: (218) 683-8994 

Email Curti s.zoller@northlandcollege. edu 

AffiCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for an 

exceptional level of safety to operations. These limitations and conditions to which Northland 

agrees to be bound when conducting commercial operations under an FAA issued exemption 

include: 

1. Safety will be the first and foremost consideration in any sUAS operation. 

2. The sUAS will weigh less than 25 lbs. 

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p

y 

requirement. 

7. Prior to a sUAS flight, an area of operation will be established. This area of operation 

will include a defined lateral and vertical area, where the sUAS will operate. 

8. Coordination will be made with all persons and property owners within the area of 

operation. 

9. The operator will have received training in general operations of sUAS and up-to-date 

information on the particular sUAS to be operated as required. 

10. If the sUAS loses communication for longer than 120 seconds, the sUAS is 

preprogrammed with a contingency plan which will be in a place to safely terminate 

flight 

11. If the sUAS loses its GPS for longer than 120 seconds, the sUAS has the capability to 

begin a circular landing near its current location. 

12. The sUAS operator has the capability to abort a flight plan and manually fly the 

aircraft in case ofunpredicted obstacles, emergencies or other events. 

13. The sUAS will at all times give way to all other aircraft. 14. Flight planning will include flight completion with at least 10% battery power 

remaining or appropriate timing as measured by the sUAS reported on the ground 

control station. 

15. A briefing will be conducted in regard to the planned sUAS operations prior to 

operation at each new location. All personnel who will be performing duties within 

the boundaries of the area of operation will be present for this briefing. 

16. The sUAS operator will comply with all appropriate laws and regulations of state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

17. Written, to include electronic, and/or oral permission from the relevant property 

owners will be obtained prior to an operation. 

18. The sUAS will operate, under normal conditions, at a speed of no more than 60 mph. 19. Operations will not be conducted closer than 3 nautical miles from any airport or 

heliport without prior coordination with the airport operator and the airport air traffic 

control tower, if applicable. 

20. Operations will be conducted in line of sight over uncongested airspace as depicted 

on VFR and WAC sectionals. 

21. A Notice to Airmen ("NOTAM") will be issued not more than 72 hours in advance of 

flight, but not less than 48 hours before flight. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

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Northland is currently operating the Vireo UAS safely within the NAS in northern Minnesota 

pursuant to a COA (2013-CSA-107) granted by the FAA in 2014. 

Northland requests an exemption to the following regulations as well as any additional 

regulations that may technically apply to the operation of sUAS. 

A. 14 C.F.R. § 21, Subpart Hand 14 C.F.R. § 91.203(a)(l)- Airworthiness certificate 

B. 14 C.F.R. § 91.9 (b)- Flight manual, marking, and placard requirements 

C. 14 C.F.R. § 45.23(b) Markings ofthe Aircraft) 

D. 14 C.F.R. § 91.203(a) and 91.203(b)- Certificate requirements 

E. 14 C.F.R. § 91.109(a)- Flight instruction 

F. 14 C.F.R. § 91.103- Preflight Action 

G. 14 C.F.R. § 61.113(a) and (b)- Private pilot privileges and limitations 

H. 14 C.F.R. § 91.119- Minimum safe altitudes 

I. 14 C.F.R. § 91.121- Altimeter Settings 

J. 14 C.F.R. 91.151(a)- Fuel requirements for flight in VFR conditions 

K. 14 C.F.R. § 91.405(a), 407(a)(l), 409(a)(2), 417(a) -Maintenance inspections 

In detail: 

A. 14 CF.R. 21 Sub art H -Airworthiness Certificate atu/14 C.F.R. 91.203 a (1l_ 

Northland seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 14 C.F .R. 

Section 91.203(a)(1). Given the size and limited operating area associated with the sUAS to be 

utilized by the petitioner for Part 21 Subpart H, it meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular sUAS. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated without 

airworthiness certificates, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional fixed-wing aircraft or rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed sUAS operations. 

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owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F .R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to their size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry 

a substantial external load. 

B. 14 C.F.R § 91.9 (b)- Flight Manual, Marking, and Placard Requirements 

Northland seeks exemption from the flight manual, marking, and placard requirements of the 

FARs because the multirotor sUAS weigh approximately 25 lbs. at its maximum gross weight 

and due to the size cannot carry the approved airplane flight manual onboard. Furthermore, 

since the multirotor sUAS are unmanned, the aircrew member is located at a ground control station. As such, Northland proposes the following conditions and limitations to its request for 

ex emption from Section 91. 9(b): 

The approved airplane flight manual must be kept at the ground control station, where it is 

immediately available for reference by the aircrew member (pilot in command) of the multi rotor 

sUAS any time the unmanned aircraft is operating. 

The approved airplane flight manual must be made available within 10 days to any FAA, U.S. 

Department of Defense, or law enforcement official upon request. 

In order of identify the aircraft, the petitioner proposes that the information found on the 

registration certificate be permanently affixed to the aircraft: 

Manufacturer: Northland Community and Technical College 

Model: Multirotor Unmanned Aircraft 

Serial Number: XXXXX 

Registration Number: XXXXX 

C 14 CF.R. § 45.23(b) Markings o(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 station, in letters not less than 2 inches nor more that 6 inches high, the words "limited", 

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

In previous Grant ofExemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identifications (N-Number) markings in 

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appropriate and current airworthiness certificate and an effective U.S. registration certificate be 

carried within the aircraft), and further, requests relieffrom the requirement of Section 91.203(b) 

(i.e., that the airworthiness certificate be displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew). As the muiltirotor sUAS are unmanned, it has no cabin, cockpit, 

pilot station, or entrances thereto. Therefore, the aircrew member is located at a ground control 

station and no passengers are carried at any time. As such, Northland proposes the following 

conditions and limitations to its request for exemption from Sections 91.203(a) and (b): 

The documents required by Sections 91.203(a) and (b) must be kept at the ground control station, 

where it is immediately available to the aircrew member (pilot in command) of the multirotor 

sUAS any time the unmanned aircraft is operating. 

The documents required by 91.203(a) and (b) must be made available within 10 days to any 

FAA, U.S. Department of Defense, or law enforcement official upon request. 

The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565,9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

E. 14CF.R §91.109(a)-Flightinstruction 

Northland requests exemption from Section 91.109(a) provides that no 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. 

sUAS and remotely piloted aircraft, by their design typically do not have fully functional dual 

controls. Flight control is accomplished through the use of a ground control station that 

communicates with the aircraft via radio communications. The multirotor ground control station 

is based on a computer and while it does not offer a second set of "controls", both the student and 

instructor can, and will, operate the single set of controls simultaneously. With both student and 

instructor having "hands-on" the controls during flight, we feel that this technique meets the 

intent 91.109 and provides an equivalent level of safety. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. 

The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

and 9862A. Also, see most recent exemption approvals for Astraeus Aerial, Aerial MOB. 

HeliVideo Productions, RC Pro Productions. Snaproll Media and Pictorvision for further 

justification of approval. 

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An equivalent level of safety will be provided by following the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actions, 

including performing all required checklists and reviewing weather, flight requirements, battery 

charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, 

before initiation of flight. 

G. 14 CF.R. 91.119 - Minimllm sa e altitudes 

Northland requests exemption from the requirement of Section 91.119. Section 91.119 

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. 

To provide the intended aerial surveys and inspections, the sUAS are normally operated below 

500 feet AGL. In addition, due to the nature of the proposed operations, the operator may at 

times be less than 500 feet away from structures during the operation. 

Compared to flight operations with conventional fixed-wing aircraft and rotorcraft weighting far 

more than the maximum 25 lbs. proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, speed of the sUAS 

as well as the location where they will be operated. As described, the sUAS will be operated in a 

restricted area, where buildings and people will not be exposed to operations without their preobtained consent. No flight will be taken without the permission of the relevant property owner 

and/or local officials. Because of the advance notice to the property owner and participants, all 

relevant affected individuals will be aware of the planned flight operations as set forth herein. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft 

that are subject to the minimum safe altitude regulations. 

H 14 CF.R. -Private ilot rivile es and limitations 

Section 61.113(a) limits private pilots to being in command of non-commercial flights. Section 

61.113(b )(1) provides an exemption that allows a private pilot to command an aircraft without 

passengers or property, in connection with business or employment if"[t]he flight is only 

incidental to that business or employment." That exemption likely does not apply to the 

proposed operations under this petition for exemption, as the flights are not incidental to the 

proposed aerial surveys and inspections but rather essential to it. Accordingly, this petition seeks 

an exemption to§ 61 .113(a)'s commercial limitation and/or Section 61.113(b)(1)'s requirement 

that the flight be incidental to the business to benefit from the exception. 

The purpose of 61 .113 is to ensure that the skill and competency of any PIC matches the airspace 

in which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

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UAS is less than the level of risk associated with commercial operations contemplated by Part 61 

when drafted- that is, allowing the proposed operations in this petition for exemption exceeds 

the present level of safety achieved by Sections 61.113 (a) and (b). 

I. 14 CF.R § 91.121-Altimeter Settings 

Section 91.121 provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet 

AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with 

other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be 

Above Ground Level and should be based on the barometric pressure at the point of launch. To 

provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground 

prior to every flight. Since the aircraft will fly no more than 50 minutes, even rapid changes in 

barometric pressure will have limited effect on the safety of the flight. Additionally, the aircraft 

maintains cruise altitude mostly from GPS altitude readings, so rapid fluctuations in atmospheric 

pressure will have even less of an effect. 

Given these conditions an equivalent level of safety is provided in line with previous exemption 

to Astraeus Aerial, Docket No. FAA-2014-0352. 

J. 14CF.R91.151(a -Fuelre uirements or i htinVFRconditions 

This regulation prohibits an individual from beginning "a flight in an airplane under Visual 

Flight Rules (VFR) conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal cruising speed-

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at 

least 45 minutes." The multirotor batteries provide up to 30 minutes of powered flight without posing risk to the 

battery system. Without an exemption from§ 14 CFR 91.151, the UAS's flights would greatly 

limit the system's ability to perform effectively. Given the limitations on its proposed operations 

and the location of those proposed operations, and daylight only VFR flight conditions, a longer 

time frame is reasonable. 

Northland believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a 

prior exemption. Operating the sUAS, without 30 minutes of reserve fuel does not engender the 

type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the 

sUAS operates. The fact that it carries no pilot, passenger, or cargo also reduces its liability. 

Additionally, limiting sUAS flights to a time limit vs a relevant battery percentage would greatly 

reduce their utility. In the unlikely event that the multi rotor aircraft should run out of fuel, it 

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Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, 

11311 and 11062. 

K 14 CF.R. § 91.405(a), 407(a)(1), 409(a) 2 417 a -Maintenance ins ections 

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this 

chapter. ... " Section 91.407 similarly makes reference to requirements in Part 43; Section 

91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

Maintenance of the multirotor sUAS will be accomplished by the owner/operator pursuant to the 

training manuals, such as exhibits, provided in the attachments. An equivalent level of safety 

will be achieved because the sUAS is small in size, will carry no external payload, will operate 

only in restricted predetermined areas and is not a complex mechanical device. The operator of 

the multirotor sUAS will ensure that the sUAS are in working order prior to initiating flight, 

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

the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft 

in an airworthy condition and to ensure an equivalent level of safety. 

OPERATOR REQUIREMENTS 

Northland respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Certain sUAS, such as the multirotor, are characterized 

by a high degree of pre-programmed control and various built-in technical capabilities that limit 

the potential for operation outside of the operating conditions set forth above. 

The multirotor sUAS have a semi-autonomous navigation and control system comprised of a 

ground control station and auto-pilot system. Flights can be pre-programmed with GPS guidance 

and do not require human intervention. However, flight mission area and routing can be changed 

after launch. The operator can change the route and the altitude; however these changes are all 

stabilized/assisted by the auto-pilot system, and the airspeed, altitude, and bank angle limits are 

all enforced by the auto-pilot, so that true 100% manual flight is never allowed. Flights are not 

directed by positive manual control, nor are evasive maneuvers. In the case of unplanned events, 

the operator inputs pre-programmed evasive maneuvers from the control unit and the control unit 

executes that maneuver. Pre-programmed operator interventions include diversion to the right; 

initiation of holding at present position; suspension of mission; fly back to launch point; fly to 

point and hold; abort mission and land; and emergency power cut off and land. 

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C. The motor is driven by a pulse width modulated signal, not an analog signal. 

Given these safety features, Northland proposes that operators of the multirotors should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required 

to have completed a minimum of a recreational or sport airman certificate. 

PUBLIC INTEREST 

An opportunity exist to bridge the gaps between an industry seeing potential in new technology 

and academic training programs that can provide education on safe operating procedures and 

guidelines. sUAS flights in the NAS are becoming more frequent and many incidence have 

recently been reported by unauthorized operators. Many of the individuals responsible for these 

incidences are not professional and have not received formalized training in sUAS operation. 

Granting this exemption will continue furthering education on safe operations of sUAS. The 

exemption will provide the industry with operators who demonstrate good aeronautical judgment 

by implementing proper risk management and safety practices while operating sUAS in the 

NAS. 

Consistent with the requirements of 14 C.F.R. § 11.81(d), Northland offers the following reasons 

why granting this petition for exemption is in the public interest. Granting the present petition of 

exemption will further the public interest by allowing Northland to safely, efficiently, and 

economically perform aerial data acquisition, research, training and educations in support of in 

support of a wide range of industries and applications. As an example the data captured by the 

multirotor sUAS will be used to help farmers plan their planting and harvesting methods, address 

fertility, disease, and pest issues in a timely manner, and market their crops. Additionally, the 

use of the multirotor sUAS significantly improves safety and reduces risk by alleviating human 

exposure to danger and emissions associated with current aerial survey and inspection methods, 

namely full-sized manned aircraft. If one of the multirotor sUAS crashes, there is no fuel to 

ignite and explode. Any impact of the multi rotor sUAS is far less than a full-sized manned 

aircraft. Furthermore, there are no privacy issues that will be raised, because the multirotor sUAS 

will only be operated in areas with the permission of the relevant property owners, and in 

accordance with all Federal Aviation Regulations. 

SUMMARY 

Northland seeks exemption from the requirements of 14 C.F.R. § 21, Subpart Hand 14 C.F.R. § 

91.203(a)(1); 14 C.F.R. § 91.9 (b); 14 C.F.R. § 45.23(b); 14 C.F.R. § 91.203(a) and 91.203(b); 

14 C.F.R. § 91.109(a); 14 C.F.R. § 91.103; 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 91.119; 

14 C.F.R. § 91.121; 14 C.F.R. 91.151(a) 14 C.F.R. § 91.405(a), 407(a)(l), 409(a)(2), 417(a) 

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If additional information is required, do not hesitate to contact the undersigned. 

Sin~U 

Curtis Zoll ~ Associate Dean Aerospace Programs 

Northland Community and Technical College 

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