U.S. Department

of Transportation Docket Management System 1200 New Jersey Ave., SE Washington,

DC 20590 To Whom

It May Concern:

RHODE ISLAND COLLEGE Office of the President In accordance with Section 333 of the FAA Modernization

and Reform Act of 2012 and 14 CFR Part 11, Rhode Island College,
an operator

of small Unmanned Aircraft Systems (UAS), respectfully applies for exemption consideration from the listed Federal Aviation Regulations

to allow commercial operation and educational programs

of designated UAS platforms, provided such operations
are conducted within and under the conditions outlined

in this application

or as may be established

by the FAA as required
by Section 333. Approval

of this exemption would

" .... establish requirements

for the safe operation

of such aircraft systems

in the National Airspace System." This project will increase public education and awareness

of UAS operations, furthering aviation safety and aid others
in fulfilling the Secretary

of Transportation's request
to educate UAS operators

on the proper conduct for flying and laws pertaining

to the operation

of UAS platforms

in the National Airspace System. Rhode Island College's mission

is to develop

a meaningful and accessible UAS curriculum and information programs that will provide education and training opportunities

for this expanding industry. In accordance with 14 C

. F.R.

§ 11.81(a), Rhode Island College offers the following information

in support
of its Petition for Exemption. The primary contact person for this exemption petition

is: Dr. Nancy Carriuolo President Rhode Island College Roberts Hall Phone: (401) 456-8100 Fax: (401) 456-8287 Web: www.ric

. edu Email: Ncarriuolo@ric.edu **'-1\_~~** Dr. Nancy Carriuolo President Rhode Island CollegePetition for Exemption For your convenience,

the Rhode Island College petition

is organized

as follows: I. Description

of Petitioner I I. Description

of Proposed Operation I I I. Vehicle Types and National Airspace System Use IV. Proposed UAS Operations Requirements

of Section 333 of the Reform Act A. Exemption

is Requested Based on the VAS's Size, Weight, Speed, and Operational Capability B. Operational Restrictions V. Regulations
For Which Exemptions
Are Requested A. 14 C.F

. R. Part 21, Subpart

H Airworthiness Certificates and 14 C.F.R.

§ 91.203 B. 14 C.F.R.

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

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

§ 91.103

: Preflight Action F. 14 C.F.R.

§ 91.109(a): Flight Instruction G. 14 C.F.R.

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

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

§ 91.151(a): Fuel Requirements

for Flight
in VFR Conditions J. 14 C.F.R.

§ 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (2); 91.417(a) and (b): Maintenance Inspections K. 14 C.F.R. Part 61, 14 C.F

. R. § 61.3, 14 C.F

. R. § 61

. 113: Private Pilot Privileges and Limitations VI. Public Interest VI I. Privacy VI
I I. Federal Register Summary I V. ConclusionI. Description

of Petitioner Rhode Island College

is located
on a 180-acre park-like campus

in the Mount Pleasant section
of Providence. This location combines

a suburban atmosphere with easy access
to the benefits and resources

of the metropolitan area. Academic offerings are provided

in five schools: the Faculty
of Arts and Sciences, the Feinstein School of Education and Human Development,

the School
of Management,

the School
of Nursing, and the School of Social Work Rhode Island College

is accredited

by the New England Association

of Schools and Colleges and has also received accreditation

for specific programs from the following agencies: Council on Social Work Education, National Association

of Schools
of Art and Design, National Association

of Schools
of Music, National Association

of State Directors

of Teacher Education and Certification, National Council for Accreditation

of Teacher Education, and the Commission

on Collegiate Nursing Education. The college now serves approximately 9,000 students

in courses and programs both on and off campus. RIC is our state's first public institution

of higher education. The college operates under the aegis of the Council
on Postsecondary Education, one of two councils that comprise the Rhode Island Board of Education. The Board of Education

is an innovative integration

of policymaking
and planning
for elementary, secondary and higher public education

in our state. II. Description

of Proposed Operation Rhode Island College intends

to establish

a small UAS Flight Education Program. This program will introduce students

to the elements

of small UAS operation
for commercial
and non-commercial

use, including aerial data collection, aerial imaging

to support
its technology education and communication programs. Our proposed UAS training and safety programs will demonstrate how UAS flight operations must fit into the National Air Space System. All UAS training and instruction activities will occur under tightly controlled conditions

on property that
is more than five miles from any airport and is owned and controlled
by Rhode Island College. Upon completion

of Rhode Island College's UAS education program, students will be provided with

a Certificate

of Achievement. This "Certificate

of Achievement"
does not permit the student

to engage

in commercial UAS activities that are not in accordance with the Federal Air Regulations,
but rather,

is intended to be an acknowledgement

that the student has successfully demonstrated

a thorough understanding

of UAS operations within the National Air Space System. Ill. Vehicle Types and National Airspace System Use UAS Platforms: Rhode Island College proposes

to use the following UAS platforms
for its operations under this application: 2- YUNEEC QSOO Typhoon
4k 1- DJI Inspire

1Information
for National Airspace System Use: Approx. distance from Rhode Island College, 600 Mt. Pleasant Ave to TF Green Airport 10. 3 miles Approx. distance from Rhode Island College, 600 Mt. Pleasant Ave to North Central Airport 9.8 miles I V. Proposed UAS Operations Requirements

of Section 333 of the Reform Act A. Exemption

is Requested Based on the UAS's Size, Weight, Speed, and Operational Capability In order to assist the FAA in making

a safety assessment

of Rhode Island College's proposed operations, below

is a summary

of operational limitations and conditions which will ensure an equivalent

or higher level of safety
to operations conducted under current regulatory guidelines: • The UAS platforms weigh 55 pounds
or less. • Maximum total flight time for each operational flight will be limited
to 25% reserve battery power remaining. • Minimum crew for each operation will consist
of the UAS Pilot and at least one Visual Observer, and may include

a third, but separate, Camera Operator. • The Pilot in Control and Visual Observer will have been trained

in operation

of UAS and receive up to date information

for the particular UAS to be operated. • Flights will be operated within the visual-line-of sight of a pilot and an observer. • Flights will be operated

at an altitude
of no more than 400 feet AGL. • Flights will be operated

at a lateral distance

of at least 500 feet from any persons, inhabited structures, vehicles
or vessels that are not involved

in the inspection unless permission
has been received and appropriate waivers have been signed by the persons
or property owners

in advance. • Flights will be limited

to a speed of 50 mph and vertical ascent will be limited

to 15 mph. • The UAS will be operated and maintained

in accordance with the requirements

of the Manufacturer's Manuals and any manufacturer Safety Bulletins. • Prior to the operation,
the flights will be fully preplanned
and briefed, including possible contingencies
and emergency procedures.• All required permissions
and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement,

fire or other appropriate governmental agencies. • If the UAS loses communication
with the PIC, it will have the capability

to return
to the home launch location
or a pre-determined

safe abort location. • Contingency plans will be in place to safely terminate flight
if there

is a loss of communication between the pilot and the observer. • The UAS will have the capability

to abort flight in the case of unpredicted obstacles or emergencies. • All PICs will have

a Class III Medical Certificate. • All UAS operations will only occur in daylight, Visual Flight Recognition ("VFR") conditions.
IFR flights are prohibited and no flights will occur at night, or in adverse weather conditions. • The UAS platforms will be controlled

by 1.) Inspire Cl

- 2.4

- 2.83 GHz Remote Control System and 2.) Yuneec Typhoon
ST 10

- 2.4 GHz Remote Control System and the radio frequency spectrum used for operation and control
of the UA shall comply with the Federal Communications Commission ("FCC")
or other appropriate government oversight agency requirements. B. Approval

is Warranted Based on the Operational Restrictions Operational Safety Assessment Because

of the small size of the intended Rhode Island College UAS platforms and the controlled environment provided, the proposed operations will adhere
to the Reform Act's safety requirements.
The UAS platforms selected
by Rhode Island College are safe when taking into account their size, weight, speed, and operational capability. The UAS platforms weigh less than four pounds and will be flown at less than 35.0 mph outside controlled airspace. Furthermore,

the UAS carry neither pilots nor passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively within the parameters stated Manufacturer's Flight Manuals. The approval

of this application presents
no national security issues. The intent of the program

is to 1) educate the public on the proper operations ofUAS platforms;

2) create opportunities

to collaborate with federal, state, and local government agencies

to safely incorporate UAS platforms into their own work;
3) meet or exceed the level of safety surrounding

the proposed operations

for our students and the public's benefit. The requested exemption

is in the public interest.Accordingly, Rhode Island College requests that the FAA grant the requested exemptions. V. Regulations
for which Exemptions
are Requested A. 14 C.F.R. Part 21, Subpart

H Airworthiness Certificates
and 14 C.F.R.

§ 91.203 In an earlier exemption petition (Exemption
No. 1111 0) the FAA has previously determined that no airworthiness certification

is required for UAS platforms similar
to those that Rhode Island College plans to operate. Therefore

, we believe that no exemption

is necessary from Part 21

, Subpart
H. Given the size and limited operating area associated with the UAS platforms

to be used by Rhode Island College

, an exemption

is warranted from Part 21 Subpart

H because the UAS platforms meet the requirements

of an equivalent level of safety under Part 11 and Section 333 ofthe FAA Modernization

and Reform Act of2012

. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 ofthe FMRA both sanction 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 UAS. In all cases

, an analysis ofthese criteria demonstrates
that the UAS operated without
an airworthiness certificate,

in the restricted environment
and under the conditions outlined

in this proposal will be at least as safe, or safer, than

a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed. The Rhode Island College UAS Platforms

to be operated under this exemption: 1. weigh less than 55 pounds fully loaded, 2. carry no pilots or passengers,

no explosive materials

or flammable liquid fuels

, 3. will operate exclusively within the operations areas defined
in this application

. Operations under this exemption will be tightly controlled and monitored

by the operator. B. 14 C.F.R.

§ 91.7(a): Civil Aircraft Airworthiness Because
no airworthiness certificate will be issued for the UAS platforms, Rhode Island College requests
an exemption from 14 C.F

. R. § 91.7(a), which requires that

a civil aircraft be in an airworthy condition

to be operated. While Rhode Island College's UAS will not have an airworthiness certificate,
the FAA has determined that for the purposes

of this exemption
the PIC may determine prior to flight activities that the aircraft

is in an airworthy condition. The manufacturer's operating documents contain procedures which allow the PIC and observer

to determine whether the aircraft

is in a condition safe for flight. As a result of this, an exemption from§ 91.7(a)

is warranted. C. 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 Section 91.9 (b) (2) provides:
No person may operate

a U.S. registered civil aircraft

... (2) For which an Airplane

or Rotorcraft Flight Manual

is not required
by §21.S of this chapter, unless there
is available

in the aircraft

a current approved airplane
or Rotorcraft Flight Manual, approved manual material, markings, and placards,

or any combination thereof. The UAS, given its size and configuration

has no ability or place to carry

a flight manual
onthe aircraft, not only because there

is no pilot on board, but because there
is no room or capacity

to carry an item of this size on the aircraft. The equivalent level of safety will be maintained

by keeping the flight manual
at the ground control point where the operator
of the UAS will have immediate access

to it. Pursuant

to 14 C.F.R.

§ 91.203(a) and (b): (a) Except

as provided in§ 91.715,
no person may operate

a civil aircraft unless

it has within it the following: (l) An appropriate
and current airworthiness certificate

..
. (b) 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 and the UAS has no cabin or cockpit. In previous FAA findings,

it was acknowledged
that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the PIC of the UAS has access
to the UAS flight manual, registration certificate, and other required documents from the ground control station from which the aircraft operates. 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
by ensuring that the pilot has access
to the documents

at the ground control station from which the UAS
is flown D. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Rhode Island College seeks an exemption from the aircraft marking and identification requirements expressed

in 14 C.F

. R. §§ 91.9(c), 45.23(b) and 45.27(a).

In previous rulings

, the FAA granted exemptions under Section 333 ofthe Reform Act. The FAA ruled 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."
The UAS platforms operated
by Rhode Island College will bear N-number markings that are as large as practicable

in accordance with 14 C

. F.R. Part 45

, Subpart

C. 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 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.Due to the size of the Rhode Island College UAS platforms, limited surface area is available and may be too small to display markings

in standard size. Therefore,
the UAS will display markings
on the largest surface area available. This accommodation should satisfy the requirements outlined

in this section and warrant
an exemption from the Aircraft Marking and Identification Requirements. E. 14 C.F.R.

§ 91

. 103

: Preflight Action This regulation requires each PIC to take certain actions before each flight to insure the safety of the flight.

It 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. The PIC will take all actions necessary

to insure the safety measures are followed including, but not limited
to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation

of flight
In this case an exemption

is warranted because FAA approved aircraft flight manuals are not required for UAS flights, and are not provided for the aircraft

. F. 14 C.F.R.

§ 91.109(a): Flight Instruction Rhode Island College seeks an exemption from 14 C.F.R.

§ 91.109(a), which 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." UAS and remotely piloted aircraft,
by their design,
do not have functional dual controls. Instead, UAS flight control

is accomplished through the use of an electronic controller that communicates with the aircraft via radio communications.

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

of aircraft and for flight instruction using UAS. 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. Accordingly,

an exemption

is warranted for the flight instruction requirements

of 14 C.F.R

. § 91.109(a). G. 14 C.F.R.

§ 91.119: Minimum Safe Altitudes Rhode Island College requests
an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 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. See 14 C.F.R.

§ 91.119(c). 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." The UAS platforms will be operated

in a restricted area that
is owned
or controlled

by Rhode Island College.

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, nonparticipants,

the UAS and other property. For these reasons,
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, instructor, and student may at times be less than 500 feet away from the UAS.H.14C.F.R.§91.121:AltimeterSettingSection121requireseachpersonoperatinganaircrafttomaintaincruisingaltitudebyreferencetoanaltimeterthatisset"totheelevationofthedepartureairportoranappropriatealtimetersettingavailablebeforedeparture."Anequivalentlevelofsafetywillbeachievedbytheoperator,pursuanttothemanufacturer'smanual,confirmingthealtitudeofthelaunchsiteshownontheGPSaltitudeindicatorbeforeflight.Accordingly,astheUASplatformsmaynothaveabarometricaltimeter,butinsteadaGPSaltitudereadout,anexemptioniswarranted.I.14C.F.R.§91.151(a):FuelRequirementsforFlightinVFRConditionsSection91.151(a)prohibitsanindividualfrombeginning"aflightinanairplaneunderVFRconditionsunless(consideringwindandforecastweatherconditions)thereisenoughfueltoflytothefirstpointofintendedlanding,and,assumingnormalcruisingspeed-(1)Duringtheday,toflyafterthatforatleast30minutes;or(2)Atnight,toflyafterthatforatleast45minutes."RhodeIslandCollegerecognizesthatanexemptionfrom14CFR§91.151(a)fallswithinthescopeofpriorexemptions.ThetechnologicallimitationsonUASbatterypowermeansthatnomeaningfulflightoperationscanbeconductedwhilestillmaintaininga30minutebatteryreserve.RhodeIslandCollegebelievesthatanequivalentlevelofsafetycanbeachievedbylimitingflightsto5minutesor25%ofbatterypowerwhicheverhappensfirstThisrestrictionwouldbemorethanadequatetoreturntheUAStoitsplannedlandingzonefromanywhereinitslimitedoperatingarea.Anexemptionfromthefuelrequirementsof14C.F.R.§91.151(a)isthereforewarranted.J.14C.F.R.§91.405(a),91.407(a)(1),91.409(a)(1)&(2);91.417(a)and(b):MaintenanceInspectionsRhodeIslandCollegeseeksexemptionfromthemaintenanceinspectionrequirementsenforcedin14C.F.R.§91.405(a);407(a)(1);409(a)(2);417(a)&(b).AnexemptionfromtheseregulationsisneededbecausethesesectionsandPart43onlyapplytoaircraftwithanairworthinesscertificate,whichtheUASisnotrequiredtohave.Maintenancewillbeaccomplishedpreandpostflightbytheoperatorundertheguidanceofthemanufacturer'soperatingmanualIfmechanicalissuesarisetheUAScanlandimmediatelyandwillbeflyingataheightof400feetorlessAGL.ThePICwillensurethattheUASisinworkingorderpriortoinitiatingflight,performrequiredmaintenance,andkeepalogofanymaintenanceperformed.Moreover,theoperatoristhepersonmostfamiliarwiththeaircraftandbestsuitedtomaintaintheaircraftinanairworthyconditiontoprovidetheequivalentlevelofsafety.AnequivalentlevelofsafetywillbeachievedbecausemaintenanceandinspectionswillbeperformedinaccordancewiththeUASManufacturer'sUserManualbythePIC.AnexemptionfromtheMaintenancerequirementsof14C.F.R.§91.405(a);407(a)(1);409(a)(2);417(a)and(b)isthereforewarranted.K.14C.F.R.§61.113(a)and(b):PrivatePilotPrivilegesandLimitations14CFR61.113(a)&(b),statesthatnopersonwhoholdsaprivatepilotcertificatemayactasapilotincommandofanaircraftthatiscarryingpassengersorpropertyforcompensationorhire.TheproposedUASoperationsmayachieveanequivalentlevelofsafetyasreachedbycurrentregulationsbecauseRhodeIslandCollege'sUASplatformswillnotcarryanypilotsorpassengersnorproperty.TheriskslinkedtotheoperationofUASarefarlessthantherisklevelsinherentinthecommercialactivitiesoutlinedin14CFR61.ThePICoftheUASwillbeanFAACertificatedPrivatePilotwithcurrentThirdClassorhighermedicalcertificate.Allstudentinstructionflightswillbeconductedundercloselycontrolledenvironments,outsideofnavigableairspaceandawayfrompersonsorpropertynotinvolvedintheinstruction.Inaddition,thestudentinstructionflightswillbeconductedundertheclosesupervisionofaflightinstructorwhowillhaveanFAACertificatedPrivatePilot'slicense.ItisbelievedthattheoperationandlimitationssetforthinthisapplicationwillequatetothesafeoperationoftheUAS.VI.PublicInterestTheproposedUASoperationsinthisPetitionforExemptionsupportthesafeandcontrolledintegrationofUASintotheNationalAirspaceSystemasdirectedbytheUSCongress.Therefore,thisgroundbreakingeducationalprogramwillbenefitthecitizensofRhodeIslandinmanyways.Forthefirsttime,RhodeIslandCollegestudents,thegeneralpublic,andcommercialinterestswillhaveaccesstoprogramsthatdemonstratethesafeandethicaluseofUASplatformsforcommercialapplicationsandforhobbyenthusiasts.TheprogramwillutilizeRhodeIslandCollege'suniquenicheinthestatetocreatecollaborativeeffortsamongmembersoftheaviationcommunity,otheracademicinstitutions,andthegeneralpublicinordertodevelopasystemforthesafeandethicaluseforUAVplatformsintheNationalAirspaceSystem.IfthisPetitionforExemptionisgrantedthepublicasawholewillbenefitfromtheuseofbestpracticesforsafeandcontrolledoperationstrainingandtheidentificationoftheoccupationalneedsofthisgrowingindustry.VII.PrivacyRhodeIslandCollege'sUASoperationsshallbeconductedinaccordancewithapplicablefederal,state,orlocallawsregardingprivacy.RhodeIslandCollegewillnotconductflightoperationsoverpropertythatitdoesnotownorcontrolwithoutthepriorconsentandknowledgeofthepropertyowner.RhodeIslandCollegewillnotcaptureoruseimagesfromneighboringpropertieswithinthevicinityofUASflightoperations.VIIIDrug&AlcoholProgramsRhodeIslandCollegecurrentlyhaspoliciesinplacetoensurethatnopersonmayparticipateinUASflightoperationsiftheyareundertheinfluenceofalcoholoranydrug.IX.FederalRegisterSummaryThissummaryisprovidedintheeventthatpublicationintheFEDERALREGISTERisrequired.RhodeIslandCollege'sUASeducationandtrainingprogramseeksexemptionfromthefollowingrulesoftheFAAModernizationandReformActof2012and14CFRPart11:A.14C.F.R.Part21,SubpartHAirworthinessCertificatesand14C.F.R.§91.203B.14C.F.R.§91.7(a):CivilAircraftAirworthinessC.14C.F.R.§91.9(b)(2):CivilAircraftFlightManualintheAircraftand14C.F.R.§91.203(a)and(b):CarryingCivilAircraftCertificationandRegistrationD.14C.F.R.§§91.9(c),45.23(b)and45.27(a):AircraftMarkingandIdentificationRequirementsE. 14 C.F.R.

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

§ 91.109(a): Flight Instruction G. 14 C.F.R.

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

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

§ 91.151(a): Fuel Requirements

for Flight
in VFR Conditions J. 14 C.F.R.

§ 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (2); 91.417(a) and (b): Maintenance Inspections K. 14 C.F.R. Part 61, 14 C.F.R.

§ 61.3, 14 C.F.R.

§ 61.113: Private Pilot Privileges and Limitations

. X. Conclusion Rhode Island College's proposed operations

of Unmanned Aircraft Systems

in this Petition for Exemption fulfill the conditions expressed

in Section 333 of the Reform Act. In comparable requests made
in the past, the FAA has issued exemption
for similar criteria based on the UAS weight, speed, operating capabilities, proximity

to airports and populated areas, operation within visual line-of-sight
and national security. We respectfully submit this Petition for Exemption because we believe that we have met or in some cases exceeded the FAA requirements

for exemption. In advance, we thank you for your thoughtful consideration of

the requested exemptions. In the event that you have any questions,

or if you need additional information

to support the requested exemptions, please do not hesitate

to contact the undersigned: 

# }:~ **~(\_** Coordinator, Technology Educatio
W gram Rhode Island College HBS 206 600 Mt. Pleasant Avenue Providence,

RI 02908 401 456-8793 CMclaughlin@ric.eduManuals