Washington, DC 20590 

To Whom It May Concern: 

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 College 
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. Conclusion 
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 1 
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. 
• 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. 
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 on 
(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. 
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. 
I. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning "a flight in an airplane under 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 least30 minutes; or (2) At night, to fly after that for at 

least 45 minutes." Rhode Island College recognizes that an exemption from 14 CFR 

§91.151(a) falls within the scope of prior exemptions. The technological limitations on UAS 

battery power means that no meaningful flight operations can be conducted while still 

maintaining a 30 minute battery reserve. Rhode Island College believes that an equivalent 

level of safety can be achieved by limiting flights to 5 minutes or 25% of battery powerwhichever happens first This restriction would be more than adequate to return the UAS to 

its planned landing zone from anywhere in its limited operating area. An exemption from the 

fuel requirements of14 C.F.R. § 91.151(a) is therefore warranted. 

J.14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2); 91.417(a) and (b): 

Maintenance Inspections 

Rhode Island College seeks exemption from the maintenance inspection requirements 

enforced in 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) &(b). An exemption from 

these regulations is needed because these sections and Part 43 only apply to aircraft with 

an airworthiness certificate, which the UAS is not required to have. Maintenance will be 

accomplished pre and post flight by the operator under the guidance of the manufacturer's 

operating manual 

If mechanical issues arise the UAS can land immediately and will be flying at a height of 400 

feet or less AGL. The PIC will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

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

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An 

equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual by the PIC. An 

exemption from the Maintenance requirements of14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) 

(2); 417( a) and (b) is therefore warranted. 

K. 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations 

14 CFR 61.113 (a) &(b), states that no person who holds a private pilot certificate may act 

as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire. The proposed UAS operations may achieve an equivalent level of 

safety as reached by current regulations because Rhode Island College's UAS platforms will 

not carry any pilots or passengers nor property. The risks linked to the operation of UAS are 

far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The 

PIC of the UAS will be an FAA Certificated Private Pilot with current Third Class or higher 
The proposed UAS operations in this Petition for Exemption support the safe and controlled 

integration of UAS into the National Airspace System as directed by the US Congress. 

Therefore, this groundbreaking educational program will benefit the citizens of Rhode 

Island in many ways. For the first time, Rhode Island College students, the general public, 

and commercial interests will have access to programs that demonstrate the safe and 

ethical use of UAS platforms for commercial applications and for hobby enthusiasts. 

The program will utilize Rhode Island College's unique niche in the state to create 

collaborative efforts among members of the aviation community, other academic 

institutions, and the general public in order to develop a system for the safe and ethical use 

for UAV platforms in the National Airspace System. 

If this Petition for Exemption is granted the public as a whole will benefit from the use of 

best practices for safe and controlled operations training and the identification of the 

occupational needs of this growing industry. 

VI I. Privacy 

Rhode Island College's UAS operations shall be conducted in accordance with applicable 

federal, state, or local laws regarding privacy. Rhode Island College will not conduct flight 

operations over property that it does not own or control without the prior consent and 

knowledge of the property owner. Rhode Island College will not capture or use images from 

neighboring properties within the vicinity of UAS flight operations. 

VIII Drug & Alcohol Programs 

Rhode Island College currently has policies in place to ensure that no person may 

participate in UAS flight operations if they are under the influence of alcohol or any drug. 

IX. Federal Register Summary 

This summary is provided in the event that publication in the FEDERAL REGISTER is 

required. 

Rhode Island College's UAS education and training program seeks exemption from the 

following rules of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11: 

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 
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 EducatioW gram 

Rhode Island College 

HBS 206 

600 Mt. Pleasant Avenue 

Providence, RI 02908 

401 456-8793 

CMclaughlin@ric.edu