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G Johnstown 

Division of Social Sciences 

Johnstown, PA 15904 

814-269-2990 

US Department of Transportation 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Petition for Exemption Under 14 CFR § 11.81 to Allow Use of Unmanned Aircraft Systems By 

Institution of Higher Education 

Petitioner: 

University of Pittsburgh at Johnstown 

Raymond B. Wrabley, PhD, Chair, Division of Social Sciences 

450 Schoolhouse Road 

lohnstown, PA 15904 

Tel: 814.269.2979 

Email:rbw@pitt.edu 

To Whom It May Concern, 

This application is substantially based on the FAA's findings in Exemption No. 11977 granted to 

Wiregrass Aerial Photography on July 6, 2015, and in reliance on the analysis provided therein. The 

requested exemption that would allow the University of Pittsburgh at Johnstown to operate a small 

Unmanned Aerial System (sUAS) over its campus for educational, research, and operations purposes will 

benefit the public and is consistent with the goals of Section 333 of the FAA Modernization and Reform 

Act of 2012. 

1.Sections from which exemptions are souaht: Application is hereby made for exemption from: 

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333 

b. 14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFR Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

V. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

X. 91.417 

2.Relief Soueht: 

a. The University of Pittsburgh at lohnstown wishes to operate small Unmanned Aircraft 

Systems (sUAS) for educational purposes to include videography, aerial photography, 
photogrammetry, facility inspections and analyses. The relief is sought because use of sUAS 

by institutions of higher education is currently prohibited by law unless performed under an 

exemption. 

b. This exemption will cover use of the following airframes, all of which weigh less than 55 

pounds including payload and energy sources: 

i. DJI Phantom 3 

ii. Other models to be added by future amendment to this exemption 

3. Public Benefit: 

a. Use of sUAS technology to obtain imagery, information, and data currently not available or 

obtained by use of manned flight or manual methods: 

i. Trains undergraduate students in the application and analysis of aerial 

photography and remote sensing for future employment in commercial, 

government, or non-profit uses of sUAS technology. 

ii. Provides the University of Pittsburgh at Johnstown with data regarding its 

campus and facilities, including biodiversity; conditions of roads, roofs, hiking 

trails, and physical plant; and traffic and parking patterns which can be used to 

enhance public safety and cost-efficiency of campus operations and benefit the 

public. 

iii. Use of a sUAS will provide an increased level of safety over the use of flights 

with crews or the use of personnel to conduct roof and structure inspections. 

iv. Reduces the cost of obtaining such information, which benefits students and the 

regional economy. 

V. Reduces environmental impact by eliminating sources of hydrocarbon emissions 

from manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 

and Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. AII repair and maintenance work will be conducted or approved by 

qualified personnel and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each aircraft. 

L. AII flight operations will be conducted by at least two individuals (PIC and observer) 

who will maintain verbal communication capability with each other at all times 

during the flight, and who will remain stationary on the ground during flight 

operations: 

i. A Pilot in Command (PIC) who possesses the following credentials or is 

trained and supervised by a person who possesses such credentials: 

1. An Airman Certificate issued under 14 CFR 61 screened by 

the TSA 

2. A Third Class medical certificate issued under 14 CFR 67 or a 

valid US driver's license issued by a state. 

3. At least 5 hours of flight experience and 3 takeoffs and 

landings in make and model being flown in the prior 90 

days. Such cycles and hours may be gained during flights 

under this exemption if a safe distance is maintained from 

persons in accordance with 14 CFR 91.119. 

ii. A Visual Observer. 

iii. A Sensor Operator as necessary. 
d. AII flight operations will be conducted in accordance with valid Certificates of 

Authorization. 

e. AII flight operations will comply with the following: 

i. The manufacturers' Aircraft Flight Manuats and Operations Guidelines which 

will be available to the PIC during flight operations. 

ii. University of Pittsburgh at Johnstown flight operation policies including lost 

communication and other emergency and safety procedures, which will be 

available to the PIC during flight operations. 

iii. Conducted in VMC conditions during daylight hours. 

iv. PIC and VO will maintain VLOS at all times. 

V. Pre-flight inspections (including ground control station) and safety risk 

assessments will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B or C, or published approach, SID or STAR space. 

ix. Restrictions required by a COA and letter of agreement with the John 

Murtha Johnstown-Cambria Airport, since the University of Pittsburgh at 

Johnstown campus is 3 nautical miles south of the airport. 

X. Not be made near persons as required in 14 CFR 91.119 and not over 

persons on the ground without their prior permission. 

xi. Conducted over the campus of the University of Pittsburgh at Johnstown. 

xii. Each flight will be logged in both the PIC's logbook and the aircraft logbook. 

xiii. Not exceed 75% of the battery of the aircraft. 

xiv. Any incidents will be reported to the NTSB within 24 hours of occurrence. 

xv. Any local FSDO requirements. 

xvi. AII other applicable regulations concerned with the operation of aircraft. 

xvii. Aircraft will use 2.4 GHz for control of aircraft with well-defined and tested 

lost link procedures. 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. Please contact me at any time if you require additional information or clarification. I look 

forward to working with your office. 

Sincerely, 

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Raymond B. Wrabley, Jr., PhD 

Chair, Division of Social Sciences 

University of Pittsburgh at Johnstown 

814-269-2979 

rbw@pitt.edu