Oct. 2 2 , 2015

Oklahoma Department of Wildlife Conservation Information and Education Division P.O. Box 53465 Oklahoma City, OK 73152 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590 RE: Petition From Oklahoma Department of Wildlife Conservation Requesting Exemption U nder Section 333 of the FAA Modernization and Reform Act Dear Sir/Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Oklahoma Department of Wildlife Conservation (ODWC), a government agency headquartered in Oklahoma City, Okla. , seeks exemption from the requirements of 14 C.F.R. Part 11 to operate U nmanned Aircraft Systems. This exemption request will permit ODWC to operate Unmanned Aircraft Systems (UAS) for aerial photography, videography, environmental assessments, wildlife and habitat surveys, research, training, and facilities inspections within the National Airspace System (NAS). ODWC submits that the requested exempt under section 333 is proper since an equivalent level of safety will be ensured. The ODWC will use experienced personnel to fly the UAS using the methods, techniques and practices prescribed in the operating manual of each system. Furthermore, ODWC will ensure that it meets all of the requirements based on the UAS's size, weight, speed and operational capability; o peration of the UAS at or below 400 feet above ground level; and op eration of the UAS within the visual line of sight of the operator. Purpose of UAS operation and why this petition is in the public interest : ODWC intends to use UAS to acquire aerial imagery, research, training, and educational programs, all of which a re beneficial to society. Specific purposes for which UAS will be employed include aerial imaging and videography for use by the ODWC’s Information and Education Division in production of television programs and media releases, assessments of water and air quality, wildlife population assessments, habitat mapping, environmental aerial surveys and facilities inspections. The use of UAS will significantly reduce safety concerns in areas where terrain or subject matter is inaccessible, inhospitable, hazardous or unsafe to enter, or may cause undue injury or loss of life.2

By incorporating UAS into the specified programs, ODWC stands to gain significant savings while maintaining higher safety standards. With ODWC being a public entity, savings from the UAS will directly reduce operating costs, which directly benefits the public. Since any UAS in the ODWC fleet is battery
- powered and serves as a safe, efficient and economical alternative to a manned aircraft, the public stands to benefit from reduced pollution an d noise, as well as increased safety of life and property in the air and on the ground. Furthermore, the use of UAS by ODWC would reduce congestion around airports caused by arriving and departing aircraft. UAS do not require an airport to take off or land . Use of UAS would result in fewer aircraft that must be handled by air traffic control during takeoff, flight duration and landing phases of flight operations. The name and address of the Petitioner and Point of Contact is: Oklahoma Department of Wildl ife Conservation Attn: Information Supervisor Micah Holmes P.O. Box 53465 Oklahoma City, OK 73152 Telephone: (405) 521
- 3851 Regarding the Unmanned Aircraft System: ODWC will employ the following UAS in its fleet : 1. DJI Phantom 2 Rotorcraft The following attachment supports ODWC’s Section 333 Exemption Request:
• Exhibit 1
- DJI Phantom 2 User Manual (EN) v1.4 Regarding the Operation of the Unmanned Aircraft : Following is a summary of operational limitations and conditions that will ensure a higher level of safety to people and property based on regulatory guidelines:

• UAS speed is limited to a maximum of 33.5 miles per hour
. • UAS will not be flown at an altitude tha t exceeds 400 feet AGL
. • UAS will always weigh less than the maximum allowed weight of 55 pound s . • UAS will be flown in such a way that flight can be safely terminated. Two individuals will be engaged during each flight: one operating the UAS and the oth er serving as a visual observer.
• Every UAS used by ODWC will have an integrated Global Positioning System that calculates the UAS position and altitude , and relays that information to the operator on the ground.
• Additionally, t he UAS contains a failsafe mode whereby If its connection to the remote control is lost, the system is programmed to return the UAS to a predetermined location.
• UAS shall be operated to remain well clear of and pose no interference with manned aircraft operations . • UAS will onl y be operated during daytime hours respecting visibility and cloud clearance requirements . • UAS will not be used to monitor or record areas where there is a reasonable expectation of privacy.
• Any time the UAS operator sees or hears another aircraft and it appears that aircraft may come within a mile of the UAS, or it is questionable whether it will do so, the UAS operator will immediately reduce altitude and direct the UAS toward the designated landing area or an alternate landing area. Flight will only be3

resumed after the operator has determined that the other aircraft has maintained a separation of at least a mile.
• Prior to UAS flight, the operator and observer will preplan the flight and discuss possible contingencies and emergency procedures. Summ ary of r egulations from which ODWC seeks exemption: • 14 CFR Part 21, Subpart H
– Airworthiness Certificates Section 333 of the Reform Act authorizes the FAA to exempt aircraft from the requirement of an airworthiness certificate of the UAS involved upon consideration of the size, weight, speed, operational capability and proximity to airports and populated areas. The UAS that will be used by ODWC are safe when taking into account their size, weight, speed and operational capability, therefore an air worthiness certificate is not applicable. • 14 CFR Part 27
– Airworthiness Standards: Normal Category Rotorcraft The UAS used by ODWC are safe when taking into account their size, weight, speed and operational capability, therefore an airworthiness c ertificate is not applicable. Additionally, no ODWC
- operated UAS will carry pilots, passengers, explosive materials or flammable liquid fuels.
• 14 CFR 45.23(b)
– Aircraft Marking and Identification Requirements Due to the small size of the UAS, there is not enough space to place required markings on the UAS; however, ODWC will be ready to place markings on any UAS it operates if required to do so.
• 14 CFR 61.113(a)(b)
– Private Pilot Privileges and Limitations Even though UAS operated by ODWC will not carry a pilot or passengers, ODWC will still operate UAS by following all safety protocols including but not limited to flying at or below 400 feet above ground level, having at least two people (an operator and an observer) , and following all requirements to ensure compliance with safety regulations. Any ODWC
- operated UAS comes with built- in safety features and characteristics including navigation (GPS) system and autopilot features that will limit the UAS ab ility to operate outside predetermined flight area s and capabilities. Furthermore, UAS automated features and advanced fly
- safe controls consistently enable safe and reliable operation. • 14 CFR 91.7(a)
– Civil Aircraft Airworthiness In accordance wi th 14 C.F.R. Part 21, Subpart H, UAS do not require an airworth iness certificate, however, ODWC will follow and apply safety standards as outlined in the UAS operating manuals and by applying safety and pre - flight checklists and following maintenance stand ards.
• 1 4 CFR 91.9(b)(2)(c)
– Civil Aircraft Flight Manual in the Aircraft Any UAS in the ODWC fleet is small in size and there is no cabin or cockpit. There is no room onboard to carry a flight manual. The UAS does not carry a pilot , crew or passen gers. Operating Manuals and User M anuals will be with the UAS operator during the flight. • 14 CFR 91.103
– Preflight Action To provide for an equivalent level of safety as required by 14 CFR § 91.103, the follow ing protocols will be in effect: The U AS operator and visual observer will take all actions including systematic and comprehensive preflight checks (visual inspection of the UAS, battery charge checks, GPS functionality, and verify communication between the UAS Radio Control and UAS), safety p lan review, weather assessment , briefing of4

flight plan operations, flight battery power needs and requirements, aircraft performance data and landing/takeoff distances as applicable before proceeding with flight operations. • 14 CFR 91.109(a)
– Flight I nstruction UAS are remotely controlled aircraft that do not, by their nature, have fully functional dual controls. Flight control is accomplished through the use of a remotely operated hand
- held controller that communicates with the aircraft via radio telemetry. Given the size and speed of the UAS that ODWC will operate , an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS. Other weight and material characteristics and features of the UAS are also considered factors that contribute to safety.
• 14 CFR 91.119
– Minimum Safe Altitudes This section establishes safe altitudes for operation of civil aircraft. An equivalent level of safety will be achieved given the size, weight and speed of the UAS . To avoid risks to manned aircraft, flight operations will be restricted to 400 feet above ground level or below. No flight operations will occur without permission of property owner

s or land management agencies. If at any time the operator sees or hears another aircraft and it appears that aircraft may come within a mile of the UAS, or it is questionable whether it will do so, the UAS operator will immediately decrease the altitude of the UAS and direct it toward the designated landing area or alternate landing area. Flight will resume after the operator determine s that the other aircraft has maintained a separation of at least a mile. • 14 CFR 91.121
– Altimeter Settings The ODWC UAS do es not have a typical barometric altimeter onboard. However, altitude informa tion of the UAS will be provided to the operator on the ground via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAS to the operator for active monitoring of the flight path. This altitude information, combined with visual line of sight, at or below 400 feet above ground level, will ensure a level of safety equivalent to Section 91.121. • 14 CFR 91.151(a)
– Fuel Requirements for Flight in VFR Conditions All ODWC UAS flight operations w ill be terminated when 25 percent battery power reserve is reached. In the unlikely event that the UAS battery becomes drained, the UAS has built- in capabilities to auto - land , reducing risks to people and property. • 14 CFR 91.203(a)(b)
– Carrying Civil Aircraft Certification and Registration Due to the small size of the UAS, there is no cabin or cockpit. Therefore, the UAS has no space or onboard storage locat ion in which to carry certification and registration documents. The UAS does not carry a pilot, passenger or flammable fuel. • 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (a)(2); and 14 CFR 91.417(a)(b)
– Maintenance Required ODWC will follow the maintenance and inspections as recommended by the UAS manufacturer in the manufacturer’s manuals and manufacturer safety bulletins. UAS software will be updated as recommended by the manufacturer. Furthermore, ODWC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on th e UAS using the methods, techniques, and practices prescribed in the operating manuals Conclusion5

This Petition for Exemption meets all the criteria articulated in Section 333 of the Reform Act of 2012 including weight, speed, operating capabilities, and operation within visual line of sight. Approval of this exemption will allow for safety , efficien cy and cost savings for the Oklahoma Department of Wildlife Conservation and the public at large in fulfilling several mission s of ODWC . Respectfully submitted ,

Micah Holmes, Information Division Supervisor Oklahoma Department of Wildlife Conservation P.O. Box 53465 Oklahoma City, OK 73152 Phone: (405) 522
- 4872 Email: micah.holmes@odwc.ok.gov