U.S. Depa rtment of Transportation December 22 , 2015 Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

**Integrated Wildlife Control** Section 333 Petition to Operate Small Unmanned Aerial Systems

Prepared by: Donald A. LaFountain Senior Partner Integrated Wildlife Control P.O. Box 61169 Florence, MA 01062 416.586.0890 don.iwc2011@gmail.com**Petition Summary** Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub L. N0. 112.85 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration's (“FAA”) general exemption authority under 49 U.S. C. section 44701(f), Integrated Wildlife Control (“Petitioner”) hereby petitions for exemptions from 14 C.F.R. Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 (Airworthiness Standards, Normal Category Rotorcraft), 14 C.F.R. sections 91.7(a), 91.119(c), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1)(2) , and 91.417(a)(b) , . The proposed exemption, if granted, would allow Petitioner to conduct commercial operations with small unmanned aircraft systems (“UAS”) also known as unmanned aerial vehicles (“UAV”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333. Petitioner is a wildlife damage control / mitigation company focusing on beaver related damage and flooding. Onsite inspections, damage assessments and situational status reports were previously done using ground and motor vehicle mounted camera systems. This has included but is not restricted to low and high elevation imaging of:

 Earthen Dams  Aqueducts  Flood Control Structures  Storm Water Control Systems  Powerline / Pipeline Access and Rights of Way  Railroad Culverts and Bridges  Water Treatment Facilities The exemption would facilitate the use of Unmanned Aerial Systems to allow more efficient and safer capture of data and images at higher altitudes (not to exceed 40 0 feet AGL) and operations over more rugged and remote locations than are currently possible with ground based systems. Other proposed operations under consideration for the petitioner include educational demonstrations for groups s uch as business, civic organizations as well as others. Donald LaFountain Senior Partner of t he Petitioner has held a Commercial Pilot Certificate ( #3108123) Lighter-Than -Air ba lloon since 2007 . He will utilize that certificate, flight review requirements , and DOT CDL (Commercial Driver’s License) medical to act as the chief pilot and flight operati ons manager for the Petitioning company. He will be examining quali fications and operating programs for various roles in the Petitioner's fligh t operations. He also h as over 100 hours of selfadministrated flight training and maneuvers in unmanned light mu lti - rotorcraft
. At this time, the Petitio ner will be operating two versions of same unmanned vehicle , the DJI Ph antom 2 (one flying at a time) utilizing observers as required. These vehicles will be flown at no more than 55 pounds total weight, and at speeds of no more than 87 knots (100 miles per hour). Energized by batteries with a flight time of up to 22 minutes, they are connected to four electric motors and four rotorblades per vehicle. The vehicles use GPS to detect their own location as well as designating critical operational areas and providing automatic return to base processes in case of loss of signal or low energy circumstances.
**Pre -** **Flight Inspection** The following inspection steps have been designed and tested for use by the Petitioner before every flight in a manner similar to manned aircraft flights. 1. Inspect all rotor blades for free and clear rotation. Check for any cracks or deformities. Replace b lades that show signs of damage
. 2. Check camera for gimbal range of motion, bent parts, or loose wires
. 3. Check battery in use for structural damage or other deformities
. 4. Check the entire frame for c racks including the landing gear. 5. Check every motor to make sure they a re seated properly and not loose (including all the screws)
. 6. Boot up the UAV on a flat surface and let it go through start- up . 7. Bring UAV to a hover slightly a bove eye - level and check for any strange movement/shaking
. 8. Do basic maneuvers (forward, backward, left, right, yaw left, yaw right, up & down). 9. Confirm no abnormal vibrations, proceed with flight operations. **Flight Operations** Our current survey and video capture operations are typically conducted in remote areas completely cleared of persons or property that would be in peril from accident other than those specific to the project. Pre - flight check with flight services and/or “DUATS” for weather forecast of VFR conditions , NOTAMS and TFRs
. Weather considerations including wind limits, humidity, and precipitation will be analyzed and applied toward every flight, as the type of aircraft being utilized need optimal conditions for safe and effective operations. Any vehicle that cannot pass its pre - flight inspection will be pulled from serv ice until repaired to satisfactory condition. Mission operations will be flown within visual line of sight of the pilot at all times, and a designated observer will maintain constant visual contact with the aircraft and verbal contact with the pilot in command. UAVs will remain 100 feet away from any inhabited structures or vehicles, but may approach closer to uninhabited elements for detailed surveying or imagery. For UAV operations within 5 nautical miles of non - towered airports, petitioner will contact airport management to obtain any necessary permission and to submit requested notifications such as “NOTAMs”. Operator will have an d use an ICOM -A6 VHF a ircraft transceiver tuned to the nearest local airport frequency to monitor and communicate as needed
.**Benefits derived from this specific petitioner.** Use of UAV/UAS vehicles would allow for legal, economical, efficient, and safe operations. Environmental impact on sensitive areas would be greatly reduced and in some cases eliminated. Greater data col lection will allow for control and better planning and protection of these areas as well as existing infrastructure

. Another major concern of petitioner is recognizing and respecting citizen's right to privacy in their homes and helping develop operational standards that will foster positive attitudes toward UAV operations as the industry expands in the future
. **Conclusion** For the reasons listed herein, we believe it would be a positive decision to grant the exemptions requested and allow the Petitioner to initiate UAS operations in accordance with safe operational documents provided by the vehicle manufacturers, the petitioner's own flight department, and operating parameters deemed necessary and appropriate by the FAA and other applicable governmental agencies moving forward.
Sincerely,

Donald A. LaFountain Senior Partner Integrated Wildlife Control