U.S. Department 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 

400 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 such as business, civic organizations as well 

as others.

Donald LaFountain Senior Partner of the Petitioner has held a Commercial Pilot 

Certificate (#3108123) Lighter-Than-Air balloon 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 operations manager for the Petitioning 

company. He will be examining qualifications and operating programs for various 

roles in the Petitioner's flight operations. He also has over 100 hours of selfadministrated flight training and maneuvers in unmanned light multi-rotorcraft.

At this time, the Petitioner will be operating two versions of same unmanned 

vehicle, the DJI Phantom 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 rotor
blades 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 blades 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 cracks including the landing gear.

5. Check every motor to make sure they are 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 above 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 service 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 and use an ICOM-A6

VHF aircraft 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 collection 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