National Headquarters – 451 McCormick Road, Coraopolis, PA 15108

Dear Sir or Madam:

The Ruffed Grouse Society (RGS) hereby submits a Petition for Exemption pursuant to Section 333 of the 

Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11 from the Federal Aviation Regulations (FARs) listed below. The purpose of this Petition is 

to allow what has been determined commercial operation of Small Unmanned Aircraft System (sUAS) in 

airspace regulated by the FAA for purposes of conducting wildlife surveys, forest habitat management 

planning, ecological research and promotional media. RGS is a 501c3 wildlife conservation organization 

operating a sUAS equipped to conduct aerial photography, videography and survey. 

Regulations from which the exemption is requested:

14 C.F.R. Part 21 Subpart H

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F .R. 91.151

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. (91.401 - 91.417)

The Ruffed Grouse Society (RGS), headquartered in Coraopolis, Pennsylvania, is a national wildlife 

conservation organization created in 1961, and since then has been dedicated to creating healthy 

forests for the benefit of ruffed grouse, American woodcock and other wildlife. RGS employs biologists 

who work with agencies and landowners to enhance this critical forest habitat utilizing scientific 

management practices, which includes conducting research and monitoring threatened wildlife

dependent upon early successional habitat and invasive plant species. At various times in the last year, 

aerial operations involving the RGS sUAS, a DJI Phantom 3 Professional Quadcopter Drone with camera,

has proven a great tool in habitat survey, project site evaluation and educational media creation due to 

the terrain, remote locale and mobility issues of high-stem volume habitat common in the grouse and 

woodcock range.

The continued incorporation of unmanned aerial systems, operations which have been discontinued 

since December 21, 2015, in various habitat and educational activities would greatly advance RGS

progress and effectiveness by providing greater project oversight and educational insight not possible 

through vantage points on the ground. The ability of a sUAS to fly slowly and quietly maneuver through 

multiple axes simultaneously and hover makes it far less intrusive than a manned or fixed-wing aircraft. 

RGS has found the DJI Phantom 3 to be an excellent tool for habitat survey while minimizing 

disturbances to the wildlife residing within these remote areas.
The RGS sUAS will be used to help our members and partners better understand healthy forest ecology

and literally provide a better look into what RGS does for the benefit of woodland wildlife. The use of

the sUAS would allow RGS wildlife biologists and state and federal wildlife biologists to survey habitat 

areas of concern without the risks to life, property and environment as well as extreme costs associated 

with low-level manned flights that have made these activities nearly impossible. The drastically reduced 

costs of such an operation would greatly extend the productivity of member donations and state, 

federal and private organization grant dollars that fund these projects that largely take place on state 

and federal lands managed for wildlife.

We are petitioning for exemption to enable the RGS (501c3 attached) to operate a DJI Phantom 3 

Professional equipped with a built-in three-axis gimbal and camera. This sUAV has a built- in capability 

to limit the height it can fly above the ground, to limit the radius of the distance it flies from the 

operator and to exclude it from Class B, C and D airspace including a no-fly zone feature. The Phantom 3 

Professional also has its “Failsafe” function of the DJI Naza-M V2 Flight Control system which 

automatically triggers a “Return Home” flight sequence, returning the sUAV to either a predetermined 

“Home” point or the exact location of take-off if the communication between the sUAV and the 

controller is disconnected. Additionally, the Phantom 3 Professional automatically enters a descent in 

the unlikely event of a loss of communication with the controller and GPS signal. This quadcopter is also 

equipped with DJI’s proprietary smart battery which adjusts low and critical battery life warnings by 

factoring in distance and altitude from the operator to prevent complete drainage of the battery in 

flight. The low battery life warning prompts the pilot with the option to immediately activate the 

“Return Home” sequence.

RGS flight operations will not deviate from the FARs except where specific exemptions are granted by 

the administrator. RGS flight operations will also meet the Model Aircraft Operating Standards as 

outlined in Section 336 of the FAA Modernization and Reform Act of 2012 and will be conducted within 

the following parameters:

• RGS will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that 

are a “sufficient distance” from populated areas within the sterile area described in the FOPM. Such

operations will insure that the sUAS will "not create a hazard to users of the national airspace system or 

the public."

• The sUAV will be programmed so that it will not be operated at an altitude of no more than 400 feet 

AGL, with most operations occurring less than 200 feet.

• Minimum crew for each operation will consist of the sUAS pilot and a visual observer.

• The sUAS operated by the petitioner will weigh less than 55 lbs. The Phantom 3 Professional weighs 

2.8lbs pounds.

• The sUAV will operate at speeds of no more than 30 knots.

Additionally, all operations will be over unpopulated natural areas that constitute the ruffed grouse and 

American woodcock ecosystem, with most flights keeping the sUAV within 1,000 feet of the pilot and 

observer. Operations will be conducted in accordance with rules and permitting requirements by 

managing agencies such as the United States Forest Service and various state wildlife and natural 

resource agencies. Although most of these areas are considered public lands, access is often extremely 

limited due to terrain and area remoteness which greatly reduce the likelihood of operating within close 

proximity to individuals or populated structures. Given the small size of the sUAS and the nature of the

environment over which it will operate, all operations would adhere to the Reform Act's safety 

requirements.
Under the requested exemption, RGS ensures that all operators have the public’s safety, both on the 

ground and in air, held at the highest priority and educated in the rules and policy the FAA has set in 

place for operating sUAVs. We respectfully request exemption under Section 333 to enable the RGS to 

operate efficient, limited, low-risk commercial sUAV operations for the activities stated respecting at all 

times the space and privacy of citizens and property while keeping the sky safe. For the additional 

review, we are also submitting documents provided by the sUAS manufacturer, including the Phantom 3 

Professional User Manual and Pilot’s Training Guide.

Sincerely,

Seth Heasley

Digital Media Specialist, Ruffed Grouse Society