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

F ederal 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 promotion al media. RGS is a 501c3 wildlif e conservation organization operating a sUAS equipped to conduct aeri al 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 c reated in 196 1 , 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 practice s , which includes conducting researc h and monitoring threatened wildlife dependent upon early successional habitat and invasive plant species

. At various times in the last year

, aeri al operations involving the RGS sUAS, a DJI Phantom 3 Professional Quadcopter Drone w ith camera

, has proven a great tool in habitat survey, project site evaluation and educational media creation due to
the terrain , r emote 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 provi ding 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
disturbance s to the wildlife residing within these remote areas

.The RGS sUAS will be used to help our members an d 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 d ollars that fund these projects that largely take place on state and federal lands managed for wi ldlife

.

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 n o

- 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

c ontroller is disconnected. Additionally, the Phantom 3 Professional automatically enters a descent in the unlikely event of a loss of communication with the c ontroller and GPS signal. This quadcopter is also equipped with DJI ’s proprietary smart battery wh ich adjusts low and critical battery life warnings by factoring in distance a nd 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
“Re turn Home” sequence.

RGS flight o perations will not deviate from the FARs except where specific exemptions are granted by the administrator. RGS flight o perations will also meet the Model Aircraft Operating Standards as
outline d 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 op erated at an altitud e 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 p ilot and a visual o bserver. • 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 s peeds of no more than 30 knots.

Additionally

, a ll operations will be over unpopulated nat ural areas that constitute the r uffed 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 t he United States Forest Service and various state wil dlife 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

pro ximity to individuals or populated structure s . Given the small size of the sUAS and the nature of the

environmen t over which it will operate, all operations would adhere to the Re form 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 ha s set in place for operating sUAVs. We respectfully request exemp tion 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 manuf acturer, including the Phantom 3
Professional User Man ual and Pilot’s Training Guide.

Sincerely,

Seth Heasley Digital Media Specialist, Ruffed Grouse Society