Petition for Exemption to Operate Unmanned Aircraft in the National Airspace System Under Section 333 of the FAA Modernization and Reform Act of 2012

Heather Graham Davis, Ph.D.

Co Own er of Bird’s Eye View Aerial Science & Imagery

227 8 th Street Petaluma, CA 94952 hgdavis@sonic.net

707.235.0716 Sport Pilot 3787382

Summary: Bird’s Eye View Consulting, an Ecologica l consulting company seeks an exemption to grant relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

– Airworthiness Certificates. We propose to use UAS for image/video production to provide scientific surveys and analyse s for ecological, biological and geographical purposes

.

Regarding the Unmanned Aircraft System

1. How the proposed UAS operation will be safely conducted to minimize risk to the NAS or to persons and property on the ground.

We intend to use a DJI Quadcopte r Inspire. Includes the Aircraft, Gimbal, Camera, Remote Control, Battery

a. Summary of Design and Operational Characteristics

i. Size: 438x451x301 mm

ii. Weight: 2935 g

iii. Speed:

1. Max Ascent Speed: 5 m/s

2. Max Descent Speed: 4 m/s

3. Max Speed: 22 m/s no wind

iv. Operating Are a: Limited to Visual Line of Sight in ecological survey areas (see Regarding the Operation of Unmanned Aircraft )

b. DJI Inspire Aircraft Specs

i. Model: T600

ii. Weight (battery included): 2935 g

iii. Hovering Accuracy: Vertical 0.5 m, Horizontal 2.5 m

iv. Max Angular Veloc ity: Pitch 300 deg/s, Yaw 150 deg/sec

v. Max Tilt Angle: 35 deg

vi. Max Ascent Speed: 5 m/s

vii. Max Descent Speed: 4 m/s

viii. Max Speed: 22 m/s no wind

ix. Max Flight Altitude: 4500 mx. Max Wind Speed Resistance: 10 m/s

xi. Max Flight Time: Approx. 18 minutes

xii. Motor Model: DJI 3510

xiii. Propeller Model: DJI 1345

xiv. Operating Temperature Range:

- 10 to 40 deg C

xv. Diagonal Distance: 559 to 581 mm

xvi. Dimensions 438x451x301 mm

2. Procedures to be implemented to ensure the UAS is in a condition for safe flight

a. Operating Procedures

i. The PIC will be thorou ghly familiar with the aircraft and interface

ii. The PIC will use pre

- flight checklists to ensure the UAS is airworthy and does not pose a threat to persons or property on the ground or in the air

iii. The PIC will ensure the UAS is maintained, and repaired if

nec essary, to ensure the aircraft is in a condition for safe flight

iv. The PIC will ensure instruments read correctly (ie altimeter).

v. The PIC will continually assess terrain and avoid potential obstacles/hazards in the area of operation

vi. The PIC will assess weath er to ensure the UAS is airborne only with minimums of 3 SM visibility while remaining clear of clouds in Class G Airspace (or required minimum clearances in other Airspace classes)

vii. The PIC will immediately avoid and give right of way to any

manned aircraf t
viii. The PIC will keep the UAS at no greater altitude than 200 feet AGL and always within line of sight.

3. Radio Frequency Spectrum (Remote Controller only transmitting equipment)

a. Operating Frequency of Remote Controller: 5.725

- 5.825 GHz, 2.400

- 2.483 GHz

b. Comp lies with the Federal Communications Commission requirements

Regarding the Unmanned Aircraft PIC

4. Qualifications of PIC

a. All UAS operations will be conducted by Heather Graham Davis

i. Sport Pilot

ii. Certificate # 3787382

iii. Trained in the use of UAS by MLB Compan y (UAS supplier to U.S. Dept. of Defense/contractor with NASA, U.S. Dept. of Agriculture, etc.)5. Medical standards and certification of PIC: not required under Sport Pilot

License

Regarding the Operation of the Unmanned Aircraft

6. Description of UAS Operat ions

a. We propose to use UAS for image/video production to provide scientific surveys and analyses for ecological, biological and geographical purposes

. Services that we will provide include:

i. Wildl ife surveys

– (i.e. migratory waterfowl population

assesment s , surveying for hazard s to protected birds )

ii. Botanical surveys ( invasive or rare species, i.e. pepperweed, vernal pool or serpentine species occurrence and extent)

iii. Agricultural surveys (i.e. looking for disease, evidence for sharpshooter damage)

iv. Geomorphol ogical surveys

– (i.e. riverbeds, fluvial connections )

v. Hydrological surveys

– (i.e. water lev els of reservoirs )

vi. UAS aerial inspections in dangerous/difficult to access situations, such as nest surveys

b. Safety

i. Many of the above actions are currently conducte d using traditional aerial surveying in fixed wing aircraft. This is inherently hazardous as it often entails flying close to terrain or over water at low altitudes (i.e. surveying migratory waterfowl). We propose to increase safety by providing aerial ima gery and so dispense with the necessity of placing pilots and staff in dangerous conditions.

ii. There will be very low risk to people or property as operations will

be conducted in un

- or sparsely populated areas such as marshes, protected wildlands or agricu ltural lands. The PIC will ensure that the UAS cannot come in contact with bystanders in the event

of a malfunction.

7. Proposed Operating Conditions

a. Maximum Operating Speeds:

1. Max Ascent Speed: 5 m/s

2. Max Descent Speed: 4 m/s

3. Max Speed: 22 m/s no wind

b. Maximu m Altitude: 200 feet AGL

c. Minimum Flight Visibility and Distance of Clouds proposed as the same VFR rules as under the PIC sport pilot’s license. 3 SM visibility in all

situations. Clear of clouds in Class G Airspace (and in the unlikely event of operating in Class B Airspace). In C, D & E Airspace, will be at least 500 feet below and 2000 feet horizontal (vertical distance above cloudsdoes not apply since UAS will go no higher than 200 feet over the ground).

d. Potential Hazards: We do not anticipate signific ant hazards to the operator or bystanders, but some hazards to the UAS and property may be present. The likeliest of these are collisions with powerlines and trees. The PIC will thoroughly assess an area of operation to identify obstacles. Since the

UAS wi ll be kept within VLOS, visual scanning should be sufficient.

8. Characteristics of the Area of Intended Operations

a. The proposed areas of operations will be un

- or sparsely populated areas. Some manmade obstacles will be present such as powerlines and tower s of

various kinds.

9. Proximity to Airports : We do not intend to operate in close proximity to any airport.

10. VLOS: The PIC will be ground

- based and will not allow the UAS to fly out of sight at any time.

11. Procedures for preflight:

a. Weather conditions suita ble

b. No bystanders or property at risk in area of operation

c. Operations free to perform in Airspace (contact tower if necessary)

d. No TFRs

e. Frame and all screws are tight.

f. Propellers not damaged and tightly fixed.

g. Battery fully charged and securely mounted.

h. Transmitter battery charged and the antennas are free.

i. Channel of the transmitter is not busy. j. Check RC operation range on the ground

k. Ensure there is nothing in the danger zone of the propellers.

l. Ensure enough space for launch and flight.

m. Ensure the GPS module has GPS fix.

n. Ensure sensors are calibrated and that the right setting is loaded.

12. FSDOs

– We do not intend to conduct operations with existing requirements necessitating contacting a Flight Standards District Office

13. COA

– We will comply with the requirement to obtain a Certificate of Waiver or Authorization from the FAA Air Traffic Organization prior to conduction operations in the NAS.