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 Owner of Bird’s Eye View Aerial Science & Imagery

227 8th Street

Petaluma, CA 94952

hgdavis@sonic.net

707.235.0716

Sport Pilot 3787382

Summary: Bird’s Eye View Consulting, an Ecological 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 analyses 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 Quadcopter 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 Area: 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 Velocity: 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 m
x. 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 thoroughly 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 

necessary, 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 weather 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 aircraft

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. Complies 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 Company (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 Operations

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. Wildlife surveys – (i.e. migratory waterfowl population 

assesments, surveying for hazards 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. Geomorphological surveys – (i.e. riverbeds, fluvial connections)

v. Hydrological surveys – (i.e. water levels 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 conducted 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 imagery 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 agricultural 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. Maximum 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 clouds 
does not apply since UAS will go no higher than 200 feet over the 

ground).

d. Potential Hazards: We do not anticipate significant 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 will 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 towers 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 suitable

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.