United States of America Department of Transportation

Federal Aviation Administration

Federal Docket Management System

Washington, D.C. 

Verron S. Federation

Southern Wildlife Management, LLC

746 Amicalola Dr

Dawsonville, GA 30534

verron@animalextractor.com

RE: Petition of Southern Wildlife Management, LLC for Exemption Pursuant to section 333 of the FAA 

Reform Act. 

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Southern Wildlife Management, LLC, operator of Small Unmanned Aircraft Systems (sUAs) 

equipped to conduct aerial photography and videography, hereby applies for an exemption from the 

listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUAs, so long as such 

operations are conducted within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333.1 

The proposed exemption, if granted, would allow Southern Wildlife Management, LLC to conduct 

commercial operations of small, unmanned aircraft systems ("UAS") meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333. 

Southern Wildlife Management, LLC plans to exploit the capabilities of Unmanned Aerial Systems to 

offer a multitude of services, including: 

• Aerial surveying of wildlife sign & damage

• Creating own Commercial Advertising 

• Structural Inspections for wildlife issues

• Aerial film making and photography 

• Construction site inspections and trap monitoring 

• Wildlife and privately-owned forestry monitoring 

• Educational and research operations

• Producing training videos 

Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides 

a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 

333(a) states that the FAA "shall determine if certain unmanned aircraft systems may operate safely in 

the national airspace system before completion of the (comprehensive) plan and rule making required 

by section 332(b)(1) of this Act or the guidance required by section 334 of this Act." In Section 332(b) (1), 

Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" 
if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations. 

The Petitioner Requests Relief from the Following: 

Regulations from which the exemption is requested:

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 (b) 

• 14 C.F.R. 61.113(a) and (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b) (2) 

• 14 C.F.R. 91.105 

• 14 C.F.R. 91.109 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203 (a) & (b) 

• 14 C.F.R. 91.205 (b) 

• 14 C.F.R. 91.215 

• 14C.F.R. (91.401-91.417) 

We are petitioning for exemption to enable Southern Wildlife Management, LLC to operate a DJI 

Phantom 3 Standard which has the following specifications: 

 AIRCRAFT SPECS: Weight (including battery) 2.68 pounds, Max Ascent Speed: 5 m/s

Max Descent Speed: 3 m/s, Max Speed: 16 m/s (ATTI mode, no wind)

 AUTOMATIC FLIGHT ASSISTANT: Fly with absolute freedom and confidence, knowing the

Phantom 3 Standard will return HOME at the press of a button. Built-in GPS records the

Phantom’s takeoff point and remembers it as it is flown. Then on command, or if the control 

signal is ever lost, the Phantom comes back instantly. The Phantom 3 Standard stays stable and 

under your control at all times during flight. After takeoff, it automatically hovers in place, 

waiting for our command. It then effortlessly changes altitude or direction at the flick of a finger. 

When we want it to stop, it again pauses and hovers, waiting for our next instruction.

 AUTO-HOVER: When we stop telling it to move, the Phantom 3 Standard hovers perfectly in 

place, holding both position and altitude. It waits for us to give it instructions

 SAFE FLIGHT LIMITS: Set height and distance limits to keep all flights within a safe area. The 

Phantom 3 Standard will automatically stop and stay inside of your chosen limits as you fly.

 LIVE GPS: Throughout each flight, the Phantom 3 Standard sends its position to a live GPS map 

on the operator’s mobile device. This map is used to see right where it is, know which direction 

it is facing, and guide it back to you in an instant. Because the Phantom knows where it is and 

where the operator is, it can calculate how much longer it can continue flying. It will send you a 

reminder to land when the battery runs low, and it can automatically come home and land 

when needed.

 FLIGHT TIME: 25 minutes on a single battery. The patented DJI Intelligent Flight Battery 

continuously tells the operator exactly how long they can continue flying, based on how far and 
at what altitude it is at, and it alerts you when it's time to head back. This information is 

streamed live to the GO app on the operator’s mobile device.

The above specifications meet with the Model Aircraft Operating Standards as set below: 

• Southern Wildlife Management, LLC 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." 

• When flying sUAs within 5 miles of an airport, airport operators will be notified and the operator will 

give the right of way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 20 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit. 

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

AGL, and not more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the sUAs Pilot, and Visual Observer. 

• The sUAs operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal) . 

• The sUAs will operate at speeds of no more than 50 knots, can hover, and can simultaneously move 

vertically and horizontally. 

• Given the small size of the sUAs and the restricted sterile environment within which they will operate, 

our sUAs operations adhere to the Reform Act's safety requirements. 

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on 

combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current 

risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With 

a small payload and maximum flight time of only 25 minutes, this platform offers little or no risk to 

national security. Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with several 

buildings and large trees. 

The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and 

benefit many property owners. All of our flights will be conducted on private property with property 

owner’s written permission and meeting the following standards:

a) No flight will be made with a Gross weight exceeding 55 pounds; 

b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed 

of no more than 25 knots and no further than 118th NM from the PIC; 

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation. 

d) Operations are always over private property will be made only with the owner's permission 

e) All required permits will be obtained from state and local government prior to operation; 

f) Southern Wildlife Management, LLC, will not be operate over densely populated areas; 
g) Southern Wildlife Management, LLC will not be operating over any open-air assembly of 

people; 

h) Southern Wildlife Management, LLC, will not be operating over heavily tracked roads; 

i) Southern Wildlife Management, LLC, will not be operating within 5 NM of an airport or 

heliport without prior permission. 

We respectfully request exemption under Section 333 to enable Southern Wildlife 

Management, LLC, to operate efficient, limited, low-risk commercial sUAs operations for the 

activities stated respecting at all times the space and privacy of citizens and property while 

keeping our skies safe. 

Safety and Benefits of the UAS

Southern Wildlife Management, LLC will be using the UAS in a variety of applications that 

generally require expensive much larger aircraft, full-size heavy equipment such as aerial lifts

and or ladders. Small, light, unmanned aerial vehicles offer myriad benefits over the use of fullsized manned aircraft for Structural inspections, advanced agriculture, film and still 

photography, just to name a few. Replacing significantly larger manned aircraft carrying crew 

and flammable fuel with small UAS carrying no passengers or crew creates a much greater 

margin of safety for the pilots and crew. By granting Southern Wildlife Management, LLC

requested exemptions, the FAA will help drive development of safe and successful commercial 

UAS operations and will advance the public knowledge base for such operations. Southern 

Wildlife Management, LLC is committed to promoting the UAS research efforts of policymakers 

including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations 

and serving as a resource for future UAS research operations. Thus, the FAA has good cause to 

grant this Petition. 

Conclusion 

As pointed out in this application, all the SUASs which our company would use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of 

sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles 

from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, 

unless the air traffic control authorities (ATC) have been notified and have authorized each flight 

within a radius of this distance. Each flight is limited to private property of our customers, in 

which we have full consent and written permission to use the UAS to perform our wildlife 

inspections. All our SUASs have proven capability for controlled flight. They are devices offered 

for general sale on the market around the world and have often been used as Model Aircraft in 

the USA. We are certain that the studies conducted until now by the FAA, about Section 332, 

Public Law 112 -95, 2014, have already provided you with the assurances on the airworthiness 

of sUAs such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and Southern 

Wildlife Management, LLC should be permitted to conduct small UAS operations in accordance 
with its manuals and all other operating parameters deemed necessary and appropriate by the 

FAA. The submission of this application and its contents is the best demonstration that indeed it 

is possible to pursue the authorization process so that some SUASs may be used for legitimate 

commercial activities and under reasonably safe conditions.

Kindly,

Verron S. Federation