### Eagle Eye Aviation, Inc

d ba : Eagle Eye Gallery

4049 West Hill Road

Homer, AK 99603

Phone: (907) 235

- 9457

Mobile: (310)908

- 1832

E

- Mail: ian@eagleeyega llery.com

Web: www.eagleeyegallery.com

May 13, 2015

Docket Operations, M

- 30

U.S. Department of Transportation

, 1200 New Jersey Avenue,

SE Room W12

- 140,

West Building Ground Floor

Washington, D.C. 20590

- 0001

Subject: Petition to the FAA for Section 333 Exemption

Dear Sir or Madam,

I, Ia n S. Reid

, C o

- owner and President of Eagle Eye Aviation, Inc hereby submits to the Federal Aviation Administration, pursuant to

the FAA Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333 of the Act.

**Eagle Eye Avi ation**  **, Inc Background:** 

Eagle Eye Aviation has pursued excellence in utilizing various aerial photographic platforms (rotorcraft and fixed wing aircr aft) to

provide photo and video imagery for a variety of purposes : aesthetic displays , industrial and wil d life surveys, descriptive

perspectives for real estate marketing and business promotion, emergency contingency response planning

. In the United States our

services have been utilized primarily in Alaska, California, Washington, Hawaii and Florida. Our a viation safety record is without

incident in the safe and legal utilization of aircraft for aerial data collection throughout the past 20 years since our foun ding in 1996.

**Purpose for the Exemption :** 

Eagle Eye Aviation desires to utilize an unmanned aircra ft system (UAS ) to accomplish aerial data collection to complement our

existing services. In the past, Eagle Eye Aviation has primarily used rotorcraft as an aerial platform but because of the obvious

limitations of safe altitude, noise, and cost, aerial d ata collection is sometimes difficult if not impossible to obtain

. As much of our

aerial data collection is accomplished at low altitudes, the reduced utilization of rotorcraft in favor of the unmanned (non flammable

fuel) aerial system described, while be ing operated under the guidelines outlined, presents a significant enhancement to public safety

as well as to that of the pilot and photographer.

**List of Specific Sections of 14 CFR for which exemption is sought:**

14 CFR 21, Subpart H

– Airworthiness Cert ificates

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors

14 CFR 91.7 (a), Airworthiness required for operation

14 CFR 91.103 (b) (2), Preflight action

14 CFR 91.105, Flight crewmembers at stations

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14 CF R 91.109, Flight instruction

14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.121, Altimeter settings

14 CFR 91.151, Fuel requirements for flights in VFR conditions

14 CFR 91.405 (a), Maintenance required

14 CFR 91.407 (a) (1), Operation after maintenance

14 CFR 91.409 (a) (2), Inspections

14 CFR 91.417 (a) and (b), Maintenance records

In accordance with the outline given in the FAA’s “Public Guidance for Petitions Filed under Section

333”, the following information is provided for each numbered item listed in that guidance:

**1. Aircraft Description :** 

Design and Operational Characteristics:

Eagle Eye Aviation, Inc plans to operate a DJI Inspire 1 comprised of an unmanned aircraft and a transportable ground station.

This aircraft is a qu ad

- copter design with gross weight (battery and propellers included) of 2935g (6.5 lbs)

The DJI Inspire 1 has an integral lightweight camera for capturing aerial still photographs and videos.

It is equipped with four rotors that are driven by battery

- powe red electric motors.

Maximum airspeed is 43 knots.

DJI Inspire 1 is equipped with a built

- in Flight Control System which includes an integral inertial sensor and a barometric altimeter

that measure both attitude and altitude.

Included is a shielded, anti

- static compass which reads geomagnetic information and assists in accurately calculating position and

altitude.

The Flight Control System includes a Failsafe Function.

It activates if the Remote Control is powered off, the DJI Inspire 1 has flown outside effective control range, the signal between the

DJI Inspire 1 and the Remote Control is blocked, or if there is interference causing a signal problem.

When activated, the Failsafe Function automatically flies the DJI Inspire 1 back to the Home Point (the start location) and lands it. If

GPS mode is not active, Failsafe will execute a controlled descend and automatic landing.

Through the DJI Inspire 1 Assistant software, each flight operation will be programmed with a maximum radius distance and

maximum al titude from the Home Point such that the flight control system will limit operations to within the confines of the property

to be surveyed by Eagle Eye Aviation f or Eagle Eye Aviation’s Clients. These performance limitation requirements are included in the

UAS Operating Pr ocedure contained in Appendic e s A and B.

Manufacturer’s Documentation:

Detailed manufacturer’s design information and operating limitations (current to this date) are contained the in the following

manuals in the appendices at the end of this document:

· Appendix A DJI

- Inspire1

- U ser M anual

· Appendix B Inspire_1_Safety_Guidelines

**2. Procedures for Ensuring UAS Is In a Condition Safe for Flight**

Preflight Checks: As a minimum, the following items will be checked prior to initiating any operation.

1

. Operations must be in daylight hours and under visual meteorological conditions (VMC)

.

2. Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for e ach leg of the flight clearly marked.

### 3

3. Flight path is at least 500 ft. from all non

- participating persons, vessels, vehicles and s tructures unless protective barriers or

structures are present, or permission is granted, or such operations present no hazard to the Pilot in Command, the Visual Observer,

trainees, and o ther essential persons.

4. Flight plan and schedule has been reviewed with site leadership and communicated to all

Eagle Eye Aviation personnel in the area.

5. Remote control, smart battery, range extender, and smart phone are fully charged.

6. Propelle rs are mounted correctly.

7. Gimbal clamp has been removed.

8. Damping absorbers are in good condition, not broken or worn.

9. Anti

- drop kits have been mounted correctly.

10. Camera lens cap has been removed.

11. Micro

- SD card has been inserted.

12. Gimbal is functioning as normal.

13. DJI Vision app can connect to the camera.

14. Compass has been calibrated.

15. Flight radius and altitude limits have been set with the DJI Inspire 1 Assistant software, not to exceed 400 ft. AGL altitude, and

radius limited to the property boundaries of Eagle Eye Aviation site.

16. The Visual Observer (VO) is stationed at the required initial observation point according to the flight plan and in view of the Pilot

in Command (PIC) and has means for continual verbal communication.

17. There are no inoperable components.

18. All site required safety permits are approved and in possession of the PIC.

19. A Notice to Airmen (NOTAM) has been requested not more than 72 hours in advance and not less than 48 hours prior t o the

operation.

20. Motors can start and function as normal.

21. Flight Indicator Lights on the aircraft verify that the Home Point is set to current location.

22. Record the Preflight Check, date and sign, and file it in the Equipment Inspection and Maintenance Record Book.

**3. Radio Frequency (RF) Spectrum For Control**

The Remote Control ground station operating frequency is 2.4

- 2.483; 5.725

- 5.825 GHz and is FCC compliant with communication

distance in an open area of 1.25 miles.

Receiver Sensitivi ty (1%PER)

- 93dBm

Transmitter Power FCC Compliance: 100mW

Battery Capacity 4500 mAh, voltage of 22.2 volts.

### 4

**4. Qualifications For The Pilot in Command (PIC)**

Certifications: Operations will be conducted by a Pilot in Command (PIC) possessing at least a private p ilot certificate and at least a

current third

- class medical certificate.

Logged Hours: Prior to operations the PIC will have accumulated and logged a minimum of 25 hours of total time as a UAS rotorcraft

pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. Training, proficiency, and experience

- building flights

in dedicated training sessions will be included in the accumulated and logged hours.

Currency: Prior to operations, the PIC will have accumulated and logged a min imum of 5 hours as UAS pilot specifically operating

the DJI Inspire 1 . The PIC will have accomplished, during dedicated training sessions, 3 take

- offs and landings in the preceding 90

days (for currency purposes).

Emergency and Evasive Maneuvers: The PIC w ill have demonstrated the ability to safely operate the DJI Inspire 1 in a manner

consistent with how it will be operated in surveying Eagle Eye Aviation Client properties, including evasive and emergency

maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures. The logged hours reference above will

document this.

**5. Medical Standards And Certification Of The PIC**

As described above, in “4. Qualifications for the Pilot in Command (PIC)”, the PIC will possess at least a current third

- class medical

certificate.

**6. Description Of Intended UAS Operations**

Operations will be restricted to Class G airspace.

No operations will occur within 5 miles of a non

- towered airport reference point as denoted on a current FAA

- published a eronautical

chart, unless a letter agreement with the airport’s management is obtained, and the operation is conducted in accordance with a Notice

to Airman (NOTAM) as required by the Certificate of Waiver or Operation (COA).

The DJI Inspire 1 will be uti lized to collect aerial data for real estate marketing, aesthetic displays (Wall Hangings) , business and

tourism promotion, i ndustrial and wild life surveys

, emergenc y contingency response planning

, soil erosion mitigation, legal

documentation, roof inspec tions.

**7. Proposed Speed, Altitude, Visibility And Distances**

Speed: Typically, slower speeds 5

- 10 knots will be observed as this yield s better clarity for video and assessing preferred still photo

vantage points. Between

Altitude: Altitudes below 400 ft. AGL are adequate for the complete range of and structures perspectives to be surveyed. The integral

Flight Control System will be set to limit the altitude to always be below that level.

Distances: The integral Flight Control System will be set to lim it the radial distance from the Home Point (point of flight

commencement) such that the DJI Inspire 1 will stay within the boundary of the property lines. The PIC will operate the equipment to

assure those limits are not reached and will maneuver the DJI I nspire 1 to follow the preplanned flight path within the property

boundaries.

The DJI Inspire 1 will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud when visibility is less

than 3 statute miles from the PIC.

Opera tions will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies.

Safe descent and landing procedures will be followed in accordance with operating documents.

**8. Description Of The Area Of Intended Operations**

Eagle Eye Aviati on will begin UAS operations in the same areas that we have been operating in for the past 10

- 20 years. Most recent

are the Kenai Peninsula, Anchorage and Fairbanks areas of Alaska. As a certificated Commercial Rotorcraft Pilot (# 3264895) who

has flown th ese areas many times I will comply with all NAS limitations and requirements to operate a UAS around those areas in

accordance with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

**9. Proximity Of Airports**

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Operatio ns will be restricted to Class G airspace.

No operations will occur within 5 miles of a non

- towered airport reference point as denoted on a current FAA

- published aeronautical

chart, unless a letter of agreement with the airport’s management is obtained, an d the operation is conducted in accordance with a

Notice to Airman (NOTAM) as required by the Certificate of Waiver or Operation (COA).

**10. Operation Within Visual Line**

**- of** 

**- Sight (VLOS)** 

In addition to the Pilot in Command (PIC), all operations will includ e a Visual Observer (VO). The VO will assure that DJI Inspire 1

is always within their visual line

- of

- sight (VLOS), as well as the PIC’s, at all times. The VO and the PIC will be able to communicate

verbally at all times

.

**11. Procedures For Preflight Saf ety Assessment** 

Prior to each flight, the PIC will inspect the DJI Inspire 1 , including the ground control station, in accordance with the Preflight

Checklist (see “2. Procedures for Ensuring UAS Is In a Condition Safe for Flight”). If the Preflight Check indicates any unsafe

conditions or a non

- functioning safety

- critical part, the flight will not commence until the needed maintenance is performed and a

satisfactory Preflight Check can be completed. All maintenance and alterations performed will be documen ted and filed in the

Equipment Inspection and Maintenance Record Book.

**12. Notifications**

In accordance with the COA, a Notice to Airmen (NOTAM) will be requested not more than 72 hours in advance and not less than 48

hours prior to an operation.

In addit ion, any notifications required by the FAA Flight Standards District Office will be made.

**13. Certificate Of Waiver Or Authorization (COA)**

Prior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate of Waiver or Operation (COA ) will be

obtained for each aircraft. Eagle Eye Aviation UAS s ervices will utilize one rental aircraft N99887 (a DJI Inspire 1) obtained from

Alaska Aerial Media of Anchorage, Alaska , with additional units added or purchased as needs for operations increa se over time. Each

DJI Inspire 1 aircraft used by Eagle Eye Aviation will be identified with its serial number, registered in accordance with 14 CFR part

47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markin gs will be as large as

practicable.

Sincerely,

Mr Ian S. Reid