Eagle Eye Aviation, Inc 

dba: Eagle Eye Gallery

4049 West Hill Road

Homer, AK 99603

Phone: (907) 235-9457

Mobile: (310)908-1832

E-Mail: ian@eagleeyegallery.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, Ian S. Reid, Co-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 Aviation, Inc Background:

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

provide photo and video imagery for a variety of purposes : aesthetic displays, industrial and wild 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 aviation safety record is without 

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

Purpose for the Exemption:

Eagle Eye Aviation desires to utilize an unmanned aircraft 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 data 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 being 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 Certificates 

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 CFR 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 quad-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-powered 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 altitude 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 for Eagle Eye Aviation’s Clients. These performance limitation requirements are included in the

UAS Operating Procedure contained in Appendices 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-User Manual

· 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 each leg of the flight clearly marked.
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3. Flight path is at least 500 ft. from all non-participating persons, vessels, vehicles and structures 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 other 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. Propellers 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 to 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 Sensitivity (1%PER) -93dBm

Transmitter Power FCC Compliance: 100mW

Battery Capacity 4500 mAh, voltage of 22.2 volts.
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4. Qualifications For The Pilot in Command (PIC)

Certifications: Operations will be conducted by a Pilot in Command (PIC) possessing at least a private pilot 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 minimum 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 will 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 from 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 aeronautical 

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 utilized to collect aerial data for real estate marketing, aesthetic displays (Wall Hangings), business and 

tourism promotion, industrial and wild life surveys, emergency contingency response planning, soil erosion mitigation, legal 

documentation, roof inspections.

7. Proposed Speed, Altitude, Visibility And Distances

Speed: Typically, slower speeds 5-10 knots will be observed as this yields 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 limit 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 Inspire 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.

Operations 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 Aviation 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 these 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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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 aeronautical 

chart, unless a letter of 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).

10. Operation Within Visual Line-of-Sight (VLOS)

In addition to the Pilot in Command (PIC), all operations will include 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 Safety 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 documented 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 addition, 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 services 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 increase 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. Markings will be as large as 

practicable.

Sincerely,

Mr Ian S. Reid