Subject: Petition for Exemption 14CFR § 11.81 Date: August 27, 2015 Submitted To: U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590 Filing Entity: Company Saddle Creek Logistics Services 3010 Saddle Creek Rd Lakeland FL 33801 Main: 863-665-0966 Filing Submitter Kent Culberson Sr. Manager Emerging Technologies Saddle Creek Logistics Services 3010 Saddle Creek Rd Lakeland FL 33801 Office: 863-668-4432 Email: kent.culberson@sclogistics.com

14 CFR Exemption 

### &Relief Request: We request the FAA granta Certificate ofWaiver orAuthorization {COA) forflights at or below 200 feet to any UAS operatorwith aSection 333 exemption for aircraftthatweigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line ofsight (VLOS) ofthe pilots, and stay certain distances away from airports or heliports: 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airportwith a published instrumentflight procedure, but not an operational tower; or 2 NM from an airportwithout a published instrumentflight procedure oran operational tower; or 2 NM from a heliportwith a published instrumentflight procedure The {/blanket" 200-footCOA allows flights anywhere in the country except restricted airspace and otherareas, such as major cities, where the FAA prohibits UAS operations. Previously, an operator had to applyfor and receive aCOA fora particular block ofairspace, a process that can take 60 days. The agency expectsthe new policy will allow companies and individuals who wantto use UAS within these limitationsto startflying much more quicklythan before. Section 333 exemption holders will automatically receive a {/blanket" 200 foot COA. For new exemption holders, the FAA will issue aCOA at the timethe exemption is approved. Anyone who wants to fly outside the blanket parameters must obtain a separate COA specific to the airspace required forthat operation.Benefit tothe public 

### as a whole: Saddle Creek requests authorization for Drone flights above its facilities and operations comprised ofstaticwarehouses and tractor-trailer parking lots to document aforementioned operations in the form ofpicture and video recordings obtained by drone. Saddle Creek also will perform RC Pilottraining and RC pilotflight maintenance operations in areas clear ofall obstacles and within the constraints ofthe 14 CFR exemption request.

Reasons whythe exemption will not adversely affect safety, or howthe exemption would provide a level of safety at least equal tothe existing rule: Saddle Creek will be followingthe guidance offered by the latest advisements and recommendations on drone safety provided by the FAA, leading droneflying clubs, and drone manufacturers in terms of: • Pre-flight planning • Approved geographric flight areas • Obstacle detection and avoidance • Pre-flight drone checklist procedures • Weatherflight-condition pre-assessments • RC pilottraining • Flight logging • Post-flight checklists • Drone maintenance Summary of Rule and Exemption: Saddle Creek Logistics Services formally requests an exemption underSection 333: 14 CFR § 11.81 forflight operations outdoors, below 200 feet and prohibited flight in accordance with all established no-fly zones and flight-restricted areas. Saddle Creek wishes to conductflight operations using lightweight, consumer-based drones (Example: DJI Matrice 100) with picture and video recording capabilities. These drone operations are anticipated to be used exclusively above and around Saddle Creek warehouse facilities. The only known exceptions are for RC Pilot training and RC Pilot maintenance which may use areas clear ofall obstacles and in accordance with FAA drone flight guidelines (IE: Emptyfields). Requested Territories for Drone Operations: Saddle Creek limitsthis exemption request to the United States. No exemption is being requested forflights outside of the United States.