Attn: 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, Palm Beach Executive Aviation, LLC , operator of Small Unmanned Aircraft Sy stems(“sUASs ”) equipped to conduct aerial photography and videograph y, hereb y applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the condi tions outlined herein or as may be established by

the FAA as required by

Section 333.1. As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in air space that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Palm Beach Executive Aviation, LLC to conduct commercial operations of small unmanned aircraft s ys tems (“UAS”) meeting or exceeding all of the oper ational and safety requirements Congress has set forth in Section 333, Page 2. Palm Beach Executive Aviation, LLC is an aviation services compan y owned and run b y Jeffrey R. Anderson

. Mr. Anderson has an Airline Transport Certificate and is ty pe rated in multiple transport aircraft. He has 22 years experience fl yi ng military airlift operations as well as Part 91 and Part 121 large cabin operatio ns. His total time is over 8,0 00 h ours. Palm Beach Executive Aviation, LLC plans to exploit the capabilities of Unmanned Aerial Sy stems to offer a multitude of services, including:

- Aerial surveying

- Event Photograph y/ Videograph y

- Golf Course Mapping

- Insurance Compan y Survey s

- Agriculture purposes

- Real Estate Photography /Videography

- Aerial Filmmaking and P hotograph y

- Construction site inspections and monitoring Statutory Authorit y Section 333, titled “Special Rules for Certain Unmanned Aircraft Sy stems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. S ection 333(a) states that the FAA “shall determine if certain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidanc e 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 comme rcial UAS operations. The petitioner requests relief from the following r egulations 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. 91.109 14 C.F. R. 91.11914 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 14 C.F.R. (91.401

- 91.417) Unmanned Aircraft Sy stem (UAS) are often times seen as superior to helicopters due to the smaller devices, cheaper e quipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safet y. We are petitioning for exemption to enable Palm Beach Executive Aviation, LLC to operate a DJII nspire 1 sUAS upgraded to the Version 1.2.1.03 firmware and equipped with a two

- axis camera gimbal and using a High

- Definition camera. This sUAS has a built

- in capability to limit the height it flies above the ground and to limit the radius of the distance it flies fr om the operator. The Inspire 1 also has the failsafe function of the autopilot sy stem which means when the communication between the Main Co ntroller and the transmitter is disconnected, the outputs of all command sticks from controller will go to the cente r position. If the GPS signal is good enough, the s ystem will automatically trigger a Return to Home function and will automatically land safel y. Please refer to the included DJ I Inspire 1 Instruction Manual for the performance limitations and flight operations. Aircraft weight is 6.5 lbs with battery , 2

- Axis Camera Gimbal, and Camera. A p re

- flight inspection will be performed by the PIC in accordance with the factory instruction manual. An added step will be the inspection of the propellers. A prope ller will be replaced if it has any nicks and cracks with a manufacturers authorized propeller. The sUAS will be maintained in accordance with the manufacturers instruction manual and onl y manufacturer's authorized replacement parts will be used.

FCC Inf ormation : The Inspire 1 Remote Controllers will be used for controlling the sUAS and complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) This device may

not cause harmful interference, and (2) this device must accept an y interference received, including interference that may cause undesired operation. The Inspire 1 radio transmitter used for controlling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulation s governing a radio transmitter in the 2.400GHz frequency with a maximum transmission distance of 2km.

Antenna Separation Distance : When operating our Inspire 1 transmitter, the PIC will maintain a separation distance of
at least 5 cm between his body (e xcluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined b y FCC regulations.

Pilot in Command and Observer Qualifications and Duties : The PI C will maintain at least a Private Pilot Certificate and a current Class III medical certificate, plus at least 2 hours flying time and 3 takeoffs and landings within 30 day s in the ty pe of UAS utilized in operations. The PI C will have at least 100 hours total timeand at least 30 hours fl yi ng Radio Control led Model Aircraft of which will be 10 hours

flying sUAS's. Training will be conducted at a local Radio Control Club flyingfield. Palm Beach Executive Aviation, LLC has the ability to provide "dual controls" utilizing two Inspire 1 transmitters with a wi reless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PI C instructor, utilizing the master transmitter, will be at all times be able assume control of the sUAS. T he PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation, in

- flight operation, post

- flight requirements, all procedures including but not limited to: Safe in

- flight operations; Risk Mitig ation to Persons and propert y; Airfield Suitability

. The Observer must have the visual acuity

to observe the sUAV and be able to communicate clearl y with the PI C.

The Observers duties are:

-- warning the PI C of any impending obstacles in the flight path of the sUAS.

-- warning the PI C of any deviations in the planned flight path of the sUAS.

-- warning the PI C should any unauthorized personnel appear in the area of the planned flight. The Observer will have the authorit y to order the PIC to terminate the flight should he feel the flight cannot be conducted safely.

General Operating Standards

• Palm Beach Executive Aviation, 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. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace s ys tem or the public." • Before an operation of a sUAV within 5NM of an airport with a control tower, the control tower will be no tified to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. The sUAS will not be operated at an altitude of over 300 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. Before an operation of a sUAS within 5NM of a non

tower controlled, airport operators will be notified and the PI C will give the right of way to avoid flying in the proximity of full

- scale aircraft. At no time will the sUAV be operated within the final approach course and the takeoff course of any runway

. • Maximum flight time for each operational flight will be 30 minutes. • Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. • The sUAV will be programmed so that it will not be operated at an altitude of 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 sUAV operated b y the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals). • The sUAV will operate at speeds of no more than 25 knots, can hover, and can simultaneously

move vertically

and horizontally

. • Giv en the small size of the sUAV and the restricted sterile environment within which they will operate, our sUAV operations adhere to the Reform Act's safet y requirements. The UAS, powered b y batteries, is smaller, lighter and more maneuverable than largera ircraft 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 onl y 20 minutes, this 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. Compared to manned aircraft, the benefits of reduced cost and improved quality

of presentation from the UA will be valuable to and benefit many buy ers and sellers of real propert y. Additionally, we request that we be allowed to use our
sy stem to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. (a) No flight will be ma de 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 3/4 NM from the PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate b y voice at all times during a flight operation; (d) Operations will be restricted to flights over private property with the permission of the propert y owner; (e) All required permits will be obtained from state and local government prior to operation; (f) Palm Beach Executive Aviation, LL C UAS aircraft will not be operated over densel y populated areas; (g) Palm Beach Executive Aviation, LL C UAS aircraft will not be operating over any
open

- air assembly

of pe ople; (h) Palm Beach Executive Aviation, LL C UAS aircraft will not be operating over heavil y traffic roads; (i) Palm Beach Executive Aviation, LL C UAS aircraft will not be operating at night. EXEMPTION REQUESTS AND EQUIVALENT L EVE L OF SAFETY Palm Beach Exe cutive Aviation, LLC requests an exemption from the following regulations as well as any additional regulations that may technicall y apply to the operation of the sUAV System: 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Sy stems, we request an experimental certificate be issued for the DJ I Inspire 1 under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating te chniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights
to show compliance for issuance of t yp e and supplemental ty pe certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market survey s, sal es demonstrations, and customercrew training, we would expect that an experimental certificate would permit our

commercial purpose as well. The aircraft will not carry persons or propert y, will not carry fuel, and will only

fly under strict operational re quirements. Combined with the UA's light weight, being constructed primaril y of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. I f an experime ntal airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety

outlined in the previo us paragraph.

14 CFR 45.23 Display

of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally , the aircraft must display
the word "EXPERI MENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safet y b y including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PI C (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft

while it is preparing for launch will be able to see the designation. Additionally , we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally , we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to any one that observes the aircraft and chooses to investigate its point of origin. 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employ ment if: (1) The flight is only

inc idental to that business or employ ment; and (2) The aircraft does
not carr y passengers or propert y for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA and since the aircraft cannot carry passengers or property , we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airwor thiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approvedflight manual is in the aircraft. We assume that the intent of this requirement is to ensure

that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safet y and meet the intent of 91.9, we
propose that a current , approved sUAS Flight Manual must be available to the crew at the ground station an yt ime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No p erson may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." Training will be conducted at a local Radio Control Club flying field. Palm Beach Executive Aviation, LLC has the abilit y to provide "dual controls" utilizing two Inspire 1 transmitters with a wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PI C instructor, utilizing the mast er transmitter, will be at all times be able assume control of the sUAV.

91.119 Minimum safe altitudes: General. The regulation states that over sparsel y populated areas the aircraft cannot be operated closer than 500 feet to an y person, vessel, vehicle, or structure. Since the t ypical mission of the sUAS would be photograph y or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only

be flown over propert y or person s where permission has been obtained and careful pre

- planned flight path has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or propert y on the surface. T herefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will alway s fl y below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board computer to the display screen held b y the PI C, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements f or flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fl y to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide

an energy reserve as a safety

buffer for delay s to landing. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft wil l never fl y more than 3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve
energy requirement of this paragraph. We request an exemption to the word "fuel" andask for an equivalent interpretation with the word "energy ".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the airc raft. Additionally , subparagraph (b) provides that the airworthiness certificate be "display ed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum
gross weight of 6.5 pounds, the sUAS is too small to carry documentation, does not have

an entrance, and is not capable of carry ing passengers or crew. To obtain an equivalent level of safety

and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircra ft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is p rimarily responsible for maintaining the aircraft in an airworth y condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after mainte nance and inspection. It is our intention that the PI C perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworth y condition prior to every

f light and in addition conduct detailed inspections after every
two hours of flight. Maintenance performed b y the PI C is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility . The PI C will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PI C can ensure an equivalent level of safet y.

Safety and Benefits of the UAS Palm Beach Executive Aviation, LLC will be using the UAS in a variet y of applications that generall y require expensive full

- size manned aircraft to complete. Small, light,

unmanned aerial vehicles offer my riad benefits over the use of full

- sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photograph y, just to name a few. Replacing significantl y larger manne d aircraft

carr yi ng crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safet y for the pilots and crew. By granting Palm Beach Executive Aviation, LLC ‘s requested exemptions, the FAA will help drive develo pment of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Palm Beach Executive Aviation, LLC is committed to promoting the UAS research efforts of policy makers including the FAA, NASA, DOD, and D ARPA 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.As pointed out in this application, all the sUAS which our compan y would use, under

authorization by

the US DOT

- FAA, are small, light

- weight devices operated within the line of sight (LOS) of the Pilot

- in

- Command (PI C), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other l ocation with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

All of our sUAS 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

assurance s on the airworthiness of sUAS such as ours. For the foregoing reasons, the exemptions requested herein should be granted and Palm Beach Executive Aviation , LLC should be permitted to conduct small UAS operations in accordance with its manuals and all oth er 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
p ossible to pursue the authorization process so that some sUAS may be used for legitimate commercial activities and under reasonably safe conditions.

Signed, Jeffrey R. Anderson Palm Beach Executive Aviation, LLC