### September 4, 2015

Exemption No. 12768 Regulatory Docket No. FAA

− 2015

− 2569

Mr. Randall Newman Princess Delivery Express, LLC P

. O

. Box 841276 Pearland, TX 77584

Dear Mr. Newman :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 3, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Princess Delivery Express, LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial imaging, monitoring, inspection, videography, and photography

.
See Appendix A for the petition submitted to the FAA des cribi ng the proposed operations and the regulations that the petitioner seeks an exemption

.
The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2

.
The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

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aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA fi nds that the requested relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11 062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Princess Delivery Express, LLC is gr anted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a)

, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.

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Conditions and Limitations

In this grant of exemption, Princess Delivery Express, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phanto m 2 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are
not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be opera ted at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in thi s grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limita tions in this exemption and the procedures outlined in the operating documents,

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the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present up dated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS op eration or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and mu st remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable com ponents, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certif icate.

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14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintainin g appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations m ay only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distan ce from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be ma de available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited fro m beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the man ufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

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22. All aircraft operated in accordance with this exemption must be identified by serial

num ber, registered in accordance with 14 CFR part 47, and have identification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcem ent official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure tha t nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipa ting persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the prop erty owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vert ical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions containe d on the NTSB Web site: www.ntsb.gov

.

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If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities t o the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permissio n must be made available to the inspector upon request;
g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

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This exemption terminates on September 30, 2 017 , unless sooner superseded or rescinded.

Sincerely,

/ s/ John S. Duncan Director, Flight Standards Service

EnclosuresFederal	Aviation	Administration	Exemption

Petition	for	Exemption	under	Section	333 FAA	Modernization	and	Reform	Act	of	2012 Public	112

- 95	Feb.	14,	2012,	Section	333 Submitted	by:	Princess	DeliveryExpress,	LLC .		( Randall	Newman )

Date: 6/3 /2015

Dear	Sir	or	Madam:

Attached please find Princess DeliveryExpress, LLC request for an exemption from the listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems ("UAS") for aerial imaging for aerial adverti sing; safety, monitoring, inspecting and/or recording of secured and controlled environment construction sites ; proposed development sites ; inspections of property and videography/ photography for realty advertisements and property listings

. This exemption request is exclusively for the use of the UAS manufactured by DJI, DJI Phantom 2. Also please find the link to the DJI Phantom 2 UAS Manual ("Manual"), which outlines the operating requirements, limitations, and technical specifications for the DJI Phantom 2 system. http://www.dji.com/product/phantom

- 2/download

We	have	reviewed	this	Manual	and	in	conjunction	with	the	requirements	outlined	in	this	document w e have found it to be acceptable for UAS operations on our project sites. Thank you for your time a nd consideration,	and	please	let	me	know	if	you have	any	questions.

Sincerely,

Randall	Newman Princess	DeliveryExpress,	LLCIntended	UAS	Use

To record video and capture pictures of client's homes/properties for the use in real estate marketing materials,	property	development,	property investigation	and	documentation	by	the	use	of	light	weight UASs	in	the	following	areas of	commerce :

• Realty and Advertising

- Selling /leasing properties, enhancing advertising campaigns, and increasing production of marketing materials. Evaluating value by documenting assets and deficits especially	in	hard	to	access	areas	as	an	alternate	to	conventional	large,	heavy,	combustible	fuel	bearing

an d	manned	vehicles	are	currently	used.

 Photo/Videography	of	rural	contracted	outdoor	recreational	activities	on	private	and	public	use lands	(Prior	Permission	and	coordination	Only). Princess	DeliveryExpress,	LLC has	a	significant
amount of interest in t aking video and photos for advertising in our local area. Utilizing the UAS will offer a significant improvement to the agency with regards to both safety and cost. Using a 6 lb. UAS compared to a gas turbine helicopter or aircraft will offer a considerable safety margin as well as cost savings advantage

.

• Property inspections

- Especially roofing inspections, especially tile roofs, are susceptible to added damage from an investigator walking on the roof to complete his initial inspection. A s UAS could do the work and record the inspection findings without the probability of additional roof damage or personnel injury from falls. This service would be valuable to companies like: Roofing contractors, Insurance	adjusters,	property	owners,	renters, etc.

• Construction defect	investigations

- Site investigation and findings specifically for building exteriors would be greatly enhanced by the use of a UAS. It can be very expensive to safely find and document exterior construction defects on multiple story building, a UAS could inspect, find and record information	that	would	be	otherwise	only	be	accessible	by	ladders	or	scaffolding.	Also	A	UAS	would	be a	much	safer	way	to	do	this	type	of	high	and/or	difficult	access	investigation.

• Site	investigatio n

- Such	as	steep	hillside	or	bluff.	Recording	the	visual	condition of existing h illsides

or bluffs that would otherwise be very difficult to access and record. It would also be less intrusive to environmentally	sensitive	areas.

• Site development

- Cre ating high resolution scalable overhead photography of a property would b e valuable to engineers, architects

, designers and landscape architects in evaluating the best use for developing a property and the potential effects that such development might hav e. Development of existing properties for remodeling or renovation especially commercial building where e quipment is located on the roof would also benefit from HD photos that document the equipment and its location. Currently Google Maps are useful for su ch endeavors but only with a very low resolution overhead photo	of	such	properties.

• Developers and Construction Companies

- To record and document the overall progress of large developments	and	to	observe	and	document	job	site	safety.

• Landscape mai ntenance

- To record landscape health and irrigation proficiency on large p roperties such as condominiums, apartment complexes, malls, golf courses or even public parks and recreation

areas.

• There are many other areas that a UAS would be a safer, accur ate and less expensive alternative to
current commercial services but Princess DeliveryExpress, LLC would be specifically interested in the areas	mentioned	above.

Specific	Section	of	14	CFR	Seeking	specific	exemption	from: Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121;	91.151(a);	91.20 3(a)	&	(b); 91.405	(a);	91.407(a)	(1);	91.409	(a)	(2);	91.417 (a)	&	(b).

Dear	Sir	or	Madam:Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, Lloyd & Associates, a design/build and construction firm, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its Small Unmanned Aircraft	Systems ("UAS") for aerial imaging for safety and	monitoring of secured	and controlled	environment	construction	sites,	so	long	as	such	operations	are	conduct ed	within	and	under the conditions outlined herein or as may be established by the FAA as required by Section 333. As detailed in this document and the link to Flight Manual, the requested exemption would permit the operation of UAS under controlled condit ions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already best practices safety protocols followed by Princess DeliveryExpress, LLC at each one of its project sites. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "...establish requirements for the safe operation of such aircraft systems	in	the	national	airspace	system."	Section	333 (c)	of	the	Reform	Act.

The	name	and	address	of	the	applicant	is: Princess	DeliveryExpress,	LLC Randall	Newman PH: 713

- 614

- 4001 Email: randy@rhnewman.com Address: PO	Box	841276

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)	&	(b) 14	C.F.R.	91.7	(a) 14	C.F.R.	91.9	(b)	(2) 14	C.F.R.	91.103 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)

STATUTORY	AUTHORITY	FOR	EXEMPTIONS The F ederal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection	(a)	or	(b)	of	this	section	or	any	sections	44702

- 44716	of	this	title	if	the	Administrator	finds the exemption	in the public interest. 49	U.S .C. §44701 (f) See also 49 USC §44711(a); 49	USC §44704; 14 CFR §91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate in the National Airspace System (NAS) without creating a ha zard to the user, the public,	or	a	threat	to	national	security.	In	making	this	determination,	the	Secretary	must	consider:

•	The	UAS's	size,	weight,	speed,	and	operational	capability; •	Whether	the	UAS	operates	within	the	visual	line	of	sight	of	the	ope rator •	Whether	the	UAS	operates	outside	of	highly	populated	areas	and	away	from	close	proximity	toairports Reform Act §333(a). If the Secretary determines that a UAS "may operate safely in the

national airspace system, the Secretary shall establish req uirements for the safe operation of such aircraft	in	the	national	airspace	system."	Id.	§333(c).

Princess DeliveryExpress, LLC UASs are multi

- rotor vehicles, weighting 10 or fewer lbs. including payload. They operate under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. The UAS will operate only in the pilot's visual line of sight at all times and will operate only within the recommendations described in the DJI Fligh t Manual. Such operations will insure that the UAS will "not create a hazard to users of the national airspace system or the public." Reform Act Section 333 (b). Given the small size of the UAS involved and the restricted and sterile environme nt within which they	will	operate,	our	application	falls	squarely	within the	zone	of	safety	(an	equivalent	level	of	safety) in which Congress envisioned that the FAA must, by exemption, allow commercia l operations of UAS
to commence immediately. Also due t o the small size of the UASs and the low altitudes and restricted

areas in which our UAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in t he Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant of the requested exemptions is in the public interest. Accordingly, Pri ncess DeliveryExpress, LLC respectfully requests that the FAA grant	the	requested	exemption	without	delay.

PUBLIC	INTEREST This	exemption	application	is	expressly	submitted	to	fulfill	Congress'	goal	in passing	Section	333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rule making required under Section 332 of the Reform Act. By granting an exemption the FAA wi ll fulfill Congress's intent of allowing UAS to operate with significant safety precautions in low risk

e nvironments. The use of UAS on a construction or inspection site can significantly reduce the risk to workers	of	falls	while	inspecting,	surveying,	or monitoring	site	progress.	UAS	can	inspect, p hotograph, and collect data on hard to get to areas that otherwise would require worker inspection. Falls are the leading source of workplace fatality and injury on construction sites', and reducing falls through UAS

use for site imaging could save workers lives. Additionally, UAS could replace the use of helicopters and small aircraft to monitor sites. The UAS we propose to fly in this application are under five pounds, and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. Shifting to UAS from helicopters presents a marked safety increase for our workers	and	the	public.

Lastly,	UAS	reduce	the	environmental	impact	by	dramatically	decreasing	the	energy	use d	for	aerial imaging	and	data	collection	over	a	construction	site.	Our	UAS	use	rechargeable	lithium	ion	batteries,

as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier.

EQUIVALENT	LEVEL	OF	SAFETY Prin cess DeliveryExpress, LLC proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of s afety to operations under the current regulatory structure because the proposed operations represent a safety 1 "Commonly Used Statistics", Occupational Safety & Health Administration. Available at: https:// www.osha.gov/oshstats/commonstats.html enhancem ent to the already safe protocols followed on construction sites and imaging and surveying operations conducted with helicopters and otherconventional aircraft. Princess DeliveryExpress, LLC will be bound by the following limitations when

conducting	its	U AS	operations	under an	FAA	issued	exemption:

1. The	UAS	will	be	less	than	10	pounds. 2. Flights	will	be	operated	within	visual	line	of	sight	of	a	pilot. 3. Maximum total flight time for	each operational flight will be 30	minutes. The UAS	calculates battery

reserve in real time, and will return to its ground station with at least 20% battery power reserve should	that	occur	prior	to	the	30	minute	limit. 4. Flights	will	be	operated	at	an	altitude	of	200	feet AGL,	never	exceeding	400	feet	AGL. 5. Crew for each operation will consist of the UAS pilot who will keep the UAS within his visual line of sight	at	all	times	and	a	spotter when	required

. 6. The UAS pilot will be trained in flight, operations, and safety procedures as detailed in this document	and as	detailed	in	the	DJI	Manual. 7. The	UAS	will	only	operate	within	a	confined	areas	as	defined	in	this	document.	This	document	and the	DJI	Manual	also	requires	the	establishment	of	a Security	Perimeter	for	the	flight	operations	area. 8. A briefing	will be	conducted	in	regard	to	the	planned	UAS	operations	prior	to	each	day's	production activities.	It	will	be	mandatory	that	all	personnel who	will	be	performing	duties	within	the	boundaries of	the	safety	perimeter	be	present	for	this	briefing. 9. All	onsite personnel	will	consent	to	the	UAS	flyover	on	site	by	waiver,	and	the	operator	will	obtain additional	verbal	or	written	consent	of	all	persons who	will	be	allowed	within	100	feet	of	the	flight operation. 10. The	pilot	will	have	been	trained	in	operation of UAS	generally	and	received	up

- to

- date	information on	the	particular	UAS	to	be	operated	as	required	by	this	document. 11. Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained. 12. All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	county	or	city jurisdictions,	including	local	law	enforcement,	fire,	or	other	appropriate	governmental	agencies. 13. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	i t	will	have	capability	to	return	to	a	pre

determined	location	within	the	Security	Perimeter	and	land.

DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91203(a)(1) Subpart H, entitled Airworthiness Cert ificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §9 1.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Princess DeliveryExpress, LLC

, an exemption from Part 21 s ubpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt air craft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operation al capability, and proximity to airports and populated areas of the particular UAS. Our small UAS will be operated at low speed in a contr olled environment, at least five miles from an airport and more than	three	miles	from	any	city	or	densely	populated	area.