USDepartmentofTransportationDocketManagementSystemsWestBuilding,GroundFloorRoomW12-1401200NewJerseyAve.,SEWashington,DC20590DroneIntegrationServices,Inc.AndresL.JusticiaDollFounder/President216ChesterfieldCourtUnitBSchaumburg,IL60193DearSirorMadam:Letthisletterandencloseddocumentationserveasarespectfulandformalrequestfromme,AndresL.JusticiaDoll,founderandpresidentofDroneIntegrationServices,Inc.,tobeallowedtooperatedrones,commercially,forcompensationorhire.Theencloseddocumentationhasbeenformattedfollowing"PetitionforExemption14CFR11.81",asfoundintheFAA'swebsite,www.faa.gov. Iamconfidentyouwillfindalltheinformationinorder.Icanbereachedforquestionsorconversationaboutthematterherebyenclosedviae-mailatjusticiadoll75@gmail.com,orviaphoneat(787)-374-3741.DroneIntegrationServices,Inc.Page[1TABLE OF CONTENT 1) GENERAL INFORMATION 2) INTRODUCTION 3) BASIS FOR PETITION 4) EXEMPTIONS SEEKED 5) EXTENT OF RELIEF 6) PUBLIC BENEFIT 7) PUBLISHABLE INFORMATION 8) ADDITIONAL INFORMATION 9) PRNILAGES OUTSIDE THE UNITES STATES

Page 

### 121) GENERAL INFORMATION a) Drone Integration Services, Inc. 1. Founder/President: Andres
L. Justicia Doll 11

. Physical/Mailing address: 216 Chesterfield Court
B Schaumburg

IL 60193 111. E-mail address: justiciadoll75@gmail.com 1v. Incorporating State: Illinois b) Andres
L. Justicia Doll: I've been

a certified pilot, in good standing with the FAA, since October 16th, 2007.

I received my instrument rating on April12 2011. Pursuant

to complying with Section 333 and the FAA's Modernization
Act of 2012,

I feel

I comply with what

I believe
to be the pivotal requirement
for commercial operation
of a drone for compensation

or hire, which
is having

a pilot's certificate and being in good standing with the FAA. Furthermore,

I have been actively involved since age twelve (12) in the radio controlled airplane hobby.

I have continuously maintained membership through the Academy
of Model Aeronautics (AMA), the governing body as it refers to the aero modeling hobby, and am currently

in good standing. 2) INTRODUCTION Drone Integration Services, Inc. is Schaumburg Illinois based company which aims to capitalize
on the commercial use of drones, for compensation

or hire, while serving several market verticals and/or industries

in a variety of specialized functions, within the continental United States (including Alaska), Puerto Rico, United States Virgin Islands and Hawaii. (Privileges outside of the continental Unites States and its territories will be addressed

in the "Privileges outside the United States" section) The ve1ticals and industries that we hope to impact with our services include, but are not limited to:
• Agriculture • Transp01tation • Infrastructure • Engineering • Architecture • Manufacturing • Health care • Legal • Non-for-profit • Higher Education • K-12 • Telecommunications • State and Local Governments • Commercial

, General • Commercial, Industrial • Marketing and Adve1tising • Real Estate • Energy • Oil & Gas

Page 13The specialized functions we hope to perfmm for companies and organizations which are patt of the ve1ticals and industries we mentioned above include, but are not limited to: 

### • still aerial photography 

### • aerial video 

### • closed set functions 

### • cinematography 

### • photometry 

### • topography studies 

### • geo mapping 

### • surveying 

### • strategic farming studies 

### • livestock monitoring 

### • logistics 

### • crowd control 

### • missing per
s on search 

### • rapid response 

### • structure inspections 

### • surveillance 

### • flight instruction/training 

### • flare stack inspections 3) BASIS FOR PETITION Drone Integration Services, Inc., pursuant

to comply and abide with and by the provisions put forward by the FAA Modernization
Act of2012 and Section 333, hereby respectfully request that petmission

be granted,
in a manner which aligns with the interest of the FAA and that of Drone Integration Services, Inc

. in conducting commercial operations safely, to operate drones, commercially,

for compensation

or hire. Drone Integration Services, Inc.'s fleet of drones comprises
of the following: DJI Phantom

2 DJI Phantom

1 DJI Inspire Free Fly Systems Alta Trimble UX-5 These are commercially available drone units which operate well within the limitations
for weight, speed, altitude and operational capabilities
set fmth by the FAA. In addition,
all of these commercially available drones have been listed in other several petitions for exemption

as being pa11 of a drone fleet. Further technical infmmation will be furnished upon request. 4) EXEMPTIONS SEEKED Following suite whereas other section 333 applicants have put forward this section for "exemptions seeked" and have successfully navigated the application process
to operate their drones, for compensation

or hire, Drone Integration Services, Inc. hereby respectfully request exemption from the following Federal Aviation Regulations patts/sections/sub-sections:

Page 

## 1414 CFR 21 subpart
H Airworthiness cetiificates 14 CFR 45.23 Display of marks, general 14 CFR 61.113 Private pilot privileges and limitations: pilot in command 14 CFR 91.9 Civil aircraft :flight manual, markings and placard requirements 14 CFR 91.1 09 Flight instruction: simulated instrument flight and cetiain flight tests 14 CFR 91.119 Minimum safe altitudes: general 14 CFR 91.121 Altimeter settings 14CFR 91.151 Fuel requirements

for flight in VFR conditions 14 CFR 91.203 Civil aircraft: cetiifications required 14 CFR 91.405 Maintenance required (a)(b) 14 CFR 91.407 Operation after maintenance, preventive maintenance, rebuilding

or alteration 14 CFR 91.409 Inspections 14 CFR 91.41
7 Maintenance records 5) EXTENT OF RELIEF Pursuant

to complying with the petition format and infmmation required,

as set forward by the "Petition for Exemption 14CFR 11.81
", as found in the FAA's website, www.faa.gov

, let the following section "Extent of Relief' serve as fmiher detail and more granular explanation
for request of exemption,

as listed above. • 14 CFR 21 subpati
H Airworthiness certificates: Based on the size, weight, operation, safety measures, conditions and limitations set fmih, and the pivotal fact that my drones are commercially available and, therefore, places the need to abide by any requirement and/or regulation that the Administrator deems necessary,
on the manufacturer, (including,

if found necessary,
an airwmihiness certificate), exemption should be granted
to Drone Integration Services, Inc, for the reason that we are, merely,

a user. As an alternative, Drone Integration Services, Inc. will set a maintenance/inspection schedule and
a maintenance
log book will be kept for each drone in operation

as to track infmmation that will include, but will not be limited to: date of inspection/repair, name of person who perfmmed repair, what part or appliance
(if any) was replaced, general items or actions performed during inspection/repair,
PIC who performed operation flight check (if applicable), return to service on date. This is an effmi to maintain the fleet in the utmost 

### ainvorthiness condition. • 14 CFR45.23 Display ofmarks, general: In the drone units commercially available today there is no entrance

to a cockpit, cabin or pilot station, therefore, the traditional placement
of flight placards

is not possible. Fmihetmore,

a standardized marking system for "drones" and uav's has not yet been set fmih.

Page 15

### As an altemative, based on Andres
L. Justicia Doll's experience

in the field of radio controlled airplane flying, and the impmiance

of, at a very basic level

, being able to identify

a flying craft, Drone Integration Services, Inc. will place the appropriate markings,

in a manner that is convenient and does not interfere with the safe operation
of the drone, as to reflect: drone's owner (Drone Integration Services, Inc

. ) and contact information. • 14 CFR 61.113 Private pilot privileges and limitations: pilot in command: By viliue of this regulation

, which prohibits

a private pilot from flying, persons
or cargo, for compensation

or hire, exemption

is necessary since the FAA has deemed the aeronautical knowledge possessed
by a private pilot as acceptable for acting
as PIC of a drone, flying commercially

, for compensation

or hire. In addition,

in the future, Drone Integration Services, Inc

. will hire pilots as pati of their expansion plans. A private, sport or recreational pilot would meet the FAA's requii·ement
for commercial operations
(as far as having the pilot in command
be a cetiificate holder in good standing with the FAA) and, as such, would respectfully request exemption

in this area

. • 14 CFR 91.9 Civil aircraft flight manual, markings and placard requii·ements: Markings and placards were previously addressed

in 14 CFR 45.23. As an altemative

, the flight manual

, while not practical

to be carried on board the flying drone

, should be kept accessible

to the pilot

, at all times,
at the ground station. Drone Integration Services, Inc. has made this pati of the operating procedures. • 14 CFR 91.109 Flight instmction: simulated instmment flight and cetiain flight tests: By virtue that
a drone is, by nature, unmanned

, therefore

, does not have

a cabin/cockpit/flight station

, instmction cannot be conducted
by use of a "dual control" system

. As an altemative

, Drone Integ

r ation Services, Inc. will establish

a pilot training program, very much like the cunent teaching method for radio controlled model airplanes. This method consists of a pilot in command and
a student. Previous

to the first flight

, the appropriate "ground" time has been spent talking about aircraft systems, control systems, basics of flight and how the actual teaching will take place. While in the air

, there
is constant verbal communication between the student and instmctor and, in the event that the student requires help, the instmctor "takes over" the control unit.

Page 

# 16

### • 14 CFR 91.119 Minimum safe altitudes: general: As set forth in the rules issued by the FAA for safe operation
of a drone, whereas the drone should be operated
no higher than 400ft AGL, exemption from 14 CFR 91.119 is inherently necessary

to comply with the 400ft AGL rule. As an alternative,

as part of Drone Integration Services, Inc.'s operational procedures,
the necessary measures will be taken as to provide for public safety by setting

a "perimeter" which allows for the safe takeoff, flight operations, and landing of the drone while avoiding close contact with the public (people not inherent

to the flight mission), structures, property, etc
.. • 14 CFR 91.121 Altimeter settings: While the drone
is not equipped with an on board pressure sensitive altimeter, the global positioning system aided guidance system (which does have altitude telemetry)

in combination with the organic nature of drone flights (low level, line of sight, one pilot in command and one visual observer), builds

a level of safety as it relates
to obstacle avoidance, controlled flight and general safety. • 14CFR 91.151 Fuel requirements

for flight in VFR conditions: This regulation addressed the traditional, av/jet/diesel/mogas

fuel dependent, flying craft. Exemption

is requested for this part since drones,
as commercially available today, do not rely on fuel as listed before but on electricity provided by a rechargeable battery, for flight. As an alternative, Drone Integration Services, Inc. will enforce the following

as part of its flight procedures:
the pilot in command shall have the ability to initiate the flight, conduct the flight and land while having
at least 20% of battery life remaining. Example: - Battery life, per flight, under normal circumstances:

3 0 minutes flight time - 20% equates
to 6 minutes - Pilot in command can fly up to 24 minutes • 14 CFR 91.203 Civil aircraft: ce1iifications required: While
it is not practical

to have any appropriate documentation aboard the drone, while in flight or on the ground (for lack of storage space onboard), Drone Integration Services, Inc. suggests that, as a viable alternative,

to have all the appropriate documentation stored, available and ready to be reviewed,

at all times, at the ground station.

Page 

# 17• 14 CFR 91.405 Maintenance required: See my explanation
for 14 CFR 21 • 14 CFR 91.407 Operation after maintenance, preventive maintenance, rebuilding

or alteration,

14 CFR 91.409 Inspections and 14 CFR 91.417 Maintenance records: Exemption

is seeked from these regulations since they only petiain
to crafts that have airw01ihiness certificates.
As such

, the drone, providing

it complies with all the limitations put forth by the Administrator, shall not be ruled under these. As an alternative, Drone Integration Services, Inc. will conduct maintenance
and repairs
as prescribed
by the manufacturers' operating handbook. Furthermore, flight, as well as maintenance, logs will be kept for each unit in use. (See 14 CFR 21) 6) PUBLIC BENEFIT The advent of drones and the gesture from the FAA in allowing certificate holders
to be able to conduct commercial operations and applications, could not have come at a better time. The public,
as well as businesses,
are constantly looking
to minimize their footprint and, at the same time, controlling costs while improving safety. Drones
in commercial applications achieve this is several levels: • Decreased congestion

of the National Airspace System • Zero emissions • Decreased noise pollution • Limiting human exposure

to inherently dangerous operations like inspections, mining studies

, surveying, etc. • Decrease cost of doing business (ex:
a drone taking aerial pictures versus

a helicopter taking pictures) • No privacy issues (flights conducted over private
or controlled propetiies, where permission has been previously received) • Employment generation 7) PUBLISHABLE INFORMATION The entire content of this document

is publishable. 8) ADDITIONAL INFORMATION Drone Integration Services, Inc. will potentially become one of the pioneering companies in the United States for commercial applications

of drones. As such, we are committed

to setting f01ih

a positive example

as it relates
to operational excellence, corporate integrity and having safety as our true n01ih. Therefore,
we hereby set forward our unconditional commitment

to following and abiding the rules set forth by the FAA. Fmihetmore,
our internal processes will Page 

### 18reflect this in a way that can be copied by other business

in the spirit of sharing best practices and benchmarking. As it relates
to enhanced safety and making safety the number one priority during pre, mission and post flight operations, Drone Integration Services, Inc. will make the following procedures pati of their operating manual.
In addition,

as best practices stati being shared, we will embrace those that pose the most benefit for enhanced safety. 1) Every unit on our fleet will abide with the limitations
set forward by the FAA as it relates to weight, speed, altitudes, operational capabilities,
etc
.. 2) Day time operations only 3) Line of sight flight 4) Minimum flight crew will consist of Pilot in Command (PIC) and Visual Observer (VO) 5) Pre-mission briefmg mandatory 6) Checklists abided by for pre-flight and post-flight 7) Comply with "minimum fuel" (20% battery life) requirement 8) Petmission (from owner or agent) will be received verbally and noted in written fmm before flight over prope1iy

is commenced 9) If flight mission requires Drone Integration Services, Inc

. to operate with
5 NM of the center of a runway complex of an airpmi, we will advise, with no less than 72 hours, the Administrator ofthe activity.

A detailed briefing ofthe operation will be furnished. On the day of the flight, the PIC will issue, by way of hand held radio, repmiing calls to the controlling tower or CT AF which will include all the pertinent data as it relates to the drone's altitude, location, proximity

to the airport and intentions. 1 0) Drones will yield and give right of way and remain clear at all times 10) PRIVILAGES OUTSIDE THE UNITED STATES The opportunity may arise where

a domestic customer/prospect
may want Drone Integration Services, Inc. to conduct operations outside of the continental United States and/or its tenitories.

If this was the case, Drone Integration Services, Inc. would,
as pati of travel abroad, take with us our safety procedures, any required hardware, software and anything else deemed necessary. Drone Integration Services, Inc. will proactively look into what considerations should be observed when travelling

to other countries (ex: acceptance
of drones
in the country, permits, safety requirements {which exceed the ones established}). Potentially contacting the United States Embassy

at that country for futiher information gathering.

In addition, find local rules for operating drones
in general.

Page 19