September 29 th , 2015

U.S. Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of th e FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113(a) & (b); 91.7 (a); 91.103; 91.119(c); 91.121; 91.151(a); 91.405; 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417 (a) & (b).

To Whom It May Concern: Pursuant to Section 333 of the FAA Modernization an d Reform Act, I, David Grayson, operator of an Unmanned Aircraft System (UAS), hereby apply, on behalf of Hillwood Construction Services, L.P., for an exemption from the listed Federal Avia tion Regulations to allow commercial operation of an unmanned aircraft system, as long as operatio ns are conducted within and under the conditions outlined below and as may be established by the FAA as required by Section 333. I would like to formally submit for an exemption fr om part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a),91.2 03(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Co de of Federal Regulations (14 CFR). This proposed exemption would allow the operation of unmanned air craft systems for the purpose of aerial videography and photography within the construction industry. Commercial operation of an UAS, as described herein , which are equipped with camera(s) and sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or p rivate use including construction, real estate, architecture, land surveying, engineering a nd other construction related activities.

2. Aerial video and/or photography for public and/or p rivate use including television, public events, cinematography and newsgathering.

3. Aerial inspection/photography of commercial structu res with consent from owners or local government authority.

4. Aerial inspection/photography of commercial utility infrastructure with consent from owners or local government authority.5. Training to persons individually or belonging to bo th private and/or public organizations to increase awareness and improve safety for current a nd future UAS operations within the NAS. As described fully below, the requested exemption w ould permit the operation of designated UAS as set forth in this document under controlled conditions in the NAS that would be

a. Limited b. Controlled

c. Predetermined d. Safe Approval of this exemption would increase public aw areness of UAS operations and enhance safety to aid in fulfilling the Secretary of Transp ortation’s (the FAA Administrator’s) responsibiliti es to “establish requirements for the safe operation o f such aircraft systems in the national airspace system.” I plan to operate a UAS, the DJI Phantom 3 Professi onal which is comprised of an unmanned aircraft and transportable ground station. The Phan tom 3 is referred to as a quad-copter with a maximum gross weight of about 3 pounds. It is equip ped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. Given the small size of the UAS’s involved and the restricted controlled environment within which they will operate, the applicant fits within that z one of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exe mption, allow commercial operations of UAS to commence immediately. Also due to the size of th e UAS and the controlled areas in which the UAS will operate, approval of the application prese nts no national security issue. Given the following, the grant of the requested exe mptions is clearly in the public interest: David Grayson proposed that the exemption requested herei n apply to civil aircraft that have the characteristics and that operate with the limitatio ns listed herein. These limitations provide for an exceptional level of safety to operations. These li mitations and conditions to which David Grayson agrees to be bound when conducting commercial opera tions under an FAA issued exemption including:

1. Operations will be limited to the following aircraf t described in the operating documents, which is a quad-rotor aircraft weighing 2.8 pounds: Phantom 3 Unmanned Aircraft System. 2. The UA will not be flown at an indicated airspeed e xceeding 50 knots. 3. The UA will be operated at an altitude of no more t han 400 feet above ground level (AGL), All altitudes reported to ATC must be in fee t AGL. 4. The UA will be operated within visual line of sight (VLOS) of the Pilot-InCommand (PIC) at all times. 5. All operations will utilize a visual observer (VO). The UA will be operated within the visualline of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and wi ll not transfer his or her designation for the duration of the flight. The PIC will ensure that th e VO can perform the functions prescribed in the operating documents. 6. The operating documents will be accessible during U AS operations and made available to the Administrator upon request. Any revisions to the op erating documents will be presented to the Administrator upon request. 7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the saf e operation of the UAS, the UAS will not be operated until the necessary ma intenance has been performed and the UAS is found to be in a condition for safe flig ht. The Ground Control Station will be included in the preflight inspection. All maintenance and alteratio ns will be properly documented in the aircraft records. 8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight criti cal component, will undergo a functional test flight. The PIC who conducts the functional te st flight will make an entry in the aircraft records. 9. The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items, o r equipment, not already covered in the relevant sections of the operating documents. 10. We will follow the UAS manufacturer’s aircraft/comp onent, maintenance, overhaul, replacement, inspection, and life limit requirements.11. We will carry out maintenance, inspections, and rec ord keeping requirements, in accordance with the operating documents. Maintenance, inspecti on, and alterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 12. Each UAS operated will comply with all manufacturer Safety Bulletins. 13. An authorized person will make an entry in the airc raft record of the corrective action taken against discrepancies discovered between inspection s. 14. The operator will have been trained in operation of UAS and received up-to-date information on the particular UAS to be operated as required. 15. Prior to operations conducted for the purpose of ae rial videography/photography and for real estate listing videos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at l east 10 hours logged as a UAS pilot with a multi -rotor UAS. 16. Prior to operations conducted for the purpose of ae rial videography/photography and for real estate listing videos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations. The PIC will accomplish 3 take-offs and landings in the preceding 90 days. 17. The PIC will not operate the UAS for the purpose of aerial videography/photography and for real estate listing videos and public and private events and similar operations, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the operating d ocuments, including evasive and emergency maneuvers and maintaining appropriate distances fro m people, vessels, vehicles and structures. 18. UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC). 19. The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart without pr ior notification to the flight control tower. 20. The UA will not be operated less than 500 feet belo w or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute mil es from the PIC. 21. If a UA loses communications or loses its GPS signa l, it will return to a predetermined location within the planned operating area and land or be re covered in accordance with the operating documents.22. The PIC will abort a flight in the event of unpredi cted obstacles or emergencies in accordance with the operating documents. 23. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. 24. We will obtain an Air Traffic Organization (ATO) is sued Certificate of Waiver or Authorization (COA) prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not more than 72 hours in advance, but not less than 48 hour s prior to the operation. 25. Before conducting operations, the radio frequency s pectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 26. The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the UAS is oper ating. These documents will be made available to the Administrator or any law enforcement official u pon request.Hillwood Construction Services

Victory Plaza -3090 Olive St., Suite 300 Dallas, Te xas 75219 Tel 972-201-2930 Fax 972-201-2929 27. The UA will remain clear and yield the right of way to all manned aviation operations and activities at all times. 28. The UAS will not be operated by the PIC from any mo ving device or vehicle. 29. The UA will not be operated over congested or dense ly populated areas. 30. Flight operations will be conducted at least 500 fe et from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficientl y protect nonparticipating persons from the UA and/or debris in the event of an accident. W e will ensure that nonparticipating persons remain under such protection. If a situatio n arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission 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, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.1 19(a). 31. All operations will be conducted over private or co ntrolled-access property with permission from the land owner/controller or authorized repres entative. Permission from land Owner/controller or authorized representative will be obtained for each flight to be conducted. 32. Any incident, accident, or flight operation that tr ansgresses the lateral or vertical boundaries of the operational area as defined by the applicable C OA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reporte d to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.Hillwood Construction Services

Victory Plaza -3090 Olive St., Suite 300 Dallas, Te xas 75219 Tel 972-201-2930 Fax 972-201-2929 Accordingly, the applicant respectfully requests th at the FAA grant the requested exemption and are prepared to modify or amend any part of this reques t to satisfy the need for an equivalent level of safety. We look forward to working with your office . Please contact me at any time if additional information or clarifications are need.

Sincerely, David Grayson Hillwood Construction Services 3090 Olive Street Suite 300 Dallas, TX 75219 214.755.9747 David.grayson@hillwood.com