Federal	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 advertising; 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 ofthe 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	documentwe have found it to be acceptable for UAS operations on our project sites. Thank you for your time and consideration,	and	please	let	me	know	if	you have	any	questions. Sincerely,

Randall	Newman Princess	DeliveryExpress,	LLCIntended	UAS	Use

To recordvideo and capture pictures ofclient's homes/properties forthe 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
and	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 amountofinterestintakingvideo and photos foradvertisingin ourlocal area. Utilizingthe UAS will offera significantimprovementto the agencywith regards to both safetyand cost. Usinga 6 lb. UAS comparedto a gas turbine helicopteroraircraftwill offera considerable safetymargin 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 roofto complete his initial inspection. A sUAS 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 forbuilding exteriors would be greatly enhanced by the use ofa 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	investigation - Such	as	steep	hillside	or	bluff.	Recording	the	visual	condition ofexisting hillsides
or bluffs thatwould otherwise bevery difficultto access and record. Itwould also be less intrusive to environmentally	sensitive	areas.

• Site development

- Creating high resolution scalable overhead photography of a property would be 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 have. Development of existing properties for remodeling or renovation especially commercial building where equipment is located on the roofwould also benefit from HD photos that document the equipment and its location. Currently Google Maps are useful for such 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 maintenance

- To record landscape health and irrigation proficiency on large properties such as condominiums, apartment complexes, malls, golfcourses or even public parks and recreation
areas.

• There are many other areas that a UAS would be a safer, accurate and less expensive alternative to current commercial services but Princess DeliveryExpress, LLCwould 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 ofthe 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 FederalAviation Regulations ("FARs") to allow commercial operation ofits Small UnmannedAircraft	Systems ("UAS") for aerial imaging for safety and	monitoring ofsecured	and controlled	environment	construction	sites,	so	long	as	such	operations	are	conducted	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 conditions 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

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-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 Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 ofthe 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	inthe 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) ofthe ReformAct assists the Secretary in determining whether UAS may operate in the National Airspace System (NAS) without creating a hazard 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	operator •	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 requirements 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 Flight 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 ofthe UAS involved and the restricted and sterile environment 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 commercial operations of UAS to commence immediately.Also due to the small size ofthe UASs and the low altitudes and restricted
areas in which our UAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the 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 ofthe requested exemptions is in the public interest. Accordingly, Princess 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	inpassing	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 will fulfill Congress's intent of allowing UAS to operate with significant safety precautions in low risk
environments. The use ofUAS 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, photograph, and collect data on hard to get to areas that otherwise would require worker inspection. Falls are the leading source ofworkplace 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	used	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 Princess 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 safety 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 enhancement 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	UAS	operations	underan	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. Maximumtotal flighttime for	each operational flightwillbe 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	feetAGL,	never	exceeding	400	feet	AGL. 5. Crew for each operation will consist ofthe UAS pilotwho will keep the UAS within hisvisual line of sight	at	all	times	and	a	spotterwhen	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. Abriefing	willbe	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 ofUAS	generally	and	received	up

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-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,	it	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 Certificates, establishes the procedural requirements for the issuance ofairworthiness 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 subpart H meets the requirements ofan 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 aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operation al capability, and proximity to airports and populated areas ofthe particular UAS. Our small UAS will be operated at low speed in a controlled environment, at least five miles from an airport and more than	three	miles	from	any	city	or	densely	populated	area.