Queen of the Drone, Inc 

Owner/UAS Operator: Tressa Cioffi 

11562 Timberline Cir 

Fort Myers, FL 33966 

239-645-5864 

U.S. Department of Transportation 

Federal Aviation Administration 

February 6, 2016 

RE: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) 

and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 

14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 

91.409(a)(1) and (2); 14 CFR 91.417(a) and (b) 

To Whom It May Concern: 

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform 

Act of 2012 (the "Reform Act'') and 14 CFR Part 11, Tressa Cioffi, owner of Queen of the Drone, 

Inc, which owns and operates an Unmanned Aircraft System (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of 

its UAS, 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. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would operate in the following manner: 

• Aerial photography and/or video for public and/or private use including real estate, 

architecture, surveying, engineering and other related professional activities. 

• Aerial video and/or photography for public and/or private use including television, public 

events, private events, cinematography and newsgatherings. 
Aerial inspection/photography of residential/commercial structures under contract with 

owners or local government authority. 

• Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation. 

Queen of the Drone, Inc operates two (2) DJI Phantom 3-Professionals ( 4) blade quad copters; 

each weighing 1280 grams. The DJI Phantom 3 Professional is vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet 

or smart phone systems. The DJI Phantom 3 Professional has a maximum gross weight of 

approximately 2.8 lb. while having a diagonal dimension of 23.2", a maximum speed of 

approximately 16.4'fps and a maximum flying height of 400'. The DJI Phantom 3 is equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI 

Phantom 3 Professional has a maximum airspeed of 16m/s and uses a remote controller 

operating on frequency range of 2.400 GHZ - 2.483 GHz. The Phantom 3 Professional is 

equipped with built-in ground support technology that allows it to fly utilizing global positioning 

system (GPS) for stability, tracking, safe flight mode and a return-to-home feature in the event 

of loss of remote control signal or critical low battery 

All flights start with a pre-flight safety check and all flight data are recorded. The Phantom 3 

Professional is equipped with a gimbal-mounted camera that sends a live video signal to the 

controller allowing the person .in control (PIC) to monitor real-time video. Flight data, speed 

height, distance, battery level and general aircraft conditions are also displayed during operation. 

The Phantom 3 Professional has a flight time of 20-25 minutes and is, therefore, always 

returned to original takeoff point and always flown utilizing visual line of sight (VLOS). I have 

been training on the DJI Phantom 3 Professional for 6 months and have become proficient in all 

aspects of flight and safety of this UAS. My request for exemption would allow me to offer 

unique aerial photography and videography services to my clientele. UAS Safety Operating 

Parameters 

I will abide by the following additional operating conditions under this exemption, which ensures 

a level of safety during UAS flight including operating the UAS below 400 feet and within a 

radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from the 

owner/controller of any vessels, vehicles and structures when operations may be conducted 

closer than 500 feet to any such vessels, vehicles or structures. I will conduct a safety 

assessment of the risk of operating closer to those objects and determine that it does not 

present an undue hazard. Other safety operating parameters include: 

• Operate the UAS for 15-20 minutes per flight. 

• Land UAS prior to the manufacturers recommended minimum level of battery power. 

• Operate the UAS during daylight hours only within VLOS. 

Utilize the UAS' GPS flight safety feature whereby it hovers and then slowly lands if 

communication with the PIC is lost or battery becomes critically low. 
• Always obtain all necessary permissions prior to operation. 

• Have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

• Review weather reports prior to flight and never operate UAS in unsafe conditions, high 

wind, low clouds or conditions that hinder visibility. 

Only operate in safe environments that are strictly controlled, are away from power lines, 

elevated lights, airports and densely populated areas. 

• Also conduct extensive preflight inspections and protocols during which safety carries 

primary importance. 

The PIC will also have a minimum of five hours logged on this craft and 10 hours minimum 

flying UAS quad copters under varying conditions and environments and will follow all safety 

protocol of QUEEN OF THE DRONE, INC as well as guidelines of 14 CFR §61.51(b) having the 

ability to safely operate the UAS in a manner consistent with the operating documents, including 

evasive and emergency maneuvers and maintaining appropriate distances from people. 

Specific Exemptions Requested 

Given the size, weight, speed and limited operating area associated with the UAS, I feel an 

exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a) 

and (b) (certificgtions required), subject to certain conditions and limitations, is warranted and 

meets the requirements for an equivalent level of safety under 14 CFR Part 11 and Section 333 

of P.L. 112-95 (Section 333). 

Queen of the Drone, Inc requests an exemption from 14 CFR 45.23 Marking of the Aircraft 

because the UAS will not have a cabin, cockpit or pilot station on which to mark certain words 

or phrases. Further, the two-inch lettering is difficult to place on such a small aircraft with 

dimensions smaller than the minimal lettering requirement. Regardless of this, I can mark the 

UAS in the largest possible lettering by placing the word "Experimental" on its fuselage as 

required by 14 CFR 45.29(f) so that anyone will see the markings. I request an exemption from 

14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command. The 

applicant's UAS do not carry any pilots or passengers nor property. The Risks attendant to the 

operation of the UAS is far less than the risk levels inherent in the commercial activities outlined 

in 14 CFR §61. The operation and limitations in the flight operation manual (FOM) will equate to 

the safe operations of the UAS. 

Queen of the Drone, Inc requests an exemption from 14 CFR 91.7 (a) which prohibits the 

operation of an aircraft without an airworthiness certificate, since there is currently no certificate 

applicable to my operation, this regulation is inapplicable. I request an exemption from 14 CFR 

91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a) 2) and 14 CFR 91.417(a) and (b) 

Maintenance inspections since they only apply to aircraft with an airworthiness certificate. 
However, as a safety precaution, I will perform a preflight inspection of the UAS before each 

flight as outlined in the attached operating documents. 

Queen of the Drone, Inc requests an exemption from 14 CFR 91.9(b)(2) which requires an 

aircraft FOM in the aircraft, however, since there are no pilots or passengers on board the 

aircraft, and given its size, this regulation is inapplicable. I believe an equivalent level of safety 

will be achieved by maintaining a safety/flight manual with the UAS ground Station. 

Queen of the Drone, Inc requests an exemption from 14 CFR 91.109 Flight Instruction : 

Simulated Instrument Flight and Certain Flight Tests. The regulation states, "No person may 

operate a civil aircraft that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. Although the DJI Phantom 3 Professional is capable of dual/linked 

controls, I will be operating with a single remote controller. 

Queen of the Drone, Inc requests an exemption from 14 CFR 91.119(c) which prescribes safe 

altitudes for the operation of civil aircraft, but allows helicopters to be operated at lower 

altitudes in certain conditions. I will not operate my UAS above the altitude of 400 feet above 

ground level (AGL) and will also only operate in safe areas away from the public and traffic, 

thus "providing a level of safety at least equivalent to or below those in relation to minimum 

safe altitudes." Given the size, weight and maneuverability and speed of the UAS, an equivalent 

or higher level of safety will be achieved. 

Queen of the Drone, Inc requests an exemption from 14 CFR 91.121 Altimeter Settings, as it is 

inapplicable since the UAS utilizes electronic GPS with a barometric sensor. 

Queen of the Drone, Inc requests an exemption from 14 CFR 91.151(a) Fuel Requirements for 

Flight in visual flight rules (VFR) conditions. The UAS is 100 percent electric and two low battery 

alerts are issued - per the operating documents, the UAS will be landed at the first alert. Also, 

my flights will last only 15-20 minutes each and the UAS has an automated function, which 

results in immediate landing when a low battery is detected. 

The PIC will not begin a flight unless, considering wind an forecast weather conditions, there is 

enough power to fly to the first point of intended landing and, assuming normal cruising speed, 

land the UAS with 30 percent battery power remaining. 

Summary 

I will comply with all of the following conditions and limitations should this grant of exemption 

be provided: 

1. Operations will be limited to the following aircraft described in the operating documents 

which is a quad-rotor aircraft weighing less than seven pounds: DJI Phantom 3 

Professional Aircraft System. 

2. The UAS will not be flown at an indicated airspeed exceeding 35.79 mph. 
3. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by 

the procedures specified in the operating documents. 

4. The UAS will be operated within VLOS of the PIC at all times. 

5. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by 

the procedures specified in the operating documents. 

6. All operations may utilize a visual observer (VO). The UAS will be operated within the 

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 will not transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform 

the functions prescribed in the operating documents. 

7. The operating documents will be accessible during the UAS operations and made 

available to the Administrator upon request. Any revisions to the operating documents 

will be presented to the Administrator upon request. 

8. 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 safe operation of the UAS, 

the UAS will not be operated until the necessary maintenance has been performed and 

the UAS is found to be in a condition for safe flight. The Ground Control Station will be 

included in the preflight inspection. All maintenance and alterations will be properly 

documents in the aircraft records. 

9. Any UAS maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, will undergo a functional 

test flight. The PIC who conducts the functional test flight will make an entry into the 

aircraft records. 

10. Queen of the Drone, Inc will carry out maintenance, inspections and record-keeping 

requirements, in accordance with the operating documents. Maintenance, inspection 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. 

11. Each UAS operated will comply with all manufacturer Safety Bulletins. 

12. An authorized person will make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections. 

13. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an 

aircraft in which the PIC is rated on. 
14. Prior to operations conducted for the purpose of aerial videography/cinematography and 

augmenting real estate listing videos (or similar operations), the PIC will have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 

five hours as an UAS pilot operating the make and model of the UAS to be used in 

operations. 

15. The PIC will not operate the UAS for the purpose of aerial videography/cinematography 

and augmenting real estate listing videos (or similar operations), unless the PIC has 

demonstrated and logged in a manner consistent with 14 CFR 61.5l(b), the ability to 

safely operate the UAS in a manner consistent with the operating documents, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

16. UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1 All 

operations will be conducted under visual meteorological conditions (VMC). 

17. The UAS will not operate within five nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart. 

18. The UAS will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than three statute miles from the PIC. 

19. If a UAS loses communications or loses its GPS signal, it will return to a predetermined 

location within the planned operating area and land or be recovered in accordance with 

the operating documents. 

20. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

21. The PIC will not begin a flight unless, considering wind and forecast weather conditions, 

there is enough power to fly at a normal cruising speed to the intended landing point 

and land the UAS with 30 percent battery power remaining. 

22. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS will comply with the Federal Communication Commission (FCC) or 

other appropriate government oversight agency requirements. 

23. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to 

the PIC at the Ground Control Station of the UAS at any time the UAS is operating. 

These documents will be made available to the Administrator or any law enforcement 

official upon request. 

24. The UAS will remain clear and yield the right of way to all manned aviation operations 

and activities at all times. 
25. The UAS will not be operated by the PIC from any moving device or vehicle. 

26. The UAS will not be operated over congested or densely populated areas unless 

contracted out to do events. 

27. Flight operations will 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 UAS and/or debris in the event of 

an accident. I will ensure that nonparticipating persons remain under such protection. If 

a situation arises where nonparticipating persons leave such protection and are within 

500 feet of the UAS, flight operations must cease immediately. 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. c. Operations near to the PIC, VO, operator trainees or 

essential persons do not present an undue hazard to those persons per 14 CFR 

91.119(a). 

28. All operations will be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

29. Any incident, accident or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable certificate of 

authorization (COA) will be reported to the FAA's UAS Integration Office (AFS- 80) within 

24 hours. Accidents will be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB website: 

www.ntsb.gov. 

On behalf of Queen of the Drone, Inc, I would like to thank you for your consideration in 

granting this exemption. 

Thanks and Regards, 

Tr~:~ C1f 

Queen of the Drone, Inc