### Queen of the Drone, Inc

Owner/UAS Operator: Tressa Cioffi 11562Timberline Cir Fort Myers, FL 33966 239-645-5864

U.S. DepartmentofTransportation 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; 14CFR 91.119(C); 14 CFR91.121; 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 ItMay Concern: Pursuantto Section 333 ofthe Federal Aviation Administration (FAA) Modernization and Reform Act of2012 (the"Reform Act'') and 14 CFR Part 11,Tressa Cioffi, ownerofQueen ofthe 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 oras may be established bythe FAA as required by Section 333. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would operate in thefollowing 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 governmentauthority. • Aerial video/photography or providing live video feed to assist with search and rescue operations in cases ofemergency or natural disaster only when the local authorities or government has requested it by contractordonation. Queen ofthe Drone, Incoperates 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 of400'. 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 supporttechnologythatallows ittofly utilizing global positioning system (GPS) for stability, tracking, safe flight mode and a return-to-home feature in the event ofloss ofremote control signal orcritical 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 aircraftconditionsare 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 ofsight (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 bythefollowing additional operating conditions underthisexemption, 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 presentan undue hazard. Othersafetyoperating parameters include:

• Operatethe UAS for 15-20 minutes perflight. • Land UAS priorto the manufacturers recommended minimum level ofbattery power. • Operatethe UAS during daylight hours only within VLOS. Utilize the UAS' GPS flight safety feature whereby it hovers and then slowly lands if communication withthe PIC is lostor battery becomes critically low.• Always obtain all necessary permissions priorto operation. • Have procedures in place to abort flights in the event of safety breaches or potential danger. • Review weather reports priorto flight and never operate UAS in unsafe conditions, high wind, low clouds orconditions thathindervisibility. Only operate in safe environmentsthatare strictly controlled, are awayfrom 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 ofQUEEN OF THE DRONE, INC as well as guidelines of 14 CFR §61.51(b) having the abilityto safelyoperatethe UAS in a mannerconsistent with theoperating documents, including evasive and emergency maneuvers and maintaining appropriatedistancesfrom 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), subjectto certain conditions and limitations, is warranted and meetsthe requirements foran equivalent level ofsafety under 14 CFR Part 11 and Section 333 ofP.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 ofthis, 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 thatanyone 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 attendantto the operation ofthe UAS is far lessthanthe risk levels inherent in thecommercial activitiesoutlined in 14CFR §61. The operation and limitations in theflightoperation manual (FOM) will equateto thesafeoperations ofthe UAS. Queen of the Drone, Inc requests an exemption from 14 CFR 91.7 (a) which prohibits the operation ofan aircraftwithoutan airworthiness certificate, sincethere 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 ofthe UAS before each flightas 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 ofsafety will be achieved by maintaining asafety/flight manual with the UAS groundStation. 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 asingle remote controller. Queen ofthe 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 of400 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, weightand maneuverabilityand speed ofthe UAS, an equivalent or higher level ofsafetywill be achieved. Queen ofthe Drone, Inc requests an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable sincethe UAS utilizes electronic GPS with a barometric sensor. Queen ofthe 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 electricand two low battery alerts are issued - per the operating documents, the UAS will be landed atthe 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 aflight unless, considering wind an forecast weather conditions, there is enough powerto flyto the first pointofintended landing and, assuming normal cruising speed, land the UAS with 30 percent battery power remaining. 

### Summary I will comply with 

### all ofthe 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 ProfessionalAircraftSystem. 2. The UAS will notbe flown atan 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 proceduresspecified in the operating documents. 4. The UAS will be operated within VLOS ofthe PIC atall times. 5. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by the proceduresspecified in the operating documents. 6. All operations may utilize a visual observer (VO). The UAS will be operated within the VLOS ofthe 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 ofthe flight. The PIC will ensure that the VO can perform thefunctions prescribed in theoperating 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 totheAdministrator upon request. 8. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe 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 ofaflightcritical 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 alterationswill 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 complywith all manufacturer Safety Bulletins

. 12.An authorized person will make an entry in the aircraft record ofthe 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. Priorto operations conducted forthe purpose ofaerial 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 forthe purpose ofaerial 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 operationswill be conducted undervisual meteorological conditions (VMC). 17.The UAS will not operate within five nautical miles of an airport reference point as denoted on acurrent FAA-published aeronautical chart. 18.The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom acloud orwhen visibility is less than three statute miles from the PIC. 19. Ifa UAS loses communications or loses its GPS signal, itwill return to a predetermined location within the planned operating area and land or be recovered in accordance with theoperating documents. 20.The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance withthe operating documents. 21.The PIC will not begin aflight 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 otherappropriate governmentoversightagency 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 ofway to all manned aviation operations and activities atall times.25.The UAS will not be operated bythe PIC from any moving device orvehicle. 26.The UAS will not be operated over congested or densely populated areas unless contracted outto 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 nearvessels, vehicles orstructureswheretheowner/controllerofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating 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/controllerorauthorized 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 tothe FAA's UAS Integration Office (AFS- 80)within 24 hours. Accidents will be reported tothe National Transportation Safety Board (NTSB) per instructionscontained on the NTSB website: www.ntsb.gov. On behalfofQueen ofthe Drone, Inc, I would liketothankyou foryourconsideration in granting this exemption.

Thanks and Regards,



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Queen ofthe Drone, Inc