April 1, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Petition under Section 333 of the FAA Modernization & Reform Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR) 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization & Reform Act and 14 C.F.R. Part 11, Columbia Timber Company and United Country Land and Lifestyle Properties hereby jointly applies for the grant of exemption from certain Federal Aviation Regulations for Phantom II (Phantom) Unmanned Aircraft manufactured by DJI Co., Ltd. of China. The requested exemption would support an application for a commercial Certificate of Authorization (COA) to use the DJI Phantom 3 Advanced drone, , hereafter referred to as “Phantom,” to support forestry application s including, but not limited to, monitoring timber health for disease and insects, soil and erosion conditions, timber damage from storms, site preparation progress, reforestation efforts, contractor compliance including logging efficien cy, more efficient timber anal ysis for potential thinning or scheduling for a final harvest, farm crop surveillance, real estate photography, videography, and aerial surveying for other commercial, rural , residential and agricultural industries and applications . The Phantom Unmanned Aircraft System (UAS) consists of a lightweight (4 lbs. ) battery operated quadcopter unmanned aircraft, onboard cameras, and associated communications equipment. The Phantom Unmanned Aircraft (UA) has previously demonstrated to have successfully met the safety and operational requirements resulting in previous grants of section 333 exemption requests by other commercial UAS operators. The Phantom UA carries an onboard camera system that allows it to perform aerial photography, videography, and surveying . By approv ing the exemption, Columbia Timber Company and United Country Land & Lifestyle Properties operations will create benefits to both the economy and the environment which are ultimately in the public interest. The aircraft will be operated with both a Pilot in Command and a Visual Observer in accordance with the following additional restrictions:

- All operations will occur at no more than 400' AGL

- The aircraft will be operated with the permission of the property owner- When necessary, applicable permits will be acquired from local authorities

- The aircraft wi ll not be operated at air shows

- The aircraft will not be operated over heavily trafficked roads

- Operations will be limited to day, visual meteorological con ditions

- Aircraft will remain within Visual Li ne of Sight at no greater than 3/4 NM of the PIC at all time

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- When necessary and app licable, Columbia Timber Com pany and United Country Land & Lifestyle Properties will file a NOTAM providing radial/DME, radius, and a date/time group for e ach operation For certain complex operations, Columbia Timber Company and United Country Land & Lifestyle Properties may assi gn one or two sensor/software operators to assist the operations. We submit that the com bination of the Phantom UAV’s light weight and historically demonstrated safe operation and receiving approvals of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operations under the guidelines established within the grant, the FAA can have confidence that Columbia Timber Company and United Country Land & Lifestyle Properties the operations will have an equivalent or greater level of safety of manned aircraft performing the same mission. We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Additional documents supporting this petition will be submitted following this request. We look forward to working with your office. Please contact us at any time if you require additional information or clarification. Respectfully,

Travis Davidson Columbia Timber Company and United Country Land & Lifestyle Properties 4424 NW 13 th Street, Suite C- 2 Gainesville, FL 32609 352 - 375 - 1473 Travis@ColumbiaTimber.com**TABLE OF CONTENTS**

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER ............ ........................................ ...........Page 4 THE SPECIFIC SECTIONS OF 14 C.F.R . FROM WHICH COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIESS SEEKS EXEMPTION............ ............................................. .Page 4 THE EXTENT OF RELIEF Columbia Timber Company and United Country Land & Lifestyle Properti es SEEKS AND THE REASONS Columbia Timber Company and United Country Land & Lifestyle Properties SEEKS THE RELIEF ............................................................... ................................................................. ..Pages 4 to 6 THE REASONS WHY GRANTING Columbia Timber Company and United Country Land & Lifestyle Properties REQUEST WOULD BE IN THE PUBLIC INTEREST. ................................................................ Page 7 THE REASONS WHY GRANTING Columbia Timber Com pany and United Country Land & Lifestyle Properties THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ..... ........................................ Page 8 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............. .................................... .... .Page 9 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Columbia Timber Company and United Country Land & Lifestyle Properties REQUEST................................ ............... .Page 10 ACRONYMS.................................................................. ..................... ........................................ .......... Pages 11 & 12**NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER**

Travis Davidson Columbia Timber Company and United Country Land & Lifestyle Properties 4424 NW 13 th Street, Suite C- 2 Gainesville, FL 32609 Email: Travis@Columbiatimber.com ( 352 ) 375 - 1473 **THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM** 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) **THE EXTENT OF RELIEF COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE**  **PROPERTIES S SEEKS AND THE REASONS**  **COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIES** **S SEEKS THE RELIEF 14 CFR 61.113 Private pilot privileges and limitati**  **ons:** Part 61.113 provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any b usiness or employment if; (1) Flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Since the aircraft cannot carry passengers or property, we request to be relieved from this regulation if our pilots at minimum, (1) Hold at least a current private pilot certificate and, (2) Hold a current third class medical certificate. By meeting conditions (1) and (2), we believe that equivalent level of safety can be achieved by complying with 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. **14 CFR 91.7 Civil Aircraft Airworthiness.** 14CFR 91.7 (a) states, “No person may operate a civil aircraft unless it is in an airworthy condition.” This rule prohibits the operation of an aircraft without an airworthiness certificate. Since there is no such existing certificate that is applicable fo r the Phantom UAS to properly comply with the FARs, we request that Columbia Timber Company and United Country Land & Lifestyle Properties to be relieved from this regulation. To provide equivalent level of safety, we will ensure that the Phantom UAS is in airworthy condition prior to every flight by following safety procedures described in our operating documents.**14 CFR 91.119 Minimum safe altitudes: General**

This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement. To provide an equivalent level of safety we will only fly over private property with the permission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and property on the ground. We maintain that due to the small size of the Phantom, the hazard to persons, vessels, ve hicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. **14 CFR 91.121 Altimeter Settings** This regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The Phantom aircraft will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to de
-conflict with other aircraft. To provide an equivalent level of safety, the PIC will check and confirm the Phantom’s GPS altitude read out before each flight. **14 CFR 91.151 Fuel requirements for flight in VFR condition s.**  The regulation provides that no person may begin a flight in an airplane under day VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We believe the intention of this rule is to provide a reserve of energy as a safety buffer for go
arounds and other delays to landing. The Phantom UAS is battery operated and the maximum duration of flight with full payload, from a single battery charge is approximately 25 minutes. We b elieve that equivalent level of safety can be achieved by limiting our flight time to 20 minutes with reserve energy 20 % (5 minutes) on the battery. **14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 ) Maintenance, Preventive Maintenance, and Alteratio**  **ns** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC, VO or authorized personnel to perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." Colu mbia Timber Company and United Country Land & Lifestyle Properties requests that exemptions to the regulations under conditions below; (1) Columbia Timber Company and United Country Land & Lifestyle Properties will follow Phantom’s manufacturer maintenance instructions, techniques and procedures(2) Columbia Timber Company and United Country Land & Lifestyle Properties will designate,

train, and document the personnel who will be authorized to perform Inspection, Maintenance and Alterations by means of ab ove stated maintenance instructions. Such designated personnel may include PIC, VO or other equivalent trained persons (3) To ensure equivalent level of safety, PIC will inspect the UA before each flight looking for any structural or mechanical malfunctio ns Due to the small size, light weight and simplicity of the Phantom UAS, we believe that the equivalent safety will be achieved by permitting any of the PIC, VO or equivalent trained personnel, to perform maintenance, inspection and alterations of the a ircraft and be authorized to approve the aircraft for return to service. **THE REASONS WHY GRANTING COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND &**  **LIFESTYLE PROPERTIE S’S REQUEST WOULD BE IN THE PUBLIC INTEREST**  We believe that granting our exemption requ est from, 14 CFR Part 21.191 14 CFR Part 45.23, 45.29 14 CFR 61.113, 61.133 14 CFR 91.9, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the public’s interest and will benefit the public as a whole for the following reasons. 1 - Phantom is battery operated and free from the harmful emissions associated with the manned aircraft that are currently used for aerial photography and videography. As recently proven by several grants of section 333 petitions, UASs offer equivale nt level of safety while reducing environmental impacts, which is in the public interest. 2 - Columbia Timber Company and United Country Land & Lifestyle Properties’ UAS operations will contribute to a **positive aggregate economic impact** resulting in **creation of jobs**  both direct and indirectly. Economic Research estimates that the UAS market will grow from $6 billion to $ 94 billion over the next decade resulting in a new workforce development. Because Columbia Timber Company and United Country Land & Lifestyle Properties’ operations will **create new jobs** such as pilots, flight operation staff, and administrative supporting staff, it will directly cause **positive economic impact**, hence granting Columbia Timber Company and United Country Land & Lifestyle Properties’ petition will benefit the public as a whole. 3 - **Congress has already proclaimed** that it is in the public’s interest to integrate commercially flown UAS(s) into the national airspace system, hence the passing of the FAA Modernization and Reform Act of 2012. Granting Columbia Timber Company and United Country Land & Lifestyle Properties’ petition furthers the public’s interest as a demonstrated progression of integrating Unmanned Aircraft Systems into National Air Space, thus it will benefit public as a whole . 4- Proper management and monitoring forest health will insure that our area pulp mills and sawmills have an adequate supply of timber to maintain jobs for both the forest product industry as well as related industries such as building contractors and service employees . 5 - Monitoring forest health contributes to the overall ecosystem management to help protect our wildlife, soil health, and water sheds. Healthy forests provide intangibleecoservice benefits for society. Forest cover is a major factor in regulat ion ambient temperature and hence climate levels both regionally and globally. 6- Forests sequester carbon and therefore have an important ecological function in fixing and storing carbon from the atmosphere. Healthy forests sequester more carbon than poorly functioning forests and monitoring forest health quickly and efficiently contributes to ecosystem services. **THE REASONS WHY GRANTING COLUMBIA TIMBER COMPANY AND UNITED COU**  **NTRY LAND & LIFESTYLE PROPERTIE** **S THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY**  Columbia Timber Company and United Country Land & Lifestyle Properties believe that the grant of exemption from, 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), will not adversely affect safety by a combination of the reasons listed below. (a) We have stated in the above section “ THE EXTENT OF RELIEF COLUMBIA TIMBER COMPANY AND UNITED COU NTRY LAND & LIFESTYLE PROPERTIE S SEEKS AND THE REASONS COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIESS SEEKS THE RELIEF ” by describing how we intend to mitigate risk and accomplish FAA equivalent and acceptable level of safety for each 14 CFR part. (b) As a result of Phantom unmanned aircraft’s size, weight, speed, operational cap ability, proximity to airports and populated areas, operation within visual line of sight combined with the implementation Columbia Timber Company and United Country Land & Lifestyle Properties’ of safety procedures, we believe that granting Columbia Timbe r Company and United Country Land & Lifestyle Properties’ exemption request will not adversely affect safety. (c) DJI Phantom II has demonstrated to satisfy necessary safety risk mitigation by FAA thus resulting in multiple grants of section 333 petitions . Because of the combination of Phantom’s proven success and the conditions and limitations of our operations, we believe granting Columbia Timber Company and United Country Land & Lifestyle Properties request will not adversely safety. **SUMMARY THAT CAN B E PUBLISHED IN THE FEDERAL REGISTER**  Department of Transportation Federal Aviation Administration Petitioner: Columbia Timber Company and United Country Land & Lifestyle Properties Video Partners LLC Petition of exemption from sections of; 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Description of relief sought;Columbia Timber Company and United Country Land & Lifestyle Properties seeks an exemption for

commercial operation of the Phantom unmanned aircraft manufactured by DJI Co, Ltd. of China. The Phantom unmanned aircraft system has an onboard camera system capable of acquiring high resolution data. Proposed operations will offer monitoring timber health for disease and insects, soil and erosion conditions, timber damage from storms, site preparation progress, reforestation efforts, contractor compliance including logging efficiency, more efficient timber analysis for potential thi nning or scheduling for a final harvest, farm crop surveillance, real estate aerial photography, videography and aerial surveying services for other commercial industries. **ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT COLUMBIA**  **TIMBE R COMPANY AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIES** **S’S REQUEST** Phantom II Unmanned Aircraft System General Features  Ready to Fly, Multifunctional Quad
- rotor System  Customized H3
- 2D and H3
- 3D Gimbal Support  Precision Flight and Stable Hove ring  25min Flight Time & Smart Battery  Auto Return -to - Home & Landing  Advanced Power Management  Intelligent Orientation Control (IOC)  Easy Battery Replacement  Self
-tightening Propeller  Video Downlink Support  CAN - Bus Expansion Module  Control Link radio operating frequency 2.4 GHz ISM  Operating Distance 0.65 miles Aircraft Performance Empty Weight 2.5 lbs. Max Take
-off Weight 4 lbs. Max Flight Speed 30 Knots Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m Max Yaw Angular Velocity 200°/s Max Tilt Angle 35° Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s Diagonal Length 350mm Flight Time 25 minutes **No Privacy Issues** Columbia Timber Company and Un ited Country Land & Lifestyle Properties’ proposed operations will create no privacy issues because the Phantom UAS will be operating in rural areas within the boundariesof the properties with the landowner’s permission. Columbia Timber Company and United Country Land

& Lifestyle Properties will also obtain any permits or authorizations from local authorities when necessary. **ACRONYMS**  AGL Above Ground Level  ALoS Acceptable Level of Safety  AMOC Alternative Method of Compliance  ASI Aviation Safety Inspector  ATC Air Traffic Control  ATCAA Air Traffic Control Assigned Airspace  ATS Air Traffic Service  AVS Aviation Safety  CFR Code of Federal Regulations  COA Certificate of Waiver or Authorization  CRM Crew Resource Management  CS Control Station  CRS Certified Repair Station  DCP Divert/Contingency Point  DHS Department of Homeland Security  DME Distance Measuring Equipment  DOD Department of Defense  DSA Detect, Sense, and Avoid System F  AA Federal Aviation Administration  FCC Federal Communications Commission  FARs Federal Aviation Regulations  FIR Flight Information Region  FL Flight Level  FSIMS Flight Standards Information Management System  FTP Flight Termination Point  FTS Flight Termination System  GHz Gigahertz  GCS Ground Control Station  MHz Megahertz MTOW Maximum Takeoff Weight  NAS National Airspace System  NM Nautical Mile  NOTAM Notice To Airman  OPA Optionally Piloted Aircraft  PIC Pilot in Command  Phantom Phantom Unmanned Aircraft System  Phantom Phantom Unmanned Aircraft  R&D Research and Development RF Radio Frequency  RM Risk Management  RNAV Area Navigation  RTB Return to Base  RVSM Reduced Vertical Separation Minimum TAS Traffic Advisory Systems

 TC Type Certificate  UA Unmanned Aircraft  UAS Unmanned Aircraft System(s)  UAV Unmanned Aerial Vehicle  VFR Visual Flight Rules  VMC Visual Meteorological Conditions VO Visual Observer