Subject: Petition for Exemption 14 CFR § 11.81

Submitted To:

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

Filing Entity:

Company

Saddle Creek Logistics Services

3010 Saddle Creek Rd

Lakeland FL 33801

Main: 863-665-0966

Filing Submitter

Kent Culberson

Sr. Manager Emerging Technologies

Saddle Creek Logistics Services

3010 Saddle Creek Rd

Lakeland FL 33801

Office: 863-668-4432

Email: kent.culberson@sclogistics.com

14 CFR Exemption & Relief Request:

We request the FAA grant a Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS 

operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight 

Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from 

airports or heliports:

5 nautical miles (NM) from an airport having an operational control tower; or

3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

2 NM from an airport without a published instrument flight procedure or an operational tower; or

2 NM from a heliport with a published instrument flight procedure

The “blanket” 200-foot COA allows flights anywhere in the country except restricted airspace and other areas, such as 

major cities, where the FAA prohibits UAS operations. Previously, an operator had to apply for and receive a COA for a 

particular block of airspace, a process that can take 60 days. The agency expects the new policy will allow companies and 

individuals who want to use UAS within these limitations to start flying much more quickly than before.

Section 333 exemption holders will automatically receive a “blanket” 200 foot COA. For new exemption holders, the FAA 

will issue a COA at the time the exemption is approved. Anyone who wants to fly outside the blanket parameters must 

obtain a separate COA specific to the airspace required for that operation.
Benefit to the public as a whole:

Saddle Creek requests authorization for Drone flights above its facilities and operations comprised of static warehouses 

and tractor-trailer parking lots to document aforementioned operations in the form of picture and video recordings 

obtained by drone. Saddle Creek also will perform RC Pilot training and RC pilot flight maintenance operations in areas 

clear of all obstacles and within the constraints of the 14 CFR exemption request.

Reasons why the exemption will not adversely affect safety, or how the exemption would provide a level of safety at 

least equal to the existing rule:

Saddle Creek will be following the guidance offered by the latest advisements and recommendations on drone safety 

provided by the FAA, leading drone flying clubs, and drone manufacturers in terms of:

 Pre-flight planning

 Approved geographric flight areas

 Obstacle detection and avoidance

 Pre-flight drone checklist procedures

 Weather flight-condition pre-assessments

 RC pilot training

 Flight logging

 Post-flight checklists

 Drone maintenance 

Summary of Rule and Exemption:

Saddle Creek Logistics Services formally requests an exemption under Section 333: 14 CFR § 11.81 for flight operations 

outdoors, below 200 feet and prohibited flight in accordance with all established no-fly zones and flight-restricted areas. 

Saddle Creek wishes to conduct flight operations using lightweight, consumer-based drones (Example: DJI Matrice 100) 

with picture and video recording capabilities. These drone operations are anticipated to be used exclusively above and 

around Saddle Creek warehouse facilities. The only known exceptions are for RC Pilot training and RC Pilot maintenance 

which may use areas clear of all obstacles and in accordance with FAA drone flight guidelines (IE: Empty fields).

Requested Territories for Drone Operations:

Saddle Creek limits this exemption request to the United States. No exemption is being requested for flights outside of 

the United States.