Page 1 March 11 , 2015

US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington,
DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and the requirements contained within 14 C.F.R. Part 11, Prestige Aerial requests an exemption from Federal Aviation Regulations (FARs) detailed below for the 3D Robotics Inc. (3DR) IRIS+, Aer o and X8+ unmanned aircraft systems.

The requested exemption would support an application for a commercial Certificate of Authorization to provide aerial photography and videography services. The 3DR IRIS+, Aero and X8+ vehicles all utilize the same intern al electronics and flight systems for consistency and compatibility, with the difference being different airframe configurations adapted for specialized applications and environments. Each vehicle carries a geo

- referenced camera that allows it to conduct p recision photography and videography services.

The managing principal of our company, and UAV pilot, is an FAA Certified Single Engine Land (“ASEL”) private pilot with experience in both certificated and experimental aircraft. He has extensive experience i n flight operations in the National Airspace System (“NAS”) and is a member of the Aircraft Owners and Pilots Association (“AOPA”), the Experimental Aircraft Association (“EAA”), and the Academy of Model Aeronautics (“AMA”). In addition, he has participate d in numerous FAA Safety seminars earning credits towards the WINGS Pilot Proficiency Program over the last 9 years.

The unmanned aircraft included in this exemption will be operated in the field with both a Pilot in Command (PIC) and a ground

- based Visua l Observer (VO) in accordance with the FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the following additional operating restrictions:

1. All operations will occur in Class G airspace at no more than 400ft AGL

2. Operations will be oper ated over private property with the permission of the land owner

3. All required permits will be obtained from state and local government prior to operation

4. The aircraft will not be operated over urban or populated areas

5. The aircraft will not be operated at a ir shows or over an open

- air assembly of people

6. The aircraft will not be operated over heavily trafficked roads

7. Operations will be limited to day and visual meteorological conditions (“VMC”)Page 2 8. Aircraft will remain within visual line of sight at all times

9. Whi le the aircraft is airborne, the VO will be positioned within voice distance to the PIC

10. PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation

The PIC and VO will meet the requirements outlined in the FAA Policy N 8900 .227 Section 16 Personnel Qualifications. The PIC and VO will perform maintenance on the system along with completing a n in

- service on maintenance, safety procedures , and operator conduct ( See
Attachments ) as part of their initial training. We do not antic ipate the need for a supplemental pilot, due to the simplicity of the system.

We submit that the combination of strict operation under the guidelines established in 8900.227 and the aircraft's light weight, historically demonstrated flight performance, and a fully qualified flight crew, the FAA can have confidence that the operation will have an equivalent or greater level of safety of a manned aircraft performing the same mission.

The name and contact information of the applicant are:

Prestige Aerial
Attn : Matthew Johnson
Ph one : 210

- 509

- 7777 Email: mjohnson@prestigeaerial.com

The regulations from which the exemption is requested are as follows:

14 CFR Part 21
14 CFR 91.203 14 CFR 45.23, 45.29 14 CFR 91.9 14 C FR 61.113(a) & (b), 61.133(a) 14 CFR 91.109, 91.119 14 CFR 91.121, 91.151 14 CFR Subpart E (91.401

- 91.417) FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to hearing from your office. Please contact us at any time.

Sincerely,

Matthew Johnson Founder, Prestige AerialPage 3 Appendices:

A. Exemption Request and Equivalent Level of Safety
B. Safety Guidelines (Safety Che ck Procedure) C. Safety Log
D

. UAV Operator Guidelines & Code of Conduct
E

. Operations Manual IRIS+
F. Flight Checklist IRIS+
G

. Maintenance Procedures IRIS+ and X8+
H. Operations Manual X8+
I. Flight Checklist X8+
J

. Operations Manual Aero
K. Flight Che cklist Aero
L

. Maintenance Procedures Aero
M

. Flight Log