AerialWorks Imaging

August 19, 2015 Page 1 of 10 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Aviation Regulations, Seeking Exemption from: 14 C.F.R. Part 21 Subpart H

– Airworthiness Certificates

14 C.F.R. Part 27

- Airworthiness Standards: Normal Category Rotorcraft 14 C.F.R. § 91.7(a)

– Civil Aircraft Airworthiness 14 CFR 91.203(a) & ( b)

– Civil Aircraft: Certifications required. 14 C.F.R. § 91.9(c), 45.23(b), 45.27(a)

– Aircraft Marking and Identification Requirements. 14 C.F.R. §§ 61.113(a) and (b)

– Private Pilot Privileges and Limitations 14 C.F.R. § 91.9

– Civil Aircraft Flight Ma nual, Marking, and Placard Requirements. 14 C.F.R. § 91.109(a)

– Flight Instruction 14 C.F.R. § 91.119

– Minimum Safe Altitudes 14 C.F.R. § 91.121

– Altimeter Settings 14 C.F.R. § 91.151(a)

– Fuel Requirements for Flight in VFR Conditions.
14 C.F.R. § 91.4 05(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b)

– Maintenance, Preventive Maintenance, and Alterations

AERIALWORKS IMAGING specifically proposes to conduct survey and aerial

data collection for real es tate and various industries (not to include closed

- set motion picture filming) with UASs including the D JI Phantom and Inspire

series rotorcraft

.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), AerialWorks Imaging (the operator), Elliot Rivera (the applicant), planned operator of Small Unmanned Aircraft Systems ( s UAS ) equipped to conduct survey and aerial data collection for real estate and various industries (not to include closed set movi e filming), hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operation of their UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA a s required by Section 333.

This requested exemption follows the language of exemptions Pursuant to Section 333 that have previously been approved by the FAA.

As described more fully below, the requested exemption would permit the operation of UASs by the applicant for commercial use that would provide the following benefits: 1. Operations would be performed in an area of operation (designated prior to flight) limited in size suitable to the specific use. 2. The flight would be planned in advance to mi nimize hazards to persons and property in the air and on the ground. 3. The operator would reasonably limit or control access to provide safety to those not involved in the operation.AerialWorks Imaging

August 19, 2015 Page 2 of 10 4. Operation of a sUAS would provide significant safety, environmental a nd other enhancements not possible by larger sized aircraft. 5. An FAA licensed airman with a Private grade or higher pilot certificate would operate the sUAS or an FAA licensed airman with a Commercial grade or higher pilot certificate would directly supe rvise the operation (as per Exemption No. 11157). 6. Provide a beneficial and currently unavailable service to government organizations and the general public that would serve the public interest.

Approval of this exemption would thereby enhance safety an d fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system” Section 333(c) of the

Reform Act.

It is possible to oper ate UASs so to not create a hazard to users of the National Airspace System (NAS), the public or pose a threat to national security if done so safely and responsibly. The applicant has demonstrated their willingness to act safely and responsibly by not eng aging in commercial sUAS operations. The applicant currently holds an FAA Rotorcraft Helicopter Commercial Pilot Certificate (Cert. # 3072198) and a current FAA Rotorcraft Helicopter Flight Instructor Certificate with Instrument Rating. This demonstrates that the applicant has a high regard to safe operations, as well as a necessary high

- level understanding of the NAS and FARs. The experience these FAA certificates represent, serves to add significantly to the level of safety in any operation performed by the applicant or the applicant’s employees.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics of sUAS and that operate with the limitations listed here in. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure as the proposed operations represent a safety enhancement to the already safe aerial commercial photography and survey o perations conducted with conventional aircraft.

The UASs planned to be operated are rotorcraft, each weighing 55 or fewer pounds including payload. They would operate, under normal conditions, at a speed of no more than 87 knots. Operations will be perfo rmed by a qualified sUAS PIC, as outlined below, to insure that the sUAS will “not create a hazard to users of the national airspace system or the public.” Given the small size of the UASs involved and the pre

- planned environment within which they will

ope rate, the applicant believes that these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also, ope ration in a researched (to include applicable NOTAMs), pre

- defined area will prevent the possibility of a national security issue. The operation of UASs by knowledgeable professionals with experience in the NAS will serve to enhance safety, add to the publ ic benefit and reduce environmental impacts related to current methods of aerial photography and survey.

Listed below are the limitations and conditions to which the operator, or its employees, acting as sUAS PIC agrees to be bound when conducting commerc ial operations under an FAA issued exemption:AerialWorks Imaging

August 19, 2015 Page 3 of 10 1. Safety will be the first and foremost consideration in any sUAS operation. 2. The sUAS pilot will be an FAA licensed airman with at least a Private Pilot certificate or the sUAS pilot will be directly superv ised by an FAA licensed airman with at least a Commercial Pilot certificate ( as per Exemption No. 11157). 3. The sUAS FAA licensed airman will be considered Pilot in Command (PIC), whether flying or supervising, and will be responsible for safe operation of the flight. 4. Flights will be operated within visual line of sight (VLOS) of the PIC and visual observer (VO). 5. The sUAS will weigh less than 55 lbs total. 6. Flights will be operated in Class G airspace whenever possible. If operation in other airsp ace is required, the relevant controlling agency will be notified at least 24 hours prior to the operation and, if required, any necessary permission

obtained. 7. Flights will be operated under visibility and cloud clearance requirements equivalent to Visu al Flight Rules (VFR). 8. The sUAS will at all times give way to any aircraft carrying persons.

9. Minimum crew for each operation will consist of the sUAS PIC and visual observer (VO). The observer and PIC will at all times be able to communicate by voice. 10. Prior to a sUAS flight, an area of operation will be established. This area of operation will include a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be established for persons, property and applicable a irspace within the area of operation.

11. Flight planning will include flight completion with at least 20% battery power remaining as measured by the sUAS or appropriate timing. 12. The sUAS aircraft used will utilize GPS navigation, failsafe, return

- to

- h ome (RTH) and/or flight abort safety features. 13. A briefing will be conducted in regard to the planned sUAS operations prior to operation at each new location. All personnel who will be performing duties within the boundaries of the area of operation wil l be present for this briefing. 14. All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. Written (to include elect ronic, and/or oral) permission from the relevant property owners will be obtained prior to an operation. 16. The sUAS pilot will be trained in advance for the safe operation of the sUAS to be operated. This training will include a minimum of 100 takeoff/la nding cycles, 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type. Prior to operations the PIC will have accumulated and logged a minimum of 5 hours as sUAS pilot operating the make and mod el of sUAS as well as 3 takeoffs and landings in the proceeding 90 days. Specific training will include normal and emergency modes of operation and will include familiarization with the operation manual published by the sUAS manufacturer. Training will als o include types of maneuvers to be performed during operations including safe operation in relation to persons, property and applicable airspace.AerialWorks Imaging

August 19, 2015 Page 4 of 10 17.The sUAS PIC will establish a working relationship with a representative at the local

FSDO with which to an nually review safety procedures and other operations to further enhance safety. 18. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the sUAS will not be operated until the necessary maintenance has been performed and the sUAS 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 documented in the aircraft records. 19. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flig ht. The PIC who conducts the functional test flight will make an entry in the aircraft records. 20. The pre

- flight inspection section in the operating documents will account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 21. The operator will follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 22. The operator will carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total t ime in service, description of work accomplished, and the signature of the authorized person returning the sUAS to service. 23. Each sUAS operated under this exemption will comply with all manufacturer Safety

Bulletins. 24. The authorized person will mak e an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

It is the applicant’s belief that the size, speed, operating environment, limitations and level of applicant’s experience in the NAS ou tlined provides an “equivalent level of safety” or better when operating a sUAS for the public interest as outlined in Section 333 in the FAA Modernization and Reform Act of 2012. It is requested that the FAA issue an exemption to permit safe, legal, comme rcial sUAS operation by the applicant as soon as possible.

Sincerely,

Elliot Rivera, Owner/CEO

Commercial & CFII Rotorcraft Helicopter, Instrument

AerialWorks Imaging

P.O. BOX 175 Riverdale, NE 68870

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August 19, 2015 Page 5 of 10 Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

AerialWorks Imaging, requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of UASs:

14 CFR Part 21, Subpart H: Airworthiness Certificates

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met, and th erefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA

- 2014

- 0352

at 13

- 14, 22. If, however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, a n exemption is requested. The AerialWorks Imaging' use of sUAS is safe when taking into account its size, weight, speed, and operational capability. Operations conducted under this exemption will be closely controlled and monitored by the operator and wil l be conducted in compliance with local public safety requirements, to provide security for the area of operation. AerialWorks Imaging will also provide the FAA with advance notice of all operations via NOTAMs and coordination with the local FSDO, as neces sary. In all cases, operation of the sUAS under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate. Further, the UAS does not need a means to communicate with other aircra ft or ATC, because those capabilities will be possessed by the PIC and Observer, who are not onboard the UAS. See Grant of Exemption, Docket FAA

- 2014

- 0352 at 13. In addition, no sense

- and

- avoid technology is necessary for the UAS because it will be operate d at all times in VFR conditions and within VLOS of the PIC and Operator.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal cate gory rotorcraft. To the extent that AerialWorks Imaging' s small UASs would otherwise require certification under Part 27, this petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certifi cate issued for the UAS, AerialWorks Imaging seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be i n airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. See Grant of Exemption to Astraeus Aerial, Docket No. FAA

- 2014

- 0 352 at 13

- 14, 22. Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance 14 CFR Part 21, Subpart H.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certi ficate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraphAerialWorks Imaging

August 19, 2015 Page 6 of 10 (b) provides that the airworthiness certificate be “displayed at the cabin or cockpit entrance so

that it i s legible to passengers or crew.” A sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents dee med appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose the use of the sUAS’ unique manufacturers serial number, an d a contact telephone number be mounted on the sUAS on a placard of reasonable size in relation to the sUAS. In the event that a unique manufacturers serial number is not available, the previously mentioned placard will be affixed to the sUAS consisting of the model name and number of the sUAS, as well as a contact telephone number.

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft marking & identification requirement 91.9(c) provides that no person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter. 45.23(b) states that when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experiment al or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable. 45.27(a) states that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. In a previous G rant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft "have identification (N

- Number) markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." FAA

Docket No. FAA

- 2014

- 0352. In order to obtain an equivalent level of safety, all UAS flown by AerialWorks Imagingwill bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. The intent of this requirement is to ensure that flight manual

information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the sUAS cannot carry such a manual, and if the sUAS did carry such manual, it would be unavailable to the crew for review. To obtain an equivalent level of saf ety and meet the intent of 91.9, we propose that a current, sUAS operation manual or equivalent be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight instruction; Simulated instrument fl ight and certain flight

tests. The regulation provides that “No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls.” The controls for a sUAS do not currently have a set of fully functioning dual controls. If a sUAS pilot is being trained, the pilot performing the training would be directly supervising and could take over the controls from the pilot in training if the need arose. This would be similar to the technique of a “t hrow

- overAerialWorks Imaging

August 19, 2015 Page 7 of 10 type” control wheel in some fixed wing aircraft. We feel that this technique meets the intent of 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation provides that over sparsely populat ed areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary

to operate c loser than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained, and careful pre

- planning has been performed. Further, sUAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and careful pre

- planning would provide an equivalent level of safety.

14 CFR 91.121Altimeter settings. The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The sUAS will always fly below 500

feet AGL , and in line of sight of the PIC and visual observer (VO). This line of sight operation

will provide separation from other aircraft, obstructions and terrain, and would override the use of an altimeter for such a purpose. We feel that this will provide an equivalent level of safety.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 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 feel the intention of this paragra ph it to provide a reasonable reserve of energy to plan for a safe landing should there be a delay in landing. The close proximity to the ground station, the ability for both rotorcraft and small fixed wing aircraft to land in a very small space and the bu ilt in energy level monitoring of the sUAS we feel provide an equivalent level of safety if the flight is planned to be completed with 20% battery energy remaining. We request an exemption to the word “fuel” and ask for an equivalent interpretation

with th e word “energy”.

14 CFR Subpart E (91.401

- 91.4171)

- Maintenance, Preventive Maintenance, and

Alterations 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 perform maintenance and inspection of the aircra ft and “be authorized to approve the aircraft for return to service.” Prior to every flight, the PIC will inspect the aircraft to ensure that it is in an airworthy condition. Any general maintenance procedures or replacement of consumable items outlined by the sUAS manufacturer, if applicable, will be complied with by the PIC. In no circumstance will a sUAS be operated in a condition that is deemed, or suspected to be, unsafe. If such a determination is reached, and the problem cannot be remedied to the sat isfaction of the PIC, the sUAS will not be operated until consulting with the manufacturer or one of its authorized dealers to complete necessary repairs. We feel that due to the size, construction, and simplicity of the aircraft, the PIC

can ensure an equ ivalent level of safety.AerialWorks Imaging

August 19, 2015 Page 8 of 10 FLIGHT RESTRICTIONS (a) No flight will be made with a sUAS Gross weight exceeding 55 pounds; (b) Operations will occur at no more than 500’ AGL, at an airspeed of no more than 87 knots and within visual line of sight (VLOS) of the PIC; (c) All operations will utilize a visual observer (VO). The VO and PIC will be able to communicate verbally at all times during a flight operation; (d) All operations will be conducted over private or controlled

- access property with permission f rom the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. (e) The PIC will have accumulated and logged, in a manner consistent w ith 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least ten hours logged as a sUAS pilot with a similar sUAS type; 5 hours as sUAS pilot operating the make

and model of sUAS as well as 3 tak eoffs and landings in the preceeding 90 days. (f) All required permits will be obtained from state and local government prior to operation; (g) The sUAS System will not be operated over densely populated areas; (h) The sUAS System will not be operated at air shows; (i) The sUAS System will not be operated over any open

- air assembly of people; (j) The sUAS System will not be operated over heavily trafficked roads; (k) The sUAS System will not be operated within 5 nautical miles of an airport unless the operator obtains a letter of agreement with that airport’s management or is otherwise permitted by a COA, and within 48 hours, but not more than 72 hours issues an appropriate NOTAM; (l) Operations will be restricted to day only and weather conditions eq uivalent to VFR; (m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location; (n) No flight may be made without a successful Pre

- Flight Inspection by the PIC before each operation to ascertai n that the sUAS is in a condition safe for flight.

PRE

- FLIGHT CHECKLIST (1) Determine that sUAS battery, remote controller, and mobile device are fully charged in order to prevent unexpected premature descent; (2) Check all wiring connections are tight; (3) Check all propellers are undamaged and no cracks exist in any structural members of the sUAS; (4) Turn on radio controller, check for adequate voltage, set it to connect to the sUAS, move all control switches the appropriate preflight position; (5) Connect the sUAS main battery, check for radio contact with sUAS’s radio receiver; (6) At a location different from previous flight, re

- set GPS and compass to current location; (7) Turn on transmitter, gimbal and camera.

OPERATING DOCUMENTS

Petitioner su bmits its Operations Manual with Training Syllabus as Confidential documents under 14 C.F.R. § l l .35(b) as they contain proprietary information that Petitioner has not and will not share with others. The documents contain operating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552.AerialWorks Imaging

August 19, 2015 Page 9 of 10 The petition and the following supporting documentation are referred to as the operating

documents: 1) Training Sylla bus included in Operations Manual: Cautions, Warnings, Basic Flight Maneuvers, Advanced Flight Maneuvers as per the DJI Pilot Training Guide and Mission Specific Flight Maneuvers 2) Operations Manual including:

Phantom 3 Professional User Manual:

Phantom _3_Professional_User_Manual_v1.4_en Phantom 3 Professional Quick Start Guide v1.2: Phantom_3_Professional_Quick_Start_Guide_en_v1.2 Phantom Pilot Training Guide: Phantom_Pilot_Training_Guide_en Phantom 3 Professional Safety Gui delines and Disclaimer Safety_Guidelines_Disclaimer_en

Phantom 3 Professional Release Note 2015.8.4
Phantom_3_Professional_Release_Note_en_0804 Intelligent Flight Battery Safety Guidelines Intelligent_Flight_Battery_Safety_Guidelines_en

Inspire 1 User Manual Inspire_1_User_Manual_v1.4_en Inspire 1 Quick Start Guide Inspire_1_Quick_Start_Guide_v1.4_en Inspire 1 Maintenance Manual Inspire_1_Maintenance_ManualV1.0_en Inspire 1 Safety Guidelines Inspire_1_Safety_Guidelines_en Inspire 1 Disclaimer and W arning Inspire_1_Disclaimer_and_Warning_en Inspire 1 Release Notes 2015.8.4 Inspire_1_Release_Notes_en_0813 Intelligent Flight Battery Safety Guidelines Intelligent_Flight_Battery_Safety_Guidelines_en.AerialWorks Imaging

August 19, 2015 Page 10 of 10 Materials to be readily available to the PIC: Operations Manual including:

 Phantom 3 Professional User Manual

 Phantom Pilot Training Guide

 Phantom 3 Professional Safety Guidelines and Disclaimer

 Smart Flight Battery Safety Guidelines

 Inspire 1 User Manual

 Inspire 1 Maintenance Manual

 In spire 1 Safety Guidelines

 Intelligent Flight Battery Safety Guidelines

 Current Sectional and TAC Aeronautical charts

 sUAS logbook and Defect Sheet(s)

 Personal pilot logbook

Petitioner submits its Operations Manual and Training Syllabus as

Confidential do cuments under 14 C.F.R. § l l .35(b) as they contain proprietary information that Petitioner has not and will not share with others. The documents contain operating conditions and procedures that are not available to the public and are protected from relea se under the Freedom of Information Act, 5 U.S.C. § 552.

CONCLUSION Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security, provide more than adequate justification for the grant of the requested exemption allowing operation of Petitioner's sUAS for survey and aerial data collection for real estate and various industries pursuant to the Ope rations Manual.

Please do not hesitate to contact me with any questions regarding this filing:

Elliot Rivera Helifly83@gmail.com

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Sincerely,

Elliot Rivera Comm, CFII 3072198

CEO AerialWorks Imaging

Attachments: AerialWorks Imaging Confidential Operations Manual