NorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 April 28 , 2015
Thomas M. Ethen 15414 W Bluegrass Rd Nine Mile Falls, WA 99026 (509) 733

- 2928 teimages@sbcglobal.net
Petition of Northwest Aerial Perspectives For Exemption Pursuant to Section 333 Of the FAA Modernization and Reform Act of 2012 To Whom It May Concern:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Northwest Aerial Perspectives ( NWAP ), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system s (i.e. , sUAS). This exemption is in accordance with protocols outlined in this petition for exemption, and any other requirements established by the FAA pursuant to Section 333 of the Reform Act. This exemption would permit commercial operation by NWAP , which uses a DJI Phantom 2, a SynDrone X8 multirotor and a Gemini fixed wing sUAS to conduct:

- Aerial surveying

- Event Photography/Videography

- Agriculture purposes

- Real Estate Photography

- Aerial F ilmmaking and P hotography

- Construction S ite Inspections and M onitoring , and

- News G athering and First Responders

. NWAP ’s operation under the exemption will be subject to strict operating requirements and conditions to ensure an equivale nt level of safety to currently authorized operations using manned aircraft and under c onditions as may be modified by the FAA as required by Section 333.
NWAP 's sUAS will be operated under controlled VFR conditions a t low altitudes

. They will operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for competency and new FAA 333 and Part 107 commercial compliance requirements . Finally, when required, the FAA ATC will approve the airspace in which the sUAS will operate in advance

. NorthWest Aerial Perspectives respectfully submits this request for an exemption because it operates sUAS's . The FAA can have confidence that the operations will b e conducted at an equivalent level of safety or greater . Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under SectionNorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 333(c) of the Reform Act to “estab lish requirements for the safe operation of such aircraft systems in the national airspace system.” For your convenience, NWAP has organized this Exemption request as follows: I. Petitioner's Description II. Relevant Statutory Authority III. Qualifications for Approval Under Section 333 of the Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested VI. Public Interest VII. Privacy VIII. Federal Registry Summary IX. Conclusion
I. Petitioner's Description: NorthWest Aerial Perspectives , headquartered in Nine Mile Falls, WA, is a company that provides sUAS support to news and event videography, real estate and construction site photography, film and movie production, precision agricultural purposes, education, and demonstration flights in a compliant and safe envir onment. NWAP plans on providing a wide range of services as the sUAS market expands.
NWAP 's goal is to operate in an accident

-free environment by:

• Demonstrating a commitment by management and all employee s to operate in a compliant
manner.
• Identifying haz ard and risk while eliminating or controlling all these risks . • Using steps to intervene and report when unsafe work practices appear to exist.

• Training all employees involved in flight operations to operate at the highest standard level.
The contact information for Petitioner is as follows: NorthWest Aerial Perspectives , 15414 W Bluegrass Rd Nine Mile Falls, WA 99026
Owners : Thomas Ethen Dave Plouffe Office: (509 ) 733

- 2928 Email: teimages@sbcglobal.net II. Relevant Statutory Authority: This petition for exemption is submitted to fulfill Co ngress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil
unmanned aircraft sys tems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the National Airspace ("NAS") before completion of t he form al UAS rulemaking, based on the following considerations:

• The UAS's size, weight, speed, and operational capability;NorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 • Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator. If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish require ments for the safe operation of such aircraft in the National Airspace System". Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards , and has done so on numerous occasions, when the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would n ot adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). The Federal Aviation Act express ly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civ il aircraft, as the term is defined under 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness
ce rtificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may grant an exemption from a requirement of a

regulation prescribed unde r subsection (a) or (b) of this section or any of sections.
III. Qualifications for Approval Under Section 333 of the Reform Act The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statut ory criteria and other relevant factors are satisfied. The proposed operations would permit NWAP the us e of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) co ntrolled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. NWAP uses s UASs that are multirotor, weighing less th an 30 pounds including payload. They operate, under normal conditions, at speeds no t to exceed 100 mph and have the capability to fly, hover, and move in the vertical and horizontal plane. NWAP ’s s UASs will operate in line of sight, during daylight hours, and will only operate within a sterile area. NWAP will operate at or below 500 feet AGL and will file a NOTAM for each flight operated in controlled airspace. All required permissions and permits would be obtained fro m territorial, state, county or city jurisdictions, including local law enforcem ent, fire, or other appropriate governmental agencies prior to operating a sUAS. Given the small size of the sUAS’s involved and the restricted sterile environment within which they will operate, NWAP ’s exemption falls within the zone of safety and demonstrate s an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pe nding completion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will operate, approval of the application presents no hazard in the NAS. Considering the clear direction in Sec tion 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant of the requested exemptions is also in the public interest.NorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 IV. Description of Proposed Operations To assist the FAA in its safety assessment of NWAP 's proposed sUAS operations, below is a summary of operational limitations and conditions that will ensure an equivalent or highe r level of safety to operations conducted under current regulatory guidelines: 1. The sUAS will weigh less than 30 pounds. 2. Flights will be operated within line of sight of the PIC and observer. 3. Maximum total flight time for each ope rational flight will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 25%. 4. Flights will be operated at an altitude of no more than 500 feet AGL. 5. Flights will be operated at a lateral dist ance of least 100 feet from any inhabited structures, buildings, vehicles, vessels, people not associated with the operation or who have not signed a waiver in advance of the operation. 6. Minimum crew for each ope ration will consist of the sUAS Pilot in Command and a Visual Observer. 7. The sUAS Pilot in Command will hold at least a sport pilot or recreational pilot certificate and a valid U.S. drivers license. 8. NWAP will designate a Pilot in Command (PIC) for each mission. 9. The sUAS will operate only within a confined "Sterile Area". 10. Prior to the operations at a particular l ocation, a site inspection will have been conducted. On the da y of the mission the management person with operational control and the PIC will concur on dispatching of the mission. 11. A briefing will be conducted in regard t o the planned sUAS operations prior to each day's missions. It will be mandatory that all personne l who will be performing duties within the boundaries of the sterile area be present for this briefing. 12. NWAP crew will use the checkli st and callouts required in the Operations Manual. 13. All sUAS’s will be maintained in acc ordance with inspection program specified in the manufacturer’s guidelines. 14. In the event of an accident involving an NWAP sUAS, they will cease operations and report the accident to the NTSB an d AFS

- 80. 15. Pilot in Command and Visual Observer will at all times be able to communicate by voice. 16. Pilot in Command, Visual Observer, Camera Operator, and Operational Personnel will have been trained and tested in accordance to FAA, NTSB, and AFS

- 80 best practices

. 17. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 18. NWAP management will submit a written “Plan of Activities” to the local Flight Standards District Office (FSDO) having jurisdiction over the area of propos ed filming three days in advance of operations during film or movie productions. 19. If the sUAS loses communications signal, the sUAS will have the cap ability to return to a pre - determined l ocation within the Sterile Area and land. 20. Contingency plans will be in place to s afely terminate flight if there is a loss of communication between the pilot and the observer. 21. The sUAS PIC has the capability to abort a flight in case of unpredicted obstacles or emergencies. 22. NWAP , by following FAA, NTSB, and AFS

- 80 best practices, will assure no individuals’ privacy is violated.NorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 23. Procedures have been established in NWAP ’s Operations Manual to contact ATC prior to operating in airspace other than G. V. Regulations From Which Exemption is Requested Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations. The Petitioner Requests Relief From the Following: A. 14 CFR § 91.103: Preflight Action NWAP requests an exemption from the preflight actions requirements of 14 CFR 91.113 that prescribes the preflight actions un der which aircraft may operate: Each pilot in command shall, before beginning a f light, become familiar with all available information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fu el requirements, alternatives availab le if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been adv

ised by ATC; b. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: i. For civil aircraft for which an approve d Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and ii. For civil aircraft other tha n those specif

ied in paragraph (b)(1) of this section, other reliable information appropria te to the aircraft, relating to aircraft performance under expected values of airport elevation an d runway slope, aircraft gross weight, and wind and temperature. NWAP will not operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. NWAP ’s sUAS’s do not have a published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing dista nce data. Equivalent Level of Safety In adherence to FAA, NTSB, and AFS

- 80 best practices, the PIC along with the person having operational control must follow regulations to assure that the weath er will be adequate to complete the mission in VFR condition

. B. 14 CFR 91.113: Right

- of

- Way Rules NWAP requests an exemption from 14 CFR 91.11 3 Right

- of

-way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear. NorthWest Aerial Perspectives operates small pilotless UAS’s and cannot comply with these rules as they have been written. Equivalent Level of Safety NWAP operates sUAS’s at or below an altitude of 500 feet AGL, well below the normal operating altitude of other aircraft. NWAP management require s that the Pilot in Command with experienceNorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 oversee each mission and has knowledge of the see - an d

- avoid rules. A Visual Observer will assist the PIC in looking for aircraft entering the operations area. It’s the responsibility of the PIC to cease operatio ns and land the UAS immediately whenever an aircraft comes into the vicinity creating a potential threat. Operations will not recommence until the threat is clear. C. 14 CFR. § 91.119: Minimum Safe Altitudes NWAP requests an exemption from the minimum s afe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe alt itudes under which aircraft may operate:

• Over any congested area of a city, town, or s ettlement, or over any open air assembly of persons, an altitude of 1,000 feet ab ove the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface , except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Section 91.119 (d) allows for a helicopter to ope rate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the heli copter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." To provide the intended operations, the sUAS is n ormally operated below 500 feet AGL. Additionally, due to the nature of the pro posed operations, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with the operation. Equivalent Level of Safety Compared to normal aircraft, NWAP ’s multi

-ro tor and fixed wing aircraft weigh a maximum of 30 pounds, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As s et forth in the FAA, NTSB, and AFS

- 80 best practices , the sUAS will be operated in a sterile area, where buildings and people will not be exposed to operations without their pre

- o btained consent. Because of the advance notice to the property owners and participants, all affe cted individuals will be well aware of the planned flight operations prior to commencement of operations. Furthermore, by operating at such lower altitudes, t he sUAS will not interfere with aircraft that are subjec t to the minimum safe altitude regulatio ns. Finally, the successful safety record of the Phantom 2, Syndrone X8 and Gemini sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer operating environments. D. 14 C.F.R. § 91.121: Altimeter Settings NWAP seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by re ference to an altimeter that is set to the elevation of the departure airport or barom etric pres sure. An exemption is required because the sUAS does not have a baromet

ric altimeter, but rather a GPS altitude read out. Equivalent Level of Safety An equivalent level of safety will be achieved by follow ing the procedures set forth in the FAA, NTSB, and AFS

- 80 best practices

. NWAP will confirm the altit ude of the launch site shown on the GPS altitude indicator before flight. Moreover, th e PIC will use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe altitudes. E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR ConditionsNorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 NWAP requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states:

a. No person may begin a flight in a n airplane under VFR condit ions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

– i. During the day, to fly after that for at least 25 minutes; or ii. At night, to fly after that for at least 45 minutes. The batteries powering NWAP ’s Phantom 2 and Syndrone X8 provide approximately 25

- 35 minutes of powered flight while the Gemini's provide 2 to 3 hours of powered flight . To meet the 30 minutes reserve requirement in 14 CFR 91.151, X8 sUAS flights could not be conducted. Given the limitation s on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safety margin based o n a reserve am ount of battery life is needed. NWAP will not be conducting any sUAS flights at night. Equivalent Level of Safety An equivalent level of safety will be achieved because t he operations will be conducted on- site without significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% reserve battery power st ill available. This restriction would be more than adequate to return the sUAS saf

ely to its planned landing zone from anywhere in its confined area of ope ration
eve n in the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was inten ded to alleviate given the size and speed of the small UAS, and the pro ximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed. F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409 (a)(2); 91.417(a) and (b): Maintenance Inspections NWAP also seeks an exemption from the maintenance in spection requirements contained in 14 CFR 91.405(a), 91.407(a) ( 1), 91.409(a) ( 2), 91.41 7(a) and (b). These regulations specify maintenance and inspection standards in refe rence to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have. Equivalent Level of Safety An equivalent level of safety will be achieved beca use maintenance and inspections will be performed in accordance with FAA, NTSB, and AFS

- 80 best practices. The operator will ensure that the sUAS is in working order prior to initiating flight, pe rform required maintenance, and keep a log of any maintenance performed. The opera tor is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the sUAS's size and carrying cap acity, and the fact that flight operations will only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional roto rcraft or fixe d wing aircraft performing the same operation. VI. PUBLIC INTEREST Granting NorthWest Aerial Perspectives an exemption further s the public interest in and around the states of Washington, Oregon, Idaho and Montana . National policy set by Congress favors early integration of s UAS into the national airspace in controlled, safe working environments suchNorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 as those propose in this petition. The one vision of NWAP is to help facilitate safe integratio n of sUAS’s into mainstream USA in the following areas:

• Aerial Surveying o As with construction imaging, aerial imaging flights will be used to capture aerial photos for the purpose of creating orthomosaics (image maps). The image maps will be used to compute volume, create 3D models, DSM’s, DTM’s, profile and contour lines.

• Movies and Event Photography o Whether the shot requires unique views and expansive panning or altitude with radical views, the s UAS is designed to hold up under demanding conditions. Because of the autopilot fe ature with pre

- designed mission management and R/C control interrupt, the pilot and camera operator can easily create the ultimate shot with HD video or HD s till photos. When working close in on a closed set the hazards to the actors are substantially reduced due to the size of the sUAS.

• Precision Agriculture o This technology, which uses a variety of spectral data, has potential for several agricultural uses, including: early

-generation crop breeding line evaluations, quick and wide

- scale scouting of croplands for crop conditions and weed densities, grassland conditions and production evaluation, detection of noxious weeds and detection of blue green algae blooms in ponds and reservoirs. In addition, the technology allow the monitoring of water use and will allow the land owner to directly control the quantity of water use.

• News Gathering o Similar to movies and event photography, eac h news assignment may require a completely different shot or view of a scen e. With budgets for traditional helicopter use being greatly reduced, the s UAS is th e perfect solution to allow for easy news gathering for a fraction of the cost. The sUAS can and will be operated in a sterile area away from the public, w hile the traditional helicopter must hover over persons and property increasing the danger to individuals.

• Construction and First Responders o Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The applicants in the past have chartered 2

- seat full

sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application.

• Real Estate o The sUAS can be used in all areas of rea l estate, including commercial, residential and industrial properties. Using a sUAS , real estate professionals can create promotional videos, photos and unique s hots that normal camera aspects cannot capture. NWAP ’s easy

-to
-use video and photo platform s enable properties to stand out, providing dazzling views that are typically shown via expensive computer animation or costly helicopter rentals. Imagine shooting a view from a high

-rise condo in stunning high definition tha t shows your potential customer the actualNorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 view from the residence. The remote platform is great for new planning, zoning and large developments. S imple and easy

-to
-use video and photos allow for multiple height pictures and elevation views.
VII. Privacy NorthWest Aerial Perspectives is deeply committed to protect ing public privacy. NWAP knows that many individual s have concerns about privacy from the operations of sUAS’s. NWAP has created a privacy notice that informs residents, commercial property owners, churches, schools, and governmental organizations of our intent to conduct commercial drone operations in proximity to their property.
VIII. Federal Registry Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: NorthWest Aerial Perspectives , seeks an exemption from the following rules:
14 C.F.R. Part 21 14 C.F.R. 45. 23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417) Approval of this exemption request allows NWAP to conduct commercial operations with small and lightweight unmanned aerial systems. NWAP ’s singular vision is to enhance safety of sUAS operations in the NAS while reducing risk to the general public and prop erty owners.
The SynDrone , the Phantom 2 and Gemini sUAS, each weighing less than 30 pounds and powered by batteries, eliminates virtually all of that risk given the reduced mass and absence of combustible fuel carried on b o ard. The sUAS is transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of this small UAS will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.NorthWest Aerial Perspectives

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– NWAP Exemption Request April 30 , 2015 If additional information is required, or if you have any questions regarding this Petition for Ex emption, please contact the undersigned at:
IX. Conclusion The petitioner is requesting this exemption for the purposes of aerial surveying, precision agriculture , real estate photography, aerial filmmaking and photography, construction site inspections and monitoring, news gathering and other flight operations . The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies o f scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS services to individual s or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner’s own market research shows pent up demand for these services currently exists in the real estate market, constructio n, movie

-making, and other markets are just beginning to emerge. The petitioner has identified Universities and other agencies that could benefit from the operation requested in this application. A quick internet search will show that many are currently o perating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those servic es while remaining in c ompliance. The petitioner has 20 years of experience in the radio control model aircraft hobby With Best Regards, Thomas Ethen, President NorthWest Aerial Perspectives Office: (509) 733

- 2928 Email: teimages@sbcglobal.net