Feb 12 16 OS:34p Stivaletta

December 31, 2015 U.S. Department ofTransportation Docket Operations

WestBldg Ground Floor, Room w12-140 1200 NewJersey Ave., SE Washington, DC 20590 508 528 SSS7

Re: Exemption Request Under Section 333 ofthe FAAReform Act andPart 11 ofthe Federal Aviation Regulations

Dear Sir orMadam:

Pursuant to Section 333 ofthe 

### FAA Modernization andReform Actof2012 (the "Reform Act") and 14 C.F.R. Part 11, DataRecon ofNewEngland/ [unmanned aerial systems], seeks an exemption from the Federal Aviation Regulations ("FARs") listed belowto allow commercial operation ofa sUAS' so long as such operations are conducted within and under the conditions outlined herein or as maybe establishedbythe FAA as required by Section 333.

The requested exemption would permit commercial operation ofDatarecon ofNewEngland (unmanned aerial systems), a multi rotor aircraft, weighing less than 55 lbs. including cargo. The applications for this sUAS device would consist ofstill photographs and/or video takenby an onboard camera and associated data processing functions and used for aerial videography and photography for weddings and special events, real estate, filmmaking and aerial inspections on construction sites ofdifficult to reach equipment or stmctures. Use ofthe sUAS for these purposes reduces the need to operate conventionalaircraft or otherequipment for the same purpose andprovides very high quality imagery at a fraction ofthe costof surveys and inspections using conventional means. Likewise, inspections of structures canbe safelyperformed without endangering the inspector or inhibiting local industrial orpublic operations with ladders, lifts or other equipment These savings result in enhanced safety. efficiency and productivity for the affected activities, as well as environmental benefits and potential savings inboth cost and hazards to the public.

The name and address ofthe applicant is: Bruce Stivaletta (Ref: Private Pilot Rotorcraft- Helicopter Certificate# 32401286 Bruce StivalettaDBA: DataRecon OfNewEngland/ (Unmanned Aerial Videography) Hereinafter called Data Recon ofNew England 33 Forge 

### Hill Rd Franklin, Ma 02038

Phone: (508)-509-9661 E-Mail is : bstiv@comcast.netFeb 12 16 06:34p Stivaletta

U.S. Department ofTransportation Docket Operations West Bldg Ground Floor, Room w12-140 1200 NewJersey Ave., SE Washington, DC 20590

Page 2


### Regulations from which the exemption is requested: 14 C.P.R. Part 21 14 C.F.R. 417 (a) & (b) 14 C.P.R. 45.23(b) 14 C.P.R. 409 (a) (2) 14 C.P.R. 61.113 (a) & 

### (b) 14 C.P.R. 407 (a) (1) 14 C.P.R. 91.7 (a) 14 C.P.R. 91.405 (a) 14 C.P.R. 91.9 (b) 

### (2) 14 C.F.R. 

### 91.203 (a) & 

### (b) 14 C.P.R. 91.103 14 C.P.R. 91.151 (a) 14 C.P.R. 91.10914 C.P.R. 91.121 14 C.P.R. 91.119 508 528 9967



### Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider whether certainunmanned aircraft systems may operate safely inthe national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofsUAS 1do not create a hazard to users ofthe NAS orthe public orpose a threat to national security in light ofthe following:

• The sUAS 1 size, weight, speed, and operational capability;

• Operationofthe sUAS in close proximity to airports and populated areas; and

• Operation ofthe sUAS withinvisual line ofsight ofthe operator.



### Reform Act 333 {a) Ifthe Secretary determines that suchvehicles 11may operate safelyin the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraftin the national airspace system. 11

The Federal Aviation Act expressly grants the FAA the authority to issue exsemptions. This statutory authority by its terms includes exempting civil aircraft,

as the tennis defined under 40101 ofthe Act, that includes sUAS\ from the requirementthat all civil aircraft must have a current airworthiness certificate.

DataRecon OfNewEngland!. understands this provision to place the duty onthe Administrator to not only process applications for exemption under section 333, but for the Administrator to craft conditions for the safe operation ofthe sUAS, ifit should be determined that the condition set forth herein do not fulfill the statutory requirements for approval p.3Feb, 

### 1"2 16 06: 35p Stivaletta

U.S. Department ofTransportation Docket Operations WestBldg Ground Floor, Room**w12~140** 1200 NewJersey Ave., SE Washington, DC 20590

Page 3 508 528 9967

The Administrator may grant an exemptionfrom a requirement ofa regulation prescribedunder subsection (a) or (b) ofthis section or any sections**44702~44716** ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S. C. 44701(t) See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91.203 (a) (1).

Stivaletta Corp/DataRecon ofnew England. will use a multiblade rotorcraft weighing less than 55 lbs. includingpayloadby myself(Ref: PrivatePilot Certificate Rotorcraft 

### # 32401286). 

### It operates under normal conditions at a speed ofno more than 30 knots and has the ability hover, and move inthe vertical andhorizontal plane simultaneously. 

### It will operate only in line ofsight (LOS) ofthe pilot and will operate only within the project area. Such operations will insure that the sUAS will not create a hazard to users ofthe national airspace system or the public.

Given the small size ofthe sUAS involved andthe restricted environment within which it will operate, DataRecon OfNewEngland. falls squarely within that zone of 

### SAFTEY(An equivalent level ofSAFETY) in which Congress envisioned the FAA must, by exemption, allow commercial operations ofsUAS to commence immediately. Also due to the size ofthe sUAS and the restricted areas in whichthe relevant sUAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended; the strong equivalent level of SAFETY surrounding the proposed operations, andthe significant public benefit, including enhanced SAFETY. reduction in environmental impacts, including reduced emissions associated with allowing sUAS for event and inspection operations the grant ofthe requested exemptions is in thepublic interest Accordingly, DataRecon ofNew England respectfully requests that the FAA grant the requested exemption without delay.



### Aircraft and equivalent Level ofSAFETY DataRecon OfNewEngland. proposes the exemption requested herein apply to Civil aircraft have the characteristics andthat operate withthe limitations listed herein. These limitations provide for at least an equivalent or even higher level of SAFETY to operations under the current regulatory structure because the proposed operations represent a SAFETYenhancement to the already safe photography and surveying operations conductedwith conventional aircraft. p.4Feb 12 

### is OS:35p Stivaletta

U.S. Department ofTransportation Docket Operations West Bldg Ground Floor, Room w12-140 1200 NewJersey Ave., SE Washington, DC 20590

Page4 508 528 9967

These limitations andconditions to whichthe DataRecon OfNewEngland agree to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55lbs. 2. Flights will be operatedwithinline ofsight ofa pilot and/or observer. 3. Maximumtotal flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute limit. 4. Flights will be operated at an altitude ofno more than400 feet AGL. 5. Minimum crew for each operation will consist ofthe sUAS Pilot and a Visual Observer. 6. sUAS Pilotwill be a skilled sUAS operator experienced in the type ofUAS flown. 7. sUAS Pilot will bePilot in Command (PIC). Ifa pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present.that person can also be designated as PIC. 8. The sUAS will only operate within a confined Project Area. 9. A briefing will be conducted inregard to the planned sUAS operations prior to aerial activities. All personnel who will be performing duties within the boundaries ofthe SAFETY perimeter will be made aware ofthe sUAS flight(s). 10. The operator will obtain the consent ofall persons involvedin the project and ensure that only consenting persons will be allowed within 100 feet of the flight operation. 11. Pilot and observer will havebeentrained in operation ofsUAS generally and received up-to-date information onthe particular sUAS to be operated. 12. Observer andpilot will at all times be able to communicate by voice andjor visuals. 13. Written and/or oral permission from the relevant propertyholders will be obtained. 14. All required permissions and permits to be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate govermnental agencies. 15. Ifthe sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a pre-determined location within the Security Perimeter and land. 16. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies. p.5Feb 12 16**06:3~~** Stivaletta

U.S. Department ofTransportation Docket Operations West Bldg Ground Floor, Room**w12~140** 1200 NewJersey Ave., SE · Washington, 

### DC 20590
Page5


### Description ofSpecific 

### Regulations: 508 528 SS67



### 14 CFRPart 21, Subpart H: 

### Airworthiness Certificates 14 C.F.R. 91.203 (a)(l) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as requiredby FAR 91.203 (a) (1). Giventhe size and limited operating area associated with the aircraft
to be utilized by the DataRecon OfNewEngland, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level of SAFETYunderPart 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.

### C. 44701 (0) and Section 333 ofthe Reform Act both authorize theFAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports andpopulated areas ofthe particular sUAS. Our small sUAS will be operated at low speed in a controlled environment at least five miles from an airport. 

### An analysis ofthese criteria demonstrates thatthe sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be atleast as 

### safe. or

### safer. than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operatedhereunder is less that 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area. Like other civil aircraft, operations underthis exemption 

### will be tightly controlled and monitored by the operator, pursuant to the Manual's requirements, andunder the requirements and in compliance with local public SAFETYrequirements, to provide security for the area ofoperation as is currently done on active construction sites. TheFAA will have advance notice ofall operations. These SAFETYenhancements, which already apply to civil aircraft operated in connection with construction sites, provide a &>Teater degree of SAFETYto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.P.R. Part 

### 21, Subpart 

### H. Lastly, application ofthese

same criteria demonstrates thatthere is no credible threat to national security posed by the sUAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load 

## no greater than two lbs. p.6Feb 12 16 06:35p Stivaletta



### U.S. Department ofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 New Jersey 

### Ave., SE Washington, DC 20590
Page6



### 14 C.F.R. 45.23(b): Marking oftheAircraft 508 528 SS67



### This regulation requires certain experimental, provisionally certificated aircraft, or light sport category aircraftto be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "experimental" can be placed. Given the size ofthe sUAS, 

### two-inch lettering will be impossible. The word "Experimental" will be placed onthe fuselage in compliance with 45.29 (t). The equivalent level ofSAFETY

### will be provided by having the sUAS marked on its fuselage as required by 45.29 (t) where the pilot, observer and others working with the sUAS will see the identification ofthe sUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 107, 8738, 10167 and 10167 A.



### 14 CFR61.113 (a) &

### (b): Private pilot privileges and limitations: Pilotin Command Sections 61.113 (a) & 

### (b) limit private pilots to non-commercial operations. Unlike

a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated withthe operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a pilot who is an experienced sUAS operator exceeds the present level ofSAFETY

### achieved by 14 

### C.F.R. 61.113 (a) & 

### (b).



### 14 C.F.R. 91.7 (a): 

### Civil aircraft airworthiness The regulation requires that no person may operate a civil aircraft unless 

### it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofSAFETY

### checklists performed by myselfan Rotorcraft-Helicopter Private Pilot, Ref: Certificate Number 32401286 prior to each flight, an equivalent level ofSAFETY

### will be provided. p.?Feb 12 16 06:36p Stivaletta

U.S. Department ofTransportation Docket Operations West Bldg Ground Floor, Room w12-140 1200 New Jersey Ave., SE Washington, DC 20590

Page7 508 528 9967

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements The sUAS, given its size and configuration has no ability orplace to carry such a flight manual onthe aircraft, not only because there is no pilot onboard, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofSAFETY will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issuedthe following exemptions to this regulation: ExemptionNos. 8607, 8737, 8738,9299, 9299A, 9565, 9565B, 10167, 10167A 10602,32827 and 10700.

14 C.F.R. 91.103: Preflight Action This regulation requires each pilot 

### in command take certain actions before flight to

ensure the SAFETYofflight. An exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checkingtakeoffand landingdistances, and all other actions in the Preflight Checklist, in the sUAS Manual. These actions will provide an equivalent level ofSAFETY.



### 14 C.F.R. 91.109: Flight Instruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of

a control boxthat communicates with the aircraftviaradio communications. The FAA has previously approved exemptions for aircraft without fully functional dual controls. SeeExemption Nos. 5778K & 9862A. The equivalent level ofSAFETY provided by the fact thatneither a pilot norpassengers 

### will be carried in the aircraft, the abHity to control the sUAS via radio signals from the controller, and by the size and speed ofthe aircraft. p.8Feb 12 16 06:37p Stivaletta

U.S. Department ofTransportation Docket Operations West Bldg Ground Floor, Room w12-140 1200 NewJersey Ave., SE Washington, DC 20590

Page 8



### 14 C.F.R. 91.119: Minimum Safe Altitudes 508 528 9967

Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. This exemption is for a multirotor craftthat flies similarly to a helicopter, withvertical take offand vertical landing, which will typically operate at altitudes of200 AGL an exemption may be needed to allow such operations. The sUAS will never operate at an altitude higher than 400 AGL and will be in a restricted area, wherebuildings and people will notbe exposed to operations with out their pre-obtained consent. The equivalent level of SAFETYwill be acheived giventhe size, weight and speed ofthe sUAS as well as the location where it is operated. No flight will be taken without thepermission ofthe property owner and any onsite personnel all affected individuals will be aware ofthe plannedflight operations. Comparedto flight operations with aircraft orrotorcraft weighing far

more than the maximum 55 lbs. proposedherein andcarrying flammable fuel, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operation at orbelow 500 AGL inthe industry. In addition, the**low~altitude** operations ofthe sUAS will ensure separation betweenthese small sUAS operations andthe operations ofconventional aircraft that must comply with Section 91.119.



### 14 C.F.R. 91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitudebyreference to an altimeter that is set 11to the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 11 As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofSAFETYwill be achieved by the operator, pursuantto the sUAS Manual and SAFETYChecklist, confirming the altitude ofthe launch site shown on the GPS altitude indicatorbefore flight. 

### 14 C.F.R. 91.151 (a): 

### Fuel requirements for flight in VFRconditions Section 91.151 

### (a) outlines fuel requirements for beginning 

### a flight inVFR conditions. Our sUAS is limited to operations in sterile and controlled environments and has a limited range and flight time which require an exemption from 14 CFR 91.15l(a). p.9Feb 12 16 06:37p Stivaletta



### U.S. Department ofTransportation Docket Operations West Bldg Ground Floor, Room wl2-140 1200 NewJersey Ave., 

### SE Washington, DC 20590

Pg9. 508 528 9967



### The battery poweringthe s UAS provides approximately 20 minutes ofpowered flight. This does not meetthe 30 minute reserve requirement in 14 CFR 91.151. DataRecon ofNewEnglandbelieves that an exemption from 14 CPR91.151(a) falls Withinthe scope ofprior exemptions See Exemption 10673 (allowingLockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS, 

### in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less that 30 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91.252 (a)

was intended to alleviate given the size and speed ofthe small sUAS. An equivalent level ofSAFETY

### can be achieved by limiting flight to 15 minutes, or enough battery

reserve to ensure that the sUAS lands at the ground station with at least20% of battery power (as determinedby the onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operation area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,.10673 and 10808.



### 14 C.F.R. 91.203 (a) & 

### (b): Carrying civil aircraft certification and registration The regulation provides in part: (a) Except as provided in 

### 91.715, no person may operate a civil aircraft unless it 

### has within it the following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. Therefore there is no ability orplace to carry certification and registration documents orto display them on the sUAS.

An equivalent level of

### SAFETYwill be achieved by keeping these documents at the ground flight control point where the pilot flying the sUAS will have immediate

access to them, 

### tothe extentthey are applicable to the sUAS. The FAA has issued

numerous exemptions to this regulation. A representative sample ofother exceptions includes ExemptionNos. 9565, 9665, 9789, 9789A, 9797, 9797 A, 

### 9816A and 10700. p.10Feb 12 16 06:38p Stivaletta

il'\•
U.S. Department ofTransportation DocketOperations WestBldg Ground Floor, Room wl2-140 1200 NewJersey Ave., SE Washington, DC 20590

Page 10 508 528 9967



### 14 C.F.R 91.405 (a); 

### 407 (a)(l); 409 (a)(2); 417 (a) & 

### (b); Maintenance Inspections These regulations require that an aircraft operator or owner "Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

... ,"and others shall inspect or maintain the aircraft in compliance with Part 43. Given these sections andPart 43 apply only to aircraftwith an airworthiness certificate these sections will not apply to DataRecon OfNew England. Maintenance will be accomplishedbythe operatorpursuant to the flight manual and operatinghandbook. 

### An equivalent level of

### SAFETYwill be achieved because these small 

### sUAS'are very limited in size and will carry a small payload and operate only in restricted areas for limited periods. Ifmechanical issues arise the sUAS can land immediately and will be in operation no higher than 400 feet AGL. The operator will insure that the sUAS is in working order prior to initiating flight, perform requiredmaintenance, andkeep a log ofany maintenance performed, (Ref: Private Pilot Certificate Number 32401286). Moreover, the operator is the person most familiar with the aircraft andbest suitedto maintainthe aircraft inan airworthy condition to provide the equivalent level of

### SAFETY.


## ********* Pursuantto 14 C.P.R. Part 11, [rule making] the following summary is provided for publication inthe Federal Register, should itbe determined that publication is needed:

DataRecon OfNewEngland. seeks an exemption from the following rules: 14 C.F.R. 21, SubpartH: [airworthiness certificates] 14 C.F.R. 45.23 (b); 14 C.F.R. 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) 

### & (b); 91.405 (a)(l); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs or less) in construction, inspection and events.
Approval ofexemptions allowing commercial operations ofsUAS in the Construction, Surveying, Special event orInspection industry enhances 

### SAFETY while reducing risk. Manned aircraftmonitoring and surveying creates a greater risk because the craft are muchlarger, have combustible fuel and carry an onboard pilot. In contrast, a sUAS will carry no passengers, crew or combustible fuel and; therefore, will not expose them to the risks associatedwith manned aircraft flights. p. 11Feb 12 16 06:38p Stivaletta

U.S. Department ofTransportation Docket Operations WestBldg Ground Floor, Room w12-140 1200 New Jersey Ave., SE Washington. DC 20590

Page 11 508 528 9967

The operation ofsmall sUAS, weighting less than 55 lbs, conducted inthe strict conditions outlined above, will provide an equivalent level of

### SAFETYsupporting the grant ofthe exemptions requested herein, including exempting DataRecon ofNewEngland. from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground and in a sterile environment and as a result, are far safer than conventional operations conducted with helicopters operating in close proximity to the ground andpeople.


### Privacy All flights will occur over private or controlled access property withthe property owner's prior consent andknowledge. Images taken will be ofindividuals who have also consentedto being filmed or otherwise have agreedto be inthe area where aerial photography will take place. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximity to airports andpopulated areas and operation within visual line ofsight and national security ---provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofDataRecon OfNewEngland. 

### sUAS'in special event, construction and inspection industry pursuant to the sUAS Manual.


### Specific Examples ofPotential sUAS use by 

### DataRecon ofNew England: DataRecon OfNew England. [Unmanned Aerial Videography} will have use ofa DJI Inspire 1 Drone and also a Parrot Bebop 2 drone with controllers, each with full gps capability, emergency shut offand return home capabilities. More advanced models Models to be used at a later date. Use ofthese tools would allow Bruce Stivaletta DBA I DataRecon ofNew Englandto:

• Inspect existing inaccessible or difficultto access structures such as wind turbine towers, sides ofbridges, industrial rooftops, and smoke stacks. This would save time and money and public inconveniencesby negatingthe need to mobilize large 

### lift equipment or close roads during bridge or public building inspections.

• Enhancedpublic awareness, Bruce Stivaletta/ DataRecon OfNewEngland

use ofvideography, still Photography for special events and the real estate market will enable the client and those in attendance to better understandthe proper and safe use of the sUAS venue as proposed by the FAA.

# ~ Sincerely, Bruce Stivaletta Private PilotRotorcraft-Helicopter Certificate Number 32401286 p. 12