From: E20N 

5250 S. Hardy Drive, Apt 2101 

Tempe, AZ 85283-5214 

To: U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington DC 20590 

.~ ;_: ~ l r. Cj 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

II of the Federal Aviation Regulations from: 14 CFR 45 .23(b); 14 CFR 21; 14 

CFR 61.113(a)&(b); 14 CFR 61.113(a)&(b); 91.7(a); 91.9(b)(2); 91.103; 

91.109; 91.119(c); 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 

91.407(a)(l); 91.409(a)(1)&(2); 91.417(a)&(b). 

January 18, 2016 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 C.F.R. Part 11, E20N ("Applicant"), an operator of Unmanned 

Aircraft systems ("UAs") for aerial transportation, surveillance, photography, and 

filming operations for a range of business applications including aerial deliveries, 

insurance, real estate, agriculture, infrastructure inspection, 3D mapping, disaster 

relief assistance, travel video/photography, motion picture, television, and internet 

video production hereby applies for an exemption from the Federal Aviation 

Regulations ("F ARs") to allow commercial operation of its UAs. 

To date, the FAA granted numerous exemptions to UAs operators. The Applicant's 

requested exemption would permit the operation of small, unmanned UAs under 

"controlled" and "sterile" airspace that is: (i) limited, (ii) predetermined, (iii) subject 

to controlled access, and (iv) provide greater safety in connection with aircraft 

operations in last mile deliveries, aerial surveillance, film and television industries. 

As established by the exemptions already granted by the FAA, approval of the 

Applicant's exemption would enhance safety and 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 (NAS)." 

Section 333(c) of the Reform Act- The name, address and point of contact for the 

applicant is: 

E20N 

Craig Arsenych 

5250 S. Hardy Drive, Apt 2101 

Tempe, AZ 85283-5214 

+ 1(530) 409-8139 

j: I.~ {j 
P(lge 2 of12 

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain Unmanned Aircraft systems (UAs) may 

operate safely in the National Airspace System (NAS) before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this 

Determination, the Secretary is required to determine which types of UAs do not 

create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the following: 

• The UA's size, weight, speed, and operational capability 

• Operation of the UAs in close proximity to airports and populated areas and 

• Operation of the UAs within visual line of sight (VLOS) of the operator. 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, 

as the term is defined under §40 101 of the Act that includes UAs from the 

requirement that all civil aircraft must have a current airworthiness certificate. 

UAs operated by the Applicant weigh less than 55 pounds, including the payload (i.e. 

cargo, camera, lens, and gimbal). They operate at speeds of no more than 50 knots, 

can hover, and can simultaneously move vertically and horizontally. The Applicant 

will only operate its UAs in VLOS and will operate only within the sterile area. Such 

operations will insure that the UAs will "not create a hazard to users of the national 

airspace system, or the public." 

The Applicant seeks an exemption to operate its DJI Phantom 3 Professional 

(N625NC) UAs for compensation, or hire within the NAS. A copy of the operating 

handbook for this aircraft will be submitted with this exemption request. The 

Applicant's UAs has a maximum gross weight under 5 pounds (including payload), 

maximum speed of 49 mph (approximately 42 knots) and a run time of 

approximately 30 minutes. 

The UAs operated by the Applicant is registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking (aircraft registration number N625NC). 

Given the small size of the Applicant's UAs and the restricted sterile environment 

within which it will operate, the Applicant's UAs operations adhere to the Reform 

Act' s safety requirements. Additionally, due to the size of the UAs and the limited 

areas in which it will operate, approval of this application presents no national 

security issues. Based on the substantial level of safety surrounding the proposed 

operations, the significant public benefit (enhanced safety), reduction in 

environmental impacts (reduced emissions and noise), the grant of the requested 

exemption is in the public interest. 
Page 3 of12 

Accordingly, the Applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

Aircraft and equivalent level of safety 

The Applicant proposes that the exemption requested apply to civil aircraft that 

have the characteristics and that operate within the limitations listed. 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 safety enhancement to the already safe aerial photography and filming 

for movie and television filming operations conducted with conventional aircraft. 

These limitations and conditions to which the Applicant agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The UAs will weigh less than 55 lbs. 

2. Flights will be operated within VLOS of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Minimum crew for each operation will consist of the UAs Pilot In Command (PIC) 

and the Visual Observer. 

6. UAs PIC will be an FAA licensed airman with at least a Sport Pilot's Certificate. 

7. UAs PIC assumes all duties and responsibilities. 

8. The UAs will only operate within a confined "Sterile Area." Security will be 

performed by the PIC and designated security personnel. 

9. A briefing will be conducted in regard to the planned UAs operation(s) prior to 

each day's activities. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be present for this briefing. 

10. The PIC will obtain the consent of all persons. 

11. When required, the PIC will submit a written Plan of Activities to the nearest 

FSDO seventy-two (72) hours prior the proposed flight operation. 

12. PIC and observer will have been trained in operation of UAs generally and 

received up-to-date information on the particular UAs to be operated. 

13. ALL crewmembers will at all times be able to communicate by ONLY voice 

to ensure all crew members maintain visual contact with the UAs at ALL TIMES. 

14. Written and/or oral permission from the relevant property holders will be 

obtained. 

15. All required permissions and/or permits shall be obtained from territorial, state, 

county, or city jurisdictions including local law enforcement, fire, or other 

appropriate governmental agencies as necessary. 

16. If the UAs loses communications, or loses its GPS signal, the UAs will have the 

capability to return to a pre-determined location within the Security Perimeter and 

land. 
Page 4 of12 

17. The UAs will have the capability to abort a flight in case of unpredicted obstacles 

or an unexpected emergency. 

Plan of Activities - The Plan of Activities shall include the following: 

Briefing 

1. Date(s) and time(s) for all flight(s). 

2. Name and phone number of the person(s) responsible for the event. 

3. Name and phone number of the person(s) responsible for the aircraft. 

4. Make, model, serial number and registration number of all UAs to be used. 

5. Name and certificate number, if applicable, of all crewmembers to be utilized in 

the event including copies ofF AA Medical Certificates and endorsements. 

6. A statement that the Waiver Holder has obtained permission from property 

owners and/or local governmental officials to conduct the event. 

7. Signature of Waiver Holder, or representative. 

8. A description of the flight activity including maps or diagrams of any area, city, 

town, county, and/or State over which flight will be conducted and the minimum 

altitudes essential to accomplish the operation. 

The Applicant and the event representative will conduct a verbal and written 

briefing for the members involved, including emergency, if applicable, and security 

personnel. This briefing will be conducted prior to each day's UAs activities and will 

include the following items: 

1. Authorization UAs flight operations, Plan of Activities, special provisions and any 

additional provisions issued by the Flight Standards District Office having 

jurisdiction over the flight area. 

2. Radio communications. 

3. Takeoff procedures. 

4. Aviation activities to be conducted during the event. 

5. Approach and landing procedures. 

6. Alternate landing zone in the event of emergency or security breach. 

7. Recall procedures. 

8. Emergency procedures. 

9. Possible risk to personnel that are involved. 

10. Control of non-participating persons. 

11. Location of boundaries or deadlines, man-made or natural, readily visible to the 

participants. 

13. Local governmental limitations, restrictions, or any special circumstances, such 

as noise sensitive areas, time of day restrictions, or changes in operating 

procedures. 

Security - The exclusion from flight operations area of unauthorized persons, 

vehicles, or aircraft will be enforced by designated event personnel, private security 

officers, or sworn law enforcement officers at the direction of the Applicant. 
Page 5 of12 

The Applicant or designated representative will halt flight operations in the event 

unauthorized persons, vehicles· or aircraft enter the flight operations area. A 

predetermined abort signal will be used to halt flight operations should a breach of 

perimeter security occur, or for any other reason in the interest of safety. Alternate 

UAs landing sites will be made available prior to the start of the event. 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR 61.113(a)&(b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203(a)&(b) 

14 CFR 91.405(a) 

14 CFR 407(a)( I) 

14 CFR 409(a)(2) 

14 CFR 417(a)&(b) 

14 CFR Part 21, Subpart H: 

Airworthiness Certificates 14 CFR §91.203(a)(1) Subpart H, entitled Airworthiness 

Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203(a)(1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act 

(49 U.S.C.§44701(t)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAs. In all cases, an analysis of these 

criteria demonstrates that the UAs operated without an airworthiness certificate, in 

the restricted environment and under the conditions proposed will be at least as 

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the restrictions and conditions proposed. 

The UAs to be operated hereunder is less than 55 lbs., fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials, or flammable liquid fuels, and 

operates exclusively within a secured area as set out in the Manual. Unlike other 

civil aircraft, operations under this exemption will be tightly controlled and 

monitored by the PIC, pursuant to the Manual's requirements, in compliance with 
Page 6 of12 

local public safety requirements, to provide security for the area of operation as is 

now done with conventional flight ope~~ations. 

The FAA will have advance notice of all flight operations. These safety enhancements, which already apply to civil aircraft operated in connection with transportation, motion picture and/or television production provide a greater degree of 

safety to the public and property owner( s) than conventional operations conducted 

with airworthiness certificates issued under 14 CFR Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAs, due to its size, speed, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external payload. 

14 CFR § 45.23(b)- Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number 

is displayed on limited, restricted or light-sport category aircraft or experimental 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 two 

(2) inches nor more than six (6) inches high, the words "limited", "restricted", 

"Light-sport", "experimental", or "provisional" as applicable. 

Even though the UAs will have no airworthiness certificate, an exemption may be 

needed as the UAs has no entrance to the cabin, cockpit or pilot station on which the 

word "experimental" can be placed. Given the size of the UAs, two (2) inch lettering 

will be impossible. 

The word "Experimental" will be limited to 1h inch lettering placed on the UAs in 

compliance with §45.29(f). 

The equivalent level of safety will be provided by having the UAs marked on its 

underbody as required by §45.29(f) where the PIC, observer and others working 

with the UAs will see the identification of the UAs as "Experimental." The FAA has 

issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 

10167 and 10167 A. 

14 C.F.R. § 61.113(a)&(b)- Private Pilot Privileges and Limitations. 

Pilot in Command (PIC). Sections 61.113(a)&(b) limit private pilots to noncommercial operations. Because the UAs will not carry a pilot, or passenger(s), the 

proposed operations can achieve the equivalent level of safety of current operations 

by requiring the PIC operating the aircraft to have a private pilot's license, or at least 

a Sport Pilot's Certificate, rather than a Commercial pilot's license to operate small 
Page 7 of12 

UAs. Unlike a conventional aircraft that carries the pilot and passenger(s), the UAs 

is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as 

set forth in the Manual. 

The level of safety provided exceeds that provided by a single individual holding a 

commercial pilot's certificate operating a conventional aircraft. The risks associated 

with the operation of the UAs are so diminished from the level of risk associated 

with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the UAs as requested with a private pilot as the PIC exceeds the 

present level of safety achieved by 14 CFR §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 of the aircraft and the requirements 

contained in the Manufacturer's Operating Manual for maintenance and use of 

safety check lists prior to each flight, an equivalent level of safety will be provided. 

14 CFR § 91.9(b)(2)- Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9(b)(2) provides: 

No person may operate (1) a U.S. registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination 

thereof. 

The UAs, given its size and configuration has no ability or place to carry a flight 

manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft. The equivalent 

level of safety will be maintained by keeping the flight manual at the ground control 

point where the PIC flying the UAs will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: 

Exemption No's: 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167 A, 

10602, 32827, and 10700. 
Page 8 of12 

14 CFR § 91.103- Preflight action 

This regulation requires each PIC to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for 

the aircraft an exemption will be needed. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. 

14 CFR §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. UAs and other remotely piloted aircraft, by their 

design do not have fully functional dual controls. Flight control is accomplished 

through the use of a single control box that communicates with the aircraft via radio 

communications. 

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. 

The equivalent level of safety can be achieved as neither a pilot, nor passenger(s) 

will be carried in the aircraft in addition to the small size and low speed of the 

aircraft. 

14 CFR §91.119- Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119(d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person(s) operating the helicopter complies with any route or 

altitudes prescribed for helicopters by the FAA. As this exemption is for a UAs that 

is a multi-rotor and the exemption requests authority to operate at altitudes up to 

400 feet AGL, or not more than 200 feet above an elevated platform from which 

operation is planned, an exemption may be needed to allow such operations. 

As set forth herein, except for the limited conditions stated in the Manual, the UAs 

will never operate at higher than 400 feet AGL. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the 

UAs, as well as the location where it is operated. No flight will be taken without the 

permission of the property owner, or local officials. Because of the advance notice 

to the property owner and participants in the flight activity, all affected individuals 

will be aware of the planned flight operation(s). 

Compared to flight operation(s) with aircraft, or rotorcraft weighting far more than 

the maximum 55 lbs proposed herein and the lack of flammable fuel, any risk 
Page 9 of12 

associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 feet AGL. In addition; the lowaltitude operations of the UAs will ensure separation between these small-UAs 

operation(s) and the operation(s) of conventional aircraft that must comply with 

Section 91.119. 

14 CFR §91.121- Altimeter Settings 

This regulation requires each person operating an aircraft to maintain altitude by 

reference to an altimeter that is "set to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAs may not have 

a barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. 

An equivalent level of safety will be achieved by the PIC, pursuant to the Manual and 

Safety Checklist, by receiving altitude information via a digitally encoded telemetric 

data feed, which downlinks from the aircraft to a ground-based on-screen display. 

This altitude information will be generated by equipment installed on board the 

aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio 

altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation 

point will be established and confirmed for accuracy by the pilot. 

14 CPR§ 91.15l(a)- Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed: (1) During the day, to fly after that for at least 30 minutes, or 

(2) At night, to fly after that for at least 45 minutes. 

The battery powering the UAs provides approximately 40 minutes of powered flight. 

To meet the 30-minute reserve requirement in 14 CFR §91.151, UAs flights would 

be limited to approximately 10 minutes in duration. Given the limitations on the 

UA's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. 

The Applicant believes that an exemption from 14 CFR §91.15l(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the 

small UAs, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 

thirty (30) minutes of reserve fuel, does not engender the type of risks that Section 

91.15l(a) was intended to alleviate given the size and speed of the small UAs. 

Additionally, limiting UAs flights to ten (10) minutes would greatly reduce the utility 

for which the exemption will be granted. 
Page 10 of12 

The Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to thirty (30) minutes, or 25% of reserved battery power whichever happens 

first. This restriction would be more than adequate to return the UAs to its planned 

landing zone from anywhere in its limited operating area. 

14 CFR §91.203(a) & (b)- Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: (a) Except as provided in §91.715, no 

person may operate a civil aircraft unless it has 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) of this 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 UAs fully loaded weighs no more than 5 lbs (including payload) and is operated 

without an onboard pilot. As such, there is no ability or place to carry certification 

and registration documents or to display them on the UAs. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point 

where the PIC flying the UAs will have immediate access to them, to the extent they 

are applicable to the UAs. The FAA has issued numerous exemptions to this 

regulation. 

A representative sample of other exceptions includes Exemption No's: 9565, 9665, 

9789, 9789A, 9797, 9797 A, 9816A and 10700. 

14 CFR §91.405(a); 407(a)(1); 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 of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter ... " and others shall inspect or 

maintain the aircraft in compliance with Part 43. Given that these sections and Part 

43 apply only to aircraft with an airworthiness certificate, these sections will not 

apply to the Applicant. 

Maintenance will be accomplished by the PIC pursuant to the flight manual and 

operating handbook. As the manufacturer does not provide specific maintenance 

instruction, UAs maintenance will be "on condition" for all aircraft and each aircraft 

will have a maintenance log. An equivalent level of safety will be achieved because 

these small UAs are very limited in size, will carry a small payload and operate only 

in restricted areas for limited periods of time. If mechanical issues arise the UAs can 

land immediately and will be operating from no higher than 400 feet AGL. As 

provided in the Manual, the PIC will ensure that the UAs is in proper working order 

prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. 
Page 11 of12 

Moreover, the PIC 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 the PIC encounters a maintenance issue that cannot be addressed, the UAs 

will be returned to the manufacturer, or a qualified repair facility where such 

repairs andjor maintenance can be performed. 

Pursuant to 14 CFR. Part II, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed. 

Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H; 14 

CFR 45.23(b); 14 CFR. §§ 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) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 

91.409(a)(2) and 91.417(a)&(b) to operate commercially a small unmanned vehicle 

(55 lbs or less) for aerial transportation, surveillance, photography and/or aerial 

filming operations. 

Approval of exemptions allowing commercial operations of UAs in the aerial 

transportation, surveillance, photo and/or film industry will enhance safety by 

reducing risk. Conventional operations, using jet or piston power aircraft, operate 

at extremely low altitudes just feet from the target location and in extreme 

proximity to people and structures; and present the risks associated with vehicles 

that weigh in the neighborhood of 4,000 lbs., carrying large amounts of jet A or 

other fuel. Such aircraft must fly to and from the aerial location. In contrast, a UAs 

weighing fewer than 55 lbs and powered by batteries eliminates virtually all of that 

risk given the reduced mass and lack of combustible fuel carried on board. The UAs 

is carried to the launch site. The UAs will carry no passenger(s) or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flight 

operation(s). 

The operation of small UAs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the Applicant from 

the requirements of Part 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 turbine 

Helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property 

owner's prior knowledge and consent. Filming will be of people who have also 

consented to being filmed or otherwise have agreed to be in the area where filming 

will take place. 
Page 12 of12 

If you have any questions, or need any additional information, please contact the 

undersigned at +1(530)409-8139 (cell), or via email arsenych@me.com. 

Sincerely yours, 

E20N, 

c~~~ Founder