Hi-vantage LLC 

2020 Metcalf St. 

Honolulu, HI 96822 

(808) 223-4013 

June 9, 2015 

U.S. Department ofTransportation Docket 

Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

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) and (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)(l) and (2); 91.417(a) and (b). 

Dear Sir or Madam: 

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

and 14 C.F.R. Part 11, Hi-vantage an operator of Unmanned Aircraft Systems ("UASs") for aerial 

photography and filming operations for a range of business including insurance, real estate, agriculture, 

infrastructure inspection, aerial 3D mapping, disaster relief assistance, travel video/photography, and 

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 UASs. 

To date, the FAA granted numerous exemptions to UAS operators. 

Hi-vantage'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 the film and television industry. As 

established by the exemptions already granted by the FAA, approval of Hi-Vantage'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." 

Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

George Russell 

Hi-vantage LLC 

2020 Metcalf St. 

Honolulu, ill 96822 

(808) 223-4013 

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 may operate safely in the national airspace system (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. ln making tbis 
determination. the Secretary is required to detennine which types of UASs 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 UAS'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 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 defmcd under §40 101 of 

the Act, that includes U ASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

UASs operated by Hi-vantage weigh less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and can simultaneously 

move vertically and horizontally. Hi-vantage will only operate its UASs in line of sight 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." 

Hi-vantage seeks an exemption to operate the DJI Phantom 2 and 3, DJI Inspire!, DJI 8900, DJI 

SIOOOFreefly Cinestar 8, and 3d Robotics "Solo'' UAS for compensation or hire within the NAS. A copy 

of the operating handbook for each aircraft will be submitted with this exemption request. Each UAS has 

a maximum gross weight under 10 pounds, maximum speed of 49 mph (approximately 42 knots), a run 

time of approximately 30 minutes. 

Each UAS operated by Hi-vantage will be 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. 

Given the small size of Hi-vantage's UASs and the restricted sterile environment within which 

they will operate, Hi-vantage's UAS operations adhere to the Reform Act's safety requirements. 

Additionally, due to the size of the UASs and the limited areas in which they will operate, approval of this 

application presents no national security issues. Based on the substantial level of safety surrounding the 

proposed operations, and 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. 

Accordingly, Hi-vantage 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 \vith 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 aerial 

filming for movie and television filming operations conducted with conventional aircraft. 

These lintitations and conditions to which Hi-vantage 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 opemted within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 ntinutes. 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 and the Visual Observer. 

6. UAS pilot will be an FAA licensed airman with at least a Sport Pilot's certificate. 

7. UAS Pilot assumes all duties and responsibilities as Pilot in Command (PIC). 

8. The UAS will only operate within a confined "Sterile Area". Security will be performed by the 

operator and designated security personnel. 

9. A briefing will be conducted in regard to the planned UAS operations prior to each day's 

production activities. It will be mandatory that all personnel who will be perfomling duties within 

the boundaries of the safety perimeter be present for this briefmg. 

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

11. When required, the operator \Vill submit a written Plan of Activities to the nearest FSDO 72 

hours prior the proposed shoot. 

12. Pilot and observer will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated. 

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

communications as to ensure all crew members maintain a visual contact with the UAS at ALL 

TIME. 

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

15. All required pemlissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local Jaw enforcement, fire, or other appropriate governmental agencies. 

16. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

retwn to a pre-determined location within the Security Perimeter and land. 

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

emergencies. 

The Plan of Activities 

The Plan of Activities must include the following: 

Briefing 

1. Dates and times for all flights; 

2. Name and phone number of the person responsible for the photography I filming event; 

3. Name and phone number of the person responsible for the aircraft; 

4. Make, model and serial number and/or registration number of all UAS t to be used; 

5. Name and certificate number, if applicable, of all crcwmembcrs 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 d.iagranlS of any area, city, town, 

county, and/or State over which filming will be conducted and the nlinimum altitudes 

essential to accomplish the operation. 

Hi-vantage 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 U AS flight operations, Plan of Activities, special provisions and any additional 

provisions issued by the Flight Standards District Office having jurisdiction over the photo I 

filming 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 the 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 Hi-vantage. 

Hi-vantage or 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 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 9l.l03 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 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 C.P.R. Part 21 , Subpart H: Airworthiness Certificates 14 C.F.R. §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 (f)) 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 tlammable 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 both the operator, pursuant to the Manual's requirements, and under 

the requirements and in compliance with local public safety requirements, to provide security for the area 

of operation as is now done with conventional filming. The FAA will have advance notice of all 

operations. These safety enhancements, which already apply to civil aircraft operated in connection with 

motion picture and television production, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible thre-at 

to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 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 2 inches nor more 

than 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 will have no entrance to the cabin, cockpit or pilot station on which the word Experimental" can be 

placed. Given the size of the sUAV, two-inch lettering will be impossible. The word "Experimental" will 

be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAV 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 10167A. 

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the U AS 

will not cany a pilot or passengers, 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 rather than a 
commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries th.e pilot 

and passengers, 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 arc 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 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 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 C.F .R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registcrcd 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 confLguration has no ability or place to carry such 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 pilot flying the UAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738. 9299, 9299A, 9565, 95658, 

10167, 10167A, 10602,32827, and 10700. 

14 C.F.R. § 9l.l03: Preflight action 

This regulation requires each pilot in command 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 injtiation of flight. 

14 C.F.R. §91.1 09: 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. 
UASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a 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 passengers will be carried in the aircraft in addition 

to the small size and low speed of the aircraft. 

14 C.F.R. §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 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 helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming 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 AGL. It will however be operated in a restricted 

area with security perimeter, where buildings and people will not be exposed to opemtions 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 pennission of the property owner 

or local officials. Because of the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maxi mum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500. In addition, the low-altitude operations of 

the UAS will ensure separation between these small-UAS operations and the operations of conventional 

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 crmsmg 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 

operator, pursuant to the Manual and Safety Check list, 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 C.P.R.§ 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 - (I) 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 I 0 
minutes in length. Given the limitations on the UAS's proposed flight area and the location of its 

proposed operations within a predetennined area, a longer time frame for flight in daylight or night VFR 

conditions is reasonable. 

Hi-vantage 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 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 I 0 minutes 

would greatly reduce the utility for which the exemption will be granted. 

Hi-vantage believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of 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 C.F.R. §91.203 (a) and (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 55 lbs 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 achlcvcd by keeping these documents at the ground control 

point where the pilot 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 Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. §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 section 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 operator pursuant to the 

flight manual and operating handbook. As the manufacturer does not provide specific maintenance 

instructions, 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 UASs are very limited in size 

and 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 operator will ensure that the UAS is in working order prior to 

initiating t1ight, perform required maintenance, and keep a log of any maintenance performed. Moreover, 

the operator 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 operator encounters a maintenance 

issue which cannot be addressed, the UAS will be returned to the manufacturer or a qualified repair 

facility where such repairs or maintenance can be performed. 

Pursuant to 14 C.F.R. 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 C.F.R. §21, subpart H; 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; 91.15l(a);9l.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 (55lbs or less) 

in aerial photography and aerial filming operations. 

Approval of exemptions allowing commercial operations of UASs in the aerial photo and film 

industry will enhance safety by reducing risk. Conventional film operations, using jet or piston power 

aircraft, operate at extremely low altitudes just feet from the subject being fi lmed and in extreme 

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

neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel. Such aircraft must fly to and 

from the film 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 film set and not flown. The UAS will carry no passengers or crew and, 

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

The operation of small UASs, 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, arc far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occm over private or controlled access property with the property owner's prior 

consent and knowledge. 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. 

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

808.223.4013 or gynnedia@mac.com. 

Sincerely yours, 
~~ George Russell 

Hi-vantage, LLC