August 28, 2015

Exemption No. 12650

Regulatory Docket No. FAA–2015–1477

Mr. Ryan Switala

1614 Copperfield Court

Howell, MI 48843

Dear Mr. Switala:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on May 6, 2015, you petitioned the Federal Aviation 

Administration (FAA) for an exemption. You requested to operate an unmanned aircraft 

system (UAS) to conduct aerial photography, videography, and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a JJRC H16 YiZhan Tarantula X6.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 
2

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Ryan Switala is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Ryan Switala is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the JJRC H16 YiZhan 

Tarantula X6 when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
4

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

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

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
To whom it may concern, 

In regards to section 333 of the FAA Modernization and reform care act of 2012 and 14 C.F.R. I Ryan 

Switala apply for exemption from the Federal Aviation Regulations to allow me to take pictures of 

short videos for commercial purposes using a Small Unmanned Aircraft System . The “sUAS” would be 

operated under the conditions outlined established by the FAA under section 333.

I intend to use my sUAS JJRC H16 YiZhan Tarantula X6 in conjunction with a Gopro hero 3 to take photos 

and short videos to enhance the cinematography of requested photos and video’s. The complete set up 

of camera a sUAS would under the weight of 4 lbs. Use a sUAS would be a more practical and cost effect 

way to achieve elevated photos and video. In addition the benefit of safety in the national airspace 

would be increased using a sUAS. 

For the reasons stated below I, Ryan Switala, respectfully request the grant of an exemption allowing me 

to operate ultra light weight, remote controlled UAS’s for commercial aerial 

photography/videography/cinematography.

I. Contact Information 

Ryan Switala 

1614 Copperfield Ct Howell, MI 48843 

ffrswitala@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Ryan Switala

Requests Exemption are:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14

C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. §

91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1);

14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417

(a) & (b)

III. The Extent of relief Ryan Switala seeks and the Reason He Seeks Such Relief:

I Ryan Switala will be the pilot in charge of the sUAS. I will not operate my sUAS near airports, hospitals, 

restricted airspace or no fly zones. At all times my sUAS will maintain a distance of 50-100 yards away 

from any public. My sUAS will be powered by a battery opposed to an engine that will require 

combustible fuels to be on board. Flight time will be spanning from five (5) To fifteen (15) Minutes and 

at no time will be over an altitude of 200 AGL. Always using a fully charged battery would ensure a safe 

flight. All fights would be based on weather, any adverse weather including winds up to and including 10 
kph the flight would be canceled. Following all the stated guidelines above I plan to keep the safety of 

any flight as the highest priority. 

I have been operating other sUAS for the past few years, using a standard pre-flight inspection process, 

checking the weather on a FAA approved website and being an active hobbyist of sUAS I have the 

experience, knowledge and skills to reduce the chance of possible accidents. By granting of an exception 

I understand that I will be under significantly more restriction than a hobby operator. 

IV. How will Ryan Switala request benefit the Public As a whole:

Aerial photography and videography will help enhance the pictures of real-estate and other memorable 

events such as weddings, birthday parties and family events. Using a sUAS would eliminate the expense 

to the customer of hiring a pilot and a plane to take pictures in the traditional matter as well as the risk 

to civilians with using a small manned aircraft. 

V. Reasons Why Ryan Switala’s Exemption Will Not Adversely Affect Safety Or How The Exemption 

Will Provide a Level of Safety At Least Equal To Existing Rule:

By granting I, Ryan Swtiala this exemption I will create a safer community. With following all the laws 

and regulation and well as adhering to personal rigorous preflight inspections, line of sight flight paths 

and keeping the sUAS at distances that are less than the required minimum I intend to keep safety as my 

number one priority. 

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my,

Ryan Switala’s, UAS permits exemption from Part 21 because my UAS meets

(and exceeds) an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's

from the airworthiness certificate requirement in consideration of the weight, size,
speed, maneuverability and proximity to areas such as airports and dense

populations. I Ryan Switala current and projected UAS's meet or exceed

each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there

are no on board pilots or passengers, and given the size of the UAS's, this

Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a

B.

safety/flight manual delineating areas of where safety can be defined.10 The

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and

32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable with my sUAS

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft

certifications and registrations. They are inapplicable for the same reasons

described above. The equivalent level of safety will be achieved by maintaining

any such required certifications and registrations by me, Ryan Switala.

14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according

to certain specifications. My UAS are, by definition, unmanned. They therefore do

not have a cabin, cockpit or pilot station on which to mark certain words or 
phrases. Further, two-inch lettering is difficult to place on such small aircraft with

dimensions smaller that minimal lettering requirement. Regardless, I will mark its

UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on

its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone

assisting me as a spotter with the UAV will see the markings. The FAA has

previously issued exemptions to this regulation through Exemptions Nos. 8738,

10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial

operations. I, Ryan Switala, can achieve an equivalent level of safety

as achieved by current regulations because my UAS does not carry any pilots or

passengers. The risks attended to the operation of my UAS is far less than the

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq.

Thus, allowing me, Ryan Switala, to operate my UAS meet and exceed current

safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It

allows helicopters to be operated at lower altitudes in certain conditions. My UAS

will never operate at an altitude greater than 200 AGL; safely below the standard

of 400 AGL. I, Ryan Switala will however operate my UAS in safe areas away

from public and traffic, providing a level of safety at least equivalent to or below

those in relation to minimum safe altitudes. Given the size, weight,

maneuverability and speed of my UAS, an equivalent or higher level of safety will

be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance
Inspections.

C.

D.

E.

The above-cited Regulations require, amongst other things, aircraft owners and

operators to “have [the] 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.

. . .”

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my, Ryan Switala’s , UAS.

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my

UAS permits exemption from Part 21 because my Ryan Switala’s, UAS meets

an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA

is authorized to exempt aircraft from the airworthiness certificate requirement

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act.

Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness

certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations.

My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the

operation of an aircraft without an airworthiness certificate. As no such certificate
will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the

aircraft. As there are no pilots or passengers, and given the size of the UAS's,

this Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a manual. The FAA has previously issued exemptions to this

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B,

10167, maintenance program that involves regular software updates and curative

measures for any damaged hardware. Therefore, an equivalent level of safety

will be achieved.

In summary, Ryan Switala seeks an exemption from the following

Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14

C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. §

91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1);

14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417

(a) & (b) to commercially operate my, Ryan Switala, small unmanned

vehicle/lightweight unmanned aircraft vehicle in thereby enhance safety. 

Thank you for your time in this matter, 

Ryan Switala