August 18, 2015

Exemption No. 12500 Regulatory Docket No. FAA

− 20 15

− 1256

Ms. Lacey Szekely

Owner Vertical Vantage

, Inc.
5600 Caleb Drive Fallon, NV 89406

Dear Ms. Szekely :

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 dated July 12, 2015

, and response posted to docket on July 22, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Vertical Vantage, Inc. ( h ereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned

ai rcraft system (UAS) to conduct aerial photography and videography

.

See Appendix A for the petition submitted to the FAA des cribing 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 DJI Inspire 1

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in2

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

14 CFR part 21

, C ertification 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 collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , 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 peti tioner 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 i nterest.

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, Vertical Vantage, Inc. 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.

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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Vertical Vantage, Inc. is hereafter referred to as the operator.

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 DJI Inspir e 1 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 p ermitted.

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 operat ed 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 maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r 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 thi s 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

limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present up dated 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 FA A’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 op eration 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 mu st 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 i s 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 comp onents, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew 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 be5

operated under this exemption, including evasive and emergency maneuvers and

main taining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (trai ni ng, 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 operat ions may only be conducted during dedicated training sessions. During

traini ng, 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 sy mbo l 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 mus t 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 sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibi ted 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 cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to co nduct 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 identification6

(N− Number) ma rkings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

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 nonpartici pating 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 r emain 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 control led

- access property with permission from the property owner/controller or aut horized 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 opera tional area as defined by the applicable COA must be reported

to the FA A'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.7

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

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 a rea 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 th e 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 certific ate 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 t o 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

essenti al 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 specifie d 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 91.8

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

Sincerely,

/ s/
John S. Duncan Director, Flight Standards Service

EnclosuresLacey Szekely

Vertical Vantage, Inc.
5600 Caleb Dr. Fallon, NV 89406

(541)727

- 1286
Docket No. FAA

- 2015

- 1256

*Note: After submitting my original petition on April 2, 2015 for exemption with respect to the DJI Phantom 2, DJI released a more sophistica ted UAS; the Inspire 1. I have purchased the DJI Inspire 1 and am seeking an exemption for that UAS. All specifications, manuals and pertinent information are attached. All requests for exemption using the Phantom 2 have been removed from this docket.

Additional Information:



## I. Regulations from which Exemption is Requested

Relief is requested from the following FAR’s:

A. **14 CFR Part 21, Subpart H: A irw**  **orthiness Certificates and 14 CFR 91.203(a) (1)**  **B. 14 CFR 61.56: Flight Review**
**C.14 CFR 6 1.113 (a) & (b): Private pilot privileges and limitations** 
**D. 14 CF R 91.119: Minimum safe altitudes**
**E. 14 CFR 91.121: A ltimeter settings**  **F. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions G. 14 CFR 91.405 (a):Maintenance required; 91**  **.407 (a) (1): Operation after maintenance, preventive**  **maintenance, rebuilding, or alteration; 91.409 (a) (2): Inspections; 91.417 (a) & (b): Maintenance records** 

**A. 14 CFR Part 21; Subpart H: A**  **irw orthiness Certificates and 14 CFR 91.203(a)(1)** 

Vertic al Vantage requests exemption from attaining airworthiness certificates required by 14 CFR 91.203(a)(1). Section 333 of the Reform Act allows the FAA to exemptaircraft from the requirement of an airworthiness certificate in consideration of the size,

wei ght, speed, operational capability, and proximity to airports and populated areas of
the UAS.

Equivalent of Safety

The DJI Inspire 1 weighs 6.4 lbs to include payload, no persons on board, and no flammable fuels. The operational location can be preloade d using GPS way points to include route altitude and speed. The DJI Inspire 1 also has a return to home button which safely brings the drone back to its starting point. The PIC and VO will do a thorough preflight to determine the airworthiness of the Ins pire 1 prior to each flight on location. The safety guidelines will be followed from the Inspire 1 User Manual, Flight Operations Manual, and preflight checklist.

**B. 14 CFR 61.56: Flight Review** 

Vertical Vantage requests exemption from 14 CFR 61.56 which re quires the PIC to conduct a flight review consisting of a minimum of 1 hour of flight training and 1 hour of ground training. This requirement is not pertinent to the safe operations of the Inspire 1.

Equivalent of Safety

The equivalent level of safety will be achieved by following the procedures of the manufacturer in the Inspire 1 User Manual and Flight Operations manual. Maintaining currency and proficiency are a top priority for Vertical Vantage Inc. Bi

- monthly flights will be the minimum requireme nt for operation of the Inspire 1. These flights, if not for business purposes will consist of at least 18 minutes (battery life limit) of flight time with Inspire 1, and 10 manual (no GPS) take off and landings.

**C. 14 CFR 61.113: Private pilot privileg**  **es and limitations: Pilot in Command**

Vertical Vantage requests exemption from 14 CFR 61.113(a) which states that Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraf t in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

The UAS will only carry a camera onboard for hire. No l iving thing at anytime will be carried, therefor an exemption from the above requirement is requested.Equivalent of Safety

Wh ile being used for commercial and private use, the UAS will never carry live people, animals, or creatures, and therefore has a much lower operational safety requirement than a passenger craft.

**D. 14 CFR 91.119(c): Minimum safe altitudes** 

Vertical Vantage request exemption from 14 CFR 91.119(c), which states that except when necessary for takeoff or landing, no person may operate a n aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or sett lement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except

over ope n water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Equivalent of Safety

Due to the small size, weight, limited speed and absence of flammable liquids o n board, the Inspire 1 is safer than an airplane. Flying will only occur with the proper consent of the property owners and/or local officials. This permission will give ample time for all owners and neighbors to be aware of the times of operation. Mul tiple signs will be posted to ensure people are aware when drone operations are being conducted. At no time will the UAS be operated at or near any airport, exceed 400ft AGL, and or be flown over any person, vessel, vehicle or structure without prior co ordination and permission of the concerned parties (i.e. base operations, FBO, marina operations manager, etc.).

**E. 14 CFR 91.121: altimeter setting**

Vertical Vantage requests exemption from 14 CFR 91.121 which states that: (a) Each person operating an a ircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the ro ute and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.The UAS needs an exemption because there is not a configurable barometric altimeter

on board.

Equivalent of Safety

Precise al titude control is accomplished easily by two methods. The first is done by pre

loading the precise GPS waypoints for the intended route of flight, to include altitude and airspeed. The second is done while operating in a manual flight mode by inputing a maximum allowable altitude into the flight control system on the controller. This limit prevents the Inspire 1 from ever exceeding that altitude. At no time will this limit exceed 400ft AGL in either pre

- planned or manual mode. The Inspire 1 will also r emain within visual line of sight at all times.

**F. 14 CFR 91.151(a): Fuel requirements for flight in VFR conditions**

Vertical Vantage requests exemption from 14 CFR 91.151(a), which states that: (a) No person may begin 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 Inspire 1 uses an 18 minute battery therefore cannot meet the criteria for this requirement.

Equivalent of Safety

Planning all flights to land after 15 minutes or 25% battery power remaining, whichever
comes first , would provide equal safety conditions. The Inspire 1 has a safety feature which automatically returns it directly to the point of origin or planned destination, whichever is closer, upon reaching 25% battery power remaining. This prevents power
loss in flight. Additionally if the remote controller is low on batteries the pilot can manually command the Inspire 1 to return to the point of origin with the push of a button. This prevents any case where airborne control of the drone may be lost due to a de ad remote control. This function can be activated at distances greater than visual range, however Vertical Vantage will only operate the UAS in visual line of sight and day VFR
conditions.

**G. 14 CFR 91.405(a) Maintenance required;91.407(a)(1) Operation a fter**  **maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a) Inspections; 91.417(a)&(b) Maintenance records** 

Vertical Vantage request exemption from maintenance and inspection requirements from 14 CFR 91.405(a), 91.407(a)(1), 91.409(a ), and 91.417(a)&(b). An exemption isrequired for aircraft holding an airworthiness certificate. Presuming an approval for

waiver of 14 CFR Part 21, subpart H and 14 CFR 91.203(a)(1) the Inspire 1 will not require an airworthiness certificate. The Inspir e 1 does not hold this certificate.

Equivalent of Safety

Ensuring the UAS is operational before a flight is key to maintaing an excellent safety record. Keeping a log book for all maintenance preformed and any maintenance test flights will be recorded. This will ensure proper user maintenance is conducted on time.
All maintenance will be in accordance with the DJI user manual.



## II. Public Interest

This exemption is in the public’s interest because it offers a more cost effective, more
efficient w ay of supporting their needs with increased safety. The use of a lightweight UAS offers the general public something only successful companies could afford; views from the sky. These aerial views can benefit small and large businesses alike.

The Inspir e 1 is a safer alternative than other methods like hiring a helicopter or airplane. A UAS can go to places those aircraft cannot and also eliminates the human risk factor. For example, someone wanting to make a short real

- estate clip of their property no longer needs to hire a helicopter which is not very cost effective or as safe. Also, for the purpose of inspecting infrastructure, trenches, agriculture, property lines etc. The UAS provides an annoyance free solution while decreasing the volume of
aircr aft in the National Airspace above 400 ft AGL. Additionally, the newest DJI UAS, the Inspire 1 incorporates increased safety measures such as push

- button return home capability, low battery sensing which activates automatic return, more efficient low

impa ct blades, and increased telemetry allowing greater control by the pilot.

Small drones can have the job done in a more timely manor with less manpower. This much safer alternative will not only mitigate unnecessary risk but provide the public an
affordabl e and dependable service. Because of this it is in my opinion that Vertical Vantage working with the Inspire1 would be in the greatest interest of the public.



## III. **Priv acy** All flights will have signed permission/consent forms from the property owner. A mple

time will be given to notify neighbors and signs will be placed in plain sight when the Inspire 1 is aerial. These flights will only occur in predetermined and controlled locations which will protect peoples privacy. Prior permission from the city, county, state or federal officials will be requested if flights need to occur over public lands/property.



## IV. **14 CFR Summary**

I, Lacey Szekely, Vertical Vantage Inc., request exemption from the following rules to commercially operate the Inspire 1 in Natio nal Airspace for Aerial photography, videography, inspection/survey and real estate services.

**14 CFR Part 21, Subpart H: A irw**  **orthiness Certificates and 14 CFR 91.203(a) (1)** 

**14 CFR 61.56: Flight Review**

**14 CFR 61.113 (a) & (b): Private pilot priv ileges and limitations** 

**14 CF R 91.119: Minimum safe altitudes**

**14 CFR 91.121: A ltimeter settings** 

**14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions**

**14 CFR 91.405 (a):Maintenance required; 91.407 (a) (1): Operation after maintenance,**  **preventive maintenance, rebuilding, or alteration; 91.409 (a)**  **(2): Inspections; 91.417 (a) & (b): Maintenance records**

Re

- submitted July 12, 2015 by: Vertical Vantage Inc. Lacey Szekely, Owner
5600 Caleb Dr. Fallon, NV 89406 Telephone: (541) 727

- 1 286 verticalvantageinc@gmail.com

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c a m p a i g n

. T h i s c a n r e s u l t i n d i s c r e p a n c i e s b e t

w e e n t h i s c o u n t

a n d t h o s e d i s p l a y e d w h e n

c o n d u c t i n g s e a r c h e s o n t h e P u b l i c S u b m i s s i o n d o c u m e n t t

y p e

. F o r

s p e c i f i c i n f o r m a t i o n a b o u t a n

a g e n c y ’ s p u b l i c s u b m i s s i o n p o l i c y

, r e f e r t o i t s w e b s i t e o r t h e F e d e r a l
R e g i s t e r d o c u m e n t

.