18400 VON KARMAN AVENUE, SUITE 800 IRVINE, CALIFORNIA 92612-0514

TELEPHONE (949) 760-1121 / FAX (949) 720-0182

Direct Dial Number: (949) 224-6247

Direct Facsimile Number: (949) 224-6407

E-Mail Address: pfraidenburgh@buchalter.com

Buchalter Nemer

Los Angeles • Irvine • San Francisco • Scottsdale

www.buchalter.com

October 20, 2014

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Mountain High Aviation, LLC’s Petition for Exemption to Operate

Small Unmanned Aircraft Systems

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER COUNSEL FOR PETITIONER

Mountain High Aviation, LLC Paul J. Fraidenburgh

Attn: Joseph Hovelman BUCHALTER NEMER

445 Dead Indian Memorial Drive 18400 Von Karman Ave, Suite 800

Ashland, OR 97520 Irvine, CA 92612

541.552.5150 949.224.6247

joseph.hovelman@mthighaviation.com pfraidenburgh@buchalter.com
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I. PETITION SUMMARY

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

Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation 

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), 

Mountain High Aviation, LLC (“Petitioner”) hereby petitions for exemptions from 14 

C.F.R. Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 (Airworthiness 

Standards: Normal Category Rotorcraft), 14 C.F.R. §§ 91.7(a), 91.9(b)(2), 91.103(b)(1),

91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.407(a)(1) 

91.409(a)(2), and 91.417(a)-(b). The proposed exemptions, if granted, would allow

Petitioner to conduct commercial operations of small unmanned aircraft systems (“UAS”)

weighing 55 pounds or less.

Based on the small size of Petitioner’s UAS, the qualifications and experience of 

Petitioner’s pilot, and the limited environments within which Petitioner will operate, the 

requested exemptions fall squarely within the zone of safety envisioned by Congress and 

set forth in Section 333. Additionally, the enhanced safety achieved by replacing 

significantly larger manned aircraft carrying crew and flammable fuel with small UAS 

carrying no passengers or crew and operated under the specific guidelines and procedures 

proposed by Petitioner gives the FAA good cause to find that the UAS operations enabled 

by the instant Petition are in the public interest. Thus, the requested exemptions should

be granted.
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II. BACKGROUND

Petitioner is a multifaceted technology company that holds an FAA Part 135 

Certificate and provides a broad range of remote sensing and aviation solutions to a 

variety of industries and government agencies. Petitioner seeks to build on its years of 

successful and safe operations and leverage its aviation skills and knowledge to offer the 

widest possible range of UAS services in a manner that is consistent with the intent of 

Congress in enacting Section 333. Petitioner seeks the requested exemptions and a 

Certificate of Authorization to permit Petitioner to offer on-demand commercial UAS 

operations for a host of industries and applications including:

• Aerial surveying

• Remote sensing

• Precision agriculture

• Aerial filmmaking and photography

• Public entity support operations

• Utility system inspections and patrolling

• Construction site inspection and monitoring

• Wildlife and forestry monitoring

• Educational and research operations

• Flare stack inspection, and

• Pipeline inspection and patrolling
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Petitioner’s team of pilots and technical experts have extensive experience in 

remote sensing, aviation, data collection, information technology, project management, 

and mechanical engineering. Petitioner’s approach to UAS integration is aimed at

building on Petitioner’s preexisting infrastructure for operating within the National 

Airspace System (“NAS”), including, to the greatest extent possible, adopting 

Petitioner’s safe operations procedures for Petitioner’s Part 135 and special missions 

operations. This will allow Petitioner to fully integrate with the established systems that 

govern all air operations, whether conducted under Part 91 or Part 135.

III. STATUTORY AUTHORITY

A. Section 333

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,”

provides a mechanism for seeking expedited FAA authorization of safe civil UAS 

operations in the NAS. Section 333(a) states that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before 

completion of the [comprehensive] plan and rulemaking required by section 332(b)(1) of 

this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), 

Congress made it clear that Section 333 provides a mechanism for “expedited operational 

authorization.”

Section 333(b) identifies several factors that the FAA should consider in 

determining whether commercial UAS operations should be approved. These include 

UAS that, “as a result of their size, weight, speed, operational capability, proximity to 
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airports and populated areas, and operation within visual line of sight do not create a 

hazard to users of the [NAS] or the public or pose a threat to national security.” See 

Section 333(b).

B. Section 44701(f)

In addition to the specific authority conferred by Section 333, the FAA

Administrator has general authority to grant exemptions from the FAA’s safety 

regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See U.S.C. § 44701(f).

IV. REQUESTED EXEMPTIONS

Petitioner requests relief from the following regulations:

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and 

changing design approvals, production approvals, airworthiness certificates, and 

airworthiness approvals.

Part 27 sets forth airworthiness standards for normal category rotorcraft.

Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil 

aircraft unless it is in an airworthy condition.

Section 91.9(b)(2) prohibits operation of U.S. registered civil aircraft 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.
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Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command 

shall, before beginning a flight, become familiar with all available information 

concerning that flight, to include, “For any flight, runway lengths at airports of intended 

use, and the following takeoff and landing distance information:... For civil aircraft for 

which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing 

distance data is required, the takeoff and landing distance data contained therein.”

Section 91.109(a) provides that “[n]o 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.”

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: “Over other than congested 

areas. An altitude of 500 feet above the surface, except over open 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.”

Section 91.121 requires, in pertinent part, each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set “to the elevation of the 

departure airport or an appropriate altimeter setting available before departure.”

Section 91.151(a) prescribes that 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 
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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.

Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft 

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an 

effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft Registration Application as provided for in 

§ 47.31(c). Section 91.203 prescribes, in subpart (b), that no person may operate a civil 

aircraft unless an airworthiness certificate or a special flight authorization issued under § 

91.715 legible to passengers or crew is displayed at the cabin or cockpit entrance.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner 

shall have the aircraft inspected as prescribed in subpart E of the same part and shall, 

between required inspections, except as provided in paragraph (c) of the same section, 

have discrepancies repaired as prescribed in Part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an 

aircraft that has undergone maintenance, preventative maintenance, rebuilding, or 

alteration unless it has been approved for return to service by a person authorized under 

§ 43.7 of the same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had an inspection for the 

issuance of an airworthiness certificate in accordance with part 21 of this chapter.
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Section 91.417(a) and (b) prescribes, in pertinent part, that-

(a) Each registered owner or operator shall keep the following records 

for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventative maintenance, and 

alteration and records of the 100-hour, annual, progressive, 

and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. The records 

must include-

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person 

approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, 

each propeller, and each rotor.

(ii) The current status of life-limited parts of each 

airframe, engine, propeller, rotor, and appliance.
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(iii) The time since last overhaul of all items installed on 

the aircraft which are required to be overhauled on a 

specified time basis.

(iv) The current inspection status of the aircraft, including 

the time since the last inspection required by the 

inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness 

directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety 

directive number and revisions date. If the AD or 

safety directive involves recurring action, the time and 

date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this 

chapter for each major alteration to the airframe and 

currently installed engines, rotors, propellers, and 

appliances.

(b) The owner or operator shall retain the following records for the 

periods prescribed:
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(1) The records specified in paragraph (a)(1) of this section shall 

be retained until the work is repeated or superseded by other 

work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall 

be retained and transferred with the aircraft at the time the 

aircraft is sold.

(3) A list of defects furnished to a registered owner or operator 

under § 43.11 of this chapter shall be retained until the 

defects are repaired and the aircraft is approved for return to 

service.

V. PETITIONER’S PROPOSED OPERATIONS SATISFY SECTION 333.

A. Unmanned Aircraft System

Petitioner intends to operate several small UAS under the requested exemptions. 

Thus, the following specifications and limitations apply to all UAS for which Petitioner 

herein seeks an exemption.

The UAS to be operated under this request will be less than 55 lbs. fully loaded, 

will be operated at a speed of no more than 50 knots, will carry neither a pilot nor 

passenger and no explosive materials or flammable liquids, and will be operated

exclusively in predetermined environments that are controlled as to access. Petitioner’s 

UAS will use a radio frequency spectrum for operation and control that complies with 

Federal Communications Commission (“FCC”) requirements, and will be operated only 
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in accordance with the procedures described in Petitioner’s Flight Operations and 

Procedures Manual (“FOPM”).

1

Petitioner’s UAS will be equipped with redundant safety mechanisms allowing 

safe operation after experiencing certain in-flight failures. If a lost-link event occurs, 

including the loss of ground communications and/or the loss of a GPS signal, Petitioner’s

UAS will have the ability to perform a pre-coordinated, predictable, automated flight 

maneuver and return to a predetermined location within a designated security perimeter 

for landing. The UAS will further have the ability to abort a flight in the event of 

unpredicted obstacles or emergencies. The maximum total flight time for each 

operational flight will be limited to the amount of time the UAS can be flown and still 

maintain a reserve battery power of no less than 25%. Thus, good cause exists for 

granting Petitioner’s requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel 

requirements for flight in VFR conditions).

Regarding Petitioner’s requested exemption from 14 C.F.R. Section 91.109(a), 

UAS, by their design, typically do not have functional dual controls. Given the size and 

speed of the UAS, an equivalent level of safe training can be performed without dual 

controls because no pilot or passengers are aboard the UAS and all persons will be a safe 

 1 The FOPM will be submitted separately and confidentially under 14 C.F.R. 11.35(b), as 

the manual contains proprietary information that the applicant has not and will not share 

with others. The manual contains operating conditions and procedures that are not 

available to the public and are protected from release under the Freedom of Information 

Act, 5 U.S.C. §§ 552, et seq.
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distance away in the event that the UAS experiences any difficulties during flight 

instruction. 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. See Exemption Nos. 5778K and 9862A. Thus, good cause exists for granting 

the requested relief from 14 C.F.R. § 91.109(a).

Petitioner’s UAS will be identified by serial number, registered in accordance with 

14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 

C.F.R. Part 45, Subpart C. Markings will be as large as practicable.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter 

Settings), Petitioner seeks such relief because Petitioner will not have a typical 

barometric altimeter onboard the UAS. Instead, altitude information will be provided to 

the UAS PIC via a digitally encoded telemetric data feed, which downlinks from the 

aircraft to a ground-based on-screen display. The altitude information will be generated 

by equipment installed onboard the UAS, using GPS triangulation, digitally encoded 

barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a 

zero altitude initiation point will be established and confirmed for accuracy by the UAS 

PIC. Thus, good cause exists for granting the requested relief from 14 C.F.R. § 91.121.

Given the size, weight, speed, and limited operating area associated with the 

aircraft to be utilized by the applicant, an exemption from 14 C.F.R. Part 21, Subpart H 

(Airworthiness Certificates), subject to certain conditions and limitations, is warranted (if 
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necessary) and meets the requirements for an equivalent level of safety under 14 C.F.R. 

Part 11 and Section 333. The UAS operated without an airworthiness certificate in the 

restricted environment and under the conditions and limitations proposed by Petitioner 

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and 

not subject to the proposed limitations and conditions.

Petitioner will strictly comply with safety and maintenance procedures included in 

all applicable UAS manufacturer’s instructions and operating manuals. To the extent 

such information is not included in the guidelines developed by the manufacturers, 

Petitioners will develop and document maintenance, overhaul, replacement, and 

inspection requirements, procedures to document and maintain maintenance records with 

regard to Petitioner’s UAS, and UAS technician qualification criteria. Petitioner’s 

operations manuals will include maintenance requirements for Petitioner’s UAS, 

including “on-condition” maintenance and modifications. In light of these mitigating 

factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b) are warranted.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s 

understanding that, in light of the operating parameters defined herein, Petitioner’s UAS 

may not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H, and exemption from 14 C.F.R. § 91.7(a) may be unnecessary. See, e.g.,
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Exemption No. 11062, Regulatory Docket No. FAA-2014-0352 (explaining no such 

exemption was necessary for the requested UAS operations). To the extent such an 

exemption is deemed necessary in this instance, Petitioner asserts that it should be 

granted in light of the safety procedures proposed herein. In accordance with the 

pertinent part of 14 C.F.R. § 91.7(b), the PIC shall be responsible for determining 

whether the aircraft is in a safe condition for flight. Petitioner’s manuals for maintenance 

and operations shall include safety checklists to be used by the PIC prior to each flight.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft 

flight manual, marking, and placard requirements) and § 91.203(a) and (b), (Civil 

aircraft: certifications required), it is Petitioner’s understanding that relief from these 

regulations is no longer necessary in light of the FAA Memorandum “Interpretation 

regarding whether certain required documents may be kept at an unmanned aircraft’s 

control station,” dated August 8, 2014. To the extent the FAA deems an exemption from 

this section necessary for Petitioner’s proposed operations, such exemption should be 

granted in light of the mitigating fact that Petitioner will maintain the documents required 

under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control station during flights.

B. UAS Pilot in Command

Petitioner’s UAS pilot in command (PIC) will be Petitioner’s Managing Director, 

Owner, CEO, and Special Missions Pilot, Joseph Hovelman. Mr. Hovelman has over 23 

years of experience in the aviation industry as a research and chief pilot, director of flight 
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operations, and project manager. Mr. Hovelman’s responsibilities have included 

management of domestic and international flight operations utilizing fixed wing aircraft, 

helicopters, pilots, and mechanics. Mr. Hovelman has been responsible for experimental 

research modifications of aircraft helicopters and marine survey vessels, and has served 

as Chief Pilot for production level wide area assessment and UXO data collection survey 

flights throughout North America. In addition, Mr. Hovelman has served as Chief Pilot 

for projects conducted on behalf of the National Aeronautics and Space Administration 

(“NASA”), the U.S. Department of Energy, U.S. Air Force, U.S. Navy, Stanford 

Research Institute & University, as well as several other public agencies and private 

companies. Highlights of Mr. Hovelman’s training and certifications include:

• Airline Transport Pilot, Multi Engine Land, Commercial Privileges with 

Instrument Rating:

 Type rated in JS-3101/02, 850 Hrs.

 Pilatus PC-12, 1700 Hrs.

 King Air B200/C12, 600 Hrs.

 Queen Air B80, 400 Hrs. 

 Cessna C-208 Caravan, 2,000 Hrs.

 Cessna 152/172/182/206/210/337

 SR-22 Cirrus GTS, 100 Hrs.

 Multiple other aircraft;
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• 5,500 Flight hours of survey, research and development and experimental 

test pilot experience;

• Department of Defense Secret Security Clearance, United States 

Government – Current; and

• Multiple professional pilot courses, initial and recurrent, Flight Safety 

International ProCard, SimCom Int.

Highlights of Mr. Hovelman’s pertinent experience include:

• Director of Flight Operations/Chief Pilot on multiple simultaneous projects 

with multiple aircraft and pilots;

• Project execution and oversight as Chief Pilot/Director of Marine and 

Flight Operations USACE specific projects, such as Ortho/LiDAR, 

HeliMag, SAR Radar, and MarineMag;

• Flown hundreds of missions and millions of acres of Ortho/LiDAR, P-Band 

SAR, Hyperspectral and Thermal data collection flights;

• Managed and flew as lead research pilot over 50 NASA missions involving 

pollution studies, forest fire mapping, and UAV electronics testing and 

development; and

• Systems design lead on multiple airborne, ground, and marine platforms.

Additionally, 100% of Petitioner’s operations will utilize a visual observer 

(“VO”). The VO may be used to satisfy the VLOS requirement as long as the PIC 
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always maintains VLOS capability. The VO and the PIC will be able to communicate 

verbally at all times during operational flights.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner 

will comply with the other applicable procedures and requirements stated in § 91.103(a) 

and (b). Specifically, the PIC will take all actions including reviewing weather, flight 

battery requirements, aircraft performance data, and landing and takeoff distances before 

initiation of a flight. The PIC will also account for all relevant site-specific conditions in 

their preflight procedures. Risks presented by sun glare will be mitigated by the PIC’s 

and VO’s ability to see other air traffic and initiate a return-to-home sequence if needed.

C. Operating Parameters of Petitioner’s UAS

Petitioner’s UAS operations will be conducted within a predetermined, access 

controlled environment. In this controlled environment, Petitioner’s operations will 

remain within VLOS of the PIC and/or VO, below 400 feet AGL, and at speeds below 50 

knots. Flights will be operated at a lateral distance of no less than 100 feet from any 

inhabited structures, buildings, vehicles, vessels, or nonparticipating persons. The UAS 

will operate in accordance with the safety and operational requirements of the FOPM. 

Prior to the operation, a Safety Risk Analysis Plan (“SRAP”) will be created which 

includes all safety and operational information necessary to safely carry out the flight. 

When applicable, all UAS operations will be conducted in accordance with any state or 

local privacy laws.
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Only participating persons will be permitted within the operating area.2 As to 

Petitioner’s filming operations, and consistent with the relief typically provided to 

manned operations under FAA Order 8900.1, Volume 3, Chapter 8, Section 1, Petitioner 

requests relief from 14 C.F.R. § 91.119(c) with respect to those participating persons, 

vehicles, and structures directly involved in the performance of the actual filming. 

Regarding distance from participating persons, the operations manual sets forth safety 

factors for authorized and consenting production personnel. Because those procedures 

are specific to participating persons, no further FSDO or aviation safety inspector 

approval is necessary for reductions to the distances specified in Petitioner’s manual.

Although Petitioner seeks to comply with the waiver process as described in FAA 

Order 8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion 

Picture and Television Filming), the current section of Order 8900.1 has specific 

processes that preclude a jurisdictional FAA FSDO from issuing the required Certificate 

of Waiver, because the section did not originally provide for UAS operations. Thus, 

Petitioner seeks exemption from the applicable regulations normally waived during that 

process. Petitioner proposes that the FAA include the required notifications and 

coordination with jurisdictional FSDOs through the conditions and limitations 

accompanying the requested exemption, and that the exemption sought herein will take 

 2 Pursuant to Order 8900.1 V3, C8, S1, as applicable to aerial filming operations, 

“participating persons” includes all persons associated with the production. Participating 

persons will be briefed on the potential risk of the proposed flight operations and must 

acknowledge and accept those risks prior to participation.
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the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 

8900.1. Under this rubric, for aerial filming operations, Petitioner will notify every 

FSDO with jurisdiction over the area that Petitioner plans to operate, just as with manned 

filming operations, and those FSDOs will have the ability to coordinate further conditions 

and limitations with the UAS Integration Office to address any local concerns.

Petitioner’s UAS will remain clear and yield the right of way to all manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, and hangliders). Petitioner will not conduct 

UAS operations within 5 nautical miles of the geographic center of a non-towered airport 

unless a letter of agreement with that airport’s management is obtained and the operation 

is conducted in accordance with a Notice to Airmen (“NOTAM”).

Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of 

Waiver or Authorization (“COA”) prior to conducting any operations under this grant of 

exemption. In fulfilling its requirements under the COA, Petitioner will be required to 

request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to 

the operation.

D. The Requested Exemption Promotes the Public Interest

The enhanced safety achieved by replacing significantly larger manned aircraft 

carrying crew and flammable fuel with small UAS carrying no passengers or crew and 

operated under the specific guidelines and procedures proposed by Petitioner gives the 
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FAA good cause to find that the UAS operations enabled by the instant Petition are in the 

public interest. Moreover, as the FAA has already recognized, UAS provide “a greater 

degree of flexibility, which supplements the current capabilities offered by manned 

aircraft.” See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 22.

By granting Petitioner’s requested exemptions, the FAA will help drive 

development of safe and successful commercial UAS operations and will advance the 

public knowledge base for such operations. Petitioner is committed to promoting the 

UAS research efforts of policymakers including the FAA, NASA, and DOD by sharing 

data from its commercial UAS operations and serving as a resource for future UAS 

research operations. Thus, the FAA has good cause to grant this Petition.

VI. CONCLUSION

For the foregoing reasons, the exemptions requested herein should be granted and 

Petitioner should be permitted to conduct small UAS operations in accordance with its 

manuals and any other operating parameters the FAA deems necessary and appropriate.

Respectfully submitted,

BUCHALTER NEMER

A Professional Corporation

By

Paul J. Fraidenburgh

Counsel for Petitioner

Mountain High Aviation, LLC