Ryka Communications, LLC (dba Ryka UAS)

918 South Horton Street

Suite 1002

Seattle, WA 98134

Phone: (425) 757-2376

Fax: (206) 260-7930

June 10, 2015

U.S. Department of Transportation (DOT) Docket Operations, M-30

1200 New Jersey Avenue SE

Room W12-140, West Building Ground Floor Washington, DC 20590-0001

Re: Exemption Request

To whom it may concern,

In agreement with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Ryka 

Communications, LLC (dba Ryka UAS), an operator of Unmanned Aircraft System (UAS) primarily for cellular

structure and compound observation in the telecommunication industry, seeks an exemption from the Federal 

Aviation Regulations (FARs) to allow commercial operations of its UAS’s.

Ryka Communications, LLC (dba Ryka UAS) requested exemption would permit the operation of UAS’s under

controlled conditions in cellular structure airspace that is: (i) limited, (ii) predetermined, (iii) subject to

controlled access through our customers, and (iv) provides greater safety in connection with aircraft operations

in the telecommunication industry. Ryka Communications, LLC (dba Ryka UAS) believes that an exemption in

the telecommunication industry would enhance safety and fulfill the Secretary of Transportation’s (The FAA

Administrator’s) responsibilities to establish safe operations of the UAS’s.

According to Wireless Estimator, since 2003 there have been a total of 118 structure fatalities, not including 

structure related injuries. The Ryka Communications, LLC (dba Ryka UAS) mission is to provide safer structure

services to the telecommunication industry. With Ryka Communications, LLC (dba Ryka UAS) UAS’s, we will 

be able to provide services that would limit the need of a structure climber, which will save lives. Through 

Ryka Communications, LLC (dba Ryka UAS) UAS’s, we will be able to observe and acquire valuable data for

our customers that would otherwise be more expensive and hazardous to individuals. Using the UAS’s Ryka 

Communications, LLC (dba Ryka UAS) will prevent climbers from making unnecessary climbs and keep

climbing purposes to installation/repair. The purpose of this petition is to improve safety at the cellular locations

by eliminating structure climbing for visual/structure height measurement and pre / post inspections of installed 

equipment.

Ryka Communications, LLC (dba Ryka UAS) UAS’s will be flown to provide aerial photos and video record

communication facilities and structures.
Ryka Communications, LLC (dba Ryka UAS) UAS flights will also be used to photograph and record

wireless communications facilities (including but not limited to Monopoles, Self-Supporting Structures 

or Lattice tower, Mono-pine, Flagpole and other Stealth structures, ball field light standards, wood 

laminate, steel and similar utility poles, and building rooftops), utility structures, water tanks, and 

similar for inspections and potential future modifications, additions, or new greenfield locations and 

opportunities and other requirements as issued by our clients in the Wind, Energy, Telecommunications 

industries and for local municipalities and government agencies. 

Video data captured from the flights will generally be used (but not limited to) to assess current 

conditions and feasibility and typically be analyzed and reviewed for: any site damage including:

lightning strikes, FAA mandated structure strobe lights, shelter and cabinet roofs, ice bridge

infrastructure, coax cable tears and similar, general condition and structural feasibility.

For every flight that Ryka Communications, LLC (dba Ryka UAS) performs, all the above parameters

will be checked for the providers, consumers, and bystander’s safety concerns in mind. Most structures

are highly restricted areas and the potential for consumers or bystanders to be in the area is very low.

These structures are also highly restricted from any and all air traffic and have minimal to zero

likelihood of nearby aircraft.

Ryka Communications, LLC (dba Ryka UAS) will be using the following UAS platforms for the above 

list flights.

DJI S1000

DJI INSPIRE

DJI PHANTOM

TURBOACE MATRIX-E

H20QUAD

H20HEX

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

1: Your name and mailing address and, if you wish, other contact information such as a fax number,

telephone number, or e-mail address;

Roger Smith

Ryka Communications, LLC (dba Ryka Communications, LLC (dba Ryka UAS)

Field Operation Manager

Re: Exemption Request

918 South Horton Street

Suite 1002

Seattle, WA 98134

Phone: (425) 757-2376

Fax: (206) 260-7930

Email: rsmith@rykauas.com
2: The specific section or sections of 14 C.F.R. from which Ryka Communications, LLC (dba Ryka 

UAS)

seeks an exemption

 21 – Subpart H Certification procedures for products and parts, Airworthiness Certificates

 45.23 – Display of marks; general

 61.113 - Private pilot privileges and limitations: Pilot in command

 91.103 – Preflight Actions

 91.105 – Flight crewmembers at stations

 91.109 – Flight instruction; Simulated instrument flight and certain flight tests

 91.119 – Minimum safe altitudes: General

 91.121– Altimeter settings

 91.151– Fuel requirements for flights in Visual Flight Rules (VFR) conditions

 91.203 – Civil aircraft: certification required

 91.405 – Maintenance required

 91.407 – Operation after maintenance, preventative maintenance, rebuilding, and alteration

 91.409 – Inspections

 91.417 – Maintenance records

We believe an exemption from the above regulations will allow Ryka Communications, LLC (dba Ryka 

UAS) to conduct the needed work as described above.

3: The extent of relief Ryka Communications, LLC (dba Ryka UAS) seeks, and the reason Ryka 

Communications, LLC (dba Ryka UAS) seeks the relief

Ryka Communications, LLC (dba Ryka UAS) seeks an exemption for several provisions of 14 C.F.R. 

Parts 21, 45, 61, and 91 to the extent to operate small UAS’s around cellular structures and compound 

facilities.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 21, Subpart H, which

states the certification procedures for products and parts as well as airworthiness certificates. Due to the

limited airspace that Ryka Communications, LLC (dba Ryka UAS) will be using at cellular locations

across the country, we are seeking exemption to the airworthiness certification process. Ryka 

Communications, LLC (dba Ryka UAS) has developed our own training procedures and regulations to

promote and provide safe flying experiences for our PIC(s) which can be viewed in section (e) of this

petition.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 45.23, which discusses 

the display of marks. Specifically, section 45.23 states, “(a) each operator of an aircraft must display on

that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration)

followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must
also be a Roman capital letter (b) 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”. Ryka 

Communications, LLC (dba Ryka UAS) will need exemption from this regulation due to the small size

of the aircraft and that there is no cabin, cockpit, or pilot station for the aircraft.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 61.113, which discusses

private pilot privileges and limitations for the Pilot in command (PIC). Specifically, section 61.113 states

“(a) 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 aircraft 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 (c) A

private pilot may not pay less than the pro rata share of the operating expenses of a flight with 

passengers, provided the expenses involve only fuel, oil, airport expenditures, or rental fees. (d) A

private pilot may act as pilot in command of a charitable, nonprofit, or community event flight described

in §91.146, if the sponsor and pilot comply with the requirements of §91.146. (e) A private pilot may be

reimbursed for aircraft operating expenses that are directly related to search and location operations,

provided the expenses involve only fuel, oil, airport expenditures, or rental fees, and the operation is 

sanctioned and under the direction and control of: (1) A local, State, or Federal agency; or (2) An

organization that conducts search and location operations. (f) A private pilot who is an aircraft salesman

and who has at least 200 hours of logged flight time may demonstrate an aircraft in flight to a 

prospective buyer. (g) A private pilot who meets the requirements of §61.69 may act as a pilot in 

command of an aircraft towing a glider or unpowered ultralight vehicle. (h) A private pilot may act as 

pilot in command for the purpose of conducting a production flight test in a light-sport aircraft intended

for certification in the light-sport category under §21.190 of this chapter, provided that— (1) The aircraft

is a powered parachute or a weight-shift-control aircraft; (2) The person has at least 100 hours of pilotin-command time in the category and class of aircraft flown; and (3) The person is familiar with the

processes and procedures applicable to the conduct of production flight testing, to include operations

conducted under a special flight permit and any associated operating limitations”. Ryka 

Communications, LLC (dba Ryka UAS) is seeking exemption from this regulation, because Ryka 

Communications, LLC (dba Ryka UAS) believes that there is inconclusive evidence that a person with a 

private pilot certificate can successfully maneuver a UAS without first hand flight experience with the

particular UAS. Therefore, we believe our own flight training with the UAS will be more than 

satisfactory.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.103, which discusses

pre-flight actions. Specifically, section 91.103 states, “Each pilot in command shall, before beginning a 
flight, become familiar with all available information concerning that flight. This information must

include: (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any 

known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight,

runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) 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; and (2) For

civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information 

appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and

runway slope, aircraft gross weight, and wind and temperature”. An exemption is requested from

section 91.103, as FAA approved rotorcraft flight manuals will not be used. In the absence of the flight

manuals the PIC will take all pre-flight actions, including reviewing weather, flight battery requirements,

landing and takeoff distances, and aircraft performance data before starting a flight.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.105, which discusses

flight crewmembers at stations. Specifically, 91.105 states “(a) During takeoff and landing, and while en

route, each required flight crewmember shall (1) Be at the crewmember station unless the absence is 

necessary to perform duties in connection with the operation of the aircraft or in connection with

physiological needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each

required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, keep his

or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply

if (1) The seat at the crewmember's station is not equipped with a shoulder harness; or (2) The

crewmember would be unable to perform required duties with the shoulder harness fastened. Ryka 

Communications, LLC (dba Ryka UAS) will need exemption from this regulation due to the fact that the

UAS will not have a flight crew or crew stations other than the PIC. The PIC will also not have to be

restrained into a seat via shoulder harness or safety belt at the time of the flight.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.109, which discusses

flight instruction, simulated instrument flight, and certain flight tests. Specifically, 91.109 states “(a) 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. However, instrument flight instruction may be

given in an airplane that is equipped with a single, functioning throw over control wheel that controls the

elevator and ailerons, in place of fixed, dual controls, when (1) The instructor has determined that the

flight can be conducted safely; and (2) The person manipulating the controls has at least a private pilot

certificate with appropriate category and class ratings. (b) An airplane equipped with a single,

functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual

controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter,

or to obtain recent flight experience or an instrument proficiency check required by §61.57 when (1) The

airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the

controls is qualified to serve and serves as pilot in command during the entire flight; (3) The instructor is

current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b),

and has logged at least 25 hours of pilot-in-command flight time in the make and model of airplane; and 
(4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No

person may operate a civil aircraft in simulated instrument flight unless (1) The other control seat is

occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings

appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side

of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety

pilot; and (3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully

functioning dual controls. However, simulated instrument flight may be conducted in a single-engine

airplane, equipped with a single, functioning, throw over control wheel, in place of fixed, dual controls

of the elevator and ailerons, when (i) The safety pilot has determined that the flight can be conducted 

safely; and (ii) The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings. (d) No person may operate a civil aircraft that is being used for a 

flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part

121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is

fully qualified to act as pilot in command of the aircraft”. Again, Ryka Communications, LLC (dba 

Ryka UAS) believes that there is inconclusive evidence that a person with a private pilot certificate or 

license can successfully maneuver or train someone to use an UAS without first hand flight experience

with the particular UAS. Therefore, we believe our own flight training and first hand experiences with

the UAS will be satisfactory. Also, the UAS will be operated by a remote control, which will only

require a one-person operator and dual controls will not be necessary.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.119, which discusses 

minimum safe altitudes. Specifically, 14 C.F.R. 91.119 states “Except when necessary for takeoff or

landing, no person may operate an 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 settlement, 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 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. (d) Helicopters, powered

parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to persons or 

property on the surface— (1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or

weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) of

this section”.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from this regulation due to the fact that

cell structures are less than 500ft and we will be flying in close proximities of the structures to gather

our information.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.121, which discusses

altimeter settings. Specifically, 14 C.F.R. 91.121 states, (a) Each person operating an aircraft 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 route 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; or (2) At or above

18,000 feet MSL, to 29.92′′ Hg. (b) The lowest usable flight level is determined by the atmospheric 

pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the

pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate

number of feet specified below, according to the current reported altimeter setting:”

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500
28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

As our UAS does not have a barometric altimeter, but instead outputs GPS altitude data, an exemption is 

needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch

site shown on the GPS altitude indicator before and during the flight.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.151, which discusses

fuel requirements for flight in VFR conditions. Specifically, 91.151 states “(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. (b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes”. Ryka Communications, LLC 

(dba Ryka UAS) UAS has a maximum flight time of 25-minutes, which is less than the 30-minute

reserve minimum. This reserve minimum would not even allow Ryka Communications, LLC (dba Ryka 

UAS) UAS a chance to fly. In Ryka Communications, LLC (dba Ryka UAS) aircraft flight manual, the

PIC is instructed to maintain flight until battery power reaches 25%. Ryka Communications, LLC (dba 

Ryka UAS) believes the restraint issued in our aircraft flight manual achieves a satisfactory safety

standard to go by. This restriction would also be more than adequate to return the UAS to its home point

or pre-determined landing-zone from anywhere in its already limited operating area. Ryka 

Communications, LLC (dba Ryka UAS) UAS will not be flown during night or late evening hours.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.203, which discusses

civil aircraft required certifications. Specifically, 91.203 states “(a) Except as provided in §91.715, no

person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current 

airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph 

(except a special flight permit, a copy of the applicable operations specifications issued under §21.197(c)

of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this

chapter containing that portion of the operations specifications issued under §21.197(c), or an 

authorization under §91.611) must have on it the registration number assigned to the aircraft under part

47 of this chapter. However, the airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to the aircraft. A revised

airworthiness certificate having on it an assigned special identification number, that has been affixed to
an aircraft, may only be obtained upon application to an FAA Flight Standards district office. (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), or a registration 

certification issued under the laws of a foreign country. (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. (c) No person may operate an aircraft with a fuel tank installed within the passenger compartment

or a baggage compartment unless the installation was accomplished pursuant to part 43 of this chapter,

and a copy of FAA Form 337 authorizing that installation is on board the aircraft. (d) No person may

operate a civil airplane (domestic or foreign) into or out of an airport in the United States unless it

complies with the fuel venting and exhaust emissions requirements of part 34 of this chapter”. Ryka 

Communications, LLC (dba Ryka UAS) believes that an appropriate and current airworthiness

certificate would not be necessary to fly a UAS given the size of the aircraft and the necessary level of 

skill needed to operate the aircraft. 

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from this regulation because we believe

this rule was not meant for a UAS and operators.

Ryka Communications, LLC (dba Ryka UAS) seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409,

and 91.417, which discusses required aircraft maintenance, operation after maintenance, preventive

maintenance, rebuilding, or alteration, inspections, and maintenance records. In Ryka Communications, 

LLC (dba Ryka UAS) aircraft flight manual, maintenance and inspection procedures have been

established for the aircraft. Ryka Communications, LLC (dba Ryka UAS)

believes these regulations are meant for manned operated aircrafts and not unmanned systems, therefore

making them unnecessary.

Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it

necessary to grant this request.

(d) The reasons why granting Ryka Communications, LLC (dba Ryka UAS) request would be in

the public interest; that is, how it would benefit the public as a whole

Ryka Communications, LLC (dba Ryka UAS) is classified as a utility by the U.S. Department of

Transportation and provides services to the Wind/Energy, Telecommunications industries and local 

municipalities. These services have become a major backbone for nationwide 911 emergency

response and Ryka Communications, LLC (dba Ryka UAS) use of a UAS can assist in verifying that the

components that make up that backbone are fully functional and in proper repair. Ryka 

Communications, LLC (dba Ryka UAS) UAS usage in the wireless industry, we will be able to gather

valuable information to help increase safety and productivity. In addition, the UAS flights will minimize

the need for technicians to climb structures, putting fewer lives in danger. Ultimately, structure climbers

will still be needed to install structure equipment, but a UAS will decrease the amount of times a climber

will be needed.
(e) The reasons why granting the exemption would not adversely affect safety, or how the

exemption would provide a level of safety at least equal to that provided by the rule from which Ryka 

Communications, LLC (dba Ryka UAS)

seeks exemption

Our Engineering department will provide a level of safety that exceeds the level of safety required by the

FAA for its use on UAS. The following are Ryka Communications, LLC (dba Ryka UAS)

safety procedures, features, regulations, and operating specifications for our UAS:

 The Pilot In Command (PIC) and potential observers will be required to wear hard hats, safety

vests, and safety glasses to protect the head and eyes from potential mishaps during given

operational flights including training or testing of UAS.

 The UAS will also be in the Visual Line of Sight (VLOS) to both the PIC and potential observers

during all flights.

 Flights must take place during good weather conditions with no rain, low laying clouds, or heavy

winds. All flights will take place during daylight hours with no evening or late night flights.

 A visual safety inspection will occur before each flight.

 The UAS will be flown under a height of 400 feet AGL and unobstructed line of site.

 No operator or potential observer will engage in, nor may an operator or potential observer

permit, any activity during a critical phase of flight so as to ensure that the UAS is in a condition

for safe flight operation and in a configuration appropriate for the purpose of the intended flight.

 If there is more than just an operator at a site during a flight, the operator and observer(s) will

maintain two-way communication with each other during all operations; if unable to maintain

two-way communications, or if any condition occurs that may otherwise cause the operation to

be unsafe, the operator will immediately conclude the operation.

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which 

you seek the exemption; and (2) A brief description of the nature of the exemption you seek

Petitioner: Ryka Communications, LLC (dba Ryka UAS)

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109;

91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21 

Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 

91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct cellular structure and 

compound surveys for wireless providers on their properties and subject to operating procedures

that meet or exceed those that FAA requires.
(g) Any additional information, views or arguments available to support your request

Please see the introduction to this exemption request.

(h) If you want to exercise the privileges of your exemption outside of the United States, the

reason why you need to do so

The Operations described in this exemption request will be conducted wholly within the United 

States.

Please do not hesitate to contact me via email at rsmith@rykauas.com if you have any questions or

concerns.

Respectfully submitted,

Roger Smith

Field Operations Manager

Ryka Communications, LLC (dba Ryka UAS)