Ry

ka Communications, LLC (dba Ry ka UAS) 918 South Horton Street Suite 1002 Seattle, WA 98134 Phone: (425) 757
-2376 Fax: (206) 260
-7930 June 10, 2015 U.S. Department ofTransportation (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 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, Ry ka Communications, LLC (dba Ry ka UAS), an operator ofUnmanned 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 ofits UAS’s. Ry ka Communications, LLC (dba Ry ka UAS) requested exemption would permit the operation ofUAS’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
. Ry ka Communications, LLC (dba Ryka UAS) believes that an exemption in the telecommunication industry would enhance safety and fulfill the Secretary ofTransportation’s (The FAA Administrator’s) responsibilities to establish safe operations ofthe UAS’s. According to Wireless Estimator, since 2003 there have been a total of 118 structure fatalities, not including structure related injuries. The Ry ka Communications, LLC (dba Ry ka UAS) mission is to provide safer structure services to the telecommunication industry
. With Ry ka Communications, LLC (dba Ry ka UAS) UAS’s, we will be able to provide services that would limit the need ofa structure climber, which will save lives. Through Ry ka Communications, LLC (dba Ry ka 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 Ry ka Communications, LLC (dba Ry ka UAS) will prevent climbers from making unnecessary climbs and keep climbing purposes to installation/repair. The purpose ofthis 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. Ry ka Communications, LLC (dba Ry ka UAS) UAS’s will be flown to provide aerial photos and video record communication facilities and structures
.Ry

ka Communications, LLC (dba Ry ka 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 ty pically be analy zed 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 Ry

ka Communications, LLC (dba Ry ka 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 ofnearby aircraft. Ry ka Communications, LLC (dba Ry ka 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 nam** **e and** **mailing address**  **and, if**  **you wish, other**  **contact information**  **such as a** **fax number,**  **telephone number,**  **or e** **- mail** **address;** Roger Smith Ry ka Communications, LLC (dba Ry ka Communications, LLC (dba Ry ka 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@ry

ka uas.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 ofmarks; 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 Ry ka Communications, LLC (dba Ry ka 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**  Ry ka Communications, LLC (dba Ry ka 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. Ry ka Communications, LLC (dba Ry ka 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 Ry

ka Communications, LLC (dba Ry ka UAS) will be using at cellular locations across the country, we are seeking exemption to the airworthiness certification process. Ry ka 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) ofthis petition. Ry ka Communications, LLC (dba Ry ka UAS) seeks exemption from 14 C.F.R. 45.23, which discusses the display ofmarks. Specifically, section 45.23 states, “(a) each operator ofan aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number ofthe aircraft. Each suffix letter used in the marks displayed mustalso 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”. Ry ka Communications, LLC (dba Ry ka UAS) will need exemption from this regulation due to the small size ofthe aircraft and that there is no cabin, cockpit, or pilot station for the aircraft. Ry ka Communications, LLC (dba Ry ka 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) ofthis section, no person who holds a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employ ment if: (1) The flight is only incidental to that business or employ ment; 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 ofthe 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 ofa charitable, nonprofit, or community event flight described in §91.146, ifthe 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 oflogged 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 ofconducting a production flight test in a light
-sport aircraft intended for certification in the light
-sport category under §21.190 ofthis chapter, provided that

— (1) The aircraft is a powered parachute or a weight
-shift
-control aircraft; (2) The person has at least 100 hours ofpilot
in
-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 ofproduction flight testing, to include operations conducted under a special flight permit and any associated operating limitations”. Ry ka Communications, LLC (dba Ry ka UAS) is seeking exemption from this regulation, because Ry ka Communications, LLC (dba Ry ka 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
. Ry ka Communications, LLC (dba Ry ka 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 aflight, 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 ofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports ofintended use, and the following takeoffand landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoffand 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) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values ofairport 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 ofthe flight manuals the PIC will take all pre-flight actions, including reviewing weather, flight battery requirements, landing and takeoffdistances, and aircraft performance data before starting a flight. Ry ka Communications, LLC (dba Ry ka UAS) seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. Specifically, 91.105 states “(a) During takeoffand 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 ofthe 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 takeoffand 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. Ry ka 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 ofthe flight. Ry ka Communications, LLC (dba Ry ka 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 offixed, 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 offixed, dual controls may be used for flight instruction to conduct a flight review required by §61.56 ofthis 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 ofthe airplane, meets the requirements of§61.195(b), and has logged at least 25 hours ofpilot
-in
-command flight time in the make and model ofairplane; 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 safetypilot has adequate vision forward and to each side ofthe aircraft, or a competent observer in the aircraft adequately supplements the vision ofthe safety pilot; and (3) Except in the case oflighter
-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 offixed, dual controls ofthe 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 ty pe 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 ofthe aircraft”. Again, Ry ka Communications, LLC (dba Ry ka 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. Ry ka Communications, LLC (dba Ry ka 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 takeoffor 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 ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. (c) Over other than congested areas. An altitude of500 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) ofthis section, provided each person operating the helicopter complies with any routes or altitudes specificallyprescribed 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”. Ry ka Communications, LLC (dba Ry ka 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 ofthe structures to gather our information. Ry ka Communications, LLC(dba Ry ka 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 ofthat 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 altimetersetting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station

within the area prescribed in paragraph (a)(1)(i) ofthis 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 ofthe 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 ofthe minimum altitude in feet and add the appropriate number offeet 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 1,50028.41 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. Ry ka Communications, LLC (dba Ry ka 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 ofintended 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 ofintended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes”. Ry ka Communications, LLC (dba Ry ka UAS) UAS has a maximum flight time of25
-minutes, which is less than the 30
-minute reserve minimum. This reserve minimum would not even allow Ry ka Communications, LLC (dba Ryka UAS) UAS a chance to fly. In Ry ka Communications, LLC (dba Ry ka UAS) aircraft flight manual, the PIC is instructed to maintain flight until battery power reaches 25%. Ry ka Communications, LLC (dba Ry ka 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 any where in its already limited operating area. Ry ka Communications, LLC (dba Ry ka UAS) UAS will not be flown during night or late evening hours.
Ry ka Communications, LLC (dba Ry ka 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 ofthe applicable operations specifications issued under §21.197(c) ofthis chapter, appropriate sections ofthe air carrier manual required byparts 121 and 135 ofthis chapter containing that portion ofthe 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 ofthis 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 toan 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 ofthe 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) ofthis 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 ofthis chapter, and a copy ofFAA 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 ofpart 34 ofthis chapter”. Ry ka Communications, LLC (dba Ry ka UAS) believes that an appropriate and current airworthiness certificate would not be necessary to fly a UAS given the size ofthe aircraft and the necessary level of skill needed to operate the aircraft. Ry ka Communications, LLC (dba Ry ka UAS) seeks exemption from this regulation because we believe this rule was not meant for a UAS and operators. Ry ka Communications, LLC (dba Ry ka 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 Ry ka Communications, LLC (dba Ry

ka UAS) aircraft flight manual, maintenance and inspection procedures have been established for the aircraft. Ry ka Communications, LLC (dba Ry ka 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 Com** **munications, LLC (dba Ryka UAS) request**  **would be**  **in the** **public interest; that**  **is, how**  **it would**  **benefit the** **public as**  **a whole**  Ry ka Communications, LLC (dba Ry ka 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 Ry

ka Communications, LLC (dba Ryka UAS) use ofa UAS can assist in verifying that the components that make up that backbone are fully functional and in proper repair. Ry ka Communications, LLC (dba Ry ka 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 ofsafety that exceeds the level ofsafety required by the FAA for its use on UAS. The following are Ry ka Communications, LLC (dba Ry ka UAS) safetyprocedures, 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 ofUAS.  The UAS will also be in the Visual Line ofSight (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 of400 f eet 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 offlight so as to ensure that the UAS is in a condition for safe flight operation and in a configuration appropriate for the purpose ofthe intended flight.
 If there is more thanjust an operator at a site during a flight, the operator and observer(s) will maintain two
-way communication with each other during all operations; ifunable to maintain two-way communications, or ifany 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: Ry

ka Communications, LLC (dba Ry ka UAS)
Sections of14 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 ofReliefSought: Petitioner seeks relieffrom 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@ry kauas.com ifyou have any questions or concerns. Respectfully submitted, Roger Smith Field Operations Manager Ry ka Communications, LLC (dba Ry ka UAS)