Willow Marketing Management, Inc.

T: 317

-257

-5225 TaylorBussick@willowmarketing.com July 18, 2015 U. S. Department of Transportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act

and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Siror Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Willow Marketing Management, Inc. (Willow Marketing), operatorof Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial videography and photographyforthe public and private motion picture, television, and commercial videography industryforclosed setfilming, as well as land surveying, architecture, real estate and other related professional activities, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.2 As described more fully below, the requested exemption would permit

the operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in the NAS that is 1) limited 2) predetermined 3) controlled as to access. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation’s (the FAAAdministrator’s) responsibilities to “...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system.” Section 333(c) ofthe Reform Act. The name and address ofthe applicant is:

Willow Marketing, Inc. Attn: Taylor Bussick & Brad Gillum Ph: 317

-257

-5225 Email: taylorbussick@willowmarketing.com or bradgillum@willowmarketing.com Address: 3590 N Meridian St. Indianapolis, IN 46208 Regulations from which the exemption is requested: 14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportation to considerwhether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine3 which types of UASs do not create a hazard to users ofthe NAS orthe

public or pose a threat to national security in light ofthe following:

• The UAS’s size, weight, speed, and operational capability;

• Operation ofthe UAS in close proximity to airports and populated areas; and

• Operation ofthe UAS within visual line ofsight ofthe operator.

Reform Act § 333 (a). Lastly, ifthe Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added). The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section or any sections 44702

-44716 ofthis title ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). Willow Marketing’s sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. Theywill operate only in line ofsight and will operate onlywithin a predetermined and closed off property area underthe permission ofthe proper ty representative. Such operations will insure that the sUAS will “not create a hazard to users ofthe national airspace system orthe public” as perthe Reform Act Section 333 (b).4 Given the small size ofthe sUASs involved and the restricted sterile

environment within which theywill operate, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the cleardirection in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and commercial videography operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafety to operations underthe current regulatory structure because the proposed operations are conducted on closed off property underthe permission ofthe property owner or property representative. These limitations and conditions to which Willow Marketing agrees to be bound when conducting commercial operations under an FAA issued exemption include: 1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa pilot and/orobserver. 3. Maximum total flight time for each operational flightwill be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto the 30 minute limit. 4. Flights will be operated at an altitude of no more than 400 feetAGL or, not more than 200 feet above an elevated platform from which5 filming is planned. Ifa structure being surveyed or photographed has

a height which exceeds 400 feetAGL, the UAS will not exceed 100’ in height above the highest point on that structure. 5. Minimum crewfor each operation will consist ofthe sUAS Pilot, and the Visual Observer. 6. sUAS Pilotwill be Pilot in Command (PIC). Ifthe PIC deems another operatorto be qualified with the necessary skills to be PIC, that person can also be designated as PIC provided they have a minimum of25 hours offlight time with the sUAS. 7. Flights will be operated at a lateral distance ofat least 100 feetfrom any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation orwho have not signed a waiver in advance ofthe operation. 8. PIC must hold either a private, recreational, orsport 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 ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. (The PIC requesting exemption is currentlyfinishing up his flight school and acknowledges that no commercial sUAS flights will be conducted until the date of receiving his Sport Pilot Certification. This is set to be completed 8/25/2015.) 9. A briefing will be conducted in regard to the planned sUAS operations priorto each day’s production activities. Itwill be mandatory that all personnel involved with the operational duties ofthe flightwithin the boundaries ofthe safety perimeter be presentforthis briefing. 10. The operatorwill file an FAA Form 7711

-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate local Flight Standards District Office.6 11. The operatorwill obtain the consent ofall persons involved in the

filming and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and this radius may be reduced to 30 feet based upon an equivalent level ofsafety determination. With the advanced permission ofthe relevant FSDO, operations at closer range can be approved. 12. Pilot and observerwill have been trained in operation of UAS generally and received up-to

-date information on the particular UAS to be operated. 13. Observer and pilotwill at all times be able to communicate byvoice, radio, and/ortext.

14. Written and/ororal permission from the relevant property holders or property representatives will be obtained.

15. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

16. Ifthe sUAS loses communications or loses its GPS signal, the sUAS will have the capability to return to a pre-determined location within the Security Perimeter and land autonomously.

17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

**14 C.F.R.**  **Part 21,**  **Subpart H:**  **Ai rw** **orthiness Certificates**  **14 C.F.R.**  **§91.203 (a)**  **(1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 217 Subpart H meets the requirements ofan equivalent level ofsafety under

Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusivelywithin a secured area. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load. **14 C.F.R.**  **§ 45.23**  **(b). Marking**  **of the**  **Ai rcraft**  The regulation requires: 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, the8 words "limited," "restricted," "light

-sport," "experimental," or "provisional," as

applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size ofthe sUAV, two

-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafetywill be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAVwill see the identification ofthe UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. **14 C.F.R.**  **§ 61.113**  **(a) &**  **(b): Private**  **Pilot Privileges**  **and Limitations:**  **Pilot in**  **Command.** Sections 61.113 (a) & (b) Willow Marketing seeks exemption from 61.113 so that it’s PIC may hold a sport pilot’s certificate instead of a commercial pilot’s certificate. In Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot’s certificate operating the Astraeus UAS would “not adversely affect operations in the NAS or present a hazard to persons or property on the ground”. Willow Marketing’s safety training provides an equivalent level of safety and potentially helps exceed current safety levels when compared to manned aerial flights. The knowledge Willow Marketing has about UAS operations is relevant and supplements the safety awareness the PIC learns from getting a sport pilot certificate. Willow Marketing provides safety and education through the use of the safety operations manual, pre flight safety checks and proper care for it’s UASs.

**14 C.F.R.**  **§91.7(a): Civil**  **aircraft airworthiness.**  The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraftfor maintenance and use ofsafety check lists priorto each flight, as9 setforth in Sections J, L and Q, an equivalent level ofsafetywill be

provided. **14 C.F.R.**  **§ 91.9**  **(b) (2):**  **Civil Ai** **rcraft Flight**  **Manual in**  **the Ai** **rcraft.** Section 91.9 (b) (2) provides:

No person may operate a U.S.

-registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, 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. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafetywill be maintained by keeping the flight manual at the ground control pointwhere the pilotflying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. **14 C.F.R.**  **§ 91.103:**  **Preflight action**  This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. **14 C.F.R.**  **§ 91.109:**  **Flight instruction** : Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fullyfunctioning dual controls.10 sUASs and remotely piloted aircraft, by their design do not have fully

functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions forflight training withoutfullyfunctional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. **14 C.F.R.**  **§ 91.119:**  **Minimum safe**  **altitudes** Section 91.119 establishes safe altitudes foroperation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feetAGL, the UAS will not be operated more than 100' above the highest point on the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafetywill be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flightwill be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low

-altitude operations of the sUAS will ensure separation between these small

- UAS operations and11 the operations ofconventional aircraftthat must complywith Section

91.119. **14 C.F.R.**  **§ 91.121**  **Al timeter**  **Settings** This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set “...to the elevation of the departure airport or an appropriate altimetersetting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safetywill be achieved by the operator, pursuant to the safety checklist and live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. **14 C.F.R.**  **§ 91.151(a):**  **Fuel Requirements**  **for Flight**  **in VFR**  **Conditions** Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane underVFR 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 afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes.” The battery powering the sUAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame forflight in daylight ortwilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility forwhich the exemption will be granted.12 Applicant believes that an equivalent level ofsafety can be achieved by

limiting flights to 30 minutes or25% of battery power
—whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to otheroperations, including Exemptions 2689F, 5745, 10673, and 10808. **14 C.F.R.**  **§91.203 (a)**  **and (b):**  **Carry ing**  **Civil Ai** **rcraft Certification**  **and Registration**  The regulation provides in pertinent part: (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.

. . . (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. The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto display them on the sUAS. An equivalent level ofsafetywill be achieved by keeping these documents at the ground control point where the pilotflying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 C.F.R.**  **§ 91.405**  **(a); 407**  **(a) (1);**  **409 (a)**  **(2); 417(a)**  **& (b):**  **Maintenance Inspections**  These regulations require that an aircraft operatororowner “shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis13 chapter...,” and others shall inspect or maintain the aircraft in compliance

with Part 43. Given that these section and Part 43 apply only to aircraftwith an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level ofsafetywill be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feetAGL. The operatorwill ensure that the UAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. An equivalent level ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual. As provided in the Operations Manual, the operatorwill ensure that the UAS is in working order priorto initiating flight and perform required maintenance needed.

**Ad ditional**  **View s**  **and Information**  As a full

-service marketing agency based in Indianapolis, Willow works with clients across the country

. Aerial videography a growing client need and terrific addition to our existing video production services. Although other agencies and individuals are using drones to capture and sell aerial footage today, our agency is seeking to launch the service offering ofaerial videography in compliance with FAA regulations. Willow Marketing is also poised to be a local advocates forsafe, legal and compliant commercial aerial videography. We are willing to invest time and effort to educate and inform the public about the value of FAA compliance, particularly among the commercial aerial videography. There are certainly important distinctions between hobbyists and qualified,14 commercial UAS operators. We believe it is important to be a resource for

those who are seeking similar commercial exemptions for UAS operators.

********* Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in motion picture, television, and commercial videography operations. Approval ofexemptions allowing commercial operations ofsUASs in the film industrywill enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, operate at extremely low altitudesjustfeetfrom the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of4,000lbs., carrying large amounts ofjetA or otherfuel (140 gallons forjet helicopters.) Such aircraft mustfly to and from the film location. In contrast, a sUAS weighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the film set. The sUAS will carry no passengers orcrew and, therefore, will not expose them to the risks associated with manned aircraftflights. The operation ofsmall UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant ofthe exemptions requested herein, including exempting the applicantfrom the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds,15 close to the ground, and in a sterile environment and, as a result, are far

saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. **Privacy** All flights will occurover private or controlled access propertywith the property representative or owner’s prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. All flights will occur in accordance with any state or local laws regarding privacy. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012

--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security

– provide more than adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant’s UAS in the motion picture, television, and commercial videography industry.

Sincerely,

Taylor Bussick Willow Marketing Management, Inc. Lead UAS Operator (PIC) Brad Gillum Willow Marketing Management, Inc. CEO/Owner