Ronald Lee Castle

802 Hannibal Street. A pt. 1 lower

Fulton NY, 13069

315

- 297

- 4622 ronald_castle@yahoo.com

June 20 , 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) And (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a ) ( 1); 14 CFR 91. 409 (a ) ( 1); 14 CFR 91.409 (a ) ( 2); 14 CFR 91.417 (a) and (b)

Dear Sir or Madam:

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Ronald Lee Castle

– iREEL Productions Hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial use of its Small Unmanned Aircraft Systems (SUASs), so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Ronald Lee Castle

– iREEL Productions is requesting this exemption because

- ( 1) existing regulations will severely hinder and burden iREEL Productions (her eafter to be

referred to as iREEL Productions ) (2) iREEL Productions can provide and execute a level of PIC competence and safety that is, at the very least, equal to (or greater than in many cases) to those provided by existing guidelines, and (3) the request is in the public interest and local benefit. The FAA’s authorit y to issue exemptions from operating rules, and the Secretary’s authority granted by Section 333 of P.L. 112

- 95, Special Rules for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain SUAS operations in the National Airspace Syste m (NAS) prior to implementationof the SUAS rule. This incremental step will allow iREEL Productions / Ronald Lee

Castle to safely and legally enter into the NAS.

The requ ested exemption will permit iREEL Productions / Ronald Lee Castle to operate

its SUAS under closely monitored conditions in airspace that is confined/limited (<300 meters in any direction and <100 meters altitude), predetermined and agreed upon, controlled to access and would provide safety enhancements to the already safe operations of those aircraft of similar size, weight, speed, and operating capability that have been granted entry into the NAS via the rules in Academy of Model Aeronautics (AMA) National Aircraft Safety Code. Approval of this exemption would thereby greatly

enhanc e safety and fulfill the Secretary of Transportation’s (the Secretary) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system” per Section 333 (c) of the Reform Act.

Ronald Lee Castle / iREEL Productions is requesting exemption from the following regulations:

14 CFR Part 21, Subpart H 14 CFR 61.23 (a) 14 CFR 61.113 (a) and (b)

14 CFR 91.109

14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a ) ( 1) 14 CFR 91.409 (a ) ( 1) 14 CFR 91.409 (a ) ( 2) 14 CFR 91.417 (a) and (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary to consider

whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rule

- making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not

create a hazard to users of t he NAS, to the public, or pose a threat to national security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned aircraft system, as a result of its size, weight, speed, operational capability, proximity to airport s and populated areas, and operation within visual line of sight (VLOS) does not create a hazard to users of the NAS or the public or pose a threat to national security, and (2) whether a certificate of waiver, certificate of authorization, or

airworthines s certification under 49 USC 44704 is required for the operation of civil (non

- governmental) UASs. Therefore, if the Secretary determines that such vehicles“may operate safely in the national airspace system, the Secretary shall establish

requirements for the safe operation of such aircraft in the national airspace system”.

iREEL Productions Overview

iREEL Productions uses small UAS (quad

- copters) weighing less than 6 lbs fully loaded (camera and battery). Quad

- copters are small, agile UASs with the abili ty to hover and move in the vertical and horizontal planes simultaneously. iREEL Productions will operate only in visual line of sight (VLOS), and only in tightly controlled and limited airspace. The UASs are capable of operating at speeds of up to 29 knot s, but are routinely operated at much lower speeds, usually at a standstill for imaging. They are most frequently operated below 200 feet above ground level (AGL), and never over 400

feet AGL. iREEL Productions exemption request would permit a commercial operation of SUAS for aerial photography and videography in tightly controlled and limited airspace. Aerial photography and videography services will be offered to homeowners, realtors, home builders, ranchers and farmers and/or home inspectors for use in, but not limited to, real estate marketing and safer inspections of home exteriors. All operations will be conducted on private property and with the written and/or oral permission of the property owner(s), and always with privacy in mind. Operations will always be conducted in areas that are clear of all people, except the pilot in command (PIC) and the PIC’s helper(s). Such operations will ensure that the SUAS will “not create a hazard to users of the national airspace system or the public”.

Our Aircraft

iREEL Productions operates and uses the YUNEEC Typhoon Q500 +

.

AirCraft specs

o Flight Time Up to 25 Minutes

o Dimension 16.5x16.5x9.5in (420x420x240mm)

o Diagonal Length Without Rotor Blades 22.2in (565mm)

o Propeller/Main Rotor Diameter 13.0in (330mm)

o Weight Without Battery and Payload 40.0oz (1130g)

o Battery 5400mAh 3S 11.1V LiPo (included)

o Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)

o Transmitter

10

- channel 2.4GHz with 5.8GHz video downlink (included)

o 3 Flight Modes Smart, An gle and Home Modes

o Maximum Flying Height Default 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI)o Maximum Rotation Rate

65°/s

o Maximum Roll Angle

35°

o Operating Temperature Range

- 5 °C to 80 °C

Our Aircraft (continued)

The Yuneec Typhoon Q500+ Quadcopter has multiple safety features programmed in to its APM flight control system. These features serve to minimize any risk posed by loss of control, loss of transmission signal or loss of orientation. These features include, but

are not limited to:

• GPS controlled positioning allows the UAS to "know" its location, attitude and altitude.

• RTH (return to home) when triggered, will bring the Typhoon back and land it autonomously in the event the PIC is unable to do so.

• FAILSAFE will return the UAS and land it autonomously should the control transmission get cut off for any reason.

• GEOFENCE allows the PIC to set a virtual "fence", or boundaries that the Typhoon cannot cross. By default, it is 300 meters lineal and 125 meters vertical. Cross ing this boundary will automatically trigger the RTH feature.

These highly advanced capabilities will ensure that the SUASs can be safely operated and “not create a hazard to users of the national airspace system or the public.”

Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the world and to minimize the risk to the NAS or to persons and property on the ground, iREEL Productions agrees to be bound by the following limitations and conditions when conducting commercial operations under a FAA issued exemption:

A. For the purposes of ensuring SUASs will be operated within the standards that the FAA has allowed in the AMA National Model Aircraft Safety Code:

1. SUASs will not be flown:

a. In a careless or reckless manner.

b. At a location where SUAS activities are prohibited.2. SUAS pilots will:

a. Yield the right of way to all human

- carrying aircraft.

b. See and avoid all aircraft and a spotter must be used when appropriate

(Continued on next page)

c. Not fly higher than 400 feet above ground level or within three (3) miles of an airport without notifying the airport operator.

d. Not interfere with operations and traffic patterns at any airport, helipo rt or seaplane base except where there is a mixed use agreement.

e. Not exceed a takeoff weight of 55 pounds (including payload).

f. Ensure the aircraft is identified by affixing the owner’s contact

information to the outside of the SUAS.

g. No t operate SUASs while under the influence of alcohol or while using

any drug that could adversely affect the PIC’s ability to safely control the

model.

h. Not operate SUASs carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property.

3. SUASs will not be flown unless:

a. The aircraft, control syst em and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific

event.

b. An inexperienced pilot is assisted by an experienced pilot.

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.

5. A successful radio equipment ground

- range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model aircraft.6. SUASs must use the radio

- control frequencies currently allowed by the Federal

Communications Commission (FCC).

7. SUASs will not knowingly operate within three (3) miles of any pre

- existing flying

site withou t a frequency

- management agreement.

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet to any individual, except for the PIC and the PIC's helper(s) located at the

takeoff site

.

9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still under power, except to divert it from striking an individual.

10. The PIC of the SUAS shall:

a. Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot.

b. Fly using the assistance of a camera or First

- Person View ( FPV) only in accordance with the procedures outlined in AMA Document #550.

c. Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560.

11. The flying area must be clea r of all utility wires or poles and an SUAV will not be flown closer than 50 feet to any above

- ground electric utility lines.

12. The flying area must be clear before the engine is started, except for PIC and the
spotter.

In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in an effort to enhance the safety offered by the already safe operations
mentioned above, iREEL Productions also agrees to be bound by the following

limitations and conditions:

1. Flights will be operated within VLOS of the PIC.

2. Maximum total flight time for each operational flight will be 18 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 18

minute limit.

3. The SUAS will only operate in tightly controlled and limited airspace.4. A briefing will be conducted in regard to the planned SUAS operations prior to

each flight. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS and received up

- to

- date information on the particular SUAS to be operated.

6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice.

(Continued from page 6)

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to return to a pre

- determined location within the security perimeter and safely land.

8. The SUAS wil l have the capability to abort a flight in case of unpredicted obstacles or emergencies.

9. All flights will be conducted on private property and with the written and/or oral permission of the property owner(s).

10. Flights will always be conducted in areas that are clear of all people, except for the PIC and the PIC's helper(s).

11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during severe weather conditions.

12. Flights w ill not occur in weather conditions that prevent the PIC from operating

within visual line

- of

- sight (VLOS) at all times or in weather conditions that dramatically affect the UAS’s flight (e.g. high winds).

13 . If an operation occurs in an area where people could inadvertently enter the area, an operational border will be established with traffic cones. If it’s not

Feasible to use traffic cones due to interference with the photography/videography, the PIC's helper (s) will be responsible for keeping a safe perimeter around the operation.

The operation will cease immediately and be rescheduled if it’s impossible to establish a safe perimeter around the operation.

14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative maintenance plan can be followed, as described in the “Preventative

Maintenance” section below.15. The SUAS will not be routinely operated in the proximity of any airports. In any

cases where the SUAS must be operated within three (3) miles of an airport, the airport operator will be notified before the operation commences. The operation of SUASs, weighing less than 6 lbs., conducted in the strict conditions as outlined above, will

provide an equivalent level of safety supporting the grant of exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlle d environment. As a result, they offer a much safer way to capture aerial photography and videography. Furthermore, the proposed operations represent a safety enhancement to the already safe operations that have been granted by the FAA for the establishmen t of the AMA National Model Aircraft Safety Code. Preflight Action Plan

The PIC will follow a comprehensive pre

- flight checklist to ensure that the SUAS is in a condition for safe flight. This plan will be improved as needed in order to ensure all

known safety precautions and/or safety precautions suggested by the manufacturer are being accounted for.

A. Pre

- flight Inspection

1. Check that the remote control, Yuneec Typhoon 1 battery (s ), ST

- 10+ 5.5" Android touch screen personal ground station , Bluetooth GCS and smartphone are all fully charged.

2. Visually inspect the LIPO batteries for signs of wear or damage. Check both battery switches for proper operation.

3. Turn the motor shafts with your fingers and verify they are smooth without

exce ssive play or binding.

4. Verify that the rotation diagram on the propellers matches the rotation diagram on

the Typhoon arms.

5. Inspect the propeller edges for nicks or cuts.

6. Flex both side of the propellers’ blades to check for hairline cracks where the blades connect in the center of the propeller.

7. Verify that the landing gear is secure (not cracked/broken/loose).

8. Verify that the retractable landing gear is func tioning smoothly.9. Verify that the Micro

- SD card has been inserted and formatted.

10. Verify that the damping absorbers are not broken and/or worn.

11. Arm/Disarm motors three separate times to allow GPS to lock on the launch site.

12. Inspect the gimbal and camera for smooth operation.

13. Verify all trims and switches set at "0".

14. Verify video connection between the Typhoon and the ST

- 10+ 5.5" Android touch screen personal ground station

.

15. Perform final area check for obstructions.

Preventative Maintenance

A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS’s software is up

- to

- date, the batteries are in good health, and the aircraft itself is always ready for safe flight

.

Pilot in Command (PIC) Qualifications

The PIC does not hold an airman certificate or medical certification. Since the SUAS is similar in size, weight, speed and operating capability as those currently allowed to be flown for hobby/recreation, holding the PIC to those same set of standards will all ow for an equivalent level of safety.

The PIC has over 20 years’ experience in piloting RC/UAS craft, and has been an instructor to many students, a few of which were pilots. Because the PIC is not actually in the aircraft, quick reflexes, manual dexteri ty and computer knowledge is more important to safely piloting the UAS than an airman certificate.

It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre

- approved airspace.Since there are no standards for either private or commercial SUAS pilot certificates,

knowledge of airspace regulations and dexterity in the control and operation of the SUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. With that in mind, iREEL Productions

proposes that its PIC be required to do the following prior to the first commercial operation (NoteThese are mostly the same requirements proposed by Singer's Creations in their successful request for exemption. iREEL Productions believes that these requirements are an excellent start to ensure the PIC is qualified to

ope rate safely ):

1. Perform 20 flights or log 20 hours of flight time (the greater of the two) with the Typhoon

.

2. Successfully learn and demonstrate all flight maneuvers in the Typhoon manual.

3. Study and be familiar with all sections of the “ Typhoon’s us er manual”.

4. Study and be familiar with all sections of the “ ST

- 10+ 5.5" Android touch screen personal ground station manual".

5. Study, be familiar with, and demonstrate (where possible) the “Always be Prepared for the Worst” scenarios.

Public Interest

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent level of safety, a reduction in environmental impacts, and are free from the harmful emissions associated with the manned aircraft that are currently use d for aerial photography and videography. Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this application presents no risk to the public. Furthermore, the public will be able to legal ly acquire aerial photography and videography to help in, but not limited to, advertising homes for sale, advertising uninhabited home lots, use of photos and video as an aid when researching homes for sale on the market, or safely accessing high and/or aw kward areas of a home’s exterior to assess damage that needs to be repaired.Privacy

Since the areas being photographed or filmed will be on private property, accessed only after given written and/or oral consent by the property owner(s), and clear of all people, except for the PIC and the PIC's helper(s), approval of this application presents no risk to the public privacy. In addition, iREEL Productions will honor all requests for "no

- fly

zone".

National Security

Due to the size of the SUAS and the tight ly controlled and limited airspace in which the SUAS will operate, approval of this application presents no risk to national security.

Requested Exemptions

Ronald Lee Castle / iREEL Productions requests exemption from the following regulations since it’s not possible to fully comply with them, and attempting to follow them for the purposes of operating a SUAS would be a burden:

(Continued on next page)

Airworthiness Certificates 14 CFR Part 21, Subpart H Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by Singer’s Creations, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular SUAS. In all cases, an analysis of these criteria demonstrates that the SUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed.

Medical certificates 14 CFR 61.23 (a ) This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks associated with the operation of the proposed SUAS are so diminished from the level of risk associated with any manned aircraft; the SUAS is of a size, weigh t, speed, and operational capabilities which makes it much safer than any mannedaircraft; since operations will occur in tightly controlled and limited airspace; and

considering that all operations will be on private property that is clear of all people, obtaining and maintaining a medical certificate would not improve the safety of the operation. In the very rare case of a mishap, the SUAS being flown will pose significantly less of a threat than manned helicopters and fixed wing aircraft because

the SUAS s are a fraction of the size, a fraction of the weight, will be flown at a fraction of the speed, carry no flammable fuel, and carry no crew or passengers.

Private pilot privileges and limitations: Pilot in command 14 CFR 61.113 (a) and (b) These regulat ions limit private pilots to non

- commercial operations. Because the SUAS will not carry a pilot or passengers; due to the SUAS’s size, weight, speed, and operational capabilities; and since operations will occur in tightly controlled and limited airspace, the proposed operations can achieve the equivalent level of safety of current operations that currently require a commercial pilot’s license. Furthermore, since there are no standards for either private or commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the SUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. It cannot be assumed that a commercial pilot, appr oved to operate a manned helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre

- approved airspace. Flight instruction 14 CFR 91.109

This r egulation provides that 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. SUASs and remotely piloted aircraft, by their design do not

h ave fully functional dual controls. Flight control is accomplished through the use of a

control box that communicates with the aircraft via radio communications. 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. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

Altimeter settings 14 CFR 91.121 This regulation requires 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.” 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 safety will be achieved by the operator byconfirming the altitude of the launch site shown on the GPS altitude indicat or before

flight.

Fuel Requirements for Flight in VFR Conditions 14 CFR 91.151 (a ) This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is

enou gh fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the SUAS provide s approximately <25 minutes of powered flight. That would make it impossible to meet the 30 minute reserve requirement. Given the limitations on the SUAS’s proposed flight area and the location of its proposed

operations within a predetermined area, a long er time frame for flight in daylight or night VFR conditions is reasonable. An equivalent level of safety can be achieved by limiting flights to <25 minutes or 25% of battery power (whichever occurs first). This restriction would be more than adequate to r eturn the SUAS to its planned landing zone from anywhere in its limited operating area.

Maintenance Inspections 14 CFR 91.405 (a); 14 CFR 91.407 (a ) ( 1); 14 CFR 91.409 (a ) ( 1); 14 CFR 91.409 (a ) ( 2); 14 CFR 91.417 (a) and (b) These regulations require tha t an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply. Maintenance will be accomplished by the operator pursuant to the aforementioned Scout 4X user manual and guide. An equivalent level of safety will be achieved because these small SUASs are very limited in size, will carry a small payload, and operate only in restricted areas

for limited periods of time. If mechanical issues arise, the SUAS can land immediately and will be operating from no higher than 400 feet AGL. As outlined in the

aforementioned Pre

- flight Action Plan, the operator will ensure that the SUAS is in working order prior to initiating flight and perform maintenance as required. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

In accordance with 14 CFR Part 11, the following summary is provided for publication in the Federal Register:The applicant seeks an exemption from the following rules: 14 CFR Part 21,

Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially operate small unmanned aircraft systems (55 lbs. or less) in order to safely and legally capture aerial

photography and videography for use by homeowners, realtors, home builders, home contractors, and/or home inspectors.

The operation of SUASs conducted in the strict conditions outlined above, will provide an equivalent and/or greater level of safety supporting the grant of the exemp tions

requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and as a result, are far sa fer than existing operations conducted with helicopters operating in close proximity to the

ground, people, or other buildings in the vicinity. Given the small size of the SUASs involved, the slow speed at which they must be operated in order to capture ph otos and videos, and the restricted environment within which they will operate, the Scout 4X demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by exemption, allow commercial Operation s of SUASs to commence immediately. Also, due to the size of the SUASs and the restricted areas in which the relevant SUASs will operate, approval of this application presents no threat to national security. Given the clear direction in Section

333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations, the significant public

benefit

– including enhanced safety, reduction in environmental impacts, no emissions,

abilit y to legally obtain aerial photography and videography services

– the grant of the requested exemptions is in

The public interest. Accordingly, iREEL Productions respectfully requests that the FAA grant the requested exemption without delay. Satisfaction of the criteria provided

in Section 333 of the Reform Act

– size, weight, speed, operating capability, proximity to airports and populated areas, operation within the visual line of sight, public safety, and national security

– provide more than adequate j ustification to grant iREEL

Productions the requested exemption, allowing for commercial operations as described herewith. Sincerely,

Founder: Ronald Lee Castle / iREEL Productions