I ' ,,

July 29, 2015 Joseph M. Carfora General Partner I Sales Director GR INNOVATIVE MEDIA WORKS, LTD. 707 Miamisburg-Centerville Rd., #122 Dayton, OH45459 Cell: 937.212.4824

United States Department ofTransportation DocketManagement System 1200 NewJerseyAve., SE WestBuilding Ground FloorRoom W12-140 Washington, DC 20590 **:~ ·~)** 

**~** j\. -.,}

**~:t**

Re: Exemption RequestPursuant To Section 333 oftheFAAReform Act of2012
Dear Sir orMadam:
I am writing pursuantto the FAAModernization and Reform Act of2012 (the "ReformAct") andthe procedures contained in 14 C.F.R. 11, to request that GRINNOVATIVE MEDIA WORKS LTD., owned and operated by Joseph Michael Carfora and three additional United States Citizen partners, each with 25% share in our privately-held start-up company established in August, 2014, Radmila Carfora, Gayatri G. Acebal (an Air Force Veteran) and Ariel 0. Acebal (an Air Force Veteran), based in Dayton, Ohio, the birthplace offlight, with a mailing address of707Miamisburg-Centerville Rd., Dayton, Ohio 45459. Joseph M. Carfora and his partners, named above, arejoint owners and operators oftwo small unmanned aircraft (UAS), request to be exempted from the Federal Aviation Regulations ("FARs") listed below so that GR INNOVATIVE MEDIA WORKS LTD. may operate its small unmanned aircraft 

### I lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA").
As identified and described within this petition, Joseph M. Carfora, and his partners, as GR INNOVATIVE MEDIA WORKS, are experienced, recognized veterans in the photography, video capture 

### I editing, and website development industries. Joseph M. Carfora is also fully employed in the medical device industry, a safety critical industry, by Boston Scientific Corporation for the past 13 years; Ariel 0. Acebal is a retired Air Force veteran since 2013, and fully employed as a civilian in aerospace research; Gayatri G. Acebal is part-time employed as a physician's assistant, and a freelance videographer; and Radmila Carfora is part-time employed as a mechanical sales engineer, and a freelance photographer. Joseph M. Carfora and his partners have been providing quality servicesto their clients since 2014 as GR INNOVATIVE MEDIA WORKS is start-up company. Joseph has also been a flight simulator enthusiast that has regularly practiced for over thirty (30) years on light commercial aircraft and airline transport aircraft mostly through PC software and several times in real simulators, although he does not hold a private pilot's license. Joseph and Ariel are avid video editors and flight enthusiasts that have piloted UAS orRC aircraft as hobby pilots inthe past. GRINNOVATIVE MEDIA WORKS, LTD. has one FAA certifiedprivate pilot on staff, Mr. SashaLazic. BetweenMr. Carfora, Mr. Lazic, Mr. Acebal and Mrs. Acebal, over45 hours have been flown and logged appropriately since July, 2014 on our well-maintained and regularly used Dll Phantom 2 Vision+ UAS. A majority ofour flights have been for hobby ornon-commercial purposes and we have donated video to
1several local Dayton and out-of-state entities to help promote their businesses while we refining and improving our UAS skills. Mr. and Mrs. Carfora also own Novation Property Management, an investment real estate management company (S-Corp) for their own investment properties in Ohio, Arizona and South Carolina. GR INNOVATNEMEDIA WORKS have used its DllPhantom 2 Vision+ to make non-commercial promotional videos in order to promote its general partners' investment properties and to also demonstrate to the public, a novel, and useful perspective toward future real estate marketing.
GR INNOVATNE MEDIA WORKS, LTD. have recently ordered a second UAS as we are working toward achieving compliance as a certified TourFactory vendor which would place us in compliance with TourFactory's COA by September 1, 2015 with Mr. Sasha Lazic as our Pilot In Charge (PIC) and Mr. Carfora as our primary trained observer for visual line ofsight (VLOS) flights below 200 feet for private and commercial real estate. We understand very well the details ofTourFactory's corporate policy and have received boththeir corporate compliancepolicy and FAAchecklist in orderto participate.
It is additionally the intention ofGR INNOVATNE MEDIA WORKS, LTD. to seek its own exemption or COA from the FAA in order to participate commercially, as we will already have the requirements in place as identified on the TourFactory COA. It only seems to be the next logical step for GR INNOVATNEMEDIA WORKS, LTD.
This is a very exciting time. Joseph Carfora and his business partners are looking to add extremely unique and valuable services to its clients through GR INNOVATNE MEDIAWORKS, LTD. through the use of our small, lightweight UAS as several of our clients have requested this type of service commercially. Primary uses will be low altitude (<200 feet) aerial photography and videography for private and commercial real estate marketing, and small and medium-sized business, during daytime hours only with one Pilot-In-Charge (PIC) and one highly trained VLOS observer for all projects to be marketed through the TourFactory website initially, and to any external customers otherthan TourFactory with this exemption. Joseph has operated GR INNOVATIVE MEDIAWORKS, LTD.'s current UAS (Dll Phantom 2 Vision+), purchased in July, 2014, on many occasions non-commercially without incident. The UAS utilizes a 5200mAh (11.1V) LiPO battery power, and not combustible fuels. Flight time ranges between five and twenty five minutes and is flown only in decent weather conditions and in winds less than 15 knots. The UAS has not been flown in proximity to people or structures for safety reasons although we have had it in a variety oflocations (Ohio, South Carolina, Florida andIllinois).
GR INNOVATNE MEDIA WORKS, LTD. are extremely aware of safety while continually reviewing weather conditions and drone no-fly zones mandated by the FAA. • Ariel 0. Acebal is also a weather expert and continually provides GR INNOVATNE MEDIA WORKS, LTD. with pre-flight weather condition briefmgs while coordinating with Joseph Carfora and ourPIC, SashaLazic. • The UAS has GPS functionality to hover in place as well as a return to home (RTH) function in case ofloss ofcontactwiththeradio. Ifthe UAS loses contactwiththeradio, itwill first increase its altitude to 150 feet (or another pre-set, pre-determined altitude) prior to returning to the last calibrationpoint. • GR INNOVATNE MEDIAWORKS, LTD. have established detailed pre-flight visual and mechanical inspections, detailed start-up procedures including compass and GPS RTH calibration which are laminated on a placard inside the travel case for each UAS, detailed landing procedures and post-flight procedures including completing a logbook entry for our UAS flights, tracking battery charge information on all ofthe UAS batteries, documenting weather, distance flown and recording flight time. 2

### • The UAS has audible and visual warning systems that will initiate a controlled, slow descent if batterypowerreaches 25%. • The failsafe software will disable the UAS from taking offand also limiting 

### Irestricting the UAS systems from operating within specific GPS preset no-fly zones and as I mentioned, we constantlyreviewthe map for no-fly zones before wetake to the air. GR INNOV ATNE MEDIAWORKS, LTD's exemption request would permit its operation of lightweight, unmanned (piloted byremote control) and comparatively inexpensive UASs intightly controlled and limited airspace.
GR INNOVATNE MEDIAWORKS, LTD. retains both general business liability insurance and a separate drone liability insurance policy of $l.OM per incident, issued through Costello Insurance of Scottsdale, Arizona, which is already compliantwith TourFactory's Corporate Policy. At the present time, similar lightweight, remote controlled UASs are legally operated by amateurs or hobbyists with little or no flight experience, no safety plan or no controls in place to prevent accidents. It is only logical to allow Joseph Carfora and Ariel 0. 

### Acebal, both experienced remote control pilots, and Sasha Lazic, an experienced remote control pilot and FAA private pilot license holder, to operate similar lightweight UASs for GR INNOVATNEMEDIAWORKS, LTD. This will actto further safety protocols specific to lightweight UASs as GR INNOVATNE MEDIAWORKS, LTD. researches flight data and other information gained through permitted flight operations.
We would also petition that the FAA grant Joseph Carfora an exemption as additional PIC, based on his logged and documented flights thathave exceed40+ hours (or 240 ten-minute flights including many take offs and many landings in both stable and windy conditions, both GPS and non-GPS mode), experience and expertise in flying the Dn Phantom 2 Vision+ Model UAS. It is GR INNOVATNE MEDIAWORKS, LTD.'s intention to use its UAS primarily, but not solely for, real estate functions but additionally for small and medium business requirements for raw aerial and raw photography and videographythatmay ormay notrequire editing. Granting this request agrees with the Secretary ofTransportation's (FAA Administrator's)responsibilities to not only integrate UASs into the national airspace system, butto "

...establish requirements for the safe operation of such aircraft systems [UASs] in the national airspace system" under Section 333(c) ofthe Reform Act. Further, GR INNOVATNE MEDIAWORKS, LTD. will conduct its operations in compliance withthe protocols described herein or as otherwise established bythe FAA.
For the reasons stated below, GRINNOVATNE MEDIAWORKS, LTD. respectfully requests the grant ofan exemption allowing itto operate lightweight, remote controlledUAS's. 1. ContactInformation: 

### JosephM. Carfora GRINNOVATNEMEDIAWORKS, LTD. 707 Miamisburg-Centerville Rd. Dayton, Ohio 45459 Tel.: (937) 212-4824 e-mail: jmcarfora@gnnediaworks.com
2. The Specific Sections ofTitle 14 ofthe Code ofFederalRegulations FromWhichWeReguest Exemption are: 

### 14 CFR21; 14 C.F.R. 45.23(b);
314 CFR61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR407 (a) (1); 14 CFR409 (a) (2); and, 14 CFR417 (a) & (b). U.S. Dep'tofTransp.
3. TheExtent ofReliefGRMEDIA WORKS,LTD. Seeks and theReasonIt Seeks SuchRelief: GRINNOVATIVE MEDIA WORKS, LTD. submits this application in accordance withthe ReformAct, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent GR INNOVATIVE MEDIAWORKS, LTD. contemplated commercial cinematic, research and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Our lightweight UAS meets the definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration of our lightweight UAS is expressly contemplated by the Reform Act. We would like to operate our lightweightUAS priorto the time periodbywhichthe Reform Actrequiresthe FAAto promulgaterules governing such craft.
TheReformAct guidesthe Secretary indeterminingthetypes ofUASsthatmayoperate safely in our National airspace system. Considerations include: • The weight, size, speedand overall capabilities oftheUAS; • WhethertheUAS willbeoperatednear airports orpopulated areas; and, • WhethertheUAS will be operatedbyline ofsight.
112 P.L. 95 § 333 (a). Each ofthese items militates in favor of an exemption for GR INNOVATNE MEDIA WORKS, LTD. Our UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It weighs less than 5 pounds, including battery and all equipment. This small unmanned aircraft is designed to primarily hover in place and operate at less than a 50-knot maximum speed. It is capable ofvertical and horizontal operations but operate only within the visual line ofsight (VLOS) of the remote control pilot. In addition to the remote control pilot, we have designated a spotter, suchthat, at minimum, two appropriately trained GR INNOVATIVE MEDIA WORKS, LTD. team members govern the safe flight ofthe aircraft at all times. Utilizing battery power and not combustible fuels, flights generally last between five and twenty-five minutes. We do not operatetheUAS with less thantwentyfive percentremainingbattery capacity. Safety systems in place include a GPS mode that allows the UAS to hover in place orreturn to takeofflocation (RTH) ifcommunication with the radio control pilot is lost and then slowly descend the UAS at twenty five percent battery capacity. We generally do not operate the UAS near airports, nearpopulated areas or near stadiums. To date, we have only operated the UAS in a non-commercial manner. However, we expectto operate commercially once we are in full compliance with the TourFactory COA and corporate policy.
Ouroperation ofthis smallunmanned aircraftwillnot "create a hazard to users ofthe national airspace system orthe public." 112P.L. 95 § 333 (b). Giventhe small size andweight ofthe UAS, combinedwith its operation in cordoned offand well-controlled areas, this falls within Congress's contemplated safety zone when it promoted the Reform Act and the corresponding directive to integrate UASs into the national airspace system. We are confident that our UAS or subsequent UAS aircraft will not pose any threatto the general public ornational security.
The FAAhas the authority to issue the exemption soughtby GRINNOVATNEMEDIA WORKS, LTD. pursuanttothe FederalAviationAct, 85 P.L. 726 (1958), as amended (the "Act").
44. Howthis Request Will Benefitthe Public As A Whole: Grantingthis exemptionrequest furthers the public interest. First, Congress has already pronouncedthat it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing ofthe Reform Act. Second, GR INNOVATIVE MEDIA WORKS, LTD. conducts research into safe UAS operations every time it flies its UAS. Flight data, visual inspections, recorded observations and flight analyses are compiled in our flight logbook, including weather conditions, location and other key details, to further enhance current safety protocols. Allowing us to achieve more flight time directly relates to our research and our ability to further enhance current safety measures. Third, the public has an interest in reducing the danger and emission associated with current aerial cinematic capture methods, namely, full size helicopters. Our UAS is battery powered and creates no emissions. Ifour UAS crashes there is no fuel to ignite and explode. The impact ofour lightweight UAS is negligible when compared to a full size helicopter, notwithstanding the statistically noteworthy safety record of full size helicopters used in motion picture capture. The public's interest is furthered by minimizing ecological and crash impacts by permitting photo and motion picture capture through our lightweightUAS. Progression ofthe arts and sciences hasbeenfundamental to our society since its inclusion in theUnited States Constitution. Indeed, Congress mandated the integration of UASs into our national airspace system, in part, to achieve progression in this noteworthy, and inevitable, field. Permitting GR INNOVATIVE MEDIA WORKS, LTD. to immediately fly within the United States furthers these goals. Whether it is the amalgam of scientific discoveries applicable to feature film making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or advancements in equipment available to law enforcement personnel I first responders that does not costmillions ofdollars, granting this exemptionrequest substantially furthers the public's interest inways known and currentlyunknown. Granting this request will also allow small business owners and home owners to be able to afford highquality aerial images and video that they would otherwise have no access to due to several factors, cost beingthebiggest.
5. Reasons Why GR INNOVATIVE MEDIA WORKS, LTD. Exemption Will Not Adversely Affect Safety OrHow The Exemption Will Provide a Level ofSafetyAtLeastEqual To Existing Rule: This exemption will not adversely affect safety. Quite the contrary, for the reasons stated, supra, permitting GR INNOVATIVE MEDIAWORKS, LTD. to log more flight time in FAA controlled airspace will allow us to innovate and implement new, as of yet undiscovered safety protocols. In addition, we submit the following representations of enhancements to current aerial photography and motion picture capturetechniques: • OurUAS weighs less than 5 pounds complete with allmounted equipment andbattery; • We only operate ourUAS below400 feet; • OurUAS only operates for 5-25 minutes perflight; • We land our UAS when itreaches 25%batterypower; • Ourremote control pilotoperates the UAS by line ofsight; • Ourremote control pilothas videobackup should he somehow lose sight ofthe UAS; • We staffeach flight with a remote control pilot and spotterwith communication systems enablingreal time communication betweenthem; • OurUAS has GPS flight modes wherebyithovers, returns to takeoffposition and then slowly lands if communication with theremote control pilotis lost orbatterypoweris below 25%; • We actively analyze electronic flight data and other sources ofinformationto constantly update and enhance safetyprotocols; • We conduct extensivebriefmgs priorto flight, during which safety carries primary importance, and;
5• Wehaveprocedures in placeto abortflights inthe event ofsafetybreaches orpotential danger.
Our safetyprotocols provide a level ofsafety atleast equal to existingrules, and in nearly every instance, greaterthan existingrules. It is importantto notethatabsentthe integration ofcommercialUASs into our national airspace system, helicopters are the primary means of aerial motion picture capture. While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery powered lightweight UAS. First, the potential loss oflife is diminished because UASs carry no people on board and GRINNOVATIVEMEDIA WORKS, LTD. only operates them in specific areas awayfrom mass population. Second, there is no fuel onboard a UAS andthusthe potential for fire orexplosions is greatly reduced. Third, the small size and extreme maneuverability ofourUAS allows ourremote controlpilotto avoid hazards and execute evasive safety measures quickly. Lastly, given their small size and weight, even when close enough to capture amazing images, our UAS needs not be so close to the objects it is focused on. Accordingly, our UAS has operated and will continue to operate at and above current safety levels.
6. A Summary TheFAAMayPublish in the Federal Register:
A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals andThe Like.
14 C.F.R. 21, Subpart H, entitledAirworthiness Certificates, sets forth requirements forprocurementof necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area ofGR INNOVATIVE MEDIA WORKS, LTD.'s UAS permits exemption from Part 21 because GR INNOVATIVE MEDIA WORKS, LTD. meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Bothpieces oflegislationpermittheFAAto exemptUASs from the airworthiness certificaterequirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. GR INNOVATIVE MEDIA WORKS, LTD.'s UAS meets or exceeds each of the elements.
14 C.F.R. 91.7(a)prohibitsthe operation ofan aircraftwithout an airworthiness certificate. Asno such certificate willbe applicable intheform contemplatedbythe FARs, this Regulation is inapplicable.
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual inthe aircraft. Asthere are no pilots or passengers, and given the size ofthe UASs, this Regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining a manual atthe flight operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.
14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as GR INNOVATIVE MEDIA WORKS, LTD.'sUAS utilizes electronic global positioning systems and internal gyroscopes to provide spatial coordination.
14 C.F.R. § 91.203 (a) and (b)providesfor the carrying ofcivil aircraft certifications andregistrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at GR INNOVATIVE MEDIA WORKS, LTD.'s flight operations center.
B. 14 C.F.R. § 45.23: Marking ofThe Aircraft. Applicable Codes ofFederalRegulationrequire aircraftto be marked accordingto certain specifications.

6

### GR INNOVATIVE MEDIAWORKS, LTD.'s UAS is, by definition, unmanned. It therefore does not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft. Regardless, GR INNOVATIVE MEDIAWORKS, LTD. will mark its UAS inthe largestpossible lettering byplacingthe word "EXPERIMENTAL" on its fuselage as required by 14 C.P.R. §45.29 (f) 

### so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through ExemptionsNos. 8738, 10167, 10167A and 10700.
C. 14 C.P.R.§ 61.113: Private PilotPrivileges and Limitations: PIC. Pursuant to 14 C.P.R.§§ 61.113 (a) & 

### (b), private pilots are limited to non-commercial operations. GR INNOVATIVE MEDIAWORKS, LTD. can achieve an equivalent level of safety as achieved by current Regulations because GR INNOVATIVE MEDIAWORKS, LTD. UAS does not carry any pilots orpassengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. Further, the risks attendant to the operation ofGR INNOVATIVE MEDIA WORKS, LTD.'s UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.P.R. § 61, et seq. Thus, allowing GR INNOVATIVE MEDIAWORKS, LTD. to operate its UAS with a private pilot as the pilot in control will exceed current safety levels inrelationto 14 C.P.R. §61.113 (a) & 

### (b).
D. 14 C.P.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. §91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicoptersto be operated at lower altitudes in certain conditions. GR INNOVATIVE MEDIAWORKS, LTD.'s UAS will never operate at an altitude greater than 400 AGL. GR INNOVATIVE MEDIAWORKS, LTD. will, however, operate its UAS in cordoned offareas with security perimeters, providing a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of GR INNOVATIVE MEDIAWORKS, LTD.'s UAS, an equivalent level of safety will be achieved.
E. 14 C.P.R. 91.405 (a); 407 (a) (1); 

### 409 (a) (2); 417(a) & 

### (b): Maintenance Inspections. The above-citedRegulations require, amongst otherthings, aircraft owners and operators to "have [the] 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 ofthis chapter

...." These Regulations only applyto aircraft with an airworthiness certificate. They will not, therefore, apply to GR INNOVATIVE MEDIAWORKS, LTD. should its requested exemption be granted. GR INNOVATIVE MEDIAWORKS, LTD. conducts an extensive maintenance programthatinvolves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safetywill be achieved.
F. Summary GR INNOVATIVE MEDIAWORKS, LTD. seeks an exemption from the following Regulations: 14 C.P.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.P.R.§§ 61.113 (a) & 

### (b); 14 C.P.R.§ 91.7 (a); 14 C.P.R. § 91.9 (b)(2); 14 C.P.R. § 91.103(b); 14 C.P.R. § 91.109; 14 C.P.R. § 91.119; 14 C.P.R. § 91.121; 14 C.P.R. § 91.151(a); 14 C.P.R. §§ 91.203(a) and (b); 14 C.P.R. § 91.405 (a); 14 C.P.R. § 91.407 (a)(1); 14 C.P.R.§ 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) & 

### (b) to commercially operate its lightweight unmanned aircraft vehicle(s) in motion picture or photography operations and to conduct its own research. Granting GR INNOVATIVE MEDIAWORKS, LTD.'s request for exemption will reduce current risk levels and thereby enhance safety. Currently, motion picture image capture relies primarily on the use oflarger aircraftrunning on combustible fuel. GR INNOVATIVE MEDIA WORKS, LTD.'s craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional motion picture aircraft. Further, GR INNOVATIVE MEDIAWORKS, LTD.'s operates at
7' '

lower altitudes and in controlled airspace. GR INNOVATIVE MEDIAWORKS, LTD.'s has been analyzing flight data and other information in compilingnovel safety protocols andthe implementation of a flight operations manual that exceeds currently accepted means and methods ofsafe flight. There are no people onboard GRINNOVATIVE MEDIAWORKS, LTD.'s UAS and therefore the likelihood ofdeath or serious bodily injury is significantly limited. GRlNNOVATIVE MEDIAWORKS, LTD.'s operation ofits UAS, weighting less than 5 pounds and travelling at speeds lower than 50-knots in cordoned off areas will provide at least an equivalent level ofsafety as that achieved under currentFARs. Accordingly, GR INNOVATIVE MEDIAWORKS, LTD. respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by GR INNOVATIVE MEDIA WORKS, LTD. pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Finally, we appreciate the time involved for the FAA to review and grant these exceptions. This represents huge potential growth for the United States economy which will positively affectjobs, lives, and small business growth such as in the case of GR INNOVATIVE MEDIAWORKS, LTD. Many people have chosen to ignore the FAA and fly "under the radar." Most have no intention of ever petitioning for an exemption or seeking appropriate insurance coverage because they don't even know it exists. We started ourbusiness lookingto the future opportunity and the potential that aerial photography and videography can bring many. We've had a year to analyze, learn and compile projects noncommercially and I am happyto say that we can initially take the next step ofmoving to "commercially" with the TourFactory exemption to start, the addition of a FAA licensed pilot to our team and the experienced we'vebuilt flying the pastyear on our ownreal estate investment projects. As I said before, this is a very exciting, yet challenging time, which presents a unique opportunity for startups like GR INNOVATIVE MEDIAWORKS, who pridethemselves on safety and compliance first. Thank you very much for your time and commitment to keep our skies safe, while also looking at the commercial opportunities that UAS presents to our great and hopefully growing economy. We look forward to your decisionto grant an exemption for GRINNOVATIVEMEDIAWORKS, LTD.

cc: A. Acebal S. Lazic

8