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July 29, 2015 

Joseph M. Carfora 

General Partner I Sales Director 

GR INNOVATIVE MEDIA WORKS, LTD. 

707 Miamisburg-Centerville Rd., #122 

Dayton, OH 45459 

Cell: 937.212.4824 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

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Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

Dear Sir or Madam: 

I am writing pursuant to the FAA Modernization and Reform Act of2012 (the "Reform Act") and the 

procedures contained in 14 C.F.R. 11, to request that GR INNOVATIVE 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 of flight, with a mailing address of707 Miamisburg-Centerville Rd., Dayton, Ohio 45459. 

Joseph M. Carfora and his partners, named above, are joint owners and operators of two 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 services to 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 or RC aircraft as hobby pilots in the past. 

GR INNOVATIVE MEDIA WORKS, LTD. has one FAA certified private pilot on staff, Mr. Sasha Lazic. 

Between Mr. Carfora, Mr. Lazic, Mr. Acebal and Mrs. Acebal, over 45 hours have been flown and logged 

appropriately since July, 2014 on our well-maintained and regularly used Dll Phantom 2 Vision+ UAS. 

A majority of our flights have been for hobby or non-commercial purposes and we have donated video to 

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several 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 INNOVATNE MEDIA WORKS have used its Dll Phantom 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 of sight (VLOS) flights below 200 feet for private 

and commercial real estate. We understand very well the details of TourFactory's corporate policy and 

have received both their corporate compliance policy and FAA checklist in order to 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 

INNOVATNE MEDIA 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 MEDIA WORKS, 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 other than 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 (11.1 V) 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 and Illinois). 

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 our PIC, Sasha Lazic. 

• The UAS has GPS functionality to hover in place as well as a return to home (RTH) function in 

case of loss of contact with the radio. If the UAS loses contact with the radio, it will first increase 

its altitude to 150 feet (or another pre-set, pre-determined altitude) prior to returning to the last 

calibration point. 

• 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 of the UAS batteries, documenting weather, distance flown and 

recording flight time. 

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• The UAS has audible and visual warning systems that will initiate a controlled, slow descent if 

battery power reaches 25%. 

• The failsafe software will disable the UAS from taking off and also limiting I restricting the UAS 

systems from operating within specific GPS preset no-fly zones and as I mentioned, we 

constantly review the map for no-fly zones before we take to the air. 

GR INNOV ATNE MEDIA WORKS, LTD's exemption request would permit its operation of 

lightweight, unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly 

controlled and limited airspace. 

GR INNOVATNE MEDIA WORKS, 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 compliant with 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 INNOVATNE MEDIA WORKS, LTD. This will act to further safety protocols 

specific to lightweight UASs as GR INNOVATNE MEDIA WORKS, 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 that have exceed 40+ 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 

MEDIA WORKS, 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 

videography that may or may not require editing. 

Granting this request agrees with the Secretary of Transportation's (FAA Administrator's) responsibilities 

to not only integrate UASs into the national airspace system, but to " ... establish requirements for the safe 

operation of such aircraft systems [UASs] in the national airspace system" under Section 333(c) of the 

Reform Act. Further, GR INNOVATNE MEDIA WORKS, LTD. will conduct its operations in 

compliance with the protocols described herein or as otherwise established by the FAA. 

For the reasons stated below, GR INNOVATNE MEDIA WORKS, LTD. respectfully requests the grant 

of an exemption allowing it to operate lightweight, remote controlled UAS' s. 

1. Contact Information: 

Joseph M. Carfora 

GR INNOVATNE MEDIA WORKS, LTD. 

707 Miamisburg-Centerville Rd. 

Dayton, Ohio 45459 

Tel.: (937) 212-4824 

e-mail: jmcarfora@gnnediaworks.com 

2. The Specific Sections of Title 14 of the Code ofFederal Regulations From Which We Reguest 

Exemption are: 

14 CFR21; 

14 C.F.R. 45.23(b); 

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14 CFR 61.113 (a) & (b); 

14 C.F.R. 91, et seq.; 

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

U.S. Dep't ofTransp. 

3. The Extent of Relief GR MEDIA WORKS, LTD. Seeks and the Reason It Seeks Such Relief: 

GR INNOVATIVE MEDIA WORKS, LTD. submits this application in accordance with the Reform Act, 

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 of civil 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 lightweight UAS prior to the time period by which the Reform 

Act requires the FAA to promulgate rules governing such craft. 

The Reform Act guides the Secretary in determining the types ofUASs that may operate safely in our 

National airspace system. Considerations include: 

• The weight, size, speed and overall capabilities of the UAS; 

• Whether the U AS will be operated near airports or populated areas; and, 

• Whether the UAS will be operated by line of sight. 

112 P.L. 95 § 333 (a). Each of these 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 of vertical and horizontal operations but operate only within the visual line of sight (VLOS) of 

the remote control pilot. In addition to the remote control pilot, we have designated a spotter, such that, at 

minimum, two appropriately trained GR INNOVATIVE MEDIA WORKS, LTD. team members govern 

the safe flight of the aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and twenty-five 

minutes. We do not operate the UAS with less than twenty five percent remaining battery capacity. Safety 

systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff location 

(RTH) if communication 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, near populated areas or 

near stadiums. To date, we have only operated the UAS in a non-commercial manner. However, we 

expect to operate commercially once we are in full compliance with the TourFactory COA and corporate 

policy. 

Our operation of this small unmanned aircraft will not "create a hazard to users of the national airspace 

system or the public." 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS, combined with 

its operation in cordoned off and 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 

threat to the general public or national security. 

The FAA has the authority to issue the exemption sought by GR INNOVATNE MEDIA WORKS, LTD. 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

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4. How this Request Will Benefit the Public As A Whole: 

Granting this exemption request furthers the public interest. First, Congress has already pronounced that it 

is in the public's interest to integrate commercially flown UASs into the national airspace system, hence 

the passing of the 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. If our UAS crashes there is no fuel to ignite and explode. The impact of our 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 

lightweight U AS. 

Progression of the arts and sciences has been fundamental to our society since its inclusion in the United 

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 cost millions of dollars, granting this exemption request substantially furthers the 

public's interest in ways known and currently unknown. 

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 

being the biggest. 

5. Reasons Why GR INNOVATIVE MEDIA WORKS, LTD. Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal 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 capture techniques: 

• Our UAS weighs less than 5 pounds complete with all mounted equipment and battery; 

• We only operate our UAS below 400 feet; 

• Our UAS only operates for 5-25 minutes per flight; 

• We land our UAS when it reaches 25% battery power; 

• Our remote control pilot operates the UAS by line of sight; 

• Our remote control pilot has video backup should he somehow lose sight of the UAS; 

• We staff each flight with a remote control pilot and spotter with communication systems enabling real 

time communication between them; 

• Our U AS has GPS flight modes whereby it hovers, returns to takeoff position and then slowly lands if 

communication with the remote control pilot is lost or battery power is below 25%; 

• We actively analyze electronic flight data and other sources of information to constantly update and 

enhance safety protocols; 

• We conduct extensive briefmgs prior to flight, during which safety carries primary importance, and; 

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• We have procedures in place to abort flights in the event of safety breaches or potential danger. 

Our safety protocols provide a level of safety at least equal to existing rules, and in nearly every instance, 

greater than existing rules. It is important to note that absent the integration of commercial UASs 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 of life is diminished because UASs carry no people on board 

and GR INNOVATIVE MEDIA WORKS, LTD. only operates them in specific areas away from mass 

population. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

reduced. Third, the small size and extreme maneuverability of our UAS allows our remote control pilot to 

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 The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

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 of the Reform Act. 

Both pieces of legislation permit the FAA to exempt U ASs from the airworthiness certificate requirement 

in consideration of the 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) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the F ARs, this Regulation is inapplicable. 

14 C.F .R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs, this Regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining a manual at the 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.'s UAS utilizes electronic global positioning systems and internal gyroscopes to 

provide spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. 

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 of Federal Regulation require aircraft to be marked according to certain specifications. 

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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 MEDIA WORKS, 

LTD. will mark its UAS in the largest possible lettering by placing the 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 UA V will see the markings. The FAA has previously issued exemptions to this regulation 

through Exemptions Nos. 8738, 10167, 10167A and 10700. 

C. 14 C.P.R.§ 61.113: Private Pilot Privileges and Limitations: 

PIC. Pursuant to 14 C.P.R.§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. 

GR INNOVATIVE MEDIA WORKS, LTD. can achieve an equivalent level of safety as achieved by 

current Regulations because GR INNOVATIVE MEDIA WORKS, LTD. UAS does not carry any pilots 

or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. Further, 

the risks attendant to the operation of GR 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 MEDIA WORKS, LTD. to operate its UAS with a private pilot as the pilot in control will 

exceed current safety levels in relation to 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 of civil aircraft. It allows helicopters to 

be operated at lower altitudes in certain conditions. GR INNOVATIVE MEDIA WORKS, LTD.'s UAS 

will never operate at an altitude greater than 400 AGL. GR INNOVATIVE MEDIA WORKS, LTD. will, 

however, operate its UAS in cordoned off areas 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 MEDIA WORKS, 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-cited Regulations require, amongst other things, aircraft owners and operators to "have [the] 

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 .... " 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply 

to GR INNOVATIVE MEDIA WORKS, LTD. should its requested exemption be granted. GR 

INNOVATIVE MEDIA WORKS, LTD. conducts an extensive maintenance program that involves regular 

software updates and curative measures for any damaged hardware. Therefore, an equivalent level of 

safety will 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 MEDIA WORKS, LTD.'s request for exemption 

will reduce current risk levels and thereby enhance safety. Currently, motion picture image capture relies 

primarily on the use of larger aircraft running 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 MEDIA WORKS, LTD.'s operates at 

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lower altitudes and in controlled airspace. GR INNOVATIVE MEDIA WORKS, LTD.'s has been 

analyzing flight data and other information in compiling novel safety protocols and the implementation of 

a flight operations manual that exceeds currently accepted means and methods of safe flight. There are no 

people on board GR INNOVATIVE MEDIA WORKS, LTD.'s UAS and therefore the likelihood of death 

or serious bodily injury is significantly limited. GR lNNOVATIVE MEDIA WORKS, LTD.'s operation 

of its 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 of safety as that achieved under current F ARs. 

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 affect jobs, lives, 

and small business growth such as in the case of GR INNOVATIVE MEDIA WORKS, 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 our business looking to 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 happy to say that we can initially take the next step of moving to "commercially" 

with the TourFactory exemption to start, the addition of a FAA licensed pilot to our team and the 

experienced we've built flying the past year on our own real 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 MEDIA WORKS, who pride themselves 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 decision to grant an exemption for GR INNOVATIVE MEDIA WORKS, LTD. 

cc: A. Acebal 

S. Lazic 

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