FAA Exemption Rulemaking

Section 333

Of The FAA Reform Act and Part 11

Prepared by

Alex Kimball

September 20, 2015

3981 Perch Circle

Willits, CA 95490

707-456-9303

abkimball84@gmail.com
Attention:

United States Secretary of Transportation

Mr. Anthony R. Foxx

1200 New Jersey Ave, SE

Washington DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and 14 CFR Part 11 of the 

Federal Aviation Regulations from 14 CFR 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);

91.409 (a) (2); 91.417 (a) & (b)

Dear Mr. Secretary,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 CFR Part 11, Sky Edge Photography., a California company and 

operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial 

photography and videography purposes, 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 under the conditions outlined herein or as may 

be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation 

of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace 

that is 1) limited, 2) predetermined, and 3) controlled as to access. Approval of this 

exemption would thereby fulfill the Secretary of Transportation’s responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national 

airspace system.” Section 333 (c) of the Reform Act. 

Sky Edge Photography requests to use the DJI Phantom 3 Professional for aerial 

imaging. The FAA has previously issued Grants of Exemption in circumstances similar in 

nearly all material respects to those presented in this petition. In previous Grants of 

Exemption [Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to 

Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket 

No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642)], 

the FAA found that the enhanced safety achieved using an unmanned aircraft with the 

specifications described by the petitioners, carrying no passengers or crew—rather than a 

manned aircraft of far greater proportions, carrying crew and flammable fuel—gave the FAA 

good cause to find that the UAS operations were in the public interest. Sky Edge 

Photography feels that the reasons stated by the FAA for granting Exemption Nos. 11062, 

11109, 11112, and 11213 would also reasonably apply to the situation presented by this 

petition. Additionally, we feel that considering the enhanced safety features provided by the 

DJI Phantom 3 Professional (the “No Fly Zone” feature in particular), as well as the cost 

effectiveness of small UAS aerial photography, a grant of exemption would be in the public 

interest. 

The name and address of the applicant is: Sky Edge Photography Attn: Alex Kimball

Phone: 707-456-9303 Email: abkimball84@gmail.com Address: 3981 Perch Circle, Willits, 

CA 95490
Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 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) of the Reform Act. This directs the Secretary of Transportation 

to consider whether certain unmanned aircraft systems may operate safely in the national 

airspace system (NAS) before completion of the rulemaking 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 the NAS or the public or pose a threat to 

national security in light of the following:

• The sUAS’s size, weight, speed, and operational capability

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

• Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. 

Reform Act §333 (a). Lastly, 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.” Reform Act §333 (c). The

Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the 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 of a regulation prescribed under subsection (a) or (b) of this section or any 

sections 4470244716 of this title if the Administrator finds the exemption in the public

interest. 49 U.S.C. §44704; 14 CFR §91.203 (a) (1).

Sky Edge Photography’s sUASs are small rotorcraft aircraft, weighing less than 60 

oz including sensor payload. We operate our rotorcraft under normal conditions at a speed 

of no more than 17 knots, usually 05 knots. The rotorcraft have the capability to hover and 

move in the vertical and horizontal plane simultaneously. We will manually operate only in 

Visual Line of Sight and will operate only within the operating parameters as described in 

the Operating Manual.
Adherence to the Operating Manual will insure that the sUASs will “not create a 

hazard to the national airspace system or the public.”

Given the small size and weight of the sUASs involved and the restricted sterile 

environment within which they will operate, Sky Edge Photography falls squarely within that 

zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA 

must, by exemption, allow commercial operations of UASs to commence immediately. Also 

due to the size of the sUASs and the areas in which the relevant sUAS will operate, 

approval of the application presents no national security issue. Given the clear direction in 

Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended, granting the requested exemptions is in the public interest for the following 

reasons: (1) the strong equivalent level of safety surrounding the proposed operations, and 

(2) the significant public benefits, including enhanced safety, reduction in environmental 

impact, including reduced emissions associated with allowing UASs for educational and 

marketing operations, (as opposed to full scale aircraft). Accordingly, Sky Edge 

Photography respectfully requests that the FAA grant the requested exemption without 

delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY Sky Edge Photography

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 possibly higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to 

the already safe filming operations conducted with conventional aircraft. These limitations 

and condition to which Sky Edge Photography agrees to be bound when conducting 

commercial operations under an FAA issued exemption include:

1. The sUASs will weigh less than 5 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and 

aircrew (Spotter / Observer).

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will 

be terminated at 25% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 200 feet AGL, though most

operations will be conducted within 50 feet of the ground

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and 

Spotter/Observer. In most cases the third aircrew member will serve as the Safety Officer.

6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical. The Spotter (Observer) will hold at least a third class 

medical.

7. The sUAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder, 

other than the sUAS Pilot, possesses the necessary PIC qualifications and is also present, 

that person may also be designated as PIC.

8. The sUAS will only operate within an area as defined in the Manual on pages 45-

48. Additionally, the sUAS will only operate under 200ft AGL, and outside a 3 statute mile 

radius of any airport. The sUAS will never enter any MOA or Restricted Airspace, nor shall it 

violate any TFR as outlined by the FAA.

9. A preflight briefing will be conducted in regard to the planned sUAS operation prior 

to each day’s flying / recording activities. It will be mandatory that all personnel who will be 

performing duties as “flight crew” be present for this briefing.
10. The Operator will obtain the consent of all persons involved in the filming and 

ensure that only consenting persons will be allowed within 100 feet of the flight operation, 

and this radius may be reduced to 30 feet based upon an equivalent level of safety 

determination.

11. Pilot, and Spotter (Observer) will have been trained in operation of sUASs 

generally and received up-to-date information on the particular sUAS to be operated as 

required.

12. Spotter (Observer) and Pilot will at all times be able to communicate by voice or 

radio.

13. Written and/or oral permission from the relevant property holders will be 

obtained.

14. If the sUAS loses communications or loses its GPS signal, the sUAS will have 

capability to return to a predetermined location and land.

15. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, 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 

Sky Edge Photography, an exemption from 14 CFR Part 21 Subpart H meets the 

requirements of an equivalent level of safety under 14 CFR Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform 

Act both authorize the FAA to exempt aircraft from the requirement capability, and proximity 

to airports and populated areas of the particular UAS. In all cases, an analysis of these 

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, or safer, 

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 weighs less than 5 lbs. fully loaded, carries 

neither a pilot nor passengers, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a limited radius area as set out in the pre-flight briefing / VLOS

operations. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the Operator, pursuant to safety requirements, and under 

the requirements and in compliance with local public safety requirements, to provide 

security for the area of operation as is now done with conventional aircraft. These safety 

enhancements, which already apply to civil aircraft operated in connection with video 

production, provide a greater degree of safety 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 of these same criteria demonstrates that there 

is no credible threat to national security posed by the sUAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load.
14 CFR §45.23 (b):

With regard to marking of the aircraft, this 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, the words “limited,” “restricted”, “light-sport,”

“experimental,” or “provisional,” as applicable.

Even though the sUASs will have no airworthiness certificate, an exemption may be needed 

as the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAVs, two inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with 14 

CFR §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage 

as required by 14 CFR §45.29 (f) where the Pilot, Spotter (Observer) and others working 

with the sUAV will see the identification of the UAS as “Experimental.” The FAA has issued 

the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A.

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations Pilot in Command 

(PIC)

Sections 61.113 (a) & (b) limit private pilots to noncommercial operations. Because the 

sUASs will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to 

have a private pilot’s license rather than a commercial pilot’s license to operate this sUAS. 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and restricted, 

and all flights are planned and coordinated in advance as set forth in the Operating Manual. 

The level of safety provided by the requirements included in the Operating Manual meets 

that provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with commercial operations contemplated by

Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot 

as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

14 CFR §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 for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Operating Manual for 

maintenance and use of safety checks prior to each flight, as set forth in the Operating 

Manual, an equivalent level of safety will be provided. However, as required by 14 CFR 

91.7(b) a preflight assessment will be conducted.
14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides:

No person may operate a U.S.registered civil aircraft ... (2) For which an Airplane or 

Rotorcraft Flight Manual is not required by §21.5 of this 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 of safety will be maintained by keeping the Operating Manual at the 

ground control point where the pilot flying 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 CFR §91.103: Preflight Action

This regulation requires each PIC to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. An equivalent level of safety will be provided as set forth in the 

Operating Manual. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation 

of flight.

14 CFR §91.109: Flight Instruction

Section 91.109 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 have 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. See Exemptions Nos. 5778K & 9862A. The 

equivalent level of safety is provided by the fact that aircraft will be piloted by a certified 

private pilot who has previously trained in remote flight areas before attempting flight within 

filming distance of structures.

14 CFR §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil 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, Sky Edge Photography requests 

authority to operate at altitudes up to 200 ft. AGL; an exemption may be needed to allow 

such operations. As set forth herein, the sUAS will never operate at higher than 200 ft. AGL. 

It will however be operated in a controlled area where buildings and people will not be 

exposed to operations without their pre-obtained consent.
The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as 

well as location where it is operated. No flight will be taken without the permission of the 

property owner and without advance notice to participants. Because of the advance notice 

to the property owner and participants in the photographic activity, all affected individuals 

will be aware of the planned flight operations as set forth in the Operating Manual. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 

5 lbs. proposed herein and because of the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 ft. AGL. In addition, the low-altitude operations of the sUAS will 

ensure separation between these small UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings

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 will 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, pursuant to the Operating 

Manual and Safety Checklist, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point 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 provides approximately 20 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would 

be impossible. Given the limitations on the sUAS’s proposed flight area and the location of 

its proposed operations within a predetermined area, a longer time frame for flight in 

daylight or night VFR conditions is reasonable.

Sky Edge Photography 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 sUAS in a tightly controlled 

area where only people and property owners or official representatives who have signed 

waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the 

type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of 

the sUAS. Additionally, limiting sUAS flights would greatly reduce the utility for which the 

exemption will be granted.

Sky Edge Photography believes that an equivalent level of safety can be achieved by

limiting flights to 20 minutes or 25% of battery power whichever happens first. This 

restriction would be more than adequate return the sUAS to its planned landing zone from 

anywhere in its limited operating area. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745,

10673, and 10808.
14 CFR §91.203 (a) and (b): Carrying Civil Aircraft 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 (b) of this 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 sUAS fully loaded weighs no more than 5 lbs. and is operated without an onboard Pilot. 

As such, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the Pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS, and should they be issued. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions 

includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require that 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 section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the Sky Edge Photography. Maintenance will be 

accomplished by the operator; pursuant to the Operating manual. An equivalent level of 

safety will be achieved because these sUASs 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 sUAS can land immediately and will be operating from no higher than 200 ft. AGL. 

As provided in the Operating Manual, the PIC (operator) will ensure that the sUAS is in 

working order prior to initiating flight, and perform required maintenance. 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.

Publication Summary

Pursuant to 14 CFR 11.81(f), 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 CFR § 21, subpart H; 14 CFR § 45.23 (b); 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) and 91.417 (a) & (b) to operate 

commercially Small Unmanned Aircraft Systems (5lbs or less) in photography and 

videography operations.
Privacy

All flights will occur over private or controlled access property with the property owner’s prior 

consent and knowledge, or over remote public land. Image capture of people will rarely take 

place, but in the event they are, they will have consented prior to being filmed or otherwise 

have agreed to be in the area where data collection will take place.

Airborne Image Capture

With regard to airborne filming, Sky Edge Photography adheres to all FAA regulations. 

Further Sky Edge Photography airborne teams operate under the principles of: Safety First, 

Quality Assurance, Accountability, Reporting, and Training. When approved by the FAA, it 

is Sky Edge Photography’s mandate to treat all sUAS operations the exact same level of 

professionalism and seriousness as that of conventional aircraft. Approval of exemptions 

allowing commercial operations of sUASs in our industry will enhance safety by reducing 

risk. Conventional operations, using turbine or piston powered aircraft, present the risks 

associated with vehicles that weigh in the neighborhood of 2,000lbs.+, carrying large 

amounts of Jet A or 100LL. Such aircraft must fly to and from location. In contrast, a sUAS 

weighing fewer than 5 lbs, and powered by batteries, eliminates virtually all of the risk, given 

the substantial reduced mass and lack of combustible fuel carried on board. The sUAS is 

typically transported to the location via auto, or cargo van, in a medium sized case and is 

never flown to the site. The sUAS will carry no passengers or crew and, therefore, will not 

expose them to the risks associated with manned aircraft.

The operation of sUASs, weighing less than 5lbs, conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of 14 CFR Part 

21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a sterile environment. As a result, they are far safer than 

conventional operations conducted with piston helicopters, or fixed wing aircraft operating in 

relatively close proximity to the ground and people.

The primary market of interest for Sky Edge Photography utilizing sUASs is aerial 

videography and photography. 

It is anticipated that the airborne image capture process will be accomplished exclusively in 

daytime VFR environments. To capture the highest quality of resolution the majority of 

airborne data collections will take place during the 10:00am – 4:00pm window.
Summary of Application

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security – provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of applicant’s sUASs for 

aerial videography and photography. Operating Manual appended hereto. Sky Edge 

Photography is eagerly standing by to support the FAA and sUAS community in its quest to 

establish proper regulations and protocols for the safe introduction of unmanned aircraft into 

the national airspace.

Sincerely,

Alex Kimball

Sky Edge Photography

3981 Perch Circle

Willits, CA 95490

707-456-9303

abkimball84@gmail.com