Aerial	Approach,	ltd.

Greyson	Morrow,	CEO

3520	26th St.	NW

Canton,	Ohio	44708

U.	S.	Department	of	Transportation	Docket	Management	System

1200	New	Jersey	Ave.,	SE	

Washington,	DC		20590		

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation	

Regulations	from	14	CFR	61.113	(a)	&	(b)	14	CFR	91.9	(b)	(2)	14	C.F.R.	91.103	14	C.F.	R.	91.119	14	C.F.R.	

91.121	14	CFR	91.151	(a)	14	CFR	91.405	(a)	14	CFR	407	(a)	(1)	14	CFR	409	(a)	(2)	14	CFR	417	(a)	&	(b)		

To	Whom	It	May	Concern:		

This	application	is	being	submitted	on	my own	behalf.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	Reform	Act)	and	14	

C.F.R.	Part	11,	Aerial	Approach,	ltd.,	 operator	of		Small	Unmanned	Aircraft	Systems	(“sUASs”)	equipped	

to	conduct	aerial	photography	and	videography for	the	real	estate	industry, 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	333.1		

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	3)	controlled	as	to	access	and	4)	would	provide	safety	enhancements	to	the	already	safe	

operations	in	the	real	estate industry presently	using	conventional	aircraft.		Approval	of	this	exemption	

would	thereby	enhance	safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’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.		The	name	and	address	of	the	applicant	is:		

Aerial	Approach,	ltd.	

Contact:	Greyson	Morrow

3520	26th St	NW

Canton,	Ohio	44708

330-232-5607
Regulations	from	which	the	exemption	is	requested:		

14	CFR	61.113	(a)	&	(b)	14	CFR	91.9	(b)	(2)	14	C.F.R.	91.103	14	C.F.	R.	91.119	14	C.F.R.	91.121	14	CFR	

91.151	(a)	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	law	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	UAS’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	of	the	operator.		

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.”	Id.	§333(c)	(emphasis	added)2.		

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.		

2	Applicant	interprets	this	provision	to	place	the	duty	on	the	Administrator	to	not	only	process	

applications	for	exemptions	under	section	333,	but	for	the	Administrator	to	craft	conditions	for	the	safe	

operation	of	the	UAS,	if	it	should	be	determined	that	the	conditions	set	forth	herein	do	not	fulfill	the	

statutory	requirements	for	approval.	

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	prescribed	under	

subsection	(a)	or	(b)	of	this	section	or	any	sections	44702-44716	of	this	title	if	the	Administrator	finds	

the	exemption	in	the	public	interest.		49	U.S.C.	§44701(f)			See	also	49	USC	§44711(a);	49	USC	§44704;	

14	CFR	§91.203	(a)	(1).		

Aerial	Approach,	ltd’s		UASs	are	rotorcraft,	weighting	5 or	fewer	lbs.	including	payload.		They	operate,	

under	normal	conditions	at	a	speed	of	no	more	than	30 knots	and	have	the	capability	to	hover,	and	

move	in	the	vertical	and	horizontal	plane	simultaneously.		They	will	operate	only	in line	of	site.		Such	

operations	will	insure	that	the	sUAS	will	“not	create	a	hazard	to	users	of	the	national	airspace	system	or	

the	public.”4		

Given	the	small	size	of	our sUASs,	the	applicant	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	UASs	and	the	restricted	areas	

in	which	the	relevant	sUASs	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;	the	strong	equivalent	level	of	safety	surrounding	the	proposed	operations,	

and	the	significant	public	benefit,	including	enhanced	safety,	reduction	in	environmental	impacts,	

including	reduced	emissions	associated	with	allowing	UASs	for	photography,	the	grant	of	the	requested	

exemptions	is	in	the	public	interest.		Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	

the	requested	exemption	without	delay.		

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY		

The	applicant	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that	have	the	

characteristics	and	that	operate	with	the	limitations	listed	herein.		These	limitations	provide	for	at	least	

an	equivalent	or	even	higher	level	of	safety	to	operations	under	the	current	regulatory	structure	

because	the	proposed	operations	represent	a	safety	enhancement	to	the	already	safe	movie	and	

television	filming	operations	conducted	with	conventional	aircraft.		

These	limitations	and	conditions	to	which	Aerial	Approach,	ltd. agrees	to	be	bound	when	conducting	

commercial	operations	under	an	FAA	issued	exemption	include:																																																	

1.	The	sUAS	will	weigh	less	than	5 lbs.	2.	Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	

observer.	3.	Maximum	total	flight	time	for	each	operational	flight	will	be	25 minutes.		Flights	will	be	

terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	the	25 minute	limit.	4.	Flights	will	be	

operated	at	an	altitude	of	no	more	than	400	feet	AGL	or,	not	more	than	200	feet	above	an	elevated	

platform	from	which	filming	is	planned.	5.	Minimum	crew	for	each	operation	will	consist	of	the	sUAS	

Pilot,	and	the	Visual	Observer.	6.	sUAS	Pilot	will	be	Pilot	in	Command	(PIC)	7.	The	UAS	will	only	operate	

within	a	confined	area.	8.	A	briefing	will	be	conducted	in	regard	to	the	planned	sUAS	operations	prior	to	

each	project.		It	will	be	mandatory	that	all	personnel	who	will	be	performing	duties	be	present	for	this	

briefing.	9.	The	operator	will	obtain	the	consent	of	all	persons	involved	in	the photography	and	filming

and	ensure	that	only	consenting	persons	be	allowed	within	50	feet	of	the	flight	operation.	10.	Pilot	and	

observer	will	have	been	trained	in	operation	of	UAS	generally	and	received	up-to-date	information	on	

the	particular	UAS	to	be.	11.	Observer	and	pilot	will	at	all	times	be	able	to	communicate	by	voice	and/or	

text.	12.	Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained.	13.	If	the	

sUAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	return	to	a	predetermined	location	within	the Security	Perimeter	and	land.		14.	The	sUAS	will	have	the	capability	to	

abort	a	flight	in	case	of	unpredicted	obstacles	or	emergencies.	

		

		

14	C.F.R.	Part	21,	Subpart	H:		Airworthiness	Certificates	14	C.F.R.	§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	the	Applicant,	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	U.S.C.§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	

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	is	less	than	5 lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger,	

carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operates	exclusively within	a	secured	area.		

Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by		

the	operator.		These	safety	enhancements	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	UAS,	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	

C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft		The	regulation	requires:		

When	marks	include	only	the	Roman	capital letter	"N"	and	the	registration	number	is	displayed	on	

limited,	restricted	or	light-sport	category	aircraft	or	experimental	or	provisionally	certificated	aircraft,	

the	operator	must	also	display	on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	

in	letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	"limited,"	"restricted,"	"lightsport,"	"experimental,"	or	"provisional,"	as	applicable.		

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

although	there	is	no	entrance	to	a cabin,	cockpit	or	pilot	station	on	which	the	word	“Experimental”	can	

be	placed.		Given	the	size	of	the	sUAV,	two-inch	lettering	will	be	impossible.		The	word	“Experimental”	

will	be	placed	on	the	fuselage	in	compliance	with	§45.29	(f).		

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

§45.29	(f)	where	the	pilot,	observer	and	others	working	with	the	sUAV	will	see	the	identification	of	the	

UAS	as	“Experimental.”	

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	flight	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	C.F.R.	§	91.103:	Preflight	action			This	regulation	requires	each	

pilot	in	command	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	Sections	J	and	K	of	the	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	C.F.R.	§91.109:	Flight	instruction:			Section	

91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	being	

used	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	Exemption	Nos.5778K	&	9862A.		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.			14	C.F.R.	§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	that	is	a	helicopter	and	the	exemption	requests	authority	to	operate	at	altitudes	up	to	400	AGL,	or	

not	more	than	200	above	an	elevated	platform	from	which	filming	is	planned,	an	exemption	may	be	

needed	to	allow	such	operations.		As	set	forth	herein,	except	for	the	limited	conditions	stated	in	the	

Manual,	the	UAS	will	never	operate	at	higher	than	400	AGL.		It	will	however	be	operated	in	a	restricted	

area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed	to	operations	without	

their	pre-obtained	consent.			

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the	UAS	as	well	as	the	

location	where	it is	operated.		No	flight	will	be	taken	without	the	permission	of	the	property	owner	or	

local	officials.		Because	of	the	advance	notice	to	the	property	owner	and	participants	in	the	filming	

activity,	all	affected	individuals	will	be	aware	of	the	planned	flight	operations.	Compared	to	flight	

operations	with	aircraft	or	rotorcraft	weighting	far	more	than	the	maximum	55lbs.	proposed	herein	and	

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	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	C.F.R.	§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	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,	pursuant	to	the	Manual	and	Safety	Check	list,	confirming	the	altitude	of	the	launch	site	shown	

on	the	GPS	altitude	indicator	before	flight.		14	C.F.R.	§	91.151(a):		Fuel	Requirements	for	Flight	in	VFR	

Conditions		Section	91.151	(a)	prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	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	30 minutes	of	powered	flight.		To	meet	the	

reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	would	be	limited	to	approximately	10-12 minutes	in	

length.		Given	the	limitations	on	the	UAS’s	proposed	flight	area	and	the	location	of	its	proposed	

operations	within	a	predetermined	area,	a	longer	time	frame	for	flight	in	daylight	or	night	VFR	

conditions	is	reasonable.		

Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	exemptions.		

See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	to	operate	without	compliance	with	FAR	

91.151	(a)).		Operating	the	small	UAS,	in	a	tightly	controlled	area	where	only	people	and	property	

owners	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	small	UAS.		Additionally,	limiting	sUAS	flights	to	10	minutes	would	greatly	

reduce	the	utility	for	which	the	exemption	will	be	granted.		

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	minutes	or	

25%	of	battery	power	whichever	happens	first.		This	restriction	would	be	more	than	adequate	to	return	

the	sUAS	to	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area.		

Similar	exemptions	have	been	granted	to	other	operations,	including	Exemptions	2689F,	5745,	10673,	

and	10808.		14	C.F.R.	§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	(a)	

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	UAS	fully	loaded	weighs	no	more	than	55	lbs	and	is	operated	without	an	onboard	pilot.		As	such,	

there	is	no	ability	or	place	to	carry	certification	and	registration	documents	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.		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	

C.F.R.	§91.405	(a);	407	(a)	(1);	409	(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	applicant.		Maintenance	

will	be	accomplished	by	the	operator	pursuant	to	the	flight	manual.	An	equivalent	level	of	safety	will	be	

achieved	because	these	small	UASs	are	very	limited	in	size	and	will	carry	a	small	payload	and	operate	

only	in	restricted	areas	for	limited	periods	of	time.		If	mechanical	issues	arise	the	UAS	can	land	

immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.		As	provided	in	the	Manual,	the	

operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight,	perform	required	

maintenance,	and	keep	a	log	of	any	maintenance	performed.		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.			

The	operation	of	small	UASs,	weighting	less	than	55	lbs.,	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	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	safer	than	conventional	operations	conducted	with	turbine	

helicopters	operating	in	close	proximity	to	the	ground	and	people.				Privacy			All	flights	will	occur	over	

private	or	controlled	access	property	with	the	property	owner’s	prior	consent	and	knowledge.		Filming	

will	be	of	people	who	have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	

where	filming	will	take	place.		

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	UAS	in	the	real	estate	industry.

Sincerely,		

Greyson Morrow

CEO

Aerial	Approach,	ltd

3520	26th St.	NW

Canton,	Ohio	44708

greyson@aerialapproach.com

330-232-5607