Aerial	Approach,	ltd

. Greyson	Morrow ,	CEO 3520	26 th 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	appli cation	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	ope ration	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	operati on	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	alr eady	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	sy stems	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	26 th St	NW Canton,	Ohio	44708 330

- 232

- 5607Regulations	from	which	the	exemption	i s	requested:

14	CFR	61.113	(a)	&	(b)	14	CFR	9 1.9	(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	submitte d	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

com pletion	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,	fro m	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	Administ rator	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	regulatio n	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 U ASs	are	rotorcraft,	weighting	5 or	fewer	lbs.	including	payload.		They	operate,
under	normal	conditio ns	at	a	speed	of	no	more	than	30 knots	and	have	the	capability	to	hover,	and move	in	the	vertical	and	horizontal	plane	simultaneou sly.		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	FederalAviation	Act,	as	amended;	the	strong	equivalent	level	of	safety	surrounding	the	p roposed	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	interes t.		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
char acteristics	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	en hancement	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	exemp tion	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	ea ch	operational	flight	will	be	25 minutes. Flights	will	be terminated	at	25%	battery	power	reserve	s hould	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	pl anned.	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 sUA S	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	p ersons	be	allowed	within 5 0	feet	of	the	flight	operation .	10 .	Pilot	and observer	will	have	been	trained	in	operation	of	UAS	generally	and	received	up

- to

- date	informat ion	on the	particular	UAS	to	be.	11 .	Observer	and	pilot	will	at	all	times	be	a ble	to	communi cate	by	voice	and/or
text.	12 .	Written	and/or	oral	permission	from	the	relevant	prope rty	holders	will	be	obtained.	13 .	If	the sUAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	return	to	a	pre

determined	locati on	within	the Security	Perimeter	and	lan d.		14 .	The	sUAS	will	have	the	capability	to abort	a	flight	in	case	of	unpredi cted	obstacles	or	emergencies.

14	C.F.R.	Part	21,	Subpart	H:		Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)		Subpart	H,	enti tled 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	Applic ant,	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	toex empt	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	de monstrates	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
airworthine ss	certificate	without	the	restrictions	and	conditions	proposed.

The	sUAS	to	be	op erated	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	convention al	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	op eration,	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,	o r	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	UAS	will	have	no	airworthiness	certificate,	an	exemption	ma y	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	fus elage	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,	bu t	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.		Th e	FAA	has	issued	the	followingexemptions	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	provide s	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	functi onal	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

a ircraft	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	helicop ter 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	platfor m	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	restric ted 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	o f	the	planned	fli ght	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	c onventional	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	befo re	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	thefirst	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	li mitations	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	§91.15 1(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,	limi ting	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	fi rst.		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	documen ts	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):		Mainten ance	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	dis crepancies	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	w ill	not	apply	to	the	applicant.		Maintenance will	be	accomplished	by	the	operator	purs uant	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
onl y	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	equival ent	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	wit h	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	cons ented	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	populat ed	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	26 th St.	NW Canton,	Ohio	44708 greyson@aerialapproach.com 330

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