Ricardo A. Pizzi President 305.804.1082 rapizzi@pzstudios.com 8895 SW 229 Street Cutler Bay , FL 33190

www. pzstudios.com 

### Tuesday, February 23, 2016



### Attn: U.S. Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

RE: PZ Studios, Inc. EXCEPTION REQUEST PURSUANT TO SECTION 333 OF THE FAA REFORM ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM:

 1 4 CFR 21 subpart H

 14 CFR 45.23(b)

 14 CFR 61.113(a) and (b)

 14 CFR 91.7(a)

 14 CFR 91.9(b) (2)

 14 CFR 91.103

 14 CFR 91.109

 14 CFR 91.119(c)

 14 CFR 91.121

 14 CFR 91.151(a)

 14 CFR 91.203 (a) and (b)

 14 CFR91.405 (a)

 14 CFR 91.407 (a) (1)

 14 CFR 91.409 (a) (1) and (2)

 14 CFR 91.417 (a) and (b)

Ricardo A. Pizzi President PZ Studios, Inc.

8895 SW 229 ST Cutler Bay, FL 33190 

### M: 305.804.1082 rapizzi@pzstudios.com2 | P a g e 

## Table of Contents

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................................ ..................... 3

INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ ................................ .................. 4

PETITIONER CONTACT INFORMATION

................................ ................................ ................................ .......... 5

UNMANNED AIRCRAFT SYSTEM: 3DR SOLO

................................ ................................ ................................ . 6

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

................................ ................................ ............................ 7

SPECIFIC SECTIONS OF 14 CFR FROM WHICH PZ STUDIOS, INC. SEEKS EXEMPTION

................................ ... 9
14 CFR Part 21, Subpart H: Airworthiness Certification

................................ ................................ ............ 9
14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

..................... 9

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

................................ ................................ ....................... 10
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

................................ ......................... 10
14 C.F.R. § 91.103: Preflight Action

................................ ................................ ................................ ........ 10
14 C.F.R. §91.109: Flight Instruction

................................ ................................ ................................ ....... 10

14 C.F.R. §91.119: Minimum Safe Altitudes

................................ ................................ ........................... 11
14 C.F.R. §91.121 Altimeter Settings

................................ ................................ ................................ ...... 11
14 C.F.R §91.145(b) Management of aircraft operations in the vicinity of aerial demonstrations and major sporting events CFR 91.145 states:

................................ ................................ .............................. 12
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

................................ .................. 12
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

.............................. 13
14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

.......................... 13

CONCLU SION

................................ ................................ ................................ ................................ ............... 143 | P a g e



## GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
ATC Air Traffic Control
CFR Code of Federal Regulations

FAA Federal Aviation Administration

FAR Federal Aviation Regulation
FOM Flight Operations Manual
GPS Global Positioning System
NAS National Airspace System
PIC Pilot In Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA)
SO Safety Observe r UA Unmanned Aircraft
UAS Unmanned Aircraft System

VFR Visual Flight Rules
VMC Visual Meteorological Conditions4 | P a g e



## INTRODUCTION AND INTERESTS OF THE PETITIONER

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11. PZ Studios, Inc., Ricardo A. Pizzi, owner of an Unmanned Aircraft System (UAS), 3DR Solo, hereby applies for an exception from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with a camera, onboard computer, sensors and safety features, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and /or private use including television, public/sporting events, cinematography, and news gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

 Aerial video and/or photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

 The ability to offer training to perso ns individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the p rotection of the people and property.

As described fully below, the requested exemption would permit the operator of a UAS under controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined and d) will provide safety
enhanceme nts to the already safe operations in the 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 requir ements for the safe operation of such aircraft systems in the national airspace system.”5 | P a g e



## PETITIONER CONTACT INFORMATION

Name:
Ricardo A. Pizzi

Company: PZ Studios, Inc.

Address:
8895 SW 229 ST Cutler Bay, FL 33190

Mobile Phone:
305.804.1082

eMai l: rapizzi@pzstudios.com6 | P a g e



## UNMANNED AIRCRAFT SYSTEM: 3DR SOLO

PZ Studios, Inc., seeks an exemption to operate the 3DR Solo UAS for compensation or hire within the
NAS. The 3DR Solo is powered by two 1 GHz computers , including many world

- first technologies and a
host of built

- in safety and support features like a pause button on the controller, an adjustabl e preconfigured flight ceiling , and in

- app flight zone information and alerts. The dual built

- in comput ers constantly monitor the UAS flight with 500 parameters of flight data, 20 times a second. This is the only
UAS that logs these data on both the controller and the copter

.
The controller provides control mechanisms and displays in

- flight data on a full

- color screen. Using twin long

- range antennas, the controller acts as the central hub for all communication on the 3DR Link network, receiving all communications from Solo and the app, forwarding telemetry outputs to the app, and managing the transmission o f all control inputs to Solo.

3 DR Solo uses a Pixhawk 2 autopilot running ArduPilot Copter software. ArduPilot is open

- source flight control based on the MAVlink communication protocol. Pixhawk 2 runs an ARM Cortex

- M4 STM32F427 processor with 2 MB of flash memory and 256 KB of RAM. Combined with an array of CAN, I2C, SPI, PWM, and UART interfaces, Pixhawk 2 uses a suite of on

- board sensors to calculate Solo’s orientation and motion in flight. This data is input into ArduPilot’s inertial navigation and posit ion

- estimation algorithms and combined with control inputs to send commands to Solo’s propulsion system.

3DR Solo uses four brushless 880 Kv motors and four self

- tightening propellers for propulsion. For control and aerodynamic efficiency, two motors spin clockwise and two motors spin counter clockwise. Navigation in the air is achieved by mixing propulsion of the four motors to actuate flight control along the roll, pitch, and yaw axes. Each of the four motors is numbered by the marking on the arm. These

n umbers correspond to the autopilot calculations for these commands and are used for indicating motor replacement procedures. Each motor is controlled by an ESC (Electronic Speed Controller) that regulates the rotation of the motors to achieve the speed com manded by the autopilot.

3DR Solo parameters are as follows:

 Estimat ed flight time up to 25 minutes

 Default maximum altitude 150 ft. (46 m) above ground level

 Range .5 mile (.8 km)

 Payload capacity 1 lb. (450 g)

 Cruise speed 18 mph (8 m/s)

 M aximum speed 33 mph (15 m/s)

 Wind speed limitation 25 mph (11 m/s)

 Operating temperature 32° F

- 113° F (0° C to 45° C)7 | P a g e



## AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 50mph.

 Flights wi ll be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

 Maximum flight time for each operational flight will be 30 minutes.

 Flights will be terminated at 30% battery power reserve or 30 minutes of flight time whiche ver occurs first.

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL)

.

 Minimum crew for each operation will consist of the UAS Pilot and the Visual Observer (VO).

 The UAS pilot will have a minimum of 50 hours of fli ght time with the UAS.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activities.

 All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. In addition, an anemometer will be used prior to flight to measure wind speed, and atmospheric pressure in current flight location.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

 If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point (ARP ) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.

 The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upo n an equivalent level of safety determination, as required un der the FOM. With the advanced permission of the FSDO, operations at closer range may be approved.

 The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.8 | P a g e

 The UAS will have the capa bility to abort a flight in case of unpredicted obstacles, weather, or emergencies.9 | P a g e



## SPECIFIC SECTIONS OF 14 CFR FROM WHICH PZ STUDIOS, INC.
SEEKS EXEMPTION 14 CFR Part 21, Subpart H: Airworthiness Certification

14 C.F.R. §91.203 (a) (1) Subpart H, entit led 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 Applican t, 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 exemp t 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
demons trates 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 c ertificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively with in a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety en hancements 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 t here 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).


### 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or prop erty for compensation or hire. PZ Studios, Inc. may achieve an equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is
far less than the risk levels inherent in the comme rcial activities outlined in 14 CFR 61. The PIC of the UAS will have a minimum of 50 hours of flight time which exceed the safety levels in relation to 14 CFR10 | P a g e

61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the sa fe operation of the UAS.


### 14 C.F.R. §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, shoul d this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided. Prop locks h ave been issued for this aircraft so the possibility of a prop flying off mid flight is inevitable which also achieves a higher safety factor.


### 14 C.F.R. § 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 ma nual material, markings, and placards, or any combination thereof. The UAS, 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 UAS will have immediate access to it. If for some reason the Pilot for get s the flight manual, The app has all documentation indicated in the hard copy manual, electronically built into the application on your smart phone or tablet.


### 14 C.F.R. § 91.103: Preflight Action

This regulation requires each pilot in command to take cer tain 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. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. Before the aircraft takes flight, a home GPS location will be set for any reason the aircr aft becomes disoriented in flight, and return safely
to home.


### 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 a ircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is11 | P a g e

accomplished through the use of a control box that communicates with the aircraft via radio

commun ications. 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. 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 operate d 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 UAS that is a helicopter and the exemption requests authority to ope rate 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, the UAS will never operate at higher than 400 AGL with the exception t hat in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area wit h security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. It also may be operated over open water close to shore keeping a distance of 500 feet as indicated in Section 91.119 (c).

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 max imum 55lbs. proposed herein and
the lack of fl ammable 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 UAS will ensure separation between these UAS operat ions 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 UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety wi ll be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The Phantom uses DJI Vision Positioning. It is a positioning sy stem that uses ultrasonic and image data to help the aircraft identify its current position.12 | P a g e

With the help of Vision Positioning, the Phantom can hover in place more precisely and fly indoors or in other environments where there is no GPS signal available. The main components of DJI Vision Positioning are located on the bottom which include two sonar sensors and one monocular camera. This provides an significant level of safety.


### 14 C.F.R §91.145(b) Management of aircraft operations in the vicinity of aeria l demonstrations and major sporting events CFR 91.145 states:

(b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or major sporting event not listed in paragraph (a) of this section, the FAA considers the follow ing factors:

1) Area where the event will be held. 2) Effect flight restrictions will have on known aircraft operations. 3) Any existing ATC airspace traffic management restrictions. 4) Estimated duration of the event 5) Degree of public interest 6) Number of spectators. 7) Provisions for spectator safety. 8) Number and types of participating aircraft 9) Use of mixed high and low performance aircraft. 10) Impact on non

- participating aircraft. 11) Weather minimums. 12) Emergency procedures tha t will be in effect.

If PZ Studios, Inc. intends to use the UAS to cover sporting events from outside the activity, coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of any other unmanned activities. Flight activity will be conducted based on safety and with particular attention to the avoidance of overflight of large concentrations of people. However, specific relief from this regulation is still necessary to ensure compliance with FARs.



### 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 UAS provides approximately 2 5 minut es of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would not be possible. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined13 | P a g e

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and proper ty 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. Additi onally, this limitation 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 15 minutes or 30% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.


### 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:

a. An appropriate and current airworthiness certificate. . . .

b) No person may operate a civil aircraft unless the airworthiness cer tificate 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 op erated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the
UAS.

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

w here the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. Again if Pilot forgets documents, all documents can be achieved via the phone/table app.


### 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 s ection, 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 to14 | P a g e

the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a s mall payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. 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. Most importantly, 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.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure
that the UAS is in wor king order prior to initiating flight and perform required maintenance needed.



## CONCLUSION

As set forth herein, PZ Studios, Inc. seek s an exemption pursuant to 14 C FR Part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3DR
Solo UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over cert ain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing PZ Studios, Inc. to safely, efficiently, and economically operate the 3DR Solo UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, PZ Studios, Inc. respectfully reques ts that the Administrator grant this Petition for an exemptio n from the requirements of 14 CF R sections 21 subpart H, 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b) (2), 91.103, 91.109, 91.119(c), 91.121, 91.151(a), 91.203 (a) and (b), 91.405 (a), 91.407 (a ) (1), 91.409 (a) (1) and (2), 91.417 (a) and (b) and permit PZ Studios, Inc. to operate 3DR Solo UAS commercially for the purpose of conducting aerial video and photography over certain areas of the
United States.

Respectfully submitted,



### Ricardo A. Pizzi President PZ Studios, Inc.

8895 SW 229 ST Cutler Bay, FL 33190 

### M: 305.804.1082 rapizzi@pzstudios.com rappz@yahoo.com