Mr. Hoot Gibson

Senior Advisor on UAS Integration

Federal Aviation Administration

Dear Mr. Gibson:

As the Director of Risk and Regulatory Affairs for the National Ski Areas Association 

(NSAA), I would like to formally support and request that Cape Productions receives an amendment to 

its current Section 333 exemption to operate the company’s drone video service at its partners' resorts 

this ski season.

NSAA is the national trade association for ski area owners and operators in the United States 

and Canada. We represent more than 330 alpine and Nordic ski resorts, which account for more than 

90 percent of the skier/snowboarder visits nationwide. Our primary objective is to meet the needs of 

ski area owners and operators nationwide, and to foster, stimulate, and promote overall growth in both 

the sport and the industry. In one of my roles as the Director of Risk and Regulatory Affairs for 

NSAA, I help educate resort owners and managers on how to better operate their resorts at the highest

levels of safety for both their guests and their employees. Because of the inherently risky nature of 

skiing and snowboarding, ski areas are often hit with claims and lawsuits resulting from guest injuries, 

which can impact insurance premiums, reputations, brands, and their overall bottom lines. 

Understandably, safety at ski resorts is of paramount importance to the ski areas, their shareholders,

NSAA, and resort risk managers and ski patrol directors across the United States.

Since its founding, Cape Productions has worked closely with ski resorts, as well as directly 

with me and NSAA, to create the new gold standard for safe drone operations at ski areas for both 

winter and summer recreational activities. I have followed Cape's business since its founding, and 

their operational record speaks for itself—thousands of successful missions across ski resorts in 

Canada and New Zealand without any incidents or injuries. Every time Cape partners with a new 

resort, they need to work directly with the resort's director of risk management, mountain operations 

director, and their ski patrol director, as well as their legal team and insurance company to ensure the 

highest levels of safety for their guests and the public. The fact that Cape already has eight resort 

partners across the United States is a testament to the levels of safety they have created through strict 

practices and protocols for their drone operations. While most ski resorts in the United States have

banned guests from operating their own drones as hobbyists at ski resorts, the industry has embraced 

Cape given the company’s operational excellence, well developed risk management practices, and their 

overall commitment to safety. 
Given their pioneering efforts at safe drone operations, once the FAA approves commercial use 

of drones in the next year or two, ski areas will be embracing and mirroring many of the practices Cape 

Productions has forged. The industry and our resort guests have tremendous interest in Cape’s 

services, and given their exemplary safety record, NSAA overwhelmingly endorses and supports 

Cape’s application for their amendment to its Section 333 application. 

If you have questions, please contact me at dbyrd@nsaa.org or at (720) 963-4213. 

Sincerely,

Dave Byrd

Director of Risk and Regulatory Affairs

National Ski Areas Association