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 receive s 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 s ki 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 i ndustry. In one of my role s 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 highes t 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, s afety 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 foundi ng, 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 sinc e its founding, and

their operat ional 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

. Th e 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 resort s 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, p lease contact me at dbyrd@nsaa.org or at (720) 963

- 4213

.

Sincerely,

Dave Byrd Director of Risk and Regulatory Affairs

National Ski Areas Association