July 29, 2015

Joseph M. Carfora
General Partner / Sales Director GR INNOVATIVE MEDIAWORKS, LTD. 707 Miamisburg-Centerville Rd., # 122 Dayton, OH 45459
Cell: 937.212.4824

United States Departrnent of Transportation Docket Management System 1200 New Jersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590

Re: Exemution Reguest Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of 2012 (the "Reform Act") and the procedures contained in 14 C.F.R. 11, to request that GR INNOVATIVE MEDIAWORKS LTD., owned and operated by Joseph Michael Carfora and three additional United States Citizen partners, each with 25% share in our privately-held start-up company established in August, 2014, Radmila Carfora, Gayatri G. Acebal (an Air Force Veteran) and Ariel O. Acebal (an Air Force Veteran), based in Dayton, Ohio, the birthplace of flight, with a mailing address of 707 Miamisburg-Centerville Rd., Dayton, Ohio 45459.

Joseph M. Carfora and his partners, named above, are joint owners and operators of two small unmanned aircrafft (UAS), request to be exempted from the Federal Aviation Regulations ("FARs") listed below so that GR INNOVATIVE MEDIAWORKS LTD. may operate its small unmanned aircraft / lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA").

As identified and described within this petition, Joseph M. Carfora, and his partners, as GR INNOVATIVE MEDIAWORKS, are experienced, recognized veterans in the photography, video capture / editing, and website development industries. Joseph M. Carfora is also fully employed in the medical device industry, a safety critical industry, by Boston Scientific Corporation for the past 13 years; Ariel O. Acebal is a retired Air Force veteran since 2013, and fully employed as a civilian in aerospace research; Gayatri G. Acebal is part-time employed as a physician's assistant, and a freelance videographer; and Radmila Carfora is part-time employed as a mechanical sales engineer, and a freelance photographer. Joseph M. Carfora and his partners have been providing quality services to their clients since 2014 as GR INNOVATIVE MEDIAWORKS is start-up company. Joseph has also been a flight simulator enthusiast that has regularly practiced for over thirty (30) years on light commercial aircraft and airline transport aircraft mostly through PC software and several times in real simulators, although he does not hold a private pilot's license. Joseph and Ariel are avid video editors and flight enthusiasts that have piloted UAS or RC aircraft as hobby pilots in the past.

GR INNOVATIVE MEDIAWORKS, LTD. has one FAA certified private pilot on staff, Mr. Sasha Lazic. Between Mr. Carfora, Mr. Lazic, Mr. Acebal and Mrs. Acebal, over 45 hours have been flown and logged appropriately since July, 2014 on our well-maintained and regularly used DJI Phantom 2 Vision+ UAS. A majority of our flights have been for hobby or non-commercial purposes and we have donated video toseveral local Dayton and out-of-state entities to help promote their businesses while we refining and

improving our UAS skills. Mr. and Mrs. Carfora also own Novation Property Management, an investment real estate management company (S-Corp) for their own investment properties in Ohio,
Arizona and South Carolina. GR INNOVATIVE MEDIAWORKS have used its DJI Phantom 2 Vision+ to make non-commercial promotional videos in order to promote its general partners' investment properties and to also demonstrate to the public, a novel, and useful perspective toward future real estate marketing.

GR INNOVATIVE MEDIAWORKS, LTD. have recently ordered a second UAS as we are working toward achieving compliance as a certified TourFactory vendor which would place us in compliance with TourFactory's COA by September 1, 2015 with Mr. Sasha Lazic as our Pilot In Charge (PIC) and Mr. Carfora as our primary trained observer for visual line of sight (VLOS) flights below 200 feet for private and commercial real estate. We understand very well the details of TourFactory's corporate policy and have received both their corporate compliance policy and FAA checklist in order to participate.

It is additionally the intention of GR INNOVATIVE MEDIAWORKS, LTD. to seek its own exemption or COA from the FAA in order to participate commercially, as we will already have the requirements in place as identified on the TourFactory COA. It only seems to be the next logical step for GR INNOVATIVE MEDIAWORKS, LTD.

This is a very exciting time. Joseph Carfora and his business partners are looking to add extremely unique and valuable services to its clients through GR INNOVATIVE 1VIEDIAWORKS, LTD. through the use of our small, lightweight UAS as several of our clients have requested this type of service commercially. Primary uses will be low altitude (<200 feet) aerial photography and videography for private and commercial real estate marketing, and small and medium-sized business, during daytime hours only with one Pilot-In-Charge (PIC) and one highly trained VLOS observer for all projects to be marketed through the TourFactory website initially, and to any external customers other than TourFactory with this exemption.

Joseph has operated GR INNOVATIVE MEDIAWORKS, LTD.'s current UAS (DJI Phantom 2 Vision+), purchased in July, 2014, on many occasions non-commercially without incident. The UAS utilizes a 5200mAh (11.1 V) LiPO battery power, and not combustible fuels. Flight time ranges between five and twenty five minutes and is flown only in decent weather conditions and in winds less than 15 knots. The UAS has not been flown in proximity to people or structures for safety reasons although we have had it in a variety of locations (Ohio, South Carolina, Florida and Illinois).

GR INNOVATIVE MEDIAWORKS, LTD. are extremely aware of safety while continually reviewing weather conditions and drone no-fly zones ma.ndated by the FAA. • Ariel O. Acebal is also a weather expert and continually provides GR INNOVATIVE MEDIAWORKS, LTD. with pre-flight weather condition briefings while coordinating with Joseph Carfora and our PIC, Sasha Lazic. • The UAS has GPS functionality to hover in place as well as a return to home (RTH) function in case of loss of contact with the radio. If the UAS loses contact with the radio, it will first increase its altitude to 150 feet (or another pre-set, pre-determined altitude) prior to returning to the last calibration point. • GR INNOVATIVE MEDIAWORKS, LTD. have established detailed pre-flight visual and mechanical inspections, detailed start-up procedures including compass and GPS RTH calibration which are laminated on a placard inside the travel case for each UAS, detailed landing procedures and post-flight procedures including completing a logbook entry for our UAS flights, tracking battery charge information on all of the UAS batteries, documenting weather, distance flown and recording flight time.

2• The UAS has audible and visual warning systems that will initiate a controlled, slow descent if

battery power reaches 25%. • The failsafe software will disable the UAS from taking off and also litniting / restricting the UAS systems from operating within specific GPS preset no-fly zones and as I mentioned, we constantly review the rnap for no-fly zones before we take to the air.

GR INNOVATIVE MEDIAWORKS, LTD's exemption request would pertnit its operation of lightweight, unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace.

GR INNOVATIVE MEDIAWORKS, LTD. retains both general business liability insurance and a separate drone liability insurance policy of $1.0M per incident, issued through Costello Insurance of Scottsdale, Arizona, which is already compliant with TourFactory's Corporate Policy.

At tlhe present time, similar lightweight, remote controlled UASs are legally operated by amateurs or hobbyists with little or no flight experience, no safety plan or no controls in place to prevent accidents. It is only logical to allow Joseph Carfora and Ariel O. Acebal, both experienced remote control pilots, and Sasha Lazic, an experienced remote control pilot and FAA private pilot license holder, to operate similar lightweight UASs for GR INNOVATIVE MEDIAWORKS, LTD. This will act to further safety protocols specific to lightweight UASs as GR INNOVATIVE MEDIAWORKS, LTD. researches flight data and other information gained through permitted flight operations.

We would also petition that the FAA grant Joseph Carfora an exemption as additional PIC, based on his logged and documented flights that have exceed 40+ hours (or 240 ten-minute fliglits including many take offs and many landings in both stable and windy conditions, both GPS and non-GPS mode), experience and expertise in flying the DJI Phantom 2 Vision+ Model UAS. It is GR INNOVATIVE MEDIAWORKS, LTD.'s intentioti to use its UAS primarily, but not solely for, real estate functions but additionally for small and medium business requirements for raw aerial atid raw photography and videography that may or may not require editing.

Grantitig this request agrees with the Secretary of Transportation's (FAA Administrator's) responsibilities to not ortly integrate UASs into the national airspace system, but to "...establish requirements for the safe operation of such aircraft systems [UASs] in the national airspace system" under Section 333(c) of tlle Reform Act. Further, GR INNOVATIVE MEDIAWORKS, LTD. will conduct its operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, GR INNOVATIVE MEDIAWORKS, LTD. respectfully requests the grant of atl exemption allowing it to operate lightweight, remote controlled UAS's.

1. Contact Information

: Joseph M. Carfora GR INNOVATIVE MEDIAWORKS, LTD. 707 Miatnisburg-Centerville Rd. Dayton, Ohio 45459 Tel.: (937) 212-4824

e-mail: imcarfora a.artnediaworks.com

2. The Specific Sections of Title 14 of the Code of Federal Regulations From Which We Reguest

Exemntion are

: 14 CFR 21; 14 C.F.R. 45.23(b);

314 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). U.S. Dep't of Transp.

3. The Extent of Relief GR MEDIAWORKS, LTD. Seeks and the Reason It Seeks Such Relief

: GR INNOVATIVE MEDIAWORKS, LTD. submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent GR INNOVATNE MEDIAWORKS, LTD. contemplated commercial cinematic, research and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Our lightweight UAS meets the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of our lightweight UAS is expressly contemplated by the Reform Act. We would like to operate our lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such crafft.

The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our National airspace system. Considerations include: • The weight, size, speed and overall capabilities of the UAS; • Whether the UAS will be operated near airports or populated areas; and, • Whether the UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for GR INNOVATIVE MEDIAWORKS, LTD. Our UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It weighs less than 5 pounds, including battery and all equipment. This small unmanned aircraft is designed to primarily hover in place and operate at less than a 50-knot maximum speed. It is capable of vertical and horizontal operations but operate only within the visual line of sight (VLOS) of the remote control pilot. In addition to the remote control pilot, we have designated a spotter, such that, at minimum, two appropriately trained GR INNOVATIVE MEDIAWORKS, LTD. team members govern the safe flight of the aircraft at all times.

Utilizing battery power and not combustible fuels, flights generally last between five and twenty-five minutes. We do not operate the UAS with less than twenty five percent remaining battery capacity. Safety systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff location (RTH) if communication with the radio control pilot is lost and then slowly descend the UAS at twenty five percent battery capacity. We generally do not operate the UAS near airports, near populated areas or near stadiums. To date, we have only operated the UAS in a non-commercial manner. However, we expect to operate commercially once we are in full compliance with the TourFactory COA and corporate policy.

Our operation of this small unmanned aircrafl will not "create a hazard to users of the national airspace system or the public" 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS, combined with its operation in cordoned off and well-controlled areas, this falls within Congress's contemplated safety zone when it promoted the Reform Act and the corresponding directive to integrate UASs into the national airspace system. We are confident that our UAS or subsequent UAS aircrafft will not pose any threat to the general public or national security.

The FAA has the authority to issue the exemption sought by GR INNOVATIVE MEDIAWORKS, LTD. pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

44. How this Reguest Will Beneft the Public As A Whole:

Granting this exemption request furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing of the Reform Act. Second, GR INNOVATNE MEDIAWORKS, LTD. conducts research into safe UAS operations every time it flies its UAS. Flight data, visual inspections, recorded observations and flight analyses are compiled in our flight logbook, including weather conditions, location and other key details, to further enhance current safety protocols. Allowing us to achieve more flight time directly relates to our research and our ability to further enhance current safety measures. Third, the public has an interest in reducing the danger and emission associated with current aerial cinematic capture methods, namely, full size helicopters. Our UAS is battery powered and creates no emissions. If our UAS crashes there is no fuel to ignite and explode. The impact of our lightweight UAS is negligible when compared to a full size helicopter, notwithstanding the statistically noteworthy safety record of full size helicopters used in motion picture capture. The public's interest is furthered by minimizing ecological and crash impacts by permitting photo and motion picture capture through our lightweight UAS.

Progression of the arts and sciences has been fundamental to our society since its inclusion in the United States Constitution. Indeed, Congress mandated the integration of UASs into our national airspace system, in part, to achieve progression in this noteworthy, and inevitable, field. Permitting GR INNOVATIVE MEDIAWORKS, LTD. to immediately fly within the United States furthers these goals. Whether it is the amalgam of scientific discoveries applicable to feature film making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or advancements in equipment available to law enforcement personnel / first responders that does not cost millions of dollars, granting this exemption request substantially furthers the public's interest in ways known and currently unknown.

Granting this request will also allow small business owners and home owners to be able to afford highquality aerial images and video that they would otherwise have no access to due to several factors, cost being the biggest.

5. Reasons Why GR INNOVATIVE MEDIAWORKS, LTD. Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Epual To Existing Rule: This exemption will not adversely affect safety. Quite the contrary, for the reasons stated, supra, permitting GR INNOVATIVE MEDIAWORKS, LTD. to log more flight time in FAA controlled airspace will allow us to innovate and implement new, as of yet undiscovered safety protocols. In addition, we submit the following representations of enhancements to current aerial photography and motion picture capture techniques: • Our UAS weighs less than 5 pounds complete with all mounted equipment and battery; • We only operate our UAS below 400 feet; • Our UAS only operates for 5-25 minutes per flight; • We land our UAS when it reaches 25% battery power; • Our remote control pilot operates the UAS by line of sight; • Our remote control pilot has video backup should he somehow lose sight of the UAS; • We staff each flight with a remote control pilot and spotter with communication systems enabling real time communication between them; • Our UAS has GPS flight modes whereby it hovers, returns to takeoff position and then slowly lands if communication with the remote control pilot is lost or battery power is below 25%; • We actively analyze electronic flight data and other sources of information to constantly update and enhance safety protocols; • We conduct extensive briefmgs prior to flight, during which safety carries primary importance, and;

~ 1• We have procedures in place to abort flights in the event of safety breaches or potential danger.

Our safety protocols provide a level of safety at least equal to existing rules, and in nearly every instance, greater than existing rules. It is important to note that absent the integration of commercial UASs into our national airspace system, helicopters are the primary means of aerial motion picture capture. While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery powered lightweight UAS. First, the potential loss of life is diminished because UASs carry no people on board and GR INNOVATIVE MEDIAWORKS, LTD. only operates them in specific areas away from mass population. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly reduced. Third, the small size and extreme maneuverability of our UAS allows our remote control pilot to avoid hazards and execute evasive safety measures quickly. Lastly, given their small size and weight, even when close enough to capture amazing images, our UAS needs not be so close to the objects it is focused on. Accordingly, our UAS has operated and will continue to operate at and above current safety

levels.

6. A Summarv The FAA Mav Publish in the Federal ReLyister

:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of GR INNOVATIVE MEDIAWORKS, LTD.'s UAS permits exemption from Part 21 because GR INNOVATIVE MEDIAWORKS, LTD. meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certifica.te requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. GR INNOVATIVE MEDIAWORKS, LTD.'s UAS meets or exceeds each of the

elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircrafft flight manual in the aircrafl. As there are no pilots or passengers, and given the size of the UASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as GR INNOVATIVE MEDIAWORKS, LTD. `s UAS utilizes electronic global positioning systems and internal gyroscopes to provide spatial coordination.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at GR INNOVATIVE MEDIAWORKS, LTD.'s flight operations center.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications.

6GR INNOVATIVE MEDIAWORKS, LTD.'s UAS is, by definition, unmanned. It therefore does not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft. Regardless, GR INNOVATIVE MEDIAWORKS, LTD. will mark its UAS in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29 (f) so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) &(b), private pilots are limited to non-commercial operations. GR INNOVATIVE MEDIAWORKS, LTD. can achieve an equivalent level of safety as achieved by current Regulations because GR INNOVATIVE MEDIAWORKS, LTD. UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. Further, the risks attendant to the operation of GR INNOVATNE MEDIAWORKS, LTD.'s UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing GR INNOVATIVE MEDIAWORKS, LTD. to operate its UAS with a private pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R. §61.113 (a) &(b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircrafft. It allows helicopters to be operated at lower altitudes in certain conditions. GR INNOVATIVE MEDIAWORKS, LTD.'s UAS will never operate at an altitude greater than 400 AGL. GR INNOVATIVE MEDIAWORKS, LTD. will, however, operate its UAS in cordoned off areas with security perimeters, providing a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of GR INNOVATIVE MEDIAWORKS, LTD.'s UAS, an equivalent level of safety will be

achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) ( 1): 409 a) (2); 417(a) & (b): Maintenance Inspections. The above-cited Regulations require, amongst other things, aircraft owners and operators to "have [the] 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. . . ."

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to GR INNOVATIVE MEDIAWORKS, LTD. should its requested exemption be granted. GR INNOVATIVE MEDIAWORKS, LTD. conducts an extensive maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

F. Summarv GR INNOVATIVE MEDIAWORKS, LTD. seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) &(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a)(2); and, 14 C.F.R. §§ 91.417 (a) &(b) to commercially operate its lightweight unmanned aircrafft vehicle(s) in motion picture or photography operations and to conduct its own research. Granting GR INNOVATIVE MEDIAWORKS, LTD.'s request for exemption will reduce current risk levels and thereby enhance safety. Currently, motion picture image capture relies primarily on the use of larger aircraft running on combustible fuel. GR INNOVATIVE MEDIAWORKS, LTD.'s craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional motion picture aircrafl. Further, GR INNOVATIVE MEDIAWORKS, LTD.'s operates at

7lower altitudes and in controlled airspace. GR INNOVATIVE IVIEDIAWORKS, LTD.'s has been

analyzing flight data and other information in compiling novel safety protocols and the implementation of a flight operations manual that exceeds currently accepted means and methods of safe flight. There are no people on board GR INNOVATIVE MEDIAWORKS, LTD.'s UAS and therefore the likelihood of death or serious bodily injury is significantly limited. GR INNOVATIVE MEDIAWORKS, LTD.'s operation of its UAS, weighting less than 5 pounds and travelling at speeds lower than 50-knots in cordoned off areas will provide at least an equivalent level of safety as that achieved under current FARs.

Accordingly, GR INNOVATIVE MEDIAWORKS, LTD. respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by GR INNOVATIVE MEDIAWORKS, LTD. pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Finally, we appreciate the time involved for the FAA to review and grant these exceptions. This represents huge potential growth for the United States economy which will positively affect jobs, lives, and small business growth such as in the case of GR INNOVATIVE MEDIAWORKS, LTD. Many people have chosen to ignore the FAA and fly "under the radar." Most have no intention of ever petitioning for an exemption or seeking appropriate insurance coverage because they don't even know it exists. We started our business looking to the future opportunity and the potential that aerial photographyand videography can bring many. We've had a year to analyze, learn and compile projects noncommercially and I am happy to say that we can initially take the next step of moving to "commercially" with the TourFactory exemption to start, the addition of a FAA licensed pilot to our team and the experienced we've built flying the past year on our own real estate investment projects. As I said before, this is a very exciting, yet challenging time, which presents a unique opportunity for startups like GR INNOVATIVE 1VIEDIAWORKS, who pride themselves on safety and compliance first.

Thank you very much for your time a.nd commitment to keep our skies safe, while also looking at the commercial opportunities that UAS presents to our great and hopefully growing economy. We look forward to your decision to grant an exemption for GR INNOVATIVE MEDIAWORKS, LTD.

Sincerely,

Jos ph M. Carfora eral Partner / Oper GR INNOVATIVE MEDIAWORKS, LTD.

cc: A. Acebal
S. Lazic

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