To	whom	it	may	concern,

My	name	is	Cody	Villalobos,	I	am	writing	you	in	regard	to	the	FAA	restrictions	on	

drone	use	for	services	other	than	recreational	in	which	to	be	granted	an	exemption.	

I	believe	I	have	a	strong	case	that	qualifies	for	an	exemption	due	to	my	clientele,	

operating	as	a	legal	business,	and	most	importantly	my	location	of	operations.

I	have	the	intentions	to	start	a	small	video	business	using	the	DJI	Inspire	drone	and	

camera.	This	is	the	newest	release	from	the	company	DJI,	which	features	the	latest	

and	SAFEST	technology.	For	instance,	this	drone	has	three	down	facing	sensors	that	

allow	the	drone	to	maintain	stability	in	any	location	if	GPS	is	not	available.	

The	strongest	point	of	contention	to	obtain	an	exemption	is	my	location.	I	will	be	

operating	in	the	desolate	state	of	Nevada	that	has	been	approved	back	on	June	9,	

2014	as	a	UAS	Drone	Test	Site.	I	will	be	conducting	the	majority	of	my	business	in	

the	small	farm	town,	where	I’m	from,	of	Yerington	Nevada.	With	a	population	of	

3,000,	Yerington	is	nationally	recognized	as	a	leader	in	produce	and	farm	

production. The	state	of	Nevada	ranks	9th least	densely	populated	in	the	entire	

nation,	with	almost	75%	of	the	population	living	in	Clark	County.	Whereas	

Yerington	is	the	county	seed	of	Lyon County	which	makes	up	for	a	mere	1.9%	of	the	

state’s	population	according	to	the	2010	census.	Although	the	majority,	not	every	

single	business	flight	will	be	flown	in	Yerington.	If	any	account	for	this	rarity,	it	will	

be	within	the	surrounding	rural	towns around	Yerington,	within	our	desolate	area.

My	second	point	of	contention	is	Nevada’s	economy.	Nevada	has been	known	for	

being	slow	and	very	much	effected	by	the	recession,	due	to	the	state’s	leading	

economic	force	being	gambling	and	tourism.	We	have	been	recognized	multiple	

times	as	having	the	highest	unemployment	rate	in	the	nation,	but	currently	made	

the	improvement	to	the	number	46	spot	of	the	50	states.	As	of	December 2014,	we	

have	been	ranked	as	fifth in	leading	the	nation	of	foreclosure	filings.	That	constitutes	

for	1	in	every	680	housing	units	receiving	foreclosure.	Our	real	estate	market	has	

taken	a	serious	hit,	and	has	struggled	repairing	itself	after	the	recession.

My	third	point	is	my	company’s	target	market.	The	clientele	I	will	be	providing	

services	to	are	those	of	whom	I	have	described	their	location	above.	From	local	

farmers	to	realtors	to	small	car	dealerships,	I	will	target	any	and	all	small	

businesses.	Yerington	is	home	to	the	company	Peri	&	Sons	Farms	along	with	Nevada	

Fresh	Pak	and	Nevada	Onion	Inc. All	three	companies	are	huge	farming	companies	

that	generate	a	huge	majority	of	our	county’s	business.	Providing	them	the	service	

of	footage	of	their	farms	from	the	air	would	give	them	a	competitive	advantage	and	

insight	to	their	own	production	as	well	as	advertising.	This	would	help	support	our	

economy’s	number	one	job	supplier,	which	would	have	a	positive	ripple	effect	

throughout	our	small	town	and	surrounding	areas.	My	next	most	likely	clientele	

would	be	realtors.	Providing	them	photos	and videos	of	properties	from	the	air	

would	make	any	and	all	listings	more	appealing	which	would	allow	them	to	sell	

easier,	which	would	boost	our	housing	market.	This	competitive	advantage would	
boost	our	foreclosure	rating	from	the	5th in	the	nation	to	something	more	

acceptable.	

My	last	point	of	contention	is	that	of	operating	as	a	legal	business.	Obtaining	legal	

business	licensing	in	order	to	provide	aerial	footage	would	be	a	taxable	small	

business	that	would	not	only	account	for	an	added	business	to	our	economy,	but	

also support	and	further	promote	fellow	Nevada	businesses	that	would	in	general	

boost	our	economy.

Granting	my	future	business	and	I	the	exemption	in	order	to	use	an	unmanned	

drone	camera	in	a	legal	format	will	allow	me	to	create	my	business	and	in	return,	

boost	any	and	all	businesses	throughout	my	area.	My	location	is	my	strongest	

contention,	by	being	very	desolate	and	having	farms surrounded	by	empty	deserts.	

All	of	my	points	come	with	safe	and	considerate	flying	techniques	in	which	will	

follow	other	FAA	guidelines	already	set	forth	for	recreation	use.	In	conclusion,	I	

request	an	exemption	for	myself	and	future	company	named	“Rise	Optics”	due	to	my	

location	and	target	clientele	which will	benefit	all	parties	involved	while	legally	

complying	to FAA	regulations.	

Thank	you	for	your	time	in	reviewing	my	application	for	exemption!

-Rise	Optics

						Cody	Villalobos