August 7, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) {2);91.103{b); 

91.109;91.119; 91.121; 91.151(a);91.203{a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Application: FAA-2015-0117 

To Whom It May Concern: 

In pursuant with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F .R. Part 11, Red 

Eye Productions, an operator of a small Unmanned Aircraft System (sUAS) for the Aerial Photography and 

Videography, seeks an exemption from the Federal Aviation Regulations (FARs) to allow commercial 

operations of its sUAS. Regulations ("FARs") to allow commercial operation of its sUASs, 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. 

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive sUAS under controlled conditions in airspace that is limited, predetermined, 

controlled as to access take photos and record videos for it's private portfolio. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the national 

airspace system." Section 333{c) of the Reform Act. 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81 

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, 

telephone number, or e-mail address; 

Red Eye Productions 

Attn: Seth Browarnik 

1691 Michigan Avenue, Suite 340 

Miami Beach, FL 33139 

Seth@WorldRedEye.com 

(b) The specific section or sections of 14 C.F.R. from which Red Eye Productions seeks an exemption 

• 21- Subpart H Certification procedures for products and parts, Airworthiness 

Certificates 

• 45.23- Display of marks; general 

• 61.113 - Private pilot privileges and limitations: Pilot in command 

• 91.103- Preflight Actions 

• 91.105- Flight crewmembers at stations 

• 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

• 91.119- Minimum safe altitudes: General 

• 91.121- Altimeter settings 

• 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

• 91.203 -Civil aircraft: certification required 
• 91.405- Maintenance required 

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, and 

alteration 

• 91.409 -Inspections 

• 91.417- Maintenance records 

(c) The extent of relief Red Eye Productions seeks, and the reason Red Eye Productions seeks the relief 

Red Eye Productions seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the 

extent to operate small UASs to record aerial photography and videography purposes. 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system" 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1). 

14 C.F.R. 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates 

Red Eye Productions seeks exemption from 14 C.F.R. 21, Subpart H which states the certification 

procedures for products and parts as well as airworthiness certificates. The sUAS 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 within a secured area as set out in the 

Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator, pursuant to the Manual's requirements, and under the requirements 

and in compliance with local public safety requirements, to provide security for the area of operation as is 

now done with conventional filming. The FAA will have advance notice of all operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with motion picture and 

television production, 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 there 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. 

Red Eye Productions has developed our own procedures and protocols to promote and provide safe flying 

experiences for our PIC(s) which can be viewed in section (e) of this petition. Unlike other civil aircraft, 
operations under this exemption will be tightly controlled and monitored by both the operator, pursuant 

to the Manual's requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Red Eye Productions seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. 

Specifically, section 45.23 states, "(a) each operator of an aircraft must display on that aircraft marks 

consisting of the Roman capital letter "N" (denoting United States registration) followed by the 

registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman 

capital letter (b) when marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," 

"light- sport," "experimental," or "provisional," as applicable". 

Red Eye Productions will need exemption from this regulation due to the small size of the aircraft and that 

there is no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" has been placed on 

the fuselage in compliance with §45.29 (f) where the pilot, observer and others working with the sUAS will 

see the identification of the UAS as "Experimental." Red Eye Productions will also register each aircraft in 

operations with a certified "N" number as required. The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

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

Red Eye Productions seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and 

limitations for the Pilot in command (PIC). 

Red Eye Productions is seeking exemption from this regulation, because Red Eye Productions believes that 

there is inconclusive evidence that a person with a private pilot certificate can successfully maneuver a 

sUAS without first hand flight experience with the particular sUAS. In fact, having a private pilot license 

does not automatically ensure competence at flying an sUAS in 3rd person view as required to properly 

operate an sUAS within the required line of sight. However, we believe that the PIC and our FOVO (Field 

Operation Visual Observer) must be able to understand and correctly interact with the general aviation 

community. Therefore, we believe our own flight training with the sUAS will be more than satisfactory. 

Our PIC and FOVO will be both certified in Ground School training to be able to properly interact with 

General Aviation protocols. They will also actively pursue at minimum a sport pilot's license as well have 

the necessary medical qualifications. 

14 C.F.R. 91.103- Preflight Actions 

Red Eye Productions seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command 

shall, before beginning a flight, become familiar with all available information concerning that flight. This 

information must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known traffic delays of which the pilot in command has been advised by ATC; actions, including 

reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance 

data before starting a flight. 

Red Eye Productions will be operating our sUAS in VFR. Our operations manual already includes preflight 

procedures directly pertaining to our sUAS which includes equipment checklist as well a preplanning 

details regarding weather conditions, review of any possible flight path of general aviation, our mission 

flight path and weather conditions amongst other parameters required to complete the mission. 

14 C.F.R. 91.105- Flight crewmembers at stations 

Red Eye Productions seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at 
stations. Specifically, 91.105 states "(a) During takeoff and landing, and while en route, each required 

flight crewmember shall (1) Be at the crewmember station unless the absence is necessary to perform 

duties in connection with the operation of the aircraft or in connection with physiological needs; and (2) 

Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a 

U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened 

while at his or her assigned duty station. This paragraph does not apply if (1) The seat at the 

crewmember's station is not equipped with a shoulder harness; or (2) The crewmember would be unable 

to perform required duties with the shoulder harness fastened. 

Red Eye Productions will need exemption from this regulation due to the fact that the sUAS will not have 

a flight crew or crew stations other than the PIC and a FOVO. The PIC, not being in the aircraft, therefore 

will also not have to be restrained into a seat via shoulder harness or safety belt at the time of the flight. 

14 C.F.R. 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

Red Eye Productions seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated 

instrument flight, and certain flight tests. Specifically, 91.109 states "(a) No person may operate a civil 

aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. However, instrument flight instruction may be given in an airplane that is 

equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when (1) The instructor has determined that the flight can be conducted 

safely; and (2) The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings. (b) An airplane equipped with a single, functioning throw over 

control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight 

instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by §61.57 when (1) The airplane is equipped with 

operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve 

and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve 

as pilot in command of the airplane, meets the requirements of §61.195(b), and has logged at least 25 

hours of pilot-in-command flight time in the make and model of airplane; and (4) The pilot in command 

and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil 

aircraft in simulated instrument flight unless (1) The other control seat is occupied by a safety pilot who 

possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft 

being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a 

competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except in 

the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, 

simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, 

functioning, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when 

(i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person 

manipulating the controls has at least a private pilot certificate with appropriate category and class 

ratings. (d) No person may operate a civil aircraft that is being used for a flight test for an airline transport 

pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless 

the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in 

command of the aircraft". Again, Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. (b) Over congested 

areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or 

sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control 

aircraft. If the operation is conducted without hazard to persons or property on the surface- (1) A 

helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) ofthis section, 

provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and (2) A powered parachute or weight-shift-control aircraft may 
be operated at less than the minimums prescribed in paragraph (c) of this section (a) Each person 

operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, 

by reference to an altimeter that is set, when operating-(1) Below 18,000 feet MSL, to-(i) The current 

reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If 

there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported 

altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a 

radio, the elevation of the departure airport or an appropriate altimeter setting available before 

departure; or (2) At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is 

determined by the atmospheric pressure in the area of operation as shown in the following table: 

Red Eye Productions believes that there is inconclusive evidence that a person with a private pilot 

certificate or license can successfully maneuver or train someone to use an sUAS without first hand flight 

experience with the particular sUAS. Flying in 3'd person orientation requires built-up experience in that 

form of flying for many years. Therefore, we believe our own flight training, pilot protocols and first hand 

experiences with the sUAS as laid out in our Flight Operations Manual meets and exceeds the 

requirements necessary to safely operate our sUAS for the tasks we purpose. Also, the sUAS will be 

operated by a remote control, which will only require a single person operator and dual controls for flight 

operation will not be necessary. 

14 C.F.R. 91.119- Minimum safe altitudes: General 

Red Eye Productions seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. As 

this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate 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, except for the limited 

conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It will however be 

operated in a restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent. 

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 as set forth in the Manual. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. 

proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than 

those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. 

In addition, the low-altitude operations of the sUAS will ensure separation between these small- UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. 91.121- Altimeter settings 

Red Eye Productions seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowest 

usable flight level since sUAS multi rotor operations will be within this ground to low-altitude airspace. 

C.F.R. 91.121 states, 

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.41 through 28.92 190 

28.91 through 28.42 195 

28.41 through 27.92 200 

27.91 through 27.42 205 

27.41 through 26.92 210 
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(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the 

pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number 

of feet specified below, according to the current reported altimeter setting:" 

Current altimeter setting Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

27.41 through 26.92 3,000 

Red Eye Productions sUAS uses both GPS altitude and barometric sensors and relays that information to 

our ground station. However, this data is used help the sUAS to automatically maintain position hold at 

the required elevation and therefore this code is not pertinent the general functionality of this sUAS. 

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

Red Eye Productions seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight 

in VFR conditions. Specifically, 91.151 states "(a) No person may begin 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. (b) No person may begin a 

flight in a rotorcraft 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, to 

fly after that for at least 20 minutes ". 

Red Eye Productions sUAS has a typical mission time of less than 15 minutes with maximum flight time of 

25 minutes. Since this amount less than the 30-minute reserve minimum, this reserve minimum would 

not even make sense in allowing the sUAS a chance to fly. According to Red Eye Productions aircraft flight 

manual, the PIC is instructed to maintain flight until battery power reaches 25%, or 151 level warning. At 

this level, landing procedures will be initiated. Once the sUAS reads 20%, 2"d level warning, the flight 

control system automatically take over and initiates safe landing sequence at the logged in takeoff point. 

Red Eye Productions policy outlined in our Flight Operations Manual achieves satisfactory safety 

standards. 

Red Eye Productions believes that an appropriate and current airworthiness certificate would not be 

necessary to fly a sUAS given the size of the aircraft and the necessary level of skill needed to operate the 

aircraft. Before putting in to service, each of our sUAS goes through our own airworthiness procedures of 

minimum test flight and reliability checks. Also, our sUAS are recalibrated each at the site location before 

each flight to ensure that all systems functions as designed. Red Eye Productions seeks exemption from 

this regulation because we believe this rule was not meant for a sUAS and operators. 

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 

Red Eye Productions seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses 

required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or 

alteration, inspections, and maintenance records. In Red Eye Productions aircraft flight manual, 

maintenance and inspection procedures have been established for the aircraft. Red Eye Productions 

believes these regulations are meant for manned operated aircrafts and not unmanned systems, 

therefore making them unnecessary. Nevertheless, we seek an exemption from any such specific 

provisions to the extent FAA finds it necessary to grant this request. 
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(d) The reasons why granting Red Eye Productions request would be in the public interest; that is, how it 

would benefit the public as a whole. 

Red Eye Productions is classified as an engineering company by the U.S. Department of Transportation 

and provides services to aerial support for commercial interest. Red Eye Productions use of a sUAS can 

assist in making task safer and minimize human exposure to being at dangerous elevations. Red Eye 

Productions sUAS usage in the aerial photography and cinematography will also reduce the time required 

to capture the needed scenes as compared to convention helicopters or airplanes. Ultimately, the result is 

quick completion of task and reduction of dangerous elevation perspective needs. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which Red Eye Productions 

seeks exemption Our Engineering department will provide a level of safety that exceeds the level of safety 

required by the FAA for its use on sUAS. The following are Red Eye Productions safety procedures, 

features, regulations, and operating specifications for our sUAS: 

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Our staff shall include at minimum of a FAA-rated private or recreational flight certificate as well 

as ground school certification. 

During operations at minimum, we will have a Pilot In Charge (PIC) and a Flight Operations Visual 

Observer (FOVO) certified under safe operations protocols. 

The flight area of the sUAS will be observed for best take off and landing locations. Desired 

conditions include: flat and level surfaces clear of debris, at least 15ft from power lines and 

structures, and a minimum distance of 12ft from the PIC and observers. 

The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all flights . 

Flights must take place during good weather conditions with no rain, low laying clouds, or heavy 

winds. All flights will take place during daylight hours with no night flights. 

The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being 

designated working flights. 

All batteries must be charged completely before each flight and each flight must end when the 

battery has a 30% power level remaining. 

A visual safety inspection will occur before each flight, testing propeller tightness, security mount 

of camera/detection equipment, remote range test, and proper safety equipment is adorned to 

PIC and FOVO. 

The sUAS will be flown under a height of 500ft AGL. 

No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase 

of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a 

configuration appropriate for the purpose of the intended flight. 

If there is more than just an operator at a site during a flight, the PIC operator and observer or 

FOVO will maintain two-way communication with each other during all operations; if unable to 

maintain two-way communications, or if any condition occurs that may otherwise cause the 

operation to be unsafe, the operator will immediately conclude the operation. 

If the communication link is lost, the sUAS will go into fail-safe mode and safely descend to its 

designated home-point location. If the communication link is reconnected during fail-safe mode, 

control of the sUAS can be regained before landing occurs at the home-point location. 

There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk of 

explosion if a crash occurs with the sUAS. 

The sUAS will feature a built in compass that will be recalibrated at every site to maintain 

accurate directional readings and help in keeping the sUAS stable during flights. 

The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum 

of 6 satellites will activate the Ready to Fly status. As well as full auto-pilot return-to-home 

feature. 

The aircrafts to be operated will include: the DJI 5900 with a wheelbase diameter of 900mm and 
' 

a flying weight of less than 181bs for heavy lift, the DJIInspire1 with a wheelbase of just under 

600mm and less than 7 lbs flying weight for medium lift as well as a DJI Phantom Series (2,3) 

aircraft with a wheelbase of 350mm and less than 3 lbs flying weight for light lift. 

• The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than O.Sm and 

1.5m respectfully. With a maximum wind resistance of 18mph. 

• The aircraft runs off a Li-Po battery. 

• A NOT AM will be issued between 48 and 72 hours before flight is to occur and will be 

coordinated with the applicable FSDO. 

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the 

exemption; and (2) A brief description of the nature of the exemption you seek 

Petitioner: Red Eye Productions. 

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 

91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F .R. 21 Subpart H; 

45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 

91.407; 91.409; and 91.417 to perform aerial photography and videography subject to operating 

procedures that meet or exceed those that FAA requires. 

(g) Any additional information, views or arguments available to support your request 

Please see the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United States, the reason why 

you need to do so 

The Operations described in this exemption request will be conducted wholly within the United States. 

Attached hereto, and submitted as a confidential document, is our Field Operations Manual. We 

respectfully submit that good cause exists so that this confidential manual does not need to be published 

in the Federal Register. 

Since I will continue to be an adviser to Red Eye Productions, please do not hesitate to call or contact me 

via email at dan@AiertSintl.com if you have any questions or concerns. 

Respectfully submitted, 

Dan Q Pham, P.E. 

Principal Engineer 

AlertS International, LLC 

4302 Hollywood Blvd, #303 

Hollywood, FL 33021 

954-918-3888