August 7, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe 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 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, Red Eye Productions, an operator ofasmall 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 underthe conditions outlined herein oras may be established by the FAA as required by Section 333.
As described morefully below, the requested exemption would permit the operation ofsmall, 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 ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333{c) ofthe Reform Act. Information Supporting this Petition as Specified in 14 C.F.R. §11.81 (a) Your name and mailing address and, ifyou wish, other contact information such as afax 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 orsections of 14 C.F.R. from which Red Eye Productions seeks an exemption • 21- Subpart HCertification 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 atstations • 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 extentto operate small UASs to record aerial photography and videography purposes. This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users ofthe NAS orthe public or pose athreatto national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator.
Reform Act§ 333 (a). Lastly, ifthe Secretary determinesthat such vehicles "mayoperate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system" The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as theterm is defined under §40101 oftheAct, 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 ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthistitle ifthe Administratorfinds 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 HCertification procedures for products and parts, Airworthiness Certificates Red Eye Productions seeks exemption from 

### 14 C.F.R. 21, Subpart Hwhich 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 orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuanttothe Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityforthe area ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements, which already applyto civil aircraft operated in connection with motion picture and television production, provide agreater degree ofsafetytothe public and property ownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load. Red Eye Productions has developed our own procedures and protocolsto promote and provide safe flying experiences for our PIC(s) which can be viewed in section (e) ofthis petition. Unlike other civil aircraft,operations underthis exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityforthe area ofoperation.
14C.F.R. § 45.23 (b). MarkingoftheAircraft Red Eye Productions seeks exemption from 14C.F.R. 45.23, which discusses the display of marks. Specifically, section 45.23 states, "(a) each operator ofan aircraft must display on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed bythe registration numberofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter (b) when marks include onlythe 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 tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, thewords "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable".
Red Eye Productions will need exemption from this regulation due tothe small size ofthe aircraft and that there is no cabin, cockpit, or pilotstation for the aircraft. The words "Experimental" has been placed on the fuselage in compliance with §45.29 (f) where the pilot, observer and others workingwith the sUAS will see the identification ofthe UAS as "Experimental." Red Eye Productions will also register each aircraft in operations with a certified "N" number as required. The FAA has issued thefollowing exemptions tothis regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
14C.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 limitationsforthe 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 withoutfirst 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 ofsight. However, we believe thatthe PIC and our FOVO (Field Operation Visual Observer) must be able to understand and correctly interactwith the general aviation community. Therefore, we believe our own flighttraining with the sUAS will be morethan satisfactory. Our PIC and FOVO will be both certified in Ground School training to be able to properly interactwith General Aviation protocols. They will also actively pursue at minimum asport pilot's license as well have the necessary medical qualifications.
14C.F.R. 91.103- PreflightActions Red Eye Productions seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, before beginning aflight, become familiar with all available information concerning thatflight. This information must include: (a) For aflight under IFR or aflight not in thevicinityofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; actions, including reviewing weather, flight battery requirements, landing and takeoffdistances, and aircraft performance data before starting aflight.
Red Eye Productions will be operating oursUAS in VFR. Our operations manual already includes preflight procedures directly pertaining to oursUAS which includes equipment checklist as well a preplanning details regarding weather conditions, review ofany possible flight path ofgeneral aviation, our mission flight path and weather conditions amongst other parameters required to complete the mission.
14C.F.R. 91.105- Flightcrewmembers atstations Red Eye Productions seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers atstations. Specifically, 91.105 states "(a) Duringtakeoffand landing, and while en route, each required flight crewmember shall (1) Be atthe crewmember station unless the absence is necessary to perform duties in connection with the operation ofthe aircraft or in connection with physiological needs; and (2) Keep the safety beltfastened while atthe crewmember station. (b) Each required flight crewmember ofa U.S.-registered civil aircraft shall, duringtakeoffand landing, keep his or hershoulder harness fastened while at his or her assigned dutystation. This paragraph does notapply if (1) The seat atthe crewmember's station is not equipped with ashoulder harness; or (2) The crewmemberwould be unable to perform required duties with the shoulder harness fastened. Red Eye Productions will need exemption from this regulation due tothefactthatthe sUAS will not have aflight crew orcrew stations otherthan the PIC and a FOVO. The PIC, not being in the aircraft, therefore will also not have to be restrained into aseatvia shoulder harness orsafety belt atthetime oftheflight. 

### 14C.F.R. 91.109- Flight instruction; Simulated instrumentflight and certainflight tests Red Eye Productions seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrumentflight, 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 forflight instruction unless that aircraft has fully functioning dual controls. However, instrumentflight instruction may be given in an airplane that is equipped with asingle, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls, when (1) The instructor has determined thattheflight can be conducted safely; and (2) The person manipulatingthe controls has at least a private pilotcertificate with appropriate category and class ratings. (b) An airplane equipped with asingle, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls may be used forflight instruction to conduct aflight review required by §61.56 ofthis chapter, orto obtain recent flight experience oran instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulatingthe controls is qualified to serve and serves as pilot in command duringthe entireflight; (3) The instructor is current and qualified to serve as pilot in command ofthe 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 ofairplane; and (4) The pilot in command and the instructor have determined theflight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrumentflight unless (1) The other control seat is occupied by a safety pilotwho possesses at least a private pilot certificate with category and class ratings appropriate tothe aircraft being flown. (2) The safety pilot has adequate vision forward and to each side ofthe aircraft, or a competent observer in the aircraft adequately supplements the vision ofthe safety pilot; and (3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fullyfunctioning dual controls. However, simulated instrumentflight may be conducted in asingle-engine airplane, equipped with asingle, functioning, throw over control wheel, in place offixed, dual controls ofthe elevator and ailerons, when (i) The safety pilot has determined thatthe flight can be conducted safely; and (ii) The person manipulatingthe controls has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraftthat is being used for aflighttest for an airline transport pilot certificate or a class ortype rating on that certificate, orfor a part 121 proficiencyflighttest, unless the pilotseated atthe controls, otherthan the pilot being checked, is fully qualified to act as pilot in command ofthe aircraft". Again, Except when necessary fortakeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area ofa city, town, orsettlement, or over any open air assembly of persons, an altitude of 1,000feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. (c) Over otherthan congested areas. An altitude of500 feet above the surface, except overopen water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feetto any person, vessel, vehicle, orstructure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe 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 orweight-shift-control aircraft may

### be operated at less than the minimums prescribed in paragraph (c) ofthis section (a) Each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating-(1) Below 18,000feet MSL, to-(i)The current reported altimetersetting ofastation along the route and within 100 nautical miles ofthe aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or

### (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure; or (2) At orabove 18,000feet MSL, to 29.92" Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area ofoperation as shown in the followingtable: Red Eye Productions believes thatthere is inconclusive evidence that a person with a private pilot certificate or license can successfully maneuver ortrain someone to use an sUAS withoutfirst hand flight experience with the particular sUAS. Flying in 

### 3'd person orientation requires built-up experience in that form offlying for manyyears. Therefore, we believe ourown flighttraining, 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 oursUAS forthetasks we purpose. Also, the sUAS will be operated by a remote control, which will only require asingle person operator and dual controlsfor 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 asUAS that is a helicopterand the exemption requests authorityto operate at altitudes up to400 AGL, or not morethan 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, except forthe limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flightwill be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice tothe property owner and participants in thefilming activity, all affected individualswill be aware ofthe planned flight operations as setforth in the Manual. Compared toflight operations with aircraft or rotorcraft weighting far morethan the maximum 551bs. proposed herein and the lack offlammable 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 ofthe sUAS will ensure separation between these small- UAS operations and the operations ofconventional aircraft that must comply with Section 91.119.
14C.F.R. 91.121-Altimetersettings Red Eye Productions seeks exemption from 14C.F.R. 91.121, which discusses altimeter settings for lowest usable flight level since sUAS multirotor operationswill be within this ground to low-altitude airspace. C.F.R. 91.121 states, Current altimetersetting 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 210I (c) To convert minimum altitude prescribed under §§91.119 and 91.177 tothe minimum flight level, the pilot shall take the flight level equivalent ofthe minimum altitude in feet and add the appropriate number offeet specified below, according tothe current reported altimetersetting:" Current altimeter setting Adjustmentfactor 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 ourground station. However, this data is used help the sUAS to automatically maintain position hold at the required elevation and therefore this code is not pertinentthe general functionality ofthis sUAS.


### 14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions Red Eye Productions seeks exemption from 14C.F.R. 91.151, which discusses fuel requirements forflight in VFR conditions. Specifically, 91.151 states "(a) No person may begin aflight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothe first point ofintended landing and, assuming normal cruising speed- (1) During the day, tofly afterthat for at least 30 minutes; or (2) At night, tofly afterthatfor at least 45 minutes. (b) No person may begin a flight in a rotorcraft underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothe first point ofintended landing and, assuming normal cruising speed, to fly afterthatfor at least 20 minutes ".
Red Eye Productions sUAS has atypical mission time ofless 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 aircraftflight manual, the PIC is instructed to maintain flight until battery power reaches 25%, or 1 51 level warning. At this level, landing procedureswill be initiated. Once the sUAS reads 20%, 2"d level warning, the flight control system automaticallytake over and initiates safe landing sequence atthe 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 tofly asUAS given the size ofthe aircraft and the necessary level ofskill needed to operate the aircraft. Before putting in to service, each ofoursUAS goes through our own airworthiness procedures of minimum test flight and reliability checks. Also, oursUAS are recalibrated each atthe 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 meantfor 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 aircraftflight manual, maintenance and inspection procedures have been established forthe aircraft. Red Eye Productions believes these regulations are meantfor manned operated aircrafts and not unmanned systems, therefore makingthem unnecessary. Nevertheless, we seek an exemption from any such specific provisions tothe extent FAA finds it necessary to grantthis request.I (d) The reasons why granting Red Eye Productions request would be in the public interest; that is, how it would benefitthe public as awhole.
Red Eye Productions is classified as an engineering company by the U.S. Department ofTransportation and provides services to aerial supportfor commercial interest. Red Eye Productions use ofasUAS can assist in making task safer and minimize human exposure to being atdangerous elevations. Red Eye Productions sUAS usage in the aerial photography and cinematographywill also reduce the time required to capture the needed scenes as compared to convention helicopters or airplanes. Ultimately, the result is quick completion oftask and reduction ofdangerous elevation perspective needs. (e) The reasons whygrantingthe exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety at least equal tothat provided by the rule from which Red Eye Productions seeks exemption Our Engineering departmentwill provide a level ofsafety that exceeds the level ofsafety required bythe FAA for its use on sUAS. The following are Red Eye Productions safety procedures, features, regulations, and operating specifications for oursUAS:


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• Our staffshall include at minimum ofa 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 OperationsVisual Observer (FOVO) certified under safe operations protocols. The flight area ofthe sUAS will be observed for besttake offand landing locations. Desired conditions include: flat and level surfaces clear ofdebris, at least 15ftfrom power lines and structures, and a minimum distance of 12ftfrom the PIC and observers. The sUAS will also be in the Visual Line ofSight (VLOS) to both the PIC and FOVO during all flights

. Flights musttake place during good weather conditions with no rain, low laying clouds, or heavy winds. All flights will take place during daylight hours with no nightflights. The PIC(s) ofthe sUAS will at least have 12 training hours or 24 flights accrued before being designated workingflights. All batteries must be charged completely before each flight and each flight must end when the battery has a30% power level remaining. Avisual safety inspection will occur before each flight, testing propellertightness, security mount ofcamera/detection equipment, remote range test, and proper safety equipment is adorned to PIC and FOVO. The sUAS will be flown under a height of500ftAGL. No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight so as to ensure thatthe sUAS is in a condition for safe flight operation and in a configuration appropriate forthe purpose ofthe intended flight. Ifthere is more than just an operator atasite during aflight, the PIC operator and observer or FOVO will maintain two-way communication with each otherduring all operations; if unable to maintain two-waycommunications, or ifany condition occurs that may otherwise cause the operation to be unsafe, the operatorwill immediately conclude the operation. Ifthe communication link is lost, the sUAS will go into fail-safe mode and safely descend to its designated home-point location. Ifthe communication link is reconnected duringfail-safe mode, control ofthe sUAS can be regained before landing occurs atthe home-point location. There is nofuel or payload tothe sUAS, therefore there will be no potential explosives or risk of explosion ifa crash occurs with the sUAS. The sUAS will feature a built in compass thatwill be recalibrated at every site to maintain accurate directional readings and help in keeping the sUAS stable duringflights. The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum of6 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 awheelbase diameter of900mm and

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aflying weight of less than 181bs for heavy lift,the DJIInspire1 with awheelbase ofjust under 600mm and less than 7 lbs flying weight for medium lift as well as a DJI Phantom Series (2,3) aircraft with awheelbase of350mm 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 offa Li-Po battery. • A NOTAM 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 briefdescription ofthe nature ofthe 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 relieffrom the requirements of 14C.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 meetor exceed those that FAA requires. (g) Any additional information, views or arguments available to supportyour request
Please see the introduction to this exemption request. (h) Ifyou wantto exercise the privileges ofyour exemption outside ofthe 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 submitthat good cause exists so thatthis confidential manual does not need to be published in the Federal Register. Since Iwill continue to be an adviserto Red Eye Productions, please do not hesitate to call or contact me via email atdan@AiertSintl.com ifyou 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