READY FOR 

October 2, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dan Q Pham, P.E. 

Principal Engineer 

AlertS International LLC 

4302 Hollywood Blvd, #303 

Hollywood, FL 33021 

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, ML3 Media 

LLC (ML3M), a leading image and video firm in the South Florida area and an operator of a small Unmanned 

Aircraft System (sUAS) aerial videography and photography, 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 

help capture videos and images for its own portfolio as well as for its clients. 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; 

ML3 Media LLC 

Attn: Michael Brandon Landsberg 

2420 S.W. 27th Ave. 

Miami, Florida 33145 

305.804.6760 

mi@ML3media.com 

(b) The specific section or sections of 14 C.F.R. from which ML3M 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 

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ML3 Media LLC- Request for 333 Exemption 

• 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 ML3M seeks, and the reason ML3M seeks the relief 

ML3M 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 

ML3M 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. 

ML3M has developed our own procedures and protocols to promote and provide safe flying experiences for our 

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'•, ML3 Media LLC - Request for 333 Exemption 

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 

ML3M 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". 

ML3M 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." ML3M 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. 

ML3M seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and limitations for the Pilot 

in command (PIC). 

ML3M is seeking exemption from this regulation, because ML3M 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 3'd 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 equivalent 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 

ML3M 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. 

ML3M 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 

ML3M 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, 

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, ML3 Media LLC- Request for 333 Exemption 

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. 

ML3M 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 

ML3M 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) of this 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 

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ML3 Media LLC - Request for 333 Exemption 

pressure in the area of operation as shown in the following table: 

ML3M 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 

ML3M 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 

ML3M 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 91121 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 

(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 

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' ML3 Media LLC - Request for 333 Exemption 

I 27.41 through 26.92 I 3,ooo 

ML3M 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 

ML3M 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". 

ML3M sUAS has a typical mission time of less than 15 minutes with maximum flight time of 25 minutes per flight. 

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 ML3M's aircraft flight manual under "In-Flight" section, the PIC is 

instructed to maintain flight until battery power reaches 30%, or 1st level warning. At this level, landing procedures 

will be initiated and the PIC will safely land the craft at the take off location. As a back up, once the sUAS reads 

10%, 2"d level warning, the flight control system automatically take over and initiates safe landing sequence. 

ML3M policy outlined in our Flight Operations Manual achieves satisfactory safety standards. 

ML3M 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. ML3M 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 

ML3M 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 ML3M aircraft flight manual, maintenance and inspection procedures have been 

established for the aircraft. ML3M 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. 

(d) The reasons why granting ML3M request would be in the public interest; that is, how it would benefit the 

public as a whole. 

ML3M is classified as an engineering company by the U.S. Department of Transportation and provides services to 

aerial support for commercial interest. ML3M use of a sUAS can assist in making task safer and minimize human 

exposure to being at dangerous elevations. ML3M 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 M L3M 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 ML3M safety procedures, features, regulations, and operating specifications for our 

sUAS: 

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ML3 Media LLC- Request for 333 Exemption 

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Our staff shall include at minimum of a recreational flight certificate as well as ground school certification 

or approved equivalent. 

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 typically flown under a height of 200ft AGL but no more than 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 S1000 with a wheelbase diameter of 1000mm and a 

flying weight of less than 221bs for heavy lift, DJI S900 with the wheelbase diameter of 900m and flying 

weight less than 181bs, the DJI lnspire1 with a wheelbase of just under 600mm and less than 7 lbs flying 

weight for medium lift as well as a DJI Phantom 3 aircraft with a wheelbase of 350mm and less than 3 lbs 

flying weight for light lift. Also, any new developed craft will be submitted to FAA for airworthiness 

approval before it can be used in operation. 

The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 1.5m 

respectfully. With a maximum wind resistance of 18m ph. 

The aircraft runs off a high quality 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: ML3MM. 

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

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ML3 Media LLC- Request for 333 Exemption 

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 1 will continue to be an adviser to ML3M, 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 

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