### READY FOR

October 21, 2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 

# -·
Dan 

## QPham,P.E. PrincipalEngineer ·AlertS InternationalLLC 4302 Hollywood Blvd, #303 Hollywood, FL 33021

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: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14C.F.R. Part 11,J

### & M Underground Engineering Corp (JMUEC), a leading contractor in the South Florida area and an operator ofasmall Unmanned Aircraft System (sUAS) for aerial video and photo imaging, seeks an exemption from the Federal Aviation Regulations (FARs) to allow commercial operations of its sUAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. As described morefully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is limited, predetermined and controlled as to helpJMUEC's Engineering and Marketingteams capture videos/images for review, analysis and use of its own projects and for its clients. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "

...establish requirements forthe safe operation of such aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. Information Supporting this Petition as Specified in 14C.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; J

### & M Underground Engineering Corp Attn:Joseph M LoBue PO Box 163109 Miami, FL 33116 (305) 345-4002 joey@downrite.com (b) The specific section orsections of 14C.F.R. from which JMUEC seeks an exemption • 21- Subpart HCertification proceduresfor 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 instrumentflight and certain flight tests • 91.119- Minimum safe altitudes: General • 91.121- Altimeter settings



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### J&M Underground Engineering Corp- Requestfor 

### 333 Exemption

• 91.151- Fuel requirementsforflights 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 reliefJMUEC seeks, and the reason JMUEC seeks the relief JMUEC 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: This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directsthe Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required underSection 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 determines thatsuch 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 requirementthat 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 orany sections 44702-44716 ofthis title iftheAdministratorfinds 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).
14C.F.R. 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates JMUEC seeks exemption from 14C.F.R. 21, Subpart H which statesthe 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 neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured area as set out in theJMUEC's Field Operations Manual (Manual). Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuant tothe 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 a greater degree ofsafetytothe public and property owners than 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 sUAS, due to their size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load. JMUEC has developed its own procedures and protocols to promote and provide safe flying experiences for its PIC(s) which can be viewed in section (e) ofthis petition. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuanttothe Manual's requirements,


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### J&M UndergroundEngineeringCorp- Requestfor 333 Exemption

and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation.
14 C.F.R. § 45.23 (b). MarkingoftheAircraft JMUEC seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. Specifically, section 45.23 states, "(a) each operator ofan aircraft mustdisplay on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed by the 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 to the cabin, cockpit, or pilotstation, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable". JMUEC will need exemption from this regulation due tothe small size ofthe aircraft and thatthere is no cabin, cockpit, or pilotstation forthe 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."JMUEC will also register each aircraft in operations with a certified "N" numberas 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. JMUEC seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and limitationsforthe Pilot in command (PIC). JMUEC is seeking exemption from this regulation, because JMUEC believes thatthere is inconclusive evidence that only a person with a private pilotcertificate can successfully maneuver asUAS withoutfirst hand flight experience with the particular sUAS. In fact, having a private pilot license does notautomatically ensure competence atflying an sUAS in 3'd 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 equivalenttrainingto be able to properly interactwith General Aviation protocols. They will also actively pursue at minimum asport pilot's license (or equivalent accepted) as well as have the necessary medical qualifications. 14C.F.R. 91.103- PreflightActions JMUEC seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, before beginning a flight, become familiarwith all available information concerningthatflight. This information must include: (a) For a flight under IFR oraflight not in thevicinity ofan 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. JMUEC will be operating its sUAS in VFR. Its Manual already includes preflight procedures directly pertaining to its sUAS which includes an equipment checklist as well preplanning details regarding weather conditions, review of any possible flight path ofgeneral aviation, its mission flight path and weather conditions amongst other parameters required to complete the mission. 14C.F.R. 91.105- Flight crewmembers at stations JMUEC seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers atstations. Specifically, 91.105 states "(a) During takeoffand 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 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 her shoulder harness fastened while at his or her assigned dutystation. This paragraph does notapply


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### J&M Underground EngineeringCorp- Requestfor 333 Exemption

if (1) The seat at the crewmember's station is not equipped with ashoulder harness; or (2) The crewmember would be unable to perform required duties with the shoulder harness fastened. JMUEC will need exemption from this regulation due to the factthat its 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 aseat via shoulder harness orsafety belt atthetime oftheflight. 

### 14C.F.R. 91.109- Flightinstruction; Simulated instrumentflight and certainflight tests JMUEC 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 for flight instruction unless that aircraft has fullyfunctioning dual controls. However, instrumentflight instruction may be given in an airplane that is equipped with asingle, functioningthrow over control wheel that controlsthe 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 pilot certificate 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 recentflight experience oran instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable rudder pedals at both pilotstations; (2) The pilot manipulatingthe controls is qualified to serve and serves as pilot in command duringthe entireflight; (3) The instructor is current and qualified toserve as pilot in command ofthe airplane, meetsthe 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 the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrumentflight unless (1) The other control seat is occupied by asafety pilotwho possesses at least a private pilot certificate with category and class ratings appropriatetothe aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, ora competent observer in the aircraft adequately supplements thevision ofthe safety pilot; and (3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning 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 aflight testfor an airline transport pilot certificate ora 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, exceptwhen necessary fortakeoffor 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, orover 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 over open water orsparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to 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 oraltitudes 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 aircraftshall 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) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimetersetting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimetersetting 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 thefollowing table:


## 4J&M Underground Engineering Corp- Request for 333 Exemption

JMUEC believes that there is inconclusive evidence that only 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 thatform offlying for many years. Therefore, JMUEC believe its own flight training, pilot protocols and first hand experiences with the sUAS as laid out in its Manual meets and exceeds the requirements necessary to safely operate its sUAS for the tasks it purposes. 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 JMUEC seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. As this exemption is for a sUAS that is a multi-rotor helicopter and the exemption requests authorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which aerial imaging 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 sUAS will never operate at higherthan 400 AGL. Itwill 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 ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken withoutthe permission of local officials, ifapplicable. All flights will be over property owned (or being developed byJMUEC so no separate property owner consent is required. Because JMUEC is the owneror developer ofthe properties where operations will occur, all affected individuals will be aware ofthe 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 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 aircraftthat must comply with Section 91.119.
14 C.F.R. 91.121-Altimeter settings JMUEC seeks exemption from 14C.F.R. 91.121, which discusses altimetersettings 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 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 26.92 210 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 tothe minimum flight level, the pilotshall take the flight level equivalent ofthe minimum altitude in feet and add the appropriate numberoffeet specified below, according to the current reported altimetersetting:" Current altimetersetting 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



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## • J&M Underground Engineering Corp- Request for 

### 333 Exemption 

# I27.41 through 26.92 

### 13,000

JMUEC 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 pertinentthe general functionality ofthis sUAS.
14 C.F.R. 91.151- Fuel requirements forflights in Visual Flight Rules (VFR) conditions JMUEC 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 aflight in an airplane underVFR 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 afterthatfor at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes. (b) No person may begin aflight in a rotorcraft underVFR 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, tofly afterthatfor at least 20 minutes". JMUEC sUAS has atypical mission time of less than 15 minutes with maximum flight time of20 minutes perflight. Since this amount is less than the 30-minute reserve minimum, this reserve minimum would not even make sense in allowing the sUAS a chance to fly. According toJMUEC's Manual under "In-Flight" section, the PIC is instructed to maintain flight until battery power reaches 

### 30%, or 1 51 level warning. Atthis level, landing procedures will be initiated and the PIC will safely land the craft atthe take off location. As a back up, once the sUAS reads 10%, 2nd level warning, theflight control system automaticallytake over and initiates safe landing sequence. JMUEC policy outlined in its Manual achieves satisfactory safety standards. JMUEC believes that an appropriate and current airworthiness certificate would not be necessary to fly asUAS given the size ofthe aircraft and the necessary level ofskill needed to operate the aircraft. Before putting in to service, each of its sUAS goes through its own airworthiness procedures of minimum testflight and reliability checks. Also, its sUAS are recalibrated atthe site location before each flight to ensure that all systems functions as designed. JMUEC seeks exemption from this regulation because it believes this rule was not meant for asUAS and operators.
14 C.F.R. 91.405, 91.407, 91.409, and 91.417 JMUEC 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, oralteration, inspections, and maintenance records. In the JMUEC Manual, maintenance and inspection procedures have been established for the aircraft. JMUEC 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 whygrantingJMUEC request would be in the public interest; that is, how itwould benefit the public as awhole. JMUEC use ofasUAS can assist in making tasks safer and minimize human exposure to being at dangerous elevations. JMUEC sUAS usage in the aerial photography and cinematography will also reduce the time as well as save fuel required to capture the needed scenes as compared to conventional helicopters orairplanes. Ultimately, the result is quick completion oftask and reduction ofdangerous elevation perspective needs. (e) The reasons whygranting the exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety at least equal to that provided by the rule from which JMUEC seeks exemption. JMUEC's Manual will provide a level ofsafety that exceeds the level ofsafety required by the FAA for its use on sUAS. The following are JM UEC safety procedures, features, regulations, and operating specifications for its sUAS:



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### J&M UndergroundEngineering Corp- Requestfor 333 Exemption



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## • Our staffshall include at minimum ofan approved certification equivalent ofa recreational flight certificate and ground school certification or FAA certified certificate ofsafe sUAS operations when developed. During operations at minimum, we will have a Pilot In Charge (PIC) and a Flight Operations Visual Observer (FOVO) certified undersafe operations protocols. The flight area ofthe sUAS will be observed for best take 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 heavywinds. All flightswill 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 working flights. 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 mountof 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 of200ftAGL but no more than 500ftAGL. No PIC or FOVO will engage in, nor may a PICor FOVO permit, any activity during a critical phase offlight so as to ensure thatthe sUAS is in a condition forsafe 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; ifunable to maintain two-way communications, 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 intofail-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 no fuel or payload tothe sUAS, thereforethere will be no potential explosives or risk ofexplosion 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 aircraftsto be operated will include: the DJI lnspire1 with awheelbase ofjust under GOOmm and less than 7 lbs flying weight for medium liftas well as a DJI Phantom (Vision+ and Professional) aircraftwith a wheelbase of350mm 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 aircraftsvertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 1.5m respectfully. With a maximum wind resistance of 18mph. The aircraft runs offa high quality Li-Po battery

. A NOT AM will be issued between 48 and 72 hours beforeflight 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: J&M Underground Engineering Corp. 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



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# • 

# ,. J&M Underground Engineering Corp- Request for 

### 333 Exemption
Description of Relief Sought: Petitioner seeks relieffrom 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 supportyour request Please see the introduction to this exemption request. (h) Ifyou wantto exercise the privileges ofyour exemption outside ofthe United States, the reason whyyou need to do so The Operations described in this exemption requestwill be conducted wholly within the United States. Attached hereto, and submitted as a

### confidential document, is JMUEC's Field Operations Manual. We respectfully submitthatgood cause exists so thatthis confidential manual does not need to be published in the Federal Register. Since Iwill continue to be an advisertoJMUEC, please do not hesitate to call or contact mevia email at dan@alertSintl.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



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