January 8th 2015

U. S. Department of Transportation Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Ave, SE Washington, DC 20590

Re: Petition of John Michael Higgins President of Helicam Helicopters Inc. for an exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012.

Dear Ms,Sir;

I, John Michael Higgins, President of Helicam Helicopters Inc., am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, John Michael Higgins, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, John Michael Higgins, may operate my small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein I, John Michael Higgins, am a Licensed Commercial Helicopter Pilot; I have been a member of AOPA for over 25 Years. I have flown numerous helicopters to acquire photographic images and presently own and operate a Mcdonnell Douglas MD 500D. I have numerous hours of flight time and years of experience providing aerial photography to local companies. I have operated for over twenty years and never had an accident or incident or had and complaints from the public. I also have many years and flight experience in the Helicopter RC Modeling and Photography. I have been a member at a locally owned helicopter flight field and have been a member of AMA [Academy of Model Aeronautics] more than 25 years. I own numerous RC Helicopters and UAS’s that are equipment with video and still camera equipment. I have acquired a Draganfly Inovations X6 sUAS that it is 100% designed and built and test flown in North America. The company provides support for both software and hardware and there sUAS’s has been approved by Transport Canada. These units are presently being operated by the RCMP [Royal Canadian Mounted Police]. I have provided Aerial photography/videography for Washington State companies including Washington State Construction Projects, Attorneys, Land Developers, Architects, Real Estate Agents, Boat Builders, and Magazine Companies. This exemption would allow me, John Michael Higgins the capability to operate UAS’s to continue these operations benefiting the community, following exemption and approval by the FAA. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

1Our operations with UAS’s will be at minimum altitudes needed to acquire the desired photographs, and well below the maximum altitude of 400’ feet. The majority of these flights will be accomplished at 200’ well below the maximum altitude limit.The base station for the Draganfly X6 system provides real-time data: UAS’s altitude, GPS position, number of current satellites being received, bearing, battery levels/health, and will bring up a screen and sound audible alarms for predetermined altitude limits. The aircraft and hand held controller feature a built in “Land Now” or “Return to Home” feature if either the signal or battery are compromised. This exemption request would permit operation in limited airspace in areas away from the general public, airports, heliports, and vehicle traffic. All flight data is logged by the UAS system and all flights will be logged and will be available for any required FAA reports to assist with future protocol and safety regulations.

Granting my, John Michael Higgins, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for Aerial Photography purposes. Further I, John Michael Higgins, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below I, John Michael Higgins, respectfully request the grant of an exemption allowing me to operate ultra light weight, remote controlled UAS’s to provide aerial images to my customers supporting community awareness to benefit/ stimulate attraction to Washington State. To continue my existing helicopter aerial photography business at competitive rates, and provide the community safer and less intrusive flights where this UAS can be effective.. This will promote local economic growth through increased property sales, employment, and increase tax revenue to the city of Seattle and Medina.

I. Contact Information: John Michael Higgins, Helicam Helicopters Inc. P.O.Box 482 Medina, Washington 98039 Office: (425 ) 450-4045 Mobile: (425 ) 450-4045 Email: mhiggins2003@msn.com John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

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. The Specific Sections of Title 14 of the Code of Federal Regulations From Which John Michael Higgins Requests Exemption are:

Part 21; Subpart H: 14 CFR Part 21 45.23 (b); 14 CFR Part 61.113 (a) & (b); 14 CFR Part 21 91.7 (a) (b) Subpart H. 14 CFR Part 21 91.9 (b)(2) 14 CFR Part 21 91.103 (b) 14 CFR Part 21 91.109 14 CFR Part 21 91.119 14 CFR part 21 91.121 14 CFR Part 21 91.151 (a) 14 CFR Part 21 91.203 (a)(b) 14 CFR part 21 91.405 (a) 14 CFR 407 (a) (1); 14 CFR 409 (a) (1) &( 2) 14 CFR 417 (a) & (b).

III. The Extent of relief John Michael Higgins seeks and the Reason He Seeks Such Relief: I, John Michael Higgins, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, John Michael Higgins, contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My,John Michael Higgins’, ultra light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, John michael Higgins. My UAS utilizes four (6) counter rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. I, John Michael Higgins, considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. When pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

3Airports, Hospitals nor Police Heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical Helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power flights generally last between three (3) to seven (7) minutes, with an altitude under two hundred (200) feet. I, John Michael Higgins, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is nine (9) to twelve (12) minutes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose a significant investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.

I, John Michael Higgins, am extremely cautious when operating of my UAS/ultra light weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. John Michael Higgins UAS, used in flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How John Michael Higgins Request Will Benefit the Public As A Whole: Aerial Photography/Videography for geographical awareness and for land development and marketing has provided companies with over views of projects giving a clear vision for future developments. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, John Michael Higgins, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around Washington State. It provides Washington State Realtors a safe and reasonably priced option to acquire Aerial Images without them purchasing cheap UAS’s and considering operating without meeting FAA requirements, putting themselves and the public in danger. My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

4The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. permitting me, John Michael Higgins, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for Washington State companies looking to build projects in the area assisting in geographical awareness. Which serve as a stimulus to the community

V. Reasons Why John Michael Higgins Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: My, John Michael Higgins, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, John Michael Higgins, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for development in cooperation with the FAA. In addition I, John Michael Higgins, submit the following representations of enhancements to current aerial videography and photography:

1. My UAS weight is (35oz)(2.18lbs) with a payload capacity:18oz and a Maximum Gross Take-off-weight: 53oz(3.31pounds). 2 . I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); 3 . My UAS only operate for 3-7 minutes per flight; 4 . I land my UAS prior to manufacturer recommended minimum level of battery power; and the base station controller provides two popup critical battery level warning

screens. 5 . I pilot my UAS through remote control only by line of sight and with a VO (visual observer). 6 . My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; 7 .I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; 8 . I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; 9 . I conduct extensive pre-flight inspections and protocol, during which safety carries primary importance; 10 . I always obtains all necessary permissions prior to operation. 11 . I have procedures in place to abort flights in the event of safety breaches or potential danger. 21 . I will operate as PIC [pilot in command] and have a Commercial Helicopters License and class two medical certificate. 13 . I will provide a VO (visual observer) with a minimum of a class three medical certificate and operate only in visual line of site (VLOS) well within his and my limits. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

514 . I will not operate in any flight conditions that exceed the manufacturers recommended flight limitations. 15. I purchase current Sectional Aeronautical Charts and fly only within the established limitations granted me by the FAA. 16. I will contact the local Airport and get ATIS information and prior to operations request a notice to airmen (NOTAM) for pilots in the NAS. 17. I will not fly over congested areas and will maintain 500’ feet distance from persons, vehicles, vessels and structures.

My, John Michael Higgins’, safety protocols provide a level of safety equal to or exceeding existing rules. 1. The potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. 2. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. 3. Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. 4. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A . 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, John Michael Higgins’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, John Michael Higgins’, current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

614 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a

safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

4 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, John Michael Higgins.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not havea cabin, cockpit or pilot station on which to mark certain words or phrases. Further, twoinch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. I, John Michael Higgins, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, John Michael Higgins, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

714 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 400 AGL; I, John Michael Higgins, will operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a)(1) & (2); 417(a) & (b): Maintenance Inspections. C.D.E.

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, John Michael Higgins’, UAS. However, as a safety precaution I inspect my UAS before and after each flight and have had it serviced and upgraded by the manufacturer. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, John Michael Higgins, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

8In summary, John Michael Higgins seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) To commercially operate my, John Michael Higgins’, small unmanned vehicle/lightweight unmanned aircraft for photographic operations in support of the local real estate market, providing community awareness and help develop economic platforms for companies in Washington State. I operate at low altitudes and in controlled airspace eliminating potential public risk. These operations will allow the business community an alternative to using full size helicopters there by providing a more economical, safer, and less intrusive method to acquiring there promotional sales materials. I, John Michael Higgins, have been analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for Aerial Photography usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, John Michael Higgins’, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, John Michael Higgins’ operation of my UAS, weighing less than 5 pounds and traveling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, John Michael Higgins, respectfully request that the FAA grant my exemption request and I am willing to cooperate in sharing information to benefit the FAA, the safety of manned aircraft, and the general public at large.

Respectfully submitted,

John Michael Higgins Helicam Helicopters Inc. P.O.Box 482 Medina, WA. 98039 John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

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# Appendix A

Five Mile Radius Restricted Flight Areas. Seattle,Washington John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

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# Appendix B

Flight Protocols

Flight safety is the first priority for all flights and following established protocols is essential. Preflight inspection of both the aircraft and the area of operation must be preformed without exception. Flight systems and protocols must be maintain within limits to provide a safe flight for everyone within proximity of the area of operation.

**Pre-Flight Protocol:** 1. Review sectional maps for proximity to Airports and Helipads. 2. Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information. 3. Inspect area of operation for any flight hazards; Towers, Power lines, Trees, Radio Towers, General Public. 4. Locate safe primary landing site and an alternative. 5. Check ATIS weather for wind advisory and NOTAM’s or other conditions that my impact flight.

**Takeoff and landing**

1. Select best pad for takeoff and landing
2. Post warning sign in residential areas.: "Attention Aerial Photography In Progress - Remain Back 150 Feet " 3. Review flight plan with observer. 4. Use preflight checklist prior to take off. 5. Scan area with observer prior to flight and maintain awareness of any flight conflicts. 6. Remained prepared for emergency landing at all times 7. Stay constantly aware of flight time. 8. Disconnect battery on Landing. John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

11**Flight log**

Take-off Time Land Time Total Flight Time Accumulated Flight Time

Wind Speed Temperature Camera Operator Camera Type

Battery # Condition Cycles Start Voltage End Voltage

Flight Authorization Information Purpose of Flight

Protocols and Controls

Aerial Community and Real Estate Videos Post flight: Emergency or Suspected Hazard: Immediate land UAS at safest and closet ground location in the event

o manned aircraft is heard or seen in vicinity of flight

o there is a public gathering within established safety boundary wanting to observe flight o pilot is being distracted from focusing on flight and safety

o sudden change in weather (wind bursts)

o sudden increase in vehicular traffic in vicinity of flight

o birds enter into proximity of flight

o any sudden unsafe event that can cause collision, distraction or interruption of control a. disconnect battery to prevent accidental activation of propulsion system b. secure UAS in a safe location c. remove all warning signs from public access areas John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

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# Appendix C 

# Safety/Flight Manual

Safety Flight Manual Aerial Community and Real Estate Videos Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. Maintaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative.

Date:____________________ Location: ___________________________________________________ Pre-flight Inspection: Yes No Comment: _________________________________________________ Elements Comment Weather Good Fair Visibility Good Fair Wind Speed Low Medium Proximity to airport: _________________ (see attached map pinpointing approximate location of flight) Airport notified Yes No Date:_______________ Time: ______________ Phone Number: _______________________ Contact Name: ___________________________________ Nearest major intersection: ______________________________________________________________ Proximity to medium traffic road: _________________________________________________________ Proximity to heavily traveled roadway road: _________________________________________________ Proximity to congested population: ________________________________________________________ Approx. Takeoff Time Approx. Landing Time Estimated Elevation Safety Concerns: Additional Comments: John Michael Higgins Commercial Helicopter Pilot - Section 333 Exemption Petition

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