U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Oct 9, 2015 

SUBJECT: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part II of 

the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 

91.121; 91.151 {a); 91.405{a); 91.407(a)(l); 91.409 (a)(!) and {2}; 91.417 {a) & (b). 

This petition is being submitted on my behalf of myself: Daniel Brent Moder! 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act), 

and 14 C.P.R. Part II, Daniel B. Moder!, a freelance photographer, hereby applies for an 

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of an 

Unmmmed Aircraft System (UAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Daniel B. Modert to pursue his commercial interests in 

providing services to clients using a UAS in the following areas: Real Estate, Marketing, Land 

Management/Surveying, and Special Events. Daniel B. Moder! states that all UAS flights will 

occur over private or controlled access property and will do so with the prope1ty owner's consent 

and knowledge and that only people who have consented or otherwise have agreed to be within 

the UAS's radius during filming and photography applications. 

Daniel B. Modert has demonstrated the ability to safely and effectively fly the UAS DJI Phantom 

3 and Inspire I which will be used for all commercial and private purposes. He complies with 

local ordinances and laws regarding the operation ofUAS, and adheres to all weather and 

environmental restrictions or limitations in reference to the operations ofUAS. 

All flights will in accordance with any and all state or local laws regarding privacy. 

I, Daniel B. Moder! am seeking the exemption because I am committed to complying with all of 

the rules, guidelines, limitations, and future legislation set fmih by the FAA. I agree to operate 

the UAS in the marmer that I have described, and for the pmposes that I have described. Without 

the exemption request granted, I would be unable to safely and effectively run my business 

legally, and it is my intention to comply with the FAA and obtain an exemption of the following 

regulations. 

I 
The following contains my list ofregulations from which I am seeking exemption, and a 

complete list of responsibilities I assume as operator; it also contains information regarding the 

aircraft, public benefit and safety features, and similar petitions requests granted. 

Regulations ft·om which exemption is requested: 

14 C.F.R. Patt 21, 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. 91.109, 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) & (b), 14 C.F.R. 91.205(b), 14 C.F.R. 91.215, 14 C.F.R. 91.401 • 91.417 

I, THE OPERATOR; ASSUME THE FOLLOWING RESPONSIBILITIES 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 and Inspire 

1 when weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (1 00 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than 

the maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. I the operator will stay below 200 feel AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cmmot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between 

the conditions and 4 limitations in tllis exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

2 
operator may update or revise its operating documents. It is the operator's responsibility to track 

such revisions and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA granted this 

exemption, then the operator must petition for an amendment to its grant of exemption. The 

FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates 

or revisions to the operating doctmlents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, must undergo a functional 

test flight prior to conducting fmiher operations under this exemption. Functional test flights may 

only be conducted by a PIC with aVO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

I 0. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer's maintenance; overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate. 5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a matmer consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and cmTency must 

be logged in a manner consistent with 14 CFR § 61.51 (b). Flights for the purposes of training the 

operator's PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under tllis exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During training, 

3 
proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonpmticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airpmt reference point (ARP) as 

denoted in the current FAA Airp01t!Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA -published aeronautical 

chart, unless a letter of agreement with that airport's management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official upon 

request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access propetty. 

19. The PIC must abmt the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited fi'om beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The exemption holder 

may apply for a new or amended COA if it intends to conduct operations that cannot be 

conducted under the tetms of the attached CO A. 6 

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpmt C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at 

all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonpatticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonpmticipating persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such protection. If a situation 

4 
arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety assessment of the 

risk of operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons 

under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the prope1ty owner/controller or authorized representative. Pennission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or ve1iical boundaries 

of the operational area as defined by the applicable COA must be rep01ied to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instmctions contained on the NTSB Web site: 

www.ntsb.gov. 

SIMILAR EXEMPTIONS 

They are similar in all/or many material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213 

Public Benefit and Safety 

Unmanned Aircraft System UASs are often seen as superior to helicopters as an aerial video 

gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced 

noise and as such, a much smaller environmental impact which promotes public safety. 

I am petitioning for an exemption to operate a DJI Phantom 3 with a built-in stabilized HD 

camera and GPS safety features which limit its ability to limit the height it flies above ground 

level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from 

operations within designated Class B, C and D airspace including a no-fly zone feature. 

The DJI Phantom 3 and Inspire I also has a failsafe function that is triggered in the event 

communication is lost between the UAS and the main controller transmitter. At that time, the 

UAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can 

regain control of flight and land manually. 

These specifications meet with the Model Aircraft Operating Standards as set below: 

• The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and will 

operate at sites that are 'sufficient distance' from populated areas within the sterile area described 

5 
in the FOPM. Such operations will ensure that the UAS will "not create a hazard to users of the 

national airspace system or the public." 

• When flying the UAS within three (3) miles of an airport, airport operators will be notified and 

the operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. 

Maximum flight time for each operation will be 30 minutes. 

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight 

time to safely land the UAS. 

• The UAS will be progrmruned so it will not be operated at an altitude that exceeds 400 feet 

AGL, and not more than 200 feet above an elevated platform from which videography is 

planned. 

• Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and 

the camera operator. 

• The UAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate 

and a current FAA medical certificate. 

• The UAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. 

camera, lens, and stabilized gimbal). 

• The UAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously 

move vertically and horizontally. 

• Given the small size of the UAS and the restricted sterile environment within which it will 

operate, SkyVideoCT's operations adhere to the Reform Act's safety requirements. 

If you have questions or need additional information, please contact me at (517) 755-7077. 

Sincerely 

01 ~- ,{/.// ,~aniel B. Moder! 

6 
P AN 

User Manual v1? 

1 

7 
Appendix 

Wa'gh! (B-'it1Cf)' & 

Prope'<ms !nc'wOud) 

lo'ax As<:Nll Spood 

Vav.. 0BscDri1 Sj:.l{X!{:I 

'-'4>< Spo~d 

Max F: f1h1 A:1-1Wo 

\':3X fl;gh1 T «!{) 

0t:A?rat.t1g Ttth!)cra~uro 

GPS Mo<kl 

Glmbiol 

C{"!fllto~'ab\Q Rango 

..,.,.,~ 

Ve!ocily Racgo 

AA.r.uOO Rango 

Opete1.ng Rat:go 

0p&." sting [)rv :1 OfifnGnt 

Came< a 

128Dg 

5m/s 

31l1/~.; 

O'C1o4o-·c 

GPS;GLONASS 

< 8 m/s (2m abJ\'O gm•.;T'<d} 

30cm-300cm 

30 cm-300 rm 

SN""' SNy EX\',QR W 3' Ei!ocWo pi•cls124 M ('D'$1 p'xo'• 12 76 M) 

Lens FOV 94~ .?fll'riir'~3!:t1'l'r.rrdorm:.~! cq:; 'o'a't:nt) 1.1.2 8 

ISO Ranll" 100-3200(1idco) 100-100(){ph<t.o) 

E!c-cttot1Cc Shu11et Spct'd Ss ·1/WOOs 

1ma9e "l4X SiJo 4000 Y. 3000 

S:n;fo st:o1 

f't':3X .B'~ta~e Of Vidro 

S!O!all" 

()petat;ng T~a1!.1Hl 

Ran~~" 

Btlrst sh'JO~·nQ 3Jf~/1 ~~lVJS 

Aw~o hpos• .. ~(l Bra.c¥;n~ ng (AfB) 3:'5 

Bfac:O:o~C{'l fratnes at 0 7EV B·as 

lnH?~ ar)So 

}.keto SO 

Ma)( c.apad:y 64GB. Class 1001 UHS-1 tafr~g wqwC1cd 

UllD 40%¥21~Cp 2·1!25, 3i>10,.;>\~Cp24125:'30 

FHD 192\}•:10BJ)p 24t/5!3£1!4B.i50,W 

liD 1;>e.or-:72Cp 2"1i?fu'?n0/~flfftf\'fl'D 

f't10~o JPEG. D~G 

V11:-k!'O MP4A~OV (M.PEG·-4 AVC(H ~) 

O'C lo40'C 

8 
MalcitllUllll '91 :t 

Altrtudo 

Aitt.'!a'lfs a!ti!I.ICkt cat'rfliY!. 

e~ til<l !lpOdlk:d vi!llue. 

f 1~11 bi!ita•x:;.o nltisl ix1 i'.1:t~in 

U\0 11illX f@C'i;u-.1. 

GPS~~ \\(i······~Y~ 

FIJ!tol twms 

W4l1n~: f fcigh1 

!fr1"1i1 r cach:xi. 

Wa-whg: .t..:m>tatX""ti 

flfllf; ff?JCIX:d. 

Mait.flvn 

lllgl11 

Al'J!ude 

~~is r&~ficJOd to4l)) 

~001. (120n)at~ ur':OC"'f. 

1.-'/tl'l'nfng: I {{}ight 3n1fl 

tDaCh!.Jd. 

Rapid red lashing 

· .... t$1 c1ooo to t+'C 

n \.Jt~ mdn;S hmi1 

• H you fly rut()! the limit )O!J e<r~l stll OOf1!ro1 tho l'h•nlm• 3, but c;!n'O!II; rl lilT/ filili.,.., H ti>e 

il\ Phanr001 3 flloo rut <litho ma• r1luiiusln Ready !0 Fly (110i>GI'S) n\01>13, ~ 1\111 !f; bi>c.l< 1\il!ln> 

tango t:J:f.!Ylla!icattv. 

• H the ftla1l'.il<fl 3 flifl!l rut()! tiK' 111BJ< r•diJJS in Ready lo Fly (llO!l-Gf'S) fllOOa, a 1\111 fly 11i0d< 

V.'t.l1itl fB119(} U!J~01'1l1l~iCHll)l. 

No·ftt Zoooo 

All No-fly Zoi>BS are lislod on Ul<l DJI o!fidal wcb!li'.a mlrttp:/~!;1<afe.dp.com/n<>-f!y. No fly L&'l:s <>'O 

civlded ifrto Anrorts and~ Aro•s. Akptl<'l<l ifdude nll!f:t airports and ft,;f>g tf!l!ds wlue rrwn!d 

affcraH t){.)Cm~o a1 KY •• ,. uhitu-dos. Hthiitic:ed Areas r1t:h . .{jO txr'det ltms bc!t~·tx:·n ,~c¥.~tlt•it..'"S- tY W1tstrvo 

instJ1u~o. lf"(} dc!arts o! tho No· I ty LO!'iOS li10 D~rtXHJ as 1oli.rtJ: 

Allport 

(1) Al1pc.t1 f\'o·l ty Lonn r¥0 cOffq_)!i!.'t:rl o1 l ukt>O'IHtrs"lric~cd J:t'WK~ ar~d K{;$:tfc!-t..'d Atr.uoo /rres. Lach 

/Ot16 fca~utiJ:'S c('clili; o~ ~Ut~ !..;iJ:L"S 

(2) H1 n'!tkl-s (vc.ti..tO of tho H1 dL";X~~us on Uw.J :;i./u and :;.h;;q.x:t o' 1ho aifptJil) ;~():..r'l.j tt:o ;~i<JXX1 hi a Tal<C· 

tlf tOOtTic!cd /XX10, i'1~idt) o1 t..1rit;tl ta'<tJ uH to p!'lilo'lffl!t!d. 

(3) From R1 n'ile to R1 • 1 roo llf<>IJfld ff>a airporl ti>e Clig!~ alli!U(fo is li:nNed to a 15 deg«"' indir><~lion. 

S1aning al65 fool (20 rl\G100!) ~om til<l edgo <ll airpor1 and raoil!lifl!J outward. H>e tilgld alli!udo Is 

knf.ed to 1640 ft.'()! (600 tnu!t:1S) a1 H1-+ 1 rn·k:t 

(4) V/non tho uh'c,att t-'·n!-t.'>fS ~~~~1~f"l320 foot (100 n'\Oie-!S) o! f\lo.f ly Lonos, a ~·l' .. Hrfng tnt.'~"~go 'o".'i!l ~){}.::~' 

on tho I)J1 1'110! ;;pp. 

41 

9 
Flight 

Once pre.ftigl~ fX<,lillali::M> is rorq-. rt Is rOC<J<>n~e~J<Je<J Ill!<! yti<J uoo tim fig~~ sil1llk'a n> «><• DJf Piltl<l 

llf'P to I !One ;<M Ugld skills lil!d r><a<iiro Uyn'Q ~. Ens!J!e Ill!<! ..U ligl<!s am artrit>d 001 han open 

wca. 

1. J)o not t..-:.:".0 th) Uk't'11Jl1 in WVi.""O .,.. e.a\i'lf}'t cO'~''iUrOf\$. lf"C'St1 t:clwdo v..-¥~d ·spfx.~ds C~CJ.2tJCfng 10 rt\1

S, 

Sf\l..W, raft1 ~1d fog. 

2. O.dy fo/ in open"'"""· TaU t111Jdutoo ,.,,; liM!¥! nlllYil ,;twc.1uroo m;,y ati<>tt til<! accura<y .:;1 ~"'onboaH.~ corrq>8"SS and GPS 'l.y..:;:t:-rn 

3. Avoid obstack:-s, om.'ds, hgll votagOIJt'Yt~\tr lrX-'S. trttJs. i$''-d tJocncs o1 W.:il~L'1. 

4. Mt,_fmi.J:o h\~L1k!t!!'C1J by ~dr<'.g trc,as v.1J1 Hgll1fl\ttts d e'liliJ'JCiti:J{Jf'i.c:iS•n. h'x:La:k"(J ba.s,o -s~.a'.lV"S 

wld rud10 t'G'"-Stnis-sk:vn to'I~'L"'-l''S 

5. A!rcmft an{~ IJa!ttHY J.HHit:rrnl-at'CC ts swt>;ni:t to fnl\li'I'Onmenlul lacto1s such ;Js air density and 

f<lnq>l~o!JAe.Bo "'~ CiM<:Au1YAI&fl fo/htg 1<1 al!<udn< <JI<'W3f !IM~~l 19,(A!'> !of~ (moo nm!L><!l) i<IV.<l """' 

·11 k.-'\'L'l, as tho ptjt'etrna~'<:iJ o' tho OO:I£ty &:'d a01C<<lt may be a~~tN:.:X'd. 

:0 6. Tt'U Pi'.:3f1~iYn 3 Pr(/t?-S.sk.:t\al cun~X>! qX.If¥3!0 .... 1:J~i·1 tt'O ~ <ir"·Oa-J.>. rl 

Flight Umits and No-Fly Zones 

Allwwnanr;cd atl'!'ial \'£4\t;iu {UAV) t:pt.'1a:O!s s1'<0;)d abldo by all rcg' •. A3:t:J:PS Sto'1 for~h Lt• gow.'1r'<t1£:-fl1 ar'd 

t~y age<\Cles kltluding ti>e ICAO and hl fAA. Fot flililc4y '""""'"'· fliglo!s "'" li!tJi',od by t!<?lau!(, 

v.11ich helps ust:is opL'Hl;o ths prod..;el sa'cty and k'Qillo/. J1J(JH hntu~k>ns ine!;..iJ1'l' tJCfg!Jt lrrth:s. dtSta~'<-":0 

~nts. a•Xl N<>lly Lr:n2s. 

~\'t':(};) 0f){}1ilti1~Q in f>.t1)(){:ffi, hfliijt>l knf!.-s. C'lis!w'CO !i:tli~-£. w~d f\l£)"f ly Lo~){!$ fwr:t:!i0f1 co:~{;uHt1TIHy to 

rnanago fhgt11 sa1

Ciy. In A·n!Odc, o·11y t:t:-ig1:t lr11f.s ¢te r1 cittlct. o"..ilk';h by dc1ault pHJWlt tt'iJ airoaft 

nltrtudo f1(xn {l~()(X"'tfrt~ 1640 lt"Xlt (t.«l rn). 

MaJdmum fllgtd alii'IIJOO & Radios Umils 

Maximum ftighl al!t!~idt) uno ftldliJS hrn;:s may 00 eht.Jr1gcd H) thJ WI P'1lO! upp. l.fu uwafo that H'.O 

ma>~num fig~~ a~d!ude artrot e>:eood 1640 !«~ (500 •"'*""). k> ac.rordm100 wi!h ti>t>OO r<!!lings, I'lL• 

f'hat-&J~n3 f'role,;,;bnol wll Hy kli• f(J!,jticledc)'ln•Oe<."" ,;i..,MII.leb.v. 

40 ________________________________________________j 

10