T

JiAA Authorization #11814 October 8, 2015

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

### Dan Q 

### Pham, P.E. Principal Engineer AlertS InternationalLLC 4302 Hollywood Blvd, #303

_, Hollywood, FL 33021 '**'~** --. i

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 MayConcern: In pursuantwith Section 333 ofthe FAA Modernization and Reform Act of2012 and 14C.F.R. Part 11, 

### Lifestyle Production Group (LPG), is a High-end Luxury property marketing company in the South Florida area and an operatorofa 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 underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. As described morefully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive sUAS undercontrolled 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 ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. Information Supporting this Petition as Specified in 14 C.F.R. §11.81 (a) Your name and mailing address and, ifyou wish, other contact information such as afax number, telephone number, or e-mail address; Lifestyle Production Group Attn: Camilo Lopez 12011 sw 114th place Miami, FL 33176 305.812.4866 Camilo@lifestyleproduction.com (b) The specific section orsections of 14 C.F.R. from which LPG seeks an exemption • 21- Subpart HCertification procedures for products and parts, Airworthiness Certificates • 45.23- Display of marks; general • 61.113 -Private pilot privileges and limitations: Pilot in command • 91.103
- Preflight Actions • 91.105- Flight crewmembers atstations • 91.109- Flight instruction; Simulated instrument flight and certain flight tests



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### Lifestyle Production Group- Requestfor 333 Exemption

• 91.119- Minimum safe altitudes: General • 91.121- Altimeter settings • 91.151- Fuel requirements forflights 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 LPG seeks, and the reason LPG seeks the relief LPG seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 tothe extentto operate small UASs to record aerial photography and videography purposes. This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) 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 under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UASs do notcreate 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 "may operate 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 statutoryauthority by its terms includes exempting civil aircraft, as theterm is defined under §40101 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have acurrent airworthiness certificate. The Administrator maygrant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section orany sections 44702-44716 ofthis title ifthe 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).
14C.F.R. 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates LPG seeks exemption from 14C.F.R. 21, Subpart Hwhich states the certification procedures for products and parts as well as airworthiness certificates. The sUAS to be operated hereunder is**l~ss** 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 the Manual. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuanttothe Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityforthe area of operation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide agreater degree ofsafety 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 ofthese same criteria demonstratesthatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry asubstantial external load. LPG has developed our own procedures and protocols to promote and provide safe flying experiences for our


## 2; Lifestyle Production Group- Request for 333 Exemption
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, pursuant tothe Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation.
14 C.F.R. § 45.23 (b). Marking oftheAircraft LPG 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 must display on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed bythe registration number ofthe 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 mustalso display on that aircraft near each entrance tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, thewords "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable". LPG will need exemption from this regulation duetothe 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 workingwiththe sUAS will see the identification ofthe UAS as "Experimental." LPG will also register each aircraft in operations with acertified "N" numberas required. The FAA has issued the following exemptions tothis 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. LPG seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and limitationsforthe Pilot in command (PIC). LPG is seeking exemption from this regulation, because LPG believes thatthere is inconclusive evidence that 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 not automatically ensure competence at flying a 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 more than satisfactory. Our PIC and FOVO will be both certified in Ground School equivalenttraining to be able to properly interactwith General Aviation protocols. They will also actively pursue at minimum asport pilot's license as well have the necessary medical qualifications.
14 C.F.R. 91.103- Preflight Actions LPG 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 the vicinity 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. LPG will be operating oursUAS in VFR. Our operations manual already includes preflight procedures directly pertaining to oursUAS which includes equipment checklist as well a preplanning details regarding weather conditions, review ofany possible flight path ofgeneral aviation, our mission flight path and weather conditions amongst other parameters required to complete the mission.
14 C.F.R. 91.105- Flight crewmembers at stations LPG 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 atthe crewmember station unless the absence is necessary to perform duties in connection with the operation ofthe aircraft or in connection with physiological needs; and (2) Keep the safety beltfastened while atthe crewmember


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### Lifestyle Production Group- Requestfor 333 Exemption

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 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 dutieswith the shoulder harness fastened. LPG will need exemption from this regulation due tothe fact thatthe 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 atthe time ofthe flight. 

### 14 C.F.R. 91.109- Flight instruction; Simulated instrument flight and certain flight tests LPG 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 acivil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fullyfunctioning dual controls. However, instrumentflight instruction may be given in an airplane that is equipped with asingle, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls, when (1) The instructor has determined thatthe flight 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 a single, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls may be used for flight instruction to conduct aflight review required by §61.56 ofthis chapter, orto obtain recent flight experience or an instrument proficiency check required by §61.57 when (1) Th'e 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 to serve as pilot in command ofthe airplane, meets the requirements of§61.195(b), and has logged at least 25 hours of pilot-in-command flight time in the make and model ofairplane; and (4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate acivil aircraft in simulated instrumentflight unless (1) The other control seat is occupied by asafety pilotwho possesses at least a private pilotcertificate with categoryand class ratings appropriate tothe 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 fullyfunctioning dual controls. However, simulated instrumentflight may be conducted in asingle-engine airplane, equipped with a single, 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 acivil aircraftthat is being used for aflight testfor an airline transport pilot certificate or aclass ortype rating on that certificate, orfor a part 121 proficiency flight test, unless the pilot seated atthe controls, otherthan the pilot being checked, is fully qualified to act as pilot in command ofthe aircraft". Again, Except when necessary fortakeoffor landing, no person may operate an aircraft belowthe following altitudes: (a) Anywhere. An altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area ofacity, town, orsettlement, or over any open air assembly of persons, an altitude of 1,000feet above the highest obstacle within a horizontal radius of2,000feet 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 feetto any person, vessel, vehicle, orstructure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe operation is conducted without hazard to persons or propertyon the surface- (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) ofthis section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters bythe 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 art aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference toan altimeterthat is set, when operating-(!) Below 18,000feet MSL, to-(i)The current reported altimeter setting ofastation along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(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 oran appropriate altimetersetting available before departure; or (2)


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### Lifestyle Production Group- Requestfor 333 Exemption

At orabove 18,000feet MSL, to 29.92" Hg. (b) The lowest usable flight level is determined bythe atmospheric pressure in the area ofoperation as shown in the following table: LPG believes thatthere is inconclusive evidence that a person with a private pilot certificate or license can successfully maneuver ortrain someone to use an sUAS withoutfirst hand flight experience with the particular sUAS. Flying in 

### 3'd person orientation requires built-up experience in thatform offlying for manyyears. 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 oursUAS forthe tasks we purpose. Also, the sUAS will be operated by a remote control, which will only require asingle person operator and dual controls forflight operation will not be necessary. 14C.F.R. 91.119- Minimum safe altitudes: General LPG 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 authorityto 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 forthe limited conditions stated in the Manual, the UAS will neveroperate at higherthan 400AGL. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice tothe property owner and participants in thefilming activity, all affected individuals will be aware ofthe planned flight operations as setforth 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 ator 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 LPG seeks exemption from 14 C.F.R. 91.121, which discusses altimetersettingsfor 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 theflight level equivalent ofthe minimum altitude in feet and add the appropriate numberoffeet specified below, according tothe 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



## 5Lifestyle Production Group- Request for 333 Exemption

27.91 through 27.42 2,500 27.41 through 26.92 3,000 LPG's sUAS uses both GPS altitude and barometric sensors and relays that information to ourground station. However, this data is used help the sUAS to automatically maintain position hold atthe required elevation and thereforethis code is not pertinentthe general functionality ofthis sUAS.
14 C.F.R. 91.151- Fuel requirements forflights in Visual Flight Rules (VFR) conditions LPG 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 tofly tothe first point ofintended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor 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 flytothefirst pointof intended landing and, assuming normal cruising speed, tofly afterthatfor at least 20 minutes". LPG sUAS has atypical mission time of less than 15 minuteswith maximum flight time of25 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 achance to fly. According to LPG's aircraftflight manual under "In-Flight" section, the PIC is instructed to maintain flight until battery power reaches 30%, or 1st 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%, 2"d level warning, the flight control system automaticallytake over and initiates safe landing sequence. LPG policy outlined in our Flight Operations Manual achieves satisfactory safety standards. LPG believes that an appropriate and current airworthiness certificate would not be necessary tofly asUAS given the size ofthe aircraft and the necessary level ofskill needed to operate the aircraft. Before putting in to service, each ofour sUAS goes through our own airworthiness procedures of minimum testflight and reliability checks. Also, oursUAS are recalibrated each atthe site location before each flight to ensure that all systems functions as designed. LPG seeks exemption from this regulation because we believe this rule was not meantfor asUAS and operators.
14 C.F.R. 91.405, 91.407, 91.409, and 91.417 LPG 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 LPG aircraftflight manual, maintenance and inspection procedures have been established for the aircraft. LPG believes these regulations are meantfor manned operated aircrafts and not unmanned systems, therefore makingthem unnecessary. Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it necessary to grantthis request. (d) The reasons why granting LPG request would be in the public interest; that is, how itwould benefitthe public as awhole. LPG use ofa sUAS can assist in making task safer and minimize human exposure to being at dangerous elevations. LPG sUAS usage in the aerial photography and videography will also reduce the time required to capture the needed scenes as compared to convention helicopters orairplanes. Ultimately, the result is quick completion of task and reduction ofdangerous elevation perspective needs. (e) The reasons whygrantingthe exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety at least equal tothat provided bythe rule from which LPG seeks exemption Our Engineering departmentwill provide a level ofsafetythat exceeds the level ofsafety required by the FAA for its use on sUAS. The following are LPG safety procedures, features, regulations, and operating specifications for our sUAS:



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### Lifestyle ProductionGroup

- Requestfor 333 Exemption



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

. Flights musttake place during good weather conditions with no rain, low laying clouds, or heavy winds. All flights will take place during daylight hours with no nightflights. The PIC(s) ofthe sUAS will at least have 12 training hours or 24 flights accrued before being designated 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 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 200ftAGL but no more than 500ftAGL. No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight so as to ensure thatthe sUAS is in acondition for safe flight operation and in aconfiguration appropriate forthe purpose ofthe intended flight. Ifthere is more than just an operator at asite during aflight, the PIC operator and observer or FOVO will maintain two-way communication with each otherduring all operations; if unable 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, therefore there will be no potential explosives or risk ofexplosion ifacrash occurs with the sUAS. A contingency plan can be found in our manual. 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, afull auto-pilot return-to-home feature is built into the system. The aircrafts to be operated will include: the DJIInspire1 with awheelbase ofjust under 600mm and less than 7 lbs flying weight for medium lift as well as DJI Phantom 3 (Standard and Pro) aircrafts with 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 aircrafts vertical 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 NOTAM will be issued between 48 before flight is to occur and will be coordinated with the applicable FSDO. (f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the exemption; and (2) A briefdescription ofthe nature ofthe exemption you seek Petitioner: Lifestyle Production Group. 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


## 7Lifestyle Production Group
- Requestfor 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 meetor exceed those that FAA requires. (g) Any additional information,views or arguments available to supportyour request Please see the introduction to this exemption request. (h) Ifyou wantto exercise the privileges ofyour exemption outside ofthe United States, the reason whyyou need to do so The Operations described in this exemption requestwill be conducted whollywithin the United States. Attached hereto, and submitted as a confidential document, is our Field Operations Manual. We respectfully submitthat good cause exists so thatthis confidential manual does not need to be published in the Federal Register. Since Iwill continue to be an adviser to LPG, please do not hesitate to call or contact me via email at dan@AiertSintl.com ifyou have any questions or concerns. Respectfully submitted,

Dan Q Pham, P.E. Principal Engineer AlertS International, LLC 4302 Hollywood Blvd, #303 Hollywood, FL 33021 954-918-3888



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