BEFORE THE
DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.
__________________________________________
)
Amendment to Application of )
)
LINEA AEREA DE SERVICIO EJECUTIVO )
REGIONAL, C.A. (COMMERCIALLY )
KNOWN AS LASER AIRLINES) ) Docket No. OST-2011-0190
)
for a foreign air carrier permit pursuant to )
49 U.S.C. § 41301 and for an )
exemption pursuant to 49 U.S.C. § 40109 )
__________________________________________)
AMENDMENT TO APPLICATION OF LASER AIRLINES
FOR A FOREIGN AIR CARRIER PERMIT AND EXEMPTION
Communications with respect to the
above should be addressed to:
Evelyn D. Sahr
Drew M. Derco
Eckert Seamans Cherin & Mellott, LLC
1717 Pennsylvania Ave., N.W.
12
th
Floor
Washington, D.C. 20006
Phone: (202) 659-6600
Fax: (202) 659-6699
E-mail: esahr@eckertseamans.com
Counsel to Laser Airlines
DATED: August 13, 2018
2
BEFORE THE
DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.
__________________________________________
)
Amendment to Application of )
)
LINEA AEREA DE SERVICIO EJECUTIVO )
REGIONAL, C.A. (COMMERCIALLY )
KNOWN AS LASER AIRLINES) ) Docket No. OST-2011-0190
)
for a foreign air carrier permit pursuant to )
49 U.S.C. § 41301 and for an )
exemption pursuant to 49 U.S.C. § 40109 )
__________________________________________)
AMENDMENT TO APPLICATION OF LASER AIRLINES
FOR A FOREIGN AIR CARRIER PERMIT AND EXEMPTION
On October 11, 2011, Linea Aerea de Servicio Ejecutivo Regional, C.A. (Laser Airlines),
a carrier of the Bolivarian Republic of Venezuela, applied for a foreign air carrier permit and an
exemption that would have allowed it to provide “(1) scheduled foreign air transportation of
persons, property and mail between Caracas, Venezuela (CCS), on the one hand, and Fort
Lauderdale, Florida, United States (FLL) on the other hand; and (2) charter foreign air
transportation of persons, property and mail between Maiquetia (MIQ), Valencia (VLN), and
Margarita Island (PMV), Venezuela, on the one hand, and FLL, on the other hand, and other
charter flights as permitted pursuant to Part 212 of the Department’s regulations.”
1
The
Department did not take action on Laser Airlines’ 2011 application.
Laser Airlines remains committed to serving the United States market. Given the time
that has lapsed since its initial request for economic authority, and changes that have occurred
both within the company and in regards to the proposed services, Laser Airlines hereby amends
1
See Application of Laser Airlines, C.A. for an Exemption and a Foreign Air Carrier Permit, Docket DOT-OST-
2011-0190 (October 11, 2011).
3
its October 11, 2011 application for a foreign air carrier permit and exemption from 49 U.S.C. §
41301 and other such applicable statutory provisions and regulations of the Department as may
be necessary to engage in scheduled and charter foreign air transportation of persons, property,
and mail between Venezuela and the United States.
Specifically, Laser Airlines now requests a foreign air carrier permit and exemption
authorizing it to engage in: (1) scheduled and charter foreign air transportation of persons,
property and mail between Caracas, Valencia, and Maracaibo, Venezuela on the one hand, and
Miami, Florida, on the other hand; and (2) charter flights as permitted pursuant to Part 212 of the
Department’s regulations.
Laser Airlines respectfully requests that DOT act promptly on this application, and
renews its request that the Department process this amended application pursuant to its
Streamlined Licensing Procedures Notice and issue a single order: (1) granting the exemption
authority sought herein for a period of two years, or until Laser Airlines’ requested foreign air
carrier permit becomes effective; and (2) tentatively awarding Laser Airlines a foreign air carrier
permit under the “show cause” procedures described in the Streamlined Licensing Procedures
Notice. In addition to the amended service proposal, Laser Airlines respectfully submits, in
support of its amended application, updated fitness information as follows:
1. State the Name and address of the applicant, the nature of its organization and, if
applicable, the name of the country under the laws of which it is organized.
211.20(a)
The complete name and address of Laser Airlines is as follows:
Linea Aerea de Servicio Ejecutivo Regional, C.A. (Laser Airlines)
Av. Ppal. de El Bosque, Torre Credicard,
Piso 13, Ofic. 132-133, Urb. El Bosque,
Caracas, Venezuela
Laser Airlines is organized under the laws of the Bolivarian Republic of Venezuela.
4
2. Name and official address of the government air transport authority having
regulatory jurisdiction over applicant. 211.20(b)
Laser Airlines is subject to the regulatory jurisdiction of the Instituto Nacional de
Aeronáutica Civil (INAC), located at:
Av. José Félix Sosa c/ Av. Luis Roche
Torre Británica de Seguros,
Pisos 2 al 8.
Chacao, Caracas 1060, estado Miranda.
3. Statement of the authority requested and a description of the services proposed.
211.20(c)
As noted above, Laser Airlines requests that DOT issue it a foreign air carrier permit and
an exemption authorizing it to engage in: (1) scheduled and charter foreign air transportation of
persons, property and mail between Caracas, Valencia, and Maracaibo, Venezuela on the one
hand, and Miami, Florida, on the other hand; and (2) other charter flights as permitted pursuant
to Part 212 of the Department’s regulations. Should the authority requested herein be granted,
Laser Airlines anticipates launching twice daily non-stop service to the United States
commencing in a period of 90 to 180 days after the corresponding approval. The service will be
operated with either B737, MD-80 or MD-90 aircraft, configured with 150 seats. Depending on
the success of the operation, Laser Airlines may upgauge to larger capacity B767 aircraft at a
later date.
4. Provide names, addresses, and citizenship of all Directors, Officers, and Key
Management Personnel. 211.20(d)
A list of Laser Airlines’ key management personnel is attached. (See Exhibit 1)
Inocencio Alvarez Vazquez (Laser Airlines’ Chairman) and Alejandro Alvarez Grueiro (Laser
Airlines’ Executive Director) are related by blood. Mr. Vasquez is Mr. Grueiro’s father.
5. Provide the names and citizenship of all persons holding five percent or more of
the capital stock or capital of the applicant, along with the number and
percentage of shares held by each. 211.20(e)
5
A summary of Laser Airlines’ ownership is attached. (See Exhibit 2) Laser Airlines’
primary shareholder, Immobiliaria Aliser, C.A., is a Venezuelan entity.
6. Does the ownership of applicant hold an interest in any other U.S. or foreign
carrier, common carrier, or person engaged in the business of aeronautics? 211.20(f)
No.
7. Relationship between the applicant and its homeland government. 211.20(g)
None. Laser Airlines is a privately held company and receives no financial assistance
from, nor is it associated with, the Government of Venezuela.
8. Applicant’s insurance coverage meets or exceeds the liability limits of 14 C.F.R.
Part 205. 211.20(h)
Laser Airlines’ liability insurance exceeds the minimum requirements of 14 C.F.R. Part
205. Laser Airlines has attached a completed certificate of insurance (DOT Form 6411), as
required by 14 C.F.R. Part 205, for the Department’s review. (See Exhibit 3) Laser Airlines will
concurrently file the certificate with the FAA.
9. Evidence of the applicant’s homeland operating authority. 211.20(i)
Laser Airlines has an Air Operator Certificate and Air Service License issued by INAC,
which are attached for the Department’s review. (See Exhibit 4) The Government of Venezuela
has authorized and designated Laser Airlines to operate on the Caracas-Miami route (see Exhibit
5), and Laser Airlines is in the process of obtaining a designation to operate the Valencia-Miami
and Maracaibo-Miami routes. Laser Airlines will provide the Department with copies of the
applicable designations as soon as they become available.
10. Summary of applicant’s operating history. 211.20(j)
Laser Airlines was established in the early 1990s and conducted its first flight in March
1994, using a leased DC-9 aircraft. From its humble beginnings as a one-aircraft operation
6
focused on providing scheduled executive services between Caracas and Margarita Island, Laser
Airlines has expanded over the last several decades, and now operates a fleet of 12 MD-80
aircraft to numerous destinations within Venezuela, as well as to international destinations in
Aruba, Panama, and the Dominican Republic. The company was recently designated and
authorized by the Colombian and Ecuadorian aviation authorities to operate scheduled service to
Bogota and Guayaquil, which Laser Airlines plans to inaugurate in summer 2018. Laser Airlines
does not presently hold economic authority from the Department, although it did apply for a
foreign air carrier permit and an exemption in 2011 (DOT took no action on that application).
11. List of aircraft owned. 211.20(k)
A complete list of Laser Airlines’ fleet is attached. (See Exhibit 6).
12. State where and by whom the maintenance of the aircraft is or will be performed.
211.20(k)
While Laser Airlines’ repair stations are currently certified to perform all type of
maintenance (major and minor) work of the company's aircraft, Laser Airlines uses repair
stations located in the United States for major maintenance. Venezuela is a contracting state to
the Convention of International Civil Aviation (Chicago Convention) and observes all applicable
ICAO standards. The equipment utilized to perform these services will be maintained by Laser
Airlines in accordance with all relevant ICAO annexes. Routine line and minor maintenance
will be undertaken at the various outstations that Laser Airlines serves.
13. Describe any arrangements or cooperative working arrangements that exist
between the applicant and a U.S. or foreign carrier that would affect the
proposed services and are not on file with the Department. 211.20(m)
Laser Airlines is currently engaged in a commercial relationship with Swift Air in
connection with public charter flights offered by Swift between CCS and MIA.
14. Financial data. 211.20(n)
7
Laser Airlines is financially qualified to provide the services at issue here. Details about
its finances are being submitted under seal along with a Motion for Confidential Treatment. (See
Exhibit 7) These materials clearly establish that Laser Airlines meets and exceeds the
Department's financial fitness criteria.
15. Amount, type and reason for financial assistance received from the applicant’s
home country government, if applicable. 211.20(o)
None.
16. Estimate of total traffic and financial results of intended service. 211.20(p)
Prior to the commencement of operations, it is difficult for Laser Airlines to accurately
predict the total number of passengers that will be served. However, Laser Airlines estimates
that approximately 172,800 passengers will be transported within the first year of non-stop
service.
17. Justifications for granting proposed air transportation services. 211.20(q)
Laser Airlines acknowledges that the current political environment between the United
States and Venezuela is complicated. However, grants of operating authority should not be
deprived based on political conditions. Rather, under 49 U.S.C. § 41302, the Department may
issue a foreign air carrier permit if it determines that the “foreign air transportation to be
provided under the permit will be in the public interest.”
2
The U.S. government has also taken
the position that any service provided pursuant to the terms of a bilateral agreement serves the
public interest
3
and that “the existence of an air service agreement demonstrates that granting
operating authority to a foreign carrier is per se in the public interest.”
4
Here, grant of the
2
See 49 U.S.C. § 41302.
3
S. REP. NO. 96-329, at 4 (1979), reprinted in 1980 U.S.C.C.A.N. 54, 57 (“[T]he negotiation of a bilateral
agreement itself represents a determination by the Government of the United States that the grant of route authority
provided for under the bilateral is in the ‘public interest.’”).
4
See Order 2016-4-12, Docket DOT-OST-2013-0204 (April 15, 2016) at 7.
8
requested foreign air carrier permit and exemption authority is fully consistent with the Air
Transport Services Agreement between the Government of the United States of America and the
Government of the Republic of Venezuela, dated August 14, 1953, as amended (U.S.-Venezuela
Agreement). Approving Laser Airlines’ request is also in the public interest, as it would promote
aviation relations between the United States and Venezuela, as well as provide vital air services
to the U.S.-Venezuela traveling public. This critical service will also provide benefits to the
economies and populations of both countries by opening another avenue for trade, including
shipments of much-needed humanitarian cargo. As the Department is aware, the population of
Venezuela is currently suffering from severe food and medicine shortages, and Venezuela needs
to pursue any opportunity to draw these much needed supplies to its country.
Additionally, Santa Barbara Airlines, which operated twice daily service between
Caracas and Miami, recently departed the market and suspended operations indefinitely. This
reduced the number of seats available in the Caracas-Miami market by approximately 316,800
seats per year, and slashed the number of Venezuelan carriers that operate scheduled service to
the United States by 50%. Currently, just one Venezuelan airline, Avior, operates own-metal
service to the United States, and there is no own-metal Venezuelan flag service between Caracas
and Miami.
18. Policy of applicant’s homeland with respect to U.S. carriers’ applications for
scheduled and charter authority. 211.20(r)
Opportunities for U.S. carriers to provide scheduled and charter service to Venezuela are
available pursuant to the U.S.-Venezuela Agreement, and at least one U.S. carrier (American
Airlines) currently provides scheduled service to Venezuela. Many other U.S. carriers are fully
authorized and designated to provide service to Venezuela under the U.S.-Venezuela Agreement,
but have chosen not to operate in the market for commercial reasons. Moreover, the Government
9
of Venezuela approved Dynamic International Airways’ application to conduct passenger flights
between New York (JFK) and Caracas, and the Department approved a number of applications
by Transcarga International Airways to conduct U.S.-Venezuela all-cargo charters based on
reciprocity.
5
19. Has applicant been involved in any safety or tariff violations or fatal accidents in
the last five years? 211.20(s)
Laser Airlines has not been involved in any safety violations or fatal aircraft accidents
within the last five years.
20. Submission of OST Form 4523 (Waiver of liability limits under the Warsaw
Convention). 211.20(t)
Laser Airlines submitted an OST Form 4523 to the Department in Docket OST-95-236.
A copy is also attached. (See Exhibit 8).
21. Attached as Exhibit 9 is a verification statement, signed by Laser Airlines as
required by 14 C.F.R. § 211.11.
Based upon the information provided in this Application, issuance of exemption authority
will not constitute a “major regulatory action” as provided for in the Energy Policy and
Conservation Act of 1975 and 14 C.F.R. Part 313. Similarly, Laser expects that its annual fuel
consumption will be less than ten million gallons. Issuance of a Foreign Air Carrier Permit and
exemption therefore will not constitute a “major federal action significantly affecting the quality
of the human environment” within the meaning of Section 102(2)(c) of the National
Environmental Policy Act.
22. A copy of Laser Airlines’ Family Assistance Plan will be filed with the
Department and the National Transportation Safety Board in accordance with 49 U.S.C. 43131.
5
See, e.g., Statement of Authorization 2017-121, authorizing certain U.S.-Venezuela all-cargo operations, issued
March 1, 2017 (undocketed).
10
23. Pursuant to 14 C.F.R. 243.13, Laser Airlines will file a statement with the
Department summarizing how it will collect and transmit passenger manifest information to the
Department of State in the event of an aviation disaster.
WHEREFORE, Laser Airlines respectfully requests that it be granted an exemption and
foreign air carrier permit to engage in scheduled and charter foreign air transportation of persons,
property and mail as more fully described above. Laser Airlines also requests expedited
approval of this Amended Application and any further that the Department may deem
appropriate.
Respectfully submitted,
.
Evelyn D. Sahr
Drew M. Derco
Counsel to Laser Airlines
Dated: August 13, 2018
Exhibit 1: Management
Key Management
Name / Nationality
Position
Professional Experience
Inocencio Alavarez Vasquez
Nationality: Venezuelan
Chairman
Chief Executive Officer and Sole Shareholder of the
following companies from 1963:
Laser Airlines, C.A
Pecuaria Mango y Limón, C.A
Ganadería Industrial Los Andes, C.A
Matadero Panamericano, C.A
Ganadería Hato Matarala, C.A
Panadería y Pastelería Alicantina, C.A
Crocante, C.A
Frigorífico Trébol, C.A
Residence: C/ARAUCA, RES. ISABEL, PH2, COL. BELLO MONTE,
CARACAS, VENEZUELA
Enail: [email protected]om.ve
Alejandro Alvarez Grueiro
Nationality: Venezuelan
Executive Director
Duties and studies 1994:
Law Degree of Universidad Católica Andres Bello,
Associate of Steel Hector & Davis, S.C (Law Firn),
Vice President of Laser Airlines
Residence: C/ORINOCO, RES. ORINOCO, PH1B, COL. BELLO MONTE,
CARACAS, VENEZUELA.
Email: aalvarez@laser.com.ve
Orlan Paul Viloria Moreno
Nationality: Venezuelan
Executive President
Aserca Airlines (Executive Vice President
Administrativo)
Aserca Airlines (Executive Director General)
Santa Barbara Airlines (Executive President)
Residence: CALLE SUR 3, RES. NARANJALES, PISO 6, APTO. 6C, URB.
LOS NARANJOS DE EL HATILLO, CARACAS, VENEZUELA
Email: [email protected]om.ve
Rene Guillermo Cortes Vidal
Nationality: Venezuelan
Executive Vice-
President
Aserca Airlines/ Santa Barbara Airlines
(Director Comercial /VP Comercial)
Avior Airlines (VP Comercial)
Residencia: CALLE LA COLINA, RESIDENCIAL VILLAS DEL ESTE, VILLA
NUMERO 5, SECTOR LA UNION DE EL HATILLO, CARACAS.
Email: [email protected]om.ve
Angel Machado
Nationality: Venezuelan
Director of
Operations
Wayman Aviation Flight School (Instructor)
Aerotécnica (Primer Oficial King 90 y DHC-6)
Laser Airlines, C.A (Director de Operaciones Aéreas y
Terrestres)
Residence: AV. FRANCISCO DE MIRANDA, EDIF. LAS LUISAS, PISO 15,
APTO. 15-A, CHACAO, ESTADO MIRANDA
Email: amachado@laser.com.ve
Milagros Quintero
Nationality: Venezuelan
Director of Airports
Aserca (Directora)
SBA (Vicepresidente)
Laser Airlines, C.A (Directora de Aeropuertos)
Residence: 2A. AV. LAS DELICIAS DE SABANA GRANDE, EDIF. WEST,
PH, ESTADO MIRANDA
Email: mquintero@laser.com.ve
Carmen Bolaños
Nationality: Venezuelan
AVSEC Manager
Avensa (Profiler)
Aeropostal (Instructora AVSEC)
Transcarga (Gerente de Seguridad)
Rubtzaida Machado
Nationality: Venezuelan
SMS Manager
Instituto Nacional de Aeronáutica Civil (Inspector II)
Centro de Instrucción Aeronáutica (Directora)
Laser Airlines, C.A (Jefa de Cabina)
Residence: PLAYA GRANDE, RESD. LOS DELFINES, PISO 3, CATIA LA
MAR, EDO. VARGAS
Email: Rmachado@laser.com.ve
Leyffer Fernandes Ibarra
Nationality: Venezuelan
Director of
Maintenance
Avior (Gerente de Control de Calidad)
Laser Airlines, C.A (Director de Control y
Aseguramiento de la Calidad)
Residence: CONJ. PLAZA MARINA, TORRE C, PISO 1, APTO 16,
LECHERIA, EDO. ANZOATEGUI
Email: lfernande@laser.com.ve
Daniel Diaz Caraballo
Nationality: Venezuelan
Director Of
Assurance and
Quality Control
Albatros Airlines (Director de Mantenimiento)
Laser Airlines, C.A (Director de Mantenimiento)
Pawa (Gerente de Aseguramiento de la Calidad)
Residence: AV. EL HOTEL, EDIF. VILLAMAR, PISO 9, SECTOR PLAYA
GRANDE, CATIA LA MAR, EDO. VARGAS
Email:[email protected]m.ve
Fernando Rivero
Nationality: Venezuelan
Adviser
Aeroambulancia C.A (Gerente de Mantenimiento)
Taller Inversiones Meivy S.A (Gerente de
Mantenimiento)
Laser Airlines, C.A (Gerente de Mantenimiento)
Residence: LOS CAOBOS NO. 48, PARAGUACHI, LA ASUNCION, EDO.
NUEVA ESPARTA
Email: [email protected]om.ve
Exhibit 2: Ownership
Laser Airlines - Ownership
SHARES
PERCENTAGE
RODOLFO AZPURUA GASPERI
1
0.000016667%
SUCESION ELBA MATILTE AZPURUA DE RIVERO
1
0.000016667%
EDUARDO SMITH
189
0.003150000%
JOSE ANTONIO ROMERO ALVAREZ
253
0.004216667%
ALICIA ALVAREZ
313
0.005216667%
JOEL BRACHO FRANCO
396
0.006600000%
MATIAS GUILLERMO SMITH
16
0.000266667%
INOCENCIO ALVAREZ VAZQUEZ
264779
4.412983333%
ALEJANDRO ALVAREZ GRUEIRO
52
0.000866667%
INMOBILIARIA ALISER, C.A.
5734000
95.566666667%
TOTAL
6000000
100.000000000%
Exhibit 3: Evidence of Insurance
Exhibit 4: Air Operator Certificate and Air Service License
Exhibit 5: Designation of Laser Airlines to Operate Caracas-
Miami Route
Exhibit 6: Fleet
Laser Airlines – Fleet List
MANUFACTURER
MODEL
SERIAL
REGISTRATION
STATE OF
REGISTRY
NAME OF REGISTERED
OWNER
ADDRESS OF REGISTERED OWNER
1
Douglas Aircraft
Company
DC-9-81
53299
YV469T
Venezuela
Bank of Utah.
Salt Lake City, UT, USA
2
Douglas Aircraft
Company
DC-9-81
53043
YV480T
Venezuela
Bank of Utah.
Salt Lake City, UT, USA
3
Douglas Aircraft
Company
DC-9-81
53301
YV492T
Venezuela
Bank of Utah.
Salt Lake City, UT, USA
4
Douglas Aircraft
Company
DC-9-81
49907
YV1240
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
5
Douglas Aircraft
Company
DC-9-81
49908
YV1243
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
6
Douglas Aircraft
Company
DC-9-82
49563
YV2923
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
7
Douglas Aircraft
Company
DC-9-82
49564
YV2945
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
8
Douglas Aircraft
Company
DC-9-82
49565
YV3145
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
9
Douglas Aircraft
Company
DC-9-82
49566
YV3053
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
10
Douglas Aircraft
Company
DC-9-82
49919
YV3244
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
11
Douglas Aircraft
Company
DC-9-82
49924
YV2927
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
12
Douglas Aircraft
Company
DC-9-82
53027
YV3367
Venezuela
Línea Aérea de Servicio
Ejecutivo Regional, C.A.
(LASER Airlines)
Av. Principal El Bosque, Edif. CREDICARD,
Piso 13, Ofic 131, Urb El Bosque, Chacao, Edo.
Miranda, Venezuela
Exhibit 7: Financial Information
Financial Information being Submitted under Seal
Pursuant to a Motion for Confidential Treatment
Exhibit 8: OST Form 4523
Exhibit 9: Verification Statement