David Constine

T: 617-359-4386 constine@gmail.com

June 19, 2015

U. S

. D epartment o f Transportation
Docket M anagement S ystem
1200 New Je rsey A ve., SE Washington, D C 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the

Federal A viation Regulations from 1 4 C.F.R. 45. 23(b);14 CFR P art 21; 91

. 7 (a);91.9 ( b) ( 2);91.103(b); 9 1.109;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).

Dear S ir or M adam:

Pursuant t o S ection 333 of the FAA M odernization and Reform A ct o f 201 2 (the Reform Act) a nd 14 C .F.R. P art 11, Illumina Filmworks LLC, a commercial video production company

e quipped to c onduct aerial phot ography for corporate video and television

, hereby appl ies for a n exempti on from t he l isted Federal A viation Regulations ( “FARs”) t o al low c ommercial oper ation
of i ts s UASs, so long a s such operations a r e conducted within and under t he conditions out lined
herein or as may be established by t he FA A a s r equired by S ection 333. 1

As des cribed m or e fully bel ow, t he r equest ed exemption would permit the operation of small, un manned and r elatively i nexpensive sUAS under c ontrolled conditions in airspace t hat i s 1) limited 2) pr edetermined 3) c ontrolled as to access 4) during daylight hours and 5 ) w ould provide safety enhancements t o the already s afe ope rations i n the film a nd television industry

pr esently us ing conventional ai rcraft. Approval of t his ex empti on would thereby enhanc e s afety
and fulfill t he Secretary o f Transportation’s ( the FA A A dministrator’s) r esponsibilities t o “...
establish requirements for t he safe oper ation of s uch ai rcraft s ystems i n t he nat ional airspace system.” Section 333(c) o f the R eform A ct.

The nam e and address o f the applicant i s:

Illumina Filmworks LLC

Attn: David Constine
Ph:6 17-359-4386
Email: constine@gmail.com

Address: 524 Walnut Street Suite 330 Kansas City, MO
64106

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8

- Issue a Certificate of Waiver for Motion Picture and Television Filming.June 19, 2015

Pag e Two

Regulations from w hich the exemption is requested:

14 CFR P art 21
14 C.F.R. 45.23(b)
14 C.F.R. 91

. 7 (a)
14 CFR 91. 9 ( b) ( 2)
14 C.F.R. 91 .103
14 C.F.R. 91 .109
14 C.F. R

. 91. 119
14 C.F.R. 91 .121
14 CFR 91. 151 ( a)
14 CFR 91. 203 ( a) & ( b)

14 CFR 91.405 (a)
14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This exempti on application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s s ize, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the nat ional airspace system.” Id. §333(c) (emphasis added) 2

.

The Federal Aviat ion Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must
have a current airworthiness certificate.

2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS , if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.June 19, 2015

Pag e Three

The A dministrator

m ay gr ant an exemption from a r equirement o f a r egulation prescribed
under su bsecti on (a) or ( b) o f this se ction or a ny s ections 44702

- 44716 of this t itle if t he
Administrator finds t he exemption in the publ ic i nterest. 49 U.S.C. §44701 (f) See also 49 US C §44711(a); 49 U SC §447 04; 14 C FR §91. 203 ( a) ( 1).

Illumina Filmworks LLC’s s UASs ar e rotorcraft, w eighting 55 or f ewer l bs. i ncluding

pay load. They oper ate, under nor mal c onditions at a speed of no more t han 50 knots and hav e the capability t o hover, and mov e in the v ertical and horizontal pl ane s imultaneously. They w ill operate onl y i n line of s ight and w ill oper at e only w ithin the sterile area. Such operations w ill

i nsur e that t he s UAS w ill “ not c reate a hazard to users o f the nat ional a irspace system o r t he public.” 4

Given the small s ize of the sUASs i nvolved and the restricted sterile environment w ithin which they w ill oper ate, t he applicant falls squarely within that z one of s afety ( an equivalent
level o f s afety) i n w hich Congress env isioned that the FAA must, by ex emption, al low
commercial oper ations o f U ASs to commence i mmediately. Also due t o the size of the UASs

and the r estricted areas i n which the relevant s UASs w ill oper ate, appr oval o f t he appl ication presents no national s ecurity i ssue. Given the clear di rection in Section 333 of t he R eform A ct, the authority c ontained in the Feder al A viation Act, as amended; t he strong equivalent l evel of safety s urrounding the proposed operations, and the significant publ ic ben efit, i ncluding enhanced safety, reduction in environmental i mpacts, i ncluding reduced e missions as sociated with allowing U ASs for

t elevision operations, the grant o f t he requested exemptions is i n the publ ic i nterest. Accordingly, t he applicant respectfully r e quests that t he FAA gr ant t he requested ex emption without del ay.

AIRCRAF T AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe movie and television filming operations conducted with conventional aircraft

.

These limitations and conditions t o which Illumina Filmworks LLC ag rees t o b e bound
when conducting c ommercial o perations unde r an FA A i ssued exemption include:

4 Reform Act Section 333 (b).June 19, 2015

Pag e Four

1. The s UAS w ill w eigh less t han 55 lbs.
2. Flights w ill be operated within line of s ight o f a pi lot and /or obs erver. 3. Maximum t otal flight t ime f or ea ch oper ational flight w ill be 10-12 minutes. Flights w ill
be terminated at 30 % ba ttery po wer r eserve should t hat oc cur p rior t o the 20
minute limit.
4. Flights w ill be operated at an altitude o f no m ore than 400 feet A GL or

, not m ore t han

200 feet abov e an el evated platform from w hic h filming is pl anned.
5. Minimum crew for eac h operati on will consist of t he sUAS Pilot, t he Visual Observer,
and the C amer a Operator.
6. The UAS w ill onl y oper ate within a confi ned “Sterile Area” and requires t he
establishment of a “Security Perimeter” for t he flight oper ations a re a. 7. A br iefing w ill be conducted in regar d to the planned sUAS oper ations pr ior t o each day’s pr oduction activities. It w ill be mandatory t hat al l per sonnel w ho will be performing dut ies w ithin t he boundaries o f t he safety per imeter be present for this briefing.
8. T he operator will fil e a FAA Form 7711 -1

, or its equivalent, as modifi ed i n light of the requested ex emption, w ith the appr opriate Flight Standards D istrict Office.
9. T he operator will obtai n t he consent of all persons involv ed in t he filming and ensu re that only consenting persons will be allowed withi n 100 feet of t he flight operation,
and this r adius m ay be reduced to 30 feet bas ed upon an equivalent l evel of s afety determination, as r equired by S ection K of t he Manual.
10. At least three (3) days prior to any scheduled filming, Illumina Filmworks will submit a written plan of activities to the local FSDO having jurisdiction over that area.

11. Pilot and observer will hav e been trai ned i n operati on of UAS generally and received

up -t o -d ate information on the particular U AS t o be operated

. 12. Observer

a nd pilot w ill at al l t imes be able t o c ommunicate by v oice.
13. Written and/or

or al pe rmissi on from t he r elevant p roperty hol ders w ill be obtained.
14. All r equired permissions and permits w ill be obtai ned from t erritorial, s tate, c ounty or city j urisdictions, i ncluding l ocal l aw enf orcement, fire, or ot her appr opriate governmental a gencies.
15. If t he sUAS loses c ommunications o r l oses i ts G PS s ignal, the UAS w ill ha ve capability t o return to a pr e -d etermined location within the Security P erimeter and
land.
16. T he sUAS will hav e t he capability t o abort a flight i n cas e of unpredict ed obstacles or emergencies.June 19, 2015

Pag e Five

14 C.F.R. P art 2 1, S ubpart H : Airworthiness C ertificates 14 C .F.R. §9 1. 203 (a) ( 1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements
for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the

size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt
aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and in compliance with local public safety requirements, to provide security for the area of operation as is now
done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with
motion picture and television production, provide a greater degree of safety 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 of these same criteria

demonstrates that there is no credible threat to national security posed by the UAS, due

to its size, speed of operati on, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45. 23 ( b). Marking of t he Aircraft

The regulation requires:

Whe n marks i nclude only t he Roman ca pital l etter " N" and t he r egistration
number i s di splayed on limited, r estricted or l ight-sport ca tegory ai rcraft or experimental or

pr ovisionally ce rtificated aircraft, the operator m ust al so display
on that ai rcraft near

each ent rance t o t he cabin, cockpit, or pi lot s tation, i n letters

not l ess t han 2 inches no r m ore t han 6 inches hi gh, the words "limited," "restricted," "l ight

- sport," " experimental," o r " provisional," as appl icable.

Even though t he U AS w ill hav e no airworthiness c ertificate, an exempti on may be

ne eded as the UAS w ill hav e no entrance t o t he cabin, co ckpit o r pi lot station on which the w ordJune 19, 2015

Pag e Six

“Experimental” ca n be pl aced. Given the si ze of t he sUAV, two

- inch lettering will be impossible.
The w ord “Experimental” w ill be placed on t he fuselage i n compliance with §45.29 ( f).

The e quivalent l evel of s afety w ill be provided by hav ing t he sUAV m arked on its fuselage as r equired by §45. 29 (f) w her e the pilot, obs erver and others w orking with t he sUAV

will s ee the identificati on of the UAS as “ Experimental.” The FA A has i ssued the following exemptions t o t his r egulation to E xemptions N os. 10700, 8738

, 10167 and 10167A.

14 C.F.R. §91 .7(a): C ivil ai rcraft a irworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft,
should this exemption be granted, no FAA regulatory standard will exist for determining
airworthiness. Given the size of the aircraft and the requirements contained in the Manual for

maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F .R . § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Se ct i on 91 .9 ( b) ( 2 ) p r ov i de s:

No person may oper ate a U.S.

- registered ci vil aircraft

...

(2) For

w hich an Airplane or Rotorcraft Fl ight M anual i s not required by §21. 5
of this ch apter, unl ess t here is av ailable in the aircraft a cu rrent app roved airplane or

R otorcraft Fl ight M anual, appr oved manual m aterial, markings, and placards, or

any co mbination thereof.June 19, 2015

Pag e Seven

The sU AS, giv en its si z e and configuration has no abi lity or pl ace to carry s uch a flight
manual on the ai rcraft, n ot onl y beca use there i s no pilot on board, bu t be cause there is no

room o r ca pacity t o ca rry su ch an i tem on t he ai rcraft.

The e quivalent l evel of s afety w ill be maintained by k eeping t he flight manual at the ground control poi nt w her e the pilot flying the sUAS w ill hav e immediate access to it. The FAA
has issued the followin g ex emptions t o t his r egulation: E xemption N os. 86 07, 8737

, 8738

, 9299

, 9299A, 9565

, 9565B

, 10 167, 10167A

, 10602

, 32 827, and 10700.

14 C.F.R. § 91. 103: P reflight ac tion

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approv ed rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including rev iewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91 .109: Fl ight i nstruction :

Section 91.103 pr ovides that no pers on may oper ate a c ivil ai rcraft ( ex cept a manned free
bal loon) t hat i s bei ng us ed for flight i nstruction unless that ai rcraft has fully func tioning dual
controls

.

s UASs and remotely pi loted airc raft, by t heir des ign do not hav e fully func tional dual
controls

. Flight c ontrol i s ac complished throug h the use of a c ontrol box that c ommunicates w ith
the aircraft v ia radi o c ommunications. The FA A h as appr oved exemptions for f light t raining
without fully f unctional d ual c ontrols for a num ber

o f ai rcraft and for

f light i nstruction in experimental ai rcraft. S ee Exemption Nos.5778K & 9862A

. The equivalent level of s afety provided by t he fact that neither a pi lot no r

pas sengers w ill be carried i n the aircraft and by the size and speed of t he ai rcraft.

14 C.F.R. §91 .119: Minimum saf e al titudes

Section 91.119 es tablishes s afe al titudes for oper ation of c iv il ai rcraft. Section 91.119 (d)
allows hel icopters t o be operated at l ess t han t he minimums pr escribed, p rovided the person operating the helicopter c omplies w ith any r oute or al titudes p res cribed for hel icopters by t he

FAA. As t his ex empti on is for a sUAS t hat i s a helicopter and t he ex emption requests a uthority to operate at al titudes up t o 400 AGL, or not more t han 200 abov e an el evated platform f rom which filming is p lann ed, an ex empti on may be needed to al low s uch operations

. As set forth herein, he UAS w ill never oper ate at higher

t han 400 AGL. It will ho wever be operated i n a restricted ar ea w ith security per ime ter, where buildings and people will not be expos ed to operations w ithout their pr e -o btained consent.June 19, 2015

Pag e Eight

The e quivalent l evel of s afety w ill be achieved given the si ze, w eight, sp eed of t he U AS

as w ell as t he location w here it i s ope rated. N o flight w ill be taken without the permission of the property ow ner

or l ocal o fficials. Because o f t he a dvance notice to t he pr operty ow ner and participants i n the filming activity

, al l a ffected i ndividuals w ill be aware of t he pl anned flight operations

. Compar ed t o flight ope rations with aircraft o r rotorcraft w eighti ng far m or e t han t he
maximum 5 5lbs. pr oposed herein and the l ack o f flammable fuel, any r isk associated with these operations i s far

l ess t han t hose presently prese nted w it h conventional ai rc raft oper ating at o r bel ow 500 AGL i n the video production industry. In addition, t he l ow -a ltit ude operations o f the

s UAS will ens ure separation between these small -U AS oper ations an d t he operations o f
conventional ai rcraft t hat must c omp ly with Section 91.119.

14 C.F.R. §91

. 121 Altimeter S ettings

This regulati on requires each person oper ating a n aircraft t o maintain cruising al titude by
referenc e to an al timeter that i s s et “...t o the elevation of t he depar ture ai rport o r a n appropriate
altimeter s etting av ailable before departure.” As the sUAS m ay no t hav e a bar ometric al timeter,
but i nstead a G PS altitude read out

, an ex emption m ay be needed. An e quivalent l evel of safety w ill be achieved by t he operator and Sa fety Ch eck lis t, c onfirming the al titude o f t he

l aunch site s hown on the G PS al titude indicator be for e flight.

14 C.F.R. § 91. 151(a): Fuel R equirement s for Flight i n VFR Conditions

Section 91.151 ( a) p rohibits an individual f rom be ginning “a flight i n an ai rplane under

VFR c onditions unl es s (considering wind and forec ast w eather c onditions) there i s enou gh fuel

t o fly t o t he firs t poi nt o f i ntended landing, and, as suming normal c ruising s peed – (1) D uring t he day, t o fly a fter

t hat for a t l east 30 minute s; or ( 2) A t night, t o fly after t hat f or at least 45
minutes .”

The bat tery pow ering the s UAS pr ovides approximately 20-25 minutes o f po wered flight.
To meet t he r eserve requirement i n 14 C FR §91. 151, s UAS flights would be limit ed to approximate ly 1 0-12 minutes i n length. Giv en the l imitations on the UAS’s p ropos ed flight area and the location o f i ts pr oposed operations w ithin a predetermined area, a longer t im e frame for flight i n daylight or

ni ght VFR c onditions i s reasonable.

Applicant bel ieves that a n exempti on from 14 C FR §91. 151(a) f alls w ithin the s cope o f prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporati on to operate
without c ompliance with FAR 91. 151 (a)). Operating the s mall U AS, i n a tightly c ontrolled area
wher e only peopl e and property ow ners or official r epres entatives w ho have signed w aivers w ill be allowed, w ith less t han 30 minutes o f r eserv e fuel, does no t en gender t he type of risks that
Sec tion 91.151(a) w as i nt ended to alleviate giv en the size and speed of the s mall UAS. Additionally, l imiting sUAS flights to 10 -12 minutes w ould greatly r educe t he u tility f or w hich the exemption will be granted.

Applicant bel ieves t hat a n equiv alent l evel of s afety c an be ac hieved by l imiti ng flights to
15 minutes o r 30 % o f ba ttery pow er w hichever

happens first. This r estriction would be moreJune 19, 2015

Pag e Nine

than adequat e t o retur n the sUAS t o i ts pl anned landing z one from any where in its l imited

oper ating a rea.

Similar ex emptions hav e been granted t o ot her operations, i ncluding Exemptions 2689F, 5745, 10673

, and 10808.

14 C.F.R. §91

. 203 (a) an d (b): Carrying Civil Aircraft C ertification and Registration

The re gulation provides in pertinent part:

(a) Exc ept as provided in § 91.715, no person may operate a civil aircraft

unless it has within it the following:

(1) An approp riate and current airworthiness certificate. . . .

(b) No pers on may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization i ssued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The UA S fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equiv alent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent

the y are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These r egulations require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given t hat these section and Part 43 apply only to aircraft with an airw orthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual.(See Sections L and Q) An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person mostJune 19, 2015

Pag e Ten

fam iliar w ith the ai rcraft a nd best su ited t o m aintain the ai rcraft i n an ai rworthy co ndition to provide the equivalent l evel of safety.

*********

Pursuant t o 14 C.F.R. P art 11, t he following su mmary i s provi ded for publ ication in the
Federal Register, sh o uld it be det ermined t hat pu blication is needed:

Applicant s eeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 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) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in motion picture and television operations.

Approval of ex emptions allowing commercial operations of sUASs in the film industry will enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters shown below). Such aircraft must fly to and from the film location. In contras t, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the film set and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operati on of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety su pporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Privac y

All f lights w ill occu r

ov er p rivate or

co ntrolled access property w ith the pr operty
owner’s pr ior

co nsent an d knowledge. Filming will be of peopl e who have also consented t o being filmed or

o therwis e have agr eed to be in the ar ea w her e filming w ill t ake pl ace.Satisfaction o f t he cr iteria provided in Section 333 of the R eform Act of 2 012

-- size,

weight, sp eed, ope rating capabilities, p roximity t o ai rports and popul ated a reas and oper ation
within visual l ine of si ght and national se curity – provide more t han ade quat e justificati on for t he grant o f t he r equested ex emptions al lowing co mmercial oper ation of appl icant’s U AS i n the motion picture and television industry pur suant t o t he M anual appended hereto.

Sincerely,



### David Constine

Owner/Partner

Illumina Filmworks LLC