Brilligan Ltd. d/b/a/ Best Light Video

51 N. Pearl St, 

Columbus, OH 43215

December 31, 2015 

US Department of Transportation Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE Washington, DC 20590 

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

Regulations from 14 CFR Part 21; 14 CFR 45.23(b); 14 CFR § 61.315 (c) (2); 61.315 (c) (3); 

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 407 (a) (1); 

91.409(a) (2); 91.417 (a) & (b); 91.7 (a); 91.9 (b) (2) 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 CFR Part 11, Brilligan Ltd. d/b/a/ Best Light Video, a video production company, 

hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of their UASs (Multi-Rotor) by certain qualified employees, so long as 

such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA. As described more fully below, the requested exemption would permit 

the operation of small, unmanned UASs under controlled conditions in airspace that is 1) limited 

2) predetermined and 3) controlled as to access. The requested exemption would provide 1) 

safety enhancements to operations in the video production industry and 2) aerial video of land 

and buildings that clients own. These operations would provide improved safety over the existing 

means of obtaining the same data with larger manned systems. 

This petition was written with regard to approved petitions numbered: 12108, 11240, 11465 and 

11625. 

2 The name and address of the applicant is: 

Brilligan Ltd. d/b/a/ Best Light Video

51 N. Pearl St, 

Columbus, OH 43215

This petition has been prepared by the following legal counsel for the applicant:

Attn: Douglas Linn

Email: Doug@LinnGrendell.com

Address: 7588 Central Parke Blvd. #227

Mason, OH 45040
Regulations from which the exemption is requested: 

14 CFR Part 21; 

14 CFR 45.23 (b); 

14 CFR § 61.315 (c) (2); 

14 CFR § 61.315 (c) (3); 

14 CFR 91.103; 

14 CFR 91.109; 

14 CFR 91.119; 

14 CFR 91.121; 

14 CFR 91.151 (a); 

14 CFR 91.203 (a) & (b); 

14 CFR 91.405 (a); 

14 CFR 91.407 (a) (1); 

14 CFR 91.409 (a) (2); 

14 CFR 91.417 (a) & (b); 

14 CFR 91.7 (a); 

14 CFR 91.9 (b) (2)

Primary Use

The primary uses of UASs by Brilligan Ltd. d/b/a/ Best Light Video in and around 

various cities are as follows: 

1) Videography of buildings and land for commercial video projects that are commissioned 

by clients. 

It is anticipated that the process will be accomplished solely during the day. To capture 

the highest quality of resolution the majority of airborne data collections will take place during 

the 8:00am to 5:00pm window. Our teams will operate under the principles of: Safety First, 

Accountability, Reporting, and Training. These lightweight aircraft will operate at slow speeds 

and under 200 feet. All flights will occur over private and controlled-access property with the 

property owner’s prior consent and knowledge. Image capture of people will rarely take place, 

but in the event it does, they will have consented prior to being filmed or otherwise have agreed 

to be in the area where data collection will take place. All flights will be conducted according to 

any State local and federal laws regarding privacy. 

Statement of Public Interest

Use of this UAS and similar UASs for the reasons listed herein is far safer than larger 

manned vehicles (whether in the case of a crane or a manned aircraft), not only for the pilot, but 

for people of the public who may be involved if there was an incident. Given the clear direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended, the strong equivalent level of safety surrounding the proposed operations, and 

significant public benefit, including enhanced safety, reduction in environmental impacts, 
(including reduced emissions associated with allowing UASs for filming and survey operations), 

the grant of the requested exemptions is in the public interest. Accordingly, the applicant 

respectfully requests that the FAA grant the exemption without delay. 

Aircraft and Equivalent Level of Safety

The UAS that we propose to use is a DJI Inspire 1. The manual can be found here. 

http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

It is estimated that the use of UAS aircraft will reduce risks of injuries to human beings. 

Aside from reducing the number of physical climbs, the utilization of UAS will dramatically

lower the use of cranes and lifts, which also pose dangerous conditions for film crews. In a 

number of instances, private land owners require aerial shots that may otherwise be inaccessible 

or difficult to access. 

Approval of exemptions allowing commercial operations of UASs in the video 

production industry will enhance safety by reducing risk. We would otherwise have to charter 

helicopters, film from higher nearby buildings or employ booms and cranes to shoot video that 

our clients require. 

Brilligan Ltd. d/b/a/ Best Light Video’s UASs are multi-rotorcraft, weighing 15lbs. or 

less, including sensor payload. They will operate their multi-rotorcraft, under normal conditions 

at a speed of no more than 35 knots and have the capability to hover, and move in the vertical 

and horizontal plane simultaneously. We will manually operate only in VLOS and will operate 

only within the private areas described herein. Given the small size and weight of the UAS 

involved and the restricted sterile environment within which they will operate, the applicant falls 

squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned 

that the FAA, by exemption, allows commercial operations of UASs to commence. Also due to 

the size of the UASs and the restricted areas in which the relevant UAS will operate, approval of 

the application presents no national security issue.

The applicant proposes that the exemptions 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 higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to the 

similar operations conducted with conventional aircraft and represent a safety enhancement 

when compared to the climbs that take place without aircraft. These limitations and conditions to 

which Brilligan Ltd. d/b/a/ Best Light Video agrees to be bound when conducting commercial 

operations under an FAA issued exemption include: 

1: The UAS will weigh less than 15 lbs when carrying a load, is constructed by a high reputation 

company and uses a Multi-copter base application. 
2. Flights will be operated manually within visual line of sight (VLOS) of the Operator (PIC) and 

Observers 

3. Maximum total flight time for each operational flight will depend on battery charge, the 

average flight will be 30 +/- minutes. Flights will be terminated at 25% battery power reserve 

should that occur prior to the 30 +/- minute limit. 

4. Flights will be operated at an altitude of no more than 200 feet AGL. 

5. Minimum two (2) man crew for each UAS operation will consist of the Operator and 

Observer. 

6. The UAS Operator will have a COA prior to conducting any operations, the COA will be 

submitted in conjunction with this petition of exemption 333, or the operator will be operating 

under the blanket COA. 

7. The UAS will only operate within a confined and controlled privately owned area. 

8. Brilligan Ltd. d/b/a/ Best Light Video will develop procedures to document and maintain a 

record of the UAS maintenance, preventative maintenance, alteration records, and status of 

replacement/overhaul component parts. 

9. A pre-flight safety risk assessment procedure, according to the manual, and a briefing will be 

conducted in regard to the planned UAS operation prior to each day’s production activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the 

safety perimeter be present for this briefing. 

10. Spotter (Observer) and Operator will at all times be able to communicate by voice, radio, 

and/or text. 

11. Generally applicant will be the owner of the property being surveyed and when it is not, 

written and/or oral permission from the relevant property holders will be obtained. 

12. All required permissions and permits will be obtained from state, county or city jurisdictions. 

13. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

14. The UAS will have the capability to abort a flight in case of unpredicted obstacles 

emergencies. 

15. The UAS will 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. 
16. The PIC will have an aviation sport license. PIC will have training on the specific manual to 

the UAS and a minimum of 7 hours or ten 30-minute practice runs with the specific UAS 

following our guidelines for operation pursuant to this petition. 

UAS Control

The Inspire One Remote Controller is a wireless communication device using the 5.8GHz 

frequency band. Remote Controller and UAS are paired before delivery. 

UAS Payload/Camera

Our Inspire 1 UAS will be using the stock camera (within the manual) with a total 

payload of approximately 7 pounds. Any change in camera will be noted in the aircraft log and 

will result in no more than a 15 pound payload. If changed, prior to resuming commercial 

operations, the UAS will be flight tested in accordance with our maintenance procedures outlined 

in our procedures summary. 

14 CFR Part 21, Subpart H: Airworthiness Certificates

14 CFR §91.203 (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 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 

multi-rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

The UAS to be operated hereunder is far less than 55 lbs. fully loaded, carries neither a 

Pilot nor Observers, carries no explosive materials nor flammable liquid fuels, and operates 

exclusively within a secured area as set out in the Manual. Operations under this exemption will 

be tightly controlled and monitored by both the Operator, pursuant to safety requirements, and 

under the requirements and in compliance with local public safety requirements, to provide 

security for the area of operation as is now done with conventional tools. These safety 

enhancements, which already apply to civil aircraft operated in connection with Industrial, 

Videography and Photography production and Real Estate, 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 operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load.
14 CFR § 45.23 (B): Marking of the Aircraft

The regulation requires that the registration number is displayed on limited, restricted or 

light-sport category aircraft or experimental or provisionally certificated aircraft. The operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted”, 

“light-sport,” “experimental,” or “provisional,” as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage 

as required by §45.29 (f) where the Operator (PIC) and Observers and others working with the 

UAS will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 CFR § 61.315 (c) (2) & (3): Pilot in Command Privileges

§ 61.315 (c) (2) says that one may not act as pilot in command of a light-sport aircraft: 

for compensation or hire and (3) says that one may not act as a PIC with a sport license in 

furtherance of a business.

Paragraph 13 under conditions included in many FAA 333 petition approval letters reads: 

“Under this grant of exemption a PIC must hold either an airline transport, commercial, private, 

recreational or sport pilot certificate.” 

Our PIC will have a light-sport pilot license. 

7 14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved multi-rotorcraft flight manuals will not be provided 

for the aircraft an exemption will be needed. An equivalent level of safety will be provided by

the Manual. The PIC will take all actions including reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. 

14 CFR §91.109: Flight Instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. UASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training 
without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety is 

accomplished because no pilots will be on the aircraft and the GCS will be a safe distance from 

the aircraft and the public, causing no safety hazard. Given the size and speed of the Inspire 1

UAS, an equivalent level of safe training can still be performed without dual controls because no 

pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the 

event that the aircraft experiences any difficulties during flight instruction. In addition, Brilligan 

Ltd. d/b/a/ Best Light Video will conduct flight training at a remote facility away from 

population centers. These training flights will be conducted on the sites and will otherwise 

comply with the provisions in the Manuals. 

14 CFR §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As set forth herein, except for the limited conditions stated in the Manual, the UAS will

never operate at higher than 200 ft. AGL. It will be operated in restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their preobtained consent. 

The equivalent level of safety will be achieved given the size, weight and speed of the 

UAS as well as location where it is operated. No flight will be taken without the permission of 

the property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 

operations as set forth in the Manual. 

Compared to flight operations with aircraft or multi-rotorcraft weighing far more than the 

maximum 55 pounds, the UAS proposed herein and the lack of flammable fuel with the UAS 

means that any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 ft. AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these small UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119. 

14 CFR §91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. 

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions
Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes.” The battery powering the UAS provides approximately 40 minutes of powered flight. 

To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight 

in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area 

where only people and property owners or official representatives who have signed waivers will 

be allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that 

Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted. Applicant believes that an equivalent level of safety can be achieved 

by limiting flights to 30 minutes or 25% of battery power whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone from 

anywhere in its limited operating area.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in §91.715, no person 

may operate a civil aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certificate... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (b) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 10 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 UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the Pilot flying the UAS will have immediate 

access to them, to the extent they are applicable to the UAS. 

14 CFR §91.405 (a); 407 (a) (1); 91.409(a) (2); 417 (a) & (b): Maintenance Inspections

These regulations 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 that these sections and Part 43 apply only to aircraft with an airworthiness 

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 

Manufactures Manual. 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 200 ft. 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 most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

14 CFR §91.7 (a): Civil Aircraft Airworthiness

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 as well as a preflight inspection, and the fact that all maintenance and 

alterations will be properly documented in the aircraft records prior to each flight, an equivalent 

level of safety will be provided. 

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Multi-rotorcraft Flight Manual is not required by §21.5 of 

this chapter, unless there is available in the aircraft a current approved Airplane or Multirotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof. 

The UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no room 

or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained 

by keeping the flight manual at the ground control point where the pilot flying the UAS will have 

immediate access to it. 

Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Brilligan Ltd. d/b/a/ Best Light Video seeks an exemption from the following rules: 14 CFR Part 

21; 14 CFR 45.23(b); 14 CFR § 61.315 (c) (2); 61.315 (c) (3); 91.103 (b); 91.109; 91.119; 

91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 407 (a) (1); 91.409(a) (2); 91.417 (a) & (b); 
91.7 (a); 91.9 (b) (2) , in order to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit Brilligan Ltd. d/b/a/ Best Light Video to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting: 

1.) Videography of buildings and land for commercial video projects that are commissioned 

by clients.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security – provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of applicant’s UAS in the Real 

Estate industry pursuant to the Manual appended hereto. Brilligan Ltd. d/b/a/ Best Light Video, 

stand by to support the FAA and UAS community in its mission to establish proper regulations 

and protocols for the safe introduction of unmanned aircraft into the national airspace. 

Sincerely, 

Douglas Linn

Legal Counsel 

Brilligan, Ltd.