December 15, 2015

1 | Mainlight Productions, LLC Petition for Exemption under Section 333

Dear Sir or Madam, 

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

14 C.F.R. Part 11, Mainlight Productions, LLC, operator of Small Unmanned Aircraft Systems 

(sUAS) equipped to conduct aerial filming and photographing to include: commercial and residential 

real estate, weddings, filmmaking, cinematography and videography infrastructure inspections, 

construction, architecture, scientific research, environmental assessment, land surveying and 

mapping and other applicable areas for pre-planned, controlled areas, training, special events: 

including high schools, colleges, professional sports, open air events and fairs, research, risk 

management assessments hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of its sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the Federal 

Aviation Administration (FAA) as required by § 333. Mainlight Productions, LLC operation of its 

sUAS for commercial purposes awaits a review and the anticipated granting of this petition by the 

FAA before conducting any operation for its clients to fully comply with all federal aviation 

regulations pertaining to sUAS. 

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and multi-rotor aircraft under controlled conditions in airspace that is 1) contained 2) 

predetermined 3) has on-site safety personnel controlling access, and 4) would provide increased 

safety and enhancements to clients' business operations. 

I am prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. I look forward to working with your office. Please contact me at any time 

if you require additional information or clarification. 

The name and address of the applicant is: 

Mainlight Productions, LLC 

Bryan Guzman

Co-Owner

Phone: 201-313-6388 

Email: bryan@mainlightproductions.com 

Address: 128 E Madison Ave Dumont NJ, 07628 

PUBLISHABLE SUMMARY 

The following summary is provided for publication in the Federal Register, should it be 

determined that publication is needed. 

Mainlight Productions, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 from the requirements of 14 CFR § 21; 
December 15, 2015

2 | Mainlight Productions, LLC Petition for Exemption under Section 333

61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 (a); 91.203; 

91.405 (a); 91.407 (a) (1); 91.409 (a) (2); and 91.417 (a) & (b). This exemption request will permit 

Mainlight Productions, LLC to operate its sUAS commercially for the purpose of aerial filming and 

photographing to include: commercial and residential real estate, weddings, filmmaking, 

cinematography and videography infrastructure inspections, construction, architecture, scientific 

research, environmental assessment, land surveying and mapping and other applicable areas for preplanned, controlled areas, training, special events: including high schools, colleges, professional 

sports, open air events and fairs, research, risk management and assessments. Mainlight Productions, 

LLC will provide a service that is beneficial to industries and organizations that are already using, 

and/or seeking to use, sUAS’s for these purposes with a legal and safe option. This will benefit the 

public with the controlled operation of sUASs and increase their integration into the NAS. 

The requested exemption should be granted because the proposed operation of the DJI Phantom 3, a 

small UAS (sUAS) weighing 2.82 Lbs., inclusive of battery and payload, conducted in the strict 

conditions outlined below, will provide an equivalent or better level of safety, as Congress intended, 

while still allowing commercial operations. The lightweight aircraft covered by the exemption is far 

safer than conventional operations conducted with helicopters and fixed-wing aircraft operating in 

close proximity to the ground and people. The seven factors Congress directed the FAA to consider 

when approving Section 333 exemption petitions - size, weight, speed, operational capability, 

proximity to airports, proximity to populated areas, and operation within visual line of sight - each 

support the request. In particular, the aircraft is small, and will operate at slow speeds, close to the 

ground, far from airports and in a low risk, low and controlled population environment. 

Name and address of petitioner: 

Mainlight Productions, LLC 

Bryan Guzman

128 E Madison Ave

Dumont, NJ 07628

Mainlight Productions, LLC

Main Business Address:

315 Closter Dock Rd. 

Closter, NJ 07624

BACKGROUND OF PETITIONER 

Mainlight Productions, LLC is a limited liability company owned and operated by (myself)

Bryan Guzman and Mr. Christopher Gorga. Mr. Gorga is currently in active pursuit of our

Private Pilot Certificate and the required medical certificate. He graduated from Rutgers 

University with a Bachelors in environmental and biological sciences. He is currently also the 

owner of CG designs for the past 3 years doing work as a web designer. I am currently up-todate with my medical certification with the American Red Cross, and also in active pursuit of a 
December 15, 2015

3 | Mainlight Productions, LLC Petition for Exemption under Section 333

Private Pilot Certificate. I am a Veteran of the United States Navy and currently employed with

The New Jersey State Parole Board.

Mainlight Productions, LLC will conduct its business using the DJI Phantom 3 sUAS. The 

Phantom 3 is a vertical takeoff and landing sUAS with a maximum gross weight of less than 55 

pounds and a maximum speed of less than 50 mph. The Phantom 3 is driven by lithium 

polymer batteries and powered by electric motors. 

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT 

This exemption request will permit Mainlight Productions, LLC to operate its sUAS 

commercially for the purpose of aerial filming and photographing to include: commercial and 

residential real estate, weddings, filmmaking, cinematography and videography infrastructure 

inspections, construction, architecture, scientific research, environmental assessment, land 

surveying and mapping and other applicable areas for pre-planned, controlled areas, training, 

special events: including high schools, colleges, professional sports, open air events and fairs, 

research, risk management, and assessment. Mainlight Productions, LLC will provide a service 

that is beneficial to industries and organizations that are already using, and seeking to use, 

sUASs for these purposes with a legal and safe option. This will benefit the public with the 

controlled operation of sUASs and increase integration into the NAS. 

Granting the present petition will further the public interest by allowing Mainlight Productions, 

LLC to perform safely, efficiently, and economically, aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. It will also 

allow better views for weddings, graduations, open air events, and any other entertainment 

based use that would require the use of an sUAS.

Additionally, use of the DJI Phantom 3 sUAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. 

The integration of sUASs into the NAS will not only replace traditionally more expensive 

options or approaches, it will enable work to be done and decisions to be made in ways that 

were simply impossible to do previously. The commercial deployment of small unmanned 

aircraft systems offers the public a new, highly efficient and relatively inexpensive platform for 

collecting, analyzing and utilizing data and photographic/video imagery. 

In deploying its sUAS, Mainlight Productions, LLC has developed specific performance 

standards, operating requirements, protocols and work processes that are aligned with the 

FAA’s continuing mission, and result in safe operating practices that are consistently applied 

and continuously improved. For its part, Mainlight Productions, LLC recognizes the important 
December 15, 2015

4 | Mainlight Productions, LLC Petition for Exemption under Section 333

role it plays in educating the public and building awareness of both the promise and 

precautions that accompany the commercial deployment of this new and exciting platform. 

The sUAS utilized by Mainlight Productions, LLC is battery-powered and serves as a safe, 

efficient and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. A grant of exemption would allow Mainlight Productions, LLC to contribute to the 

reduction of manned aircraft needed to perform the aerial acquisition of data, video and 

photographic content and subsequently reduce the volume of manned aircraft in the NAS. 

Conducting aerial acquisitions with the DJI Phantom 3 sUAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power 

and electric motors, the DJI Phantom 3 sUAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 sUAS, while 

reducing the carbon footprint of aerial acquisitions, also sharply reduces noise pollution, as the 

sUAS is propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the DJI Phantom 3 sUAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. The DJI 

Phantom 3 sUAS (weighing approximately 2.82 with battery and propellers attached and a its 

dimensions of 23.2” diagonal with propellers), has less physical potential for collateral damage 

to life and property on the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

Previously, such services as high-resolution digital aerial real estate photography, surveying 

and inspections were limited and affordable to a relatively small group of agencies, companies 

and organizations with significant operating capital. The granting of this exemption will enable 

Mainlight Productions, LLC to change this by deploying its sUAS in ways that make aerial 

photography and other sUAS services accessible and affordable to a significantly larger portion 

of individuals, organizations and businesses. The many new forms of aerial content would 

have immediate and direct benefits to service providers, business owners and consumers alike.

PUBLIC SAFETY 

With safety as its primary operational requirement, Mainlight Productions, LLC will plan, 

conduct and manage its flight operations within very specific and well-defined operating 

limitations and standards detailed in its flight operations protocols. These protocols also clearly

define the roles and responsibilities of the pilot in charge (PIC), visual observer (VO), sensor 

operator (SO) and the client representative working with the Mainlight Productions team. 
December 15, 2015

5 | Mainlight Productions, LLC Petition for Exemption under Section 333

In seeking this exemption, Mainlight Productions, LLC submits that the DJI Phantom 3 sUAS 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by the 

characteristics of the DJI Phantom 3 sUAS, the pilot certification requirements, and the 

specific operating limitations. The specifications of the DJI Phantom 3 sUAS demonstrate its 

safe characteristics. The DJI Phantom 3 sUAS does not create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security considering its size, weight, speed, 

and operational capability. Many of the functional capabilities and features of the DJI 

Phantom 3 sUAS enable it to be operated in a highly controlled, precise and safe manner. 

The DJI Phantom 3 sUAS autonomous flight and navigation modes enable it to remain within a 

defined operational area. Also, the DJI Phantom 3 sUAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 3 sUAS is provided on pages 12-16 and 45-50 of the DJI Phantom 3 User 

Manual.

The DJI Phantom 3 sUAS includes automatic return-to-home-point or hover functionality in 

the event of loss of the control link or navigation. When the control ink is lost, the DJI

Phantom 3 sUAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, 

the DJI Phantom 3 sUAS does not reacquire control link data from the ground control 

station/remote controller, the sUAS will assume that the control link is lost and will return to 

the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown. 

Whether helping to protect the public, inspecting infrastructure, conducting site and land 

surveys or acquiring aerial imagery and video, Mainlight Productions LLc sUAS will be 

providing its customers with more accurate and timely information. The real-time situational 

awareness and improved decision-making this achieves will enable Mainlight Productions 

customers and clients to communicate with and more safely serve and support their respective 

constituents. 

Strict adherence to specific flight operations protocols (see Attachment G and H), the use of the 

DJI Phantom 3 sUAS configured with significant safety functionality, the acquisition of an 

accurate understanding of both the flight operations area and its adjacencies using Mainlight 

Productions’ Site Safety and Planning Template (see Attachment L), and the use of Mainlight 

Productions’ On-Site Client Safety Briefing (see Attachment M) will provide a level of safety 

and oversight that is in complete alignment with the FAA’s mission to “provide the safest, 

most efficient aerospace system in the world.” [FAA online document, Public Guidance for 

Petitions for Exemption Filed under Section 333. Rev. 9/25/2014] 

PRIVACY 

All flights will occur over private or controlled-access property with the property owner’s or 

controlling authority’s prior consent and knowledge. Aerial photography and video capture 
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6 | Mainlight Productions, LLC Petition for Exemption under Section 333

will be of people who have provided their written consent to being photographed or have been 

authorized to be in the area where flight operations are taking place. Establishing and 

maintaining tight controls over access to the flight operations area will minimize privacy

issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Mainlight Productions, LLC’s proposed operation of the DJI Phantom 3 sUAS will not 

implicate any privacy issues. Specifically, the DJI Phantom 3 sUAS will be operated under 

detailed operational protocols designed to ensure client or property owner involvement as well 

as local law enforcement notification. Flight operations will be conducted in accordance with 

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 

91.119. 

Mainlight Productions, LLC has developed a proprietary work-site planning template (see 

Attachment L) that will be completed and reviewed with the client’s onsite representative prior 

to the commencement of any operation or project. This detailed diagram of the operational 

environment will provide the PIC), VO(s), SO, and any other designated support and security

personnel with a full understanding of the site or subject’s structural characteristics, layout, 

topography, adjacencies, and all significant and relevant natural and manmade features within 

the operational area. The template will also be used by Mainlight Productions, LLC personnel 

to gain a clear picture of any area or condition immediately adjacent to or near the operational 

area. The will enable Mainlight Productions, LLC to acquire a detailed understanding of the 

larger geographical context surrounding the flight operations area and review relevant factors 

with the client before the commencement of any work or service. 

CONDITIONS AND LIMITATIONS 

As set forth in Mainlight Productions, LLC Flight Operations and Procedures Manual (FOPM), 

which includes: All manufacturer documentation for the Phantom 3 sUAS and Mainlight 

Productions, LLC proprietary operations documentation for all sUAS operations (e.g., Flight 

Operations Protocols, Flight Checklists and Operating Procedures, Pilot Flight Log, sUAS Flight 

Log, Monthly 

Maintenance Log, Client Site Safety and Planning Template, Pre-Flight Operations On-Site Client 

Safety Briefing, Battery Power Management Matrix, and Permission to Conduct Onsite Flight 

Operations Consent Form), the applicant proposes the following limitations and conditions: 

1. UAS must weigh less than 55 pounds; 

2. UAS airspeed is not to exceed 50 knots; 

3. UAS flights may not operate at more than 400 AGL. Altitudes reported to ATC must be 

in feet AGL; 

4. UAS must be operated within Visual Line of Sight (VLOS) of the PIC and VO; 

5. All operations will utilize a VO. The VO may be utilized as long as the PIC maintains 

VLOS capability and can communicate with the VO at all times; 
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7 | Mainlight Productions, LLC Petition for Exemption under Section 333

6. The operator’s manuals and flight operations protocols will be amended to and revised as 

new conditions and/or limitations become known; 

7. The PIC will conduct a full inspection of the sUAS (including remote controllers) to 

ensure it is in full working order and safe for flight prior to every takeoff; 

8. A functional test flight must be performed following the maintenance, alteration or repair 

of any sUAS. Test flights will be performed by the PIC prior to the sUAS’s return to 

service. All such test flights will be noted and logged in the Monthly Maintenance Log 

the PIC’s personal Pilot Flight Log and the sUAS Flight Log. 

9. The operator must follow the manufacturer’s sUAS aircraft/component, maintenance, 

overhaul, replacement inspection and life limit requirements. The following must be 

included in the operator’s manual; 

a. Actuators/Servos; 

b. Power plant (motors); 

c. Propellers; 

d. Electronic speed controller; 

e. Batteries; 

f. Mechanical or dynamic components; 

g. Remote command and controller(s); 

h. Navigational screen/interface; and any other component(s) as determined by the 

operator. 

10. The PIC must possess at minimum a light sport pilot certificate and a valid U.S. driver’s 

license. Additionally, the PIC must meet the flight review requirements specified in 14 

CFR § 61.56; 

11. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 

(b), a minimum of 200 flight hours and 25 hours as a UAS rotorcraft pilot and at least ten 

hours logged as a UAS pilot with a similar sUAS type; 

12. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 

(b), a minimum of five hours as a sUAS pilot operating the make and model of sUAS to be 

utilized for operations under the exemption and three takeoffs and three landings in the 

preceding 90 days. The PIC must operate the sUAS with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119; 

13. The PIC and VO must have completed a qualification process; 

14. A flight demonstration, administered by an operator and a qualified pilot must be 

completed and documented in accordance with the operator’s manual; 

15. The sUAS may not be operated directly over any person, except authorized and consenting 

inspection and/or operations personnel, below an altitude that is hazardous to persons or 

property; 

16. All participating persons must be essential and consent to the sUAS operation which 

should require no further FSDO or ASI approval; 

17. The operator must ensure that no persons are allowed within 500 feet of the area except 

those consenting to be involved and who are necessary for the on-going operation of the 

entity being inspected or photographed; 
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8 | Mainlight Productions, LLC Petition for Exemption under Section 333

18. If the sUAS loses communications or loses its GPS signal, the sUAS must return to a 

predetermined location within the security perimeter of the flight operations area and land 

or be recovered in accordance with the operator’s manual; 

19. The PIC must abort the sUAS flight in the event of unpredicted obstacles or emergencies 

in accordance with the operator’s manual; 

20. Each operation must be completed within 20 minutes flight time or with no less than 25% 

battery power remaining, whichever occurs first; 

21. The operator must contain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this grant of exemption. 

This COA will also require the operator to request a Notice to Airman (NOTAM) not 

more than 72 hours in advance, but no less than 48 hours prior to the operation; 

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

number, registered in accordance with 14 CFR part 47 and have identification (NNumber) 

markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as 

possible; 

23. The operator must develop procedures to document and maintain a record of the sUAS 

maintenance, alterations, status of replacement/overhaul component parts and the total 

time in service of the sUAS; 

24. Each sUAS operated under this exemption will comply with all manufacturing safety 

bulletins; 

25. The operator will develop sUAS technician qualification criteria. And the criteria will be 

in the operator’s manual; 

26. The pre-flight inspections section of the operator’s manual will include the requirement 

that the pre-flight inspection will account for all discrepancies, e.g., inoperable 

components, items, or equipment; 

27. Before conducting operations, the radio frequency spectrum used for operation and control 

of the sUAS will comply with the FCC or other appropriate government oversight agency

requirements; 

28. At least three days before a scheduled flight operation the operator of the sUAS affected 

by this exemption will submit a written plan of activity to the local FSDO with jurisdiction 

over the area of the proposed inspection. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities will include the following: 

a. Dates and times for all flights 

b. Name and phone number of the operator for the sUAS flight operation conducted 

under this grant of exemption 

c. Name and phone number of the person responsible for the on-site operation of the 

sUAS 

d. Make, model, and serial and N-number of sUAS to be used 

e. Name and certificate number of sUAS PIC(s) involved in the flight operation 

f. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the flight operation; the list of those who gave permission 

shall be made available to the inspector upon request 

g. Signature of exemption-holder or representative 
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9 | Mainlight Productions, LLC Petition for Exemption under Section 333

h. The description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which the flight operation will be conducted and 

the altitudes essential to accomplish the operation 

i. The documents required under 14 CFR §§91.9 and 91.203 must be available to the 

PIC at the ground control station of the sUAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request. 

29. The sUAS must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to ultra-light vehicles, parachute activities, 

parasailing activities, hand gliding, etc.); 

30. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1 

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

under special visual flight rules (SVFR) are not authorized; 

32. The sUAS cannot be operated by the PIC from any moving device or vehicle; 

33. The sUAS may not be operated less than 500 feet below or less than 2000 feet horizontally

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

34. The sUAS may not be operated in class B, C, or D airspace without written approval from 

the FAA. The sUAS may not operate within 5 nautical miles of the geographic center of a 

non-towered airport as denoted on a current FAA- published aeronautical chart unless a 

letter of agreement with the airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the administrator upon 

request; 

35. Any 1) Incident, 2) Accident, or 3) Flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the Federal Aviation Administration's (FAA) UAS Integration Office (AFS-80) within 24 

hour. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instruction contained on the NTSB website: www.ntsb.gov. Further flight operations may

not be conducted until the incident, accident or transgression is reviewed by the AFS-80 

and authorization to resume operations is provided; 

36. The sUAS, PIC and operator will comply with all applicable parts of 14 CFR including, 

but not limited to, parts 45, 47, 61, and 91. 

LIST OF PROPRIETARY FLIGHT OPERATIONS, STANDARDS, PROTOCOLS AND 

PROCEDURES DOCUMENTATION 

As noted earlier, Mainlight productions FOPM includes all manufacturer’s documentation for the 

DJI Phantom 3 sUAS, as well as a number of flight operations protocols, requirements and 

procedures Mainlight Productions, LLC considers proprietary. Together, these documents 

governing the planning, management and execution of all Mainlight Productions, LLC flight 

operations. The FOPM is reviewed and updated on a regular basis to ensure it is accurate, current 

and reflects any new FAA requirement, change of standard and any improvement or addition to its 

flight operations Mainlight Productions, LLC considers to be in its clients’ and the public’s best 

interest. 
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10 | Mainlight Productions, LLC Petition for Exemption under Section 333

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED: 

14 CFR Part 21 

14 CFR 61.113 (a) & (b) 

14 CFR 61.133 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.109 (a) 

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 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

14 C.F.R. 21: Certification Procedures for Products and Parts 

This section outlines requirements for the issue of design and production approvals, 

airworthiness certificates, and other airworthiness approvals. Mainlight Productions, LLC

is aware that if an exemption is granted as per Section 333, an airworthiness certificate 

would be issued and a request for exemption from Part 21 is unnecessary. However, as 

outlined in the List of Limitations and Conditions in this application, as well as all of the 

Attachments to this application, comprising the FOPM, Mainlight Productions, LLC seeks 

to uphold the same level or exceeded level of safety as described in Part 21 of 14 C.F.R. 

14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: Pilot in 

Command. Commercial Pilot Privileges and Limitations. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because 

the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot’s license rather than a commercial pilot’s license to operate this 

sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is 

remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the FOPM. 

The level of safety provided by the requirements included in the FOPM exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the operation of the sUAS are so 

diminished from the level of risk associated with commercial operations contemplated by

Part 61 when drafted, that allowing operations of the sUAS as requested with a private 

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & 

(b). 
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11 | Mainlight Productions, LLC Petition for Exemption under Section 333

14 C.F.R. § 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 FOPM 

for maintenance and use of safety checklists prior to each flight, an equivalent level of 

safety will be provided. 

14 C.F.R. § 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 Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof. The sUAS, 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. 

14 C.F.R. § 91.109 (a): 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. sUAS 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. 

14 C.F.R. § 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 this exemption is for a sUAS that is a helicopter and the 

exemption requests authority to 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 for the limited conditions stated in the 

Manual, the UAS will never operate at higher than 400 AGL. It will however be operated 

in a restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre-obtained consent. The equivalent level of safety will be 

achieved given the size, weight and speed of the sUAS as well as the 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 
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12 | Mainlight Productions, LLC Petition for Exemption under Section 333

activity, all affected individuals will be aware of the planned flight operations as set forth 

in the FOPM. 

14 C.F.R. § 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 sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption is needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the FOPM, 

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

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

This regulation 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 sUAS provides approximately 18 minutes of 

powered flight. To meet the 30-minute reserve requirement in 14 CFR § 91.151, sUASs 

flights would be limited to approximately 10 minutes in length. Given the limitations on 

the sUAS 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. Limiting sUAS flights to 10 minutes would greatly reduce the utility for which 

the exemption will be granted. An equivalent level of safety can be achieved by limiting 

flights to 20 minutes or 25% of battery power whichever is reached first. This restriction 

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

anywhere in its limited operating area. 

14 C.F.R. § 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 (a) 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 sUAS, 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 equivalent level of safety

will be achieved by keeping these documents at the ground control point where the PIC 

flying the sUAS will have immediate access to them, to the extent they are applicable to the 

sUAS. 

14 C.F.R. § 91.405 (a); 407 (a) (1); 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 
December 15, 2015

13 | Mainlight Productions, LLC Petition for Exemption under Section 333

prescribed in part 43 of this chapter...” and others shall inspect or maintain the aircraft in 

compliance with Part 43. Given that these section and Part 43 apply only to aircraft with 

an airworthiness certificate, these sections will not apply to the applicant. The operator 

pursuant to the FOPM will accomplish maintenance. An equivalent level of safety will be 

achieved because this sUAS is 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 

sUAS can land immediately and will be operating from no higher than 400 feet AGL. As 

provided in the FOPM, the operator will ensure that the sUAS 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. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Mainlight Productions, LLC submits that grant of this exemption application advances the 

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of 

sUASs into the NAS if it can be accomplished safely. This law directs the Secretary of 

Transportation to consider whether certain UASs may operate safely in the 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 sUASs do not create a 

hazard to users of the NAS, the public, or pose a threat to national security in light of the 

following: 

• The UAS’s size, 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 PIC. 

Reform Act § 333 (a) (1). 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 national airspace system.” Id. § 333 (c). 

The Federal Aviation 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, from the requirement that all civil aircraft must have a current 

Airworthiness certificate and those regulations requiring commercial pilots to operate aircraft 

in commercial service: 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections 4470244716 of this title if the 

Administrator finds the exemption is in the public interest. 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as 
December 15, 2015

14 | Mainlight Productions, LLC Petition for Exemption under Section 333

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

significant public benefit, including enhanced safety and cost savings associated with use of 

UASs for aerial videography/photography, the reduction or elimination of unregulated 

operators, and the safe integration of UASs. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay. 

CONCLUSION 

As set forth herein, Mainlight Productions, LLC seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 from the 

requirements of 14 CFR § 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 

91.119 (c); 91.121; 91.151 (a); 91.203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & 

(b), which will permit safe operation of the sUAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial imagery over small, defined operational 

areas of the United States. 

Approval of the exemption allowing commercial operations of Mainlight Productions, LLC

sUAS will increase safety by permitting an operator to conduct a service safely by adhering to 

the prescribed guidelines. The exemption will also encourage the education of sUAS operators 

and the adoption of FAA guidelines and approval for commercial sUAS operations as pertains 

to Mainlight Productions, LLC employees and contractors. It will allow Mainlight Productions, 

LLC to provide a service that benefits the public and local businesses. It benefits the public 

through a higher level of safety of sUAS operations and through a smooth integration of 

sUASs into the NAS. Having a pilot-owned business bridges the gap between the advancement 

of sUAS technology and the current practices and operations in the NAS and with the FAA. 

This assists the FAA with its mission of promoting aviation while preserving safety of aviators, 

the public and property. The sUAS operated by Mainlight Productions, LLC satisfies the 

criteria set forth in § 333 of the Reform Act – size, weight, speed, operating capabilities, 

operation within visual line of sight, and national security – and showing an equivalent level of 

safety to manned aircraft flights through appropriate pilot certification and safety-focused 

standards of operation. This provides more than adequate justification for the grant of the 

requested exemptions allowing commercial operations. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate 

of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public by allowing Mainlight Productions, LLC to safely, efficiently and economically operate 

the sUAS commercially within the NAS. 

Respectfully, 

Bryan Guzman

Mainlight Productions, LLC 
December 15, 2015

15 | Mainlight Productions, LLC Petition for Exemption under Section 333

Attachments:

Mainlight Productions, LLC - certificate of formation.

Mainlight Productions, LLC – Employee Identification Forms