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 Sy stems (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 an d other ap plicable areas for pre

- planned, controlled areas, training, special events: including high schools, colleges, professional sports, open air events and fairs , research, risk management assessment s hereb y applies for an exemption from the listed Fe deral 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 b y § 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 compl y with all federal aviation regulations pertai ning to sUAS.

As described more full y 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 safet y personnel controlling access, and 4) would provide increased safet y and enhancements to clients' business operations.

I am prepared to modify

or amend an y part of this request to satisfy the need for an equivalent level of safet y. Ilook forward to working with your office. Please contact me at an y time if you require additional information or clarification. The name and address of the applicant is:
**Mainlight Productions, LLC Bryan Guzman**  **Co**

**- O**  **wner Phone: 201** 

**- 313** 

**- 6388**  **Email: bryan@mainlightproduction**  **s.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 t o operate its sUAS commercially for the purpose of aerial filming and photographing to include: commercial and residential real estate, weddings, filmmaking, cinematograph y and videograph y infrastructure inspections, construction, architecture, scientific research, environmental assessment, land surveying and mapping and other applicable areas for pre

planned, controlled areas, tra ining, special events: including high schools, colleges, professional sports, open air events and f airs, research, risk management and assessment s

. Mainlight Productions, LLC will provide a service that is beneficial to industries and organizations that ar e 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 b ecause the propose d operation of the DJ I 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, whil e 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 (m ys elf) Bryan Guzman and Mr. Christopher Gorga. Mr. Gorga is currentl y 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 c urrentl y also the owner of CG designs for the past 3 y ears doing work as a web designer. I am currentl y up
- to

date with my

medical certification with the American Red Cross, and also in active pursuit of aDecember 15, 2015

**3** | **Mainlight Productions, LLC Petition for Exemption under Section 333**  Private Pilot Certificate. I am a Veteran of the Unite d States Nav y and currently emplo yed with The New Jersey

State Parole Board. Mainlight Productions, LLC will conduct its business using the DJ I 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 poly mer batteries and powered b y electric motors.

**PUBLIC INTEREST AND HOW THE PUBLI C WILL BENEFIT**  This exemption request will permit Mainlight Productions, LLC to operate its sUAS commerciall y 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 fo r 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 b y allowing Mainlight Productions, L LC to perform safel y, efficientl y, and economically, aerial video and photograph y of construction sites, real estate, and landscape over certain areas of the United States. Itwill also allow better views for weddings, graduations, open air events, and an y other entertainment based use that would require the use of an sUAS. Additionally , use of the DJIPhantom 3 sUAS will decrease congestion of the NAS, reduce pollution, and provide signif icant 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 way s that were simpl y impossible to do previously. The commercial deplo ym ent of smal l unmanned aircraft s ys tems offers the public a new, highl y efficient and relativel y inexpensive platform for collecting, anal yz ing and utilizing data and photographic/video imagery

. In deploying its sUAS, Mainlight Productions, LLC has developed spec ific 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 Pr oductions, LL C recognizes the importantDecember 15, 2015

**4** | **Mainlight Productions, LLC Petition for Exemption under Section 333**  role it play s in educating the public and building awareness of both the promise and precautions that accompany the commercial deploy

ment of this new and exciting platform. The sUAS utilized by Mainlight Productio ns, 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 mann ed 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 DJIPhantom 3 sUAS, instead of manned aircraft, will greatl y benefit the public by drasticall y 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 DJIPhantom 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 t ypically utilized for aerial video and photograph y, while burning approximately

20

- 30 gallons per hour of leaded aviation fuel. The DJ I 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 comb ustion engine.
By using the DJ I Phantom 3 sUAS to perform aerial acquisitions, the substantial risk to life and propert y 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 DJ I Phantom 3 sUAS (weighing approximately 2.82 with battery and propellers attached and a its dimensions of 23.2” diagonal with propellers ), has less phy sical potential for collateral damage to life and propert y on th e 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 , suc h services as high

- resolution digital aerial real estate photograph y, 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 exempt ion will enable Mainlight Productions, LLC to change this by deploying its sUAS in way s that make aerial photograph y 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 mana ge 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 (PI C), 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 safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y the characteristics of the DJ I Phantom 3 sUAS, the pilot certification requirements, and the specific operating limitations. The specifications of the DJ I Phantom 3 sUAS demonstrate its safe characteristics. The DJIPhantom 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 DJ I Phantom 3 sUAS enable it t o be operated in a highly controlled, precise and safe manner.

The DJ I Phantom 3 sUAS autonomous flight and navigation modes enable it to remain within a defined operational area. Also, the DJ I 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 DJ I Phantom 3 sUAS is provided on pages 12

- 16 and 45

- 50 of the DJ I Phantom 3 User Manual.

The DJ I 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 DJ I Phantom 3 sUAS does not reacquire control link d ata 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 survey s or acquiring aerial imagery and video, Mainlight Productions LLc sUAS will be providing its customers with more accurate and timely information. The real

- ti me 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 operati ons protocols (see Attachment G and H), the use of the DJIPhantom 3 sUAS configured with significant safet y functionalit y, 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 Safet y Briefing (see Attachment M) will provide a level of safety and oversight that is in complete alignment with the FAA’s mission to “provide th e safest, most efficient aerospace sy stem 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 authorit y’s prior consent and knowledge. Aerial photograph y and video captureDecember 15, 2015

**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 DJ I Phantom 3 sUAS will not implicate any

privacy issues. Specificall y, 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 plann ing 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 PI C), VO(s), SO, and any other designated support and security personnel with a full understanding of the site or subject’s structural characteristics, layout, topograph y, 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 an y work or service.

**CONDITIONS AND LIMITATIONS**

As set forth in Mainlight Productions, LLC Flight Operatio ns 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 Op erating Procedures, Pilot Flight Log, sUAS Flight Lo g, Monthl y Maintenance Lo g, Client Site Safety and Planning Template, Pre

- Flight Operations On

- Site Client Safety Briefing, Battery

Power Management Matrix, and Permission to Conduct Onsite Flight Operat ions 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 L ine 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;December 15, 2015

**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 PI C will conduct a full inspection of the sUAS (including remote controllers) to ensure it is in full working orde r and safe for flight prior to every takeoff; 8. A functional test flight must be performed following the maintenance, alteration or repair of an y sUAS. Test flights will be performed b y the PI C prior to the sUAS’s return to service. All such test flights will be noted and logged in the Monthl y Maintenance Log the PI C’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 requirem ents. 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 an y other component(s) as determined by the operator. 10. The PI C must possess at minimum a light sport pilot certificate and a valid U.S. driver’s license. Additionally , the PI C must meet the flight review requirements s pecified in 14 CFR § 61.56; 11. A PI C 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 ty pe ; 12. A PI C 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 landing s in the preceding 90 day s. The PIC must operate the sUAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119; 13. The PI C 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 directl y over an y person, except authorized and consenting inspection and/or operations personnel, below an altitude that is hazardous to persons or propert y; 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 are a except those consenting to be involved and who are necessary for the on

- going operation of the entity being inspected or photographed;December 15, 2015

**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 PI C 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 an y 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 (NNum ber) 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 part s and the total time in service of the sUAS; 24. Each sUAS operated under this exemption will comply with all manufacturing safet y 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 radi o 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 day s before a scheduled flight operation the operator of the sUAS affected by this exe mption 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 PI C(s) involved in the flight operation f. A statement that the operator has obtained permission from propert y 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 representativeDecember 15, 2015

**9** | **Mainlight Productions, LLC Petition for Exemption under Section 333** 

h. The description of the flight activity , including maps or diagrams of an y area, cit y, town, county , and/or state over which the fl ight 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 PI C at the ground control station of the sUAS any time the aircraft is operating. Th ese documents must be made available to the Administrator or any law enforcement official upon request. 29. The sUAS must remain clear and yi eld 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 und er special visual flight rules (SVFR) are not authorized; 32. The sUAS cannot be operated b y 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 visibil ity is less than 3 statute miles from the PI C; 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 denote d 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 m anagement 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 b y the applicable COA must be reported to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS

- 8 0) 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 re viewed by the AFS

- 80 and authorization to resume operations is provided; 36. The sUAS, PI C 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, STAN DARDS, 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 an y new FAA requirement, change of standard and an y improvement or addition to its flight operations Mainlight Productions, LL C considers to be in its clients’ and the public’s best interest.December 15, 2015

**10** | **Mainlight Productions, LLC Petition for Exemption under Section 333**  **REGULATIONS FROM WHICH THE EXEMPTION IS REQUE STED:** 

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 approva ls. 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 L ist of L imitations 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), 6 1.133 (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 safet y of current operations by requiring the PI C 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 safet y provided by the requirements included in the FOPM exceeds that provided b y 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 PI C exceeds the present level of safet y achieved b y 14 C.F.R. §61.113 (a) & (b).December 15, 2015

**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 airworth y 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 safet y checklists prior to each flight, an equivalent level of safet y will be provide d.
**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 b y §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 an y combination thereof. The sUAS, given its size and configuration has no ability or pla ce 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 remotel y piloted aircraft, b y 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 an y route or altitudes prescrib ed for helicopters b y 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 securit y perimeter, where buildings an d people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safet y 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 pe rmission of the propert y owner or local officials. Because of the advance notice to the property owner and participants in theDecember 15, 2015

**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. § 91.12 1 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 de parture.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption is needed. An equivalent level of safet y will be achieved b y the operator, pursuant to the FOPM, confirming the altitude of the launch site shown o n 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 for ecast 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 fl y 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 propose d 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. L imiting sUAS flights to 10 minutes would greatl y reduce the utility for which the exemption will be granted. An equivalent level of safet y 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 any where 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 i t 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 b y paragraph (a) of this section or a special flight authorization issue d under §91.715 is display ed 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

certific ation and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved b y 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 asDecember 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 appl y 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 onl y 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 airworth y condition to provide the equivalent level of safet y.
**THE APPLICABLE LEGAL STANDARD UNDER SECTION 333** Mainlight Productions, LLC submits that grant of this exemption application advances the Congressional mandat e 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 safel y 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 t ypes 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 PI C. Reform Act § 333 (a) (1). If the Secretary determines that such vehicles “may operate safely

in the national airspace s ys tem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace s ys tem.” Id. § 333 (c)

. The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authorit y, b y its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, from the requirement that all civil airc raft 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 Ref

orm Act; the additional authority in the Federal Aviation Act, asDecember 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 /photograph y, the reduction or elimination of unregulated operators, and the safe integration of UASs. Accordingl y, 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 commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial imagery ov er 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 prescri bed 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 Pr oductions, LLC to provide a service that benefits the public and local businesses. It benefits the public through a higher level of safet y 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 safet y 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 safet y to manned aircraft flights through appropri ate pilot certification and safet y - 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 fulfi lling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public by allowing Mainlight Productions, LL C to safel y, efficientl y and economically operate the sUAS commerciall y within the NAS. Respectfully ,

Bryan Guzman Mainlight Productions, LLCDecember 15, 2015

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

- certificate of formation. Mainlight Productions, LLC

– Employee I dentification Forms