December 15, 2015

Dear Sir or Madam,

Pursuantto§ 333 ofthe FAAModernization and

### ~form Act of2012 

### (tlld**Rahrin.~A¢i)** atidUL: 14 C.F.R. Part 11, MainlightProductions, LLC, operator ofSmall Unmanned Aircraft Systems (sUAS) equippedto conduct aerial filming andphotograp.i.ing to include: commercial and residential real estate, weddings, filmmaking, cinematography and 'ideography infrastructure inspections, construction, architecture, scientific research, environ'hental assessment, land surveying and mapping and other applicable areas for pre-planned, controlled areas, training, special events: including high schools, colleges, professional spcrts, open air events and fairs, research, risk management assessments hereby applies for anexemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation ofits sUAS, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe Federal Aviation Administration (FAA) as reC;uired by § 3 33. Mainlight Productions, LLC operation ofits sUAS for commercial purposes awaits a review and the anticipated granting ofthis petitionby the FAA before conducting any operationfor its clients to fully comply with all federal aviation regulations pertaining to sUAS. ·
As described more fully below,the requested exemption wouldpermitthe operation ofsmall, unmanned and multi-rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on-site safetypersonnel controlling access, and 4) would provide increased safety and enhancements to clients' business operations.

I amprepared to modify or amend any part ofthis request to satisfythe need for an equivalent level ofsafety. I look forwarc to working with your office. Please contact me at any time ifyou require additional information or (Jarification.
The name and address ofthe 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 ',

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The following summary is providedfor publication in the Federal Register, should it be determinedthatpublicationis needed. Mainlight Productions, LLC seeks a!). exemptionpursuantto 14 C.F.R. § 11.61 and Section 3 3 3 ofthe FAAModernization and Reformf\ct of2012 from the requirements of 14 CFR § 21;

1 I MainlightProductions, LLC Petition for Exemption under Section 333December 15, 2015

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 ofaerial filming and photographingto 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 alreadyusing, and/or seekingto use, sUAS's for these purposes with a legal and safe option. This will benefitthe public withthe controlled operation ofsUASs and increase their integration into the NAS.
The requested exemption should be grantedbecause the proposed operation ofthe DJI Phantom 3, a small UAS (sUAS) weighing 2.82 Lbs., inclusive ofbattery and payload, conducted inthe strict conditions outlined below, will provide an equivalent orbetter level ofsafety, as Congress intended, while still allowing commercial operations. The lightweight aircraft covered by the exemption is far saferthan conventional operations conducted with helicopters and fixed-wing aircraft operating in close proximityto the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions- size, weight, speed, operational capability, proximityto airports, proximity to populated areas, and operationwithin visual line ofsight

- each supportthe request. In particular, the aircraft is small, and will operate at slow speeds, close to the ground, far from airports and in a lowrisk, low and controlled population environment.

Narne and address ofpetitioner: MainlightProductions,LLC Bryan Guzman 128 E Madison Ave Dumont,NJ 07628 Mainlight Productions, LLC Main Business Address: 315 Closter DockRd. Closter, NJ 07624


### BACKGROUND OFPETITIONER Mainlight Productions, LLC is a**lirnit~d** liability company owned and operated by (myself) Bryan Guzman and Mr. Christopher Gorga. Mr. Gorga is currently in active pursuit ofour Private Pilot Certificate and the requir¢d medical certificate. He graduated from Rutgers University with a Bachelors in environ\mental and biological sciences. He is currently also the
owner ofCG designs for the past 3 ye<l\rs doing work as a web designer. I am currently up-todate with my medical certificationwit11 the American Red Cross, and also in active pursuit ofa

2 I MainlightProductions,LLC Petition for Exemption under Section 333December 15, 2015

Private Pilot Certificate. I am a Veteran ofthe United StatesNavy and currently employed with TheNewJersey State Parole Board. MainlightProductions, LLC will conduct its business using the DJI Phantom 3 sUAS. The Phantom 3 is a vertical takeoffand landing sUAS with a maximum gross weight oflessthan 55 pounds and a maximum speed oflessthan 50 mph. The Phantom 3 is driven by lithium polymer batteries andpowered by electric motors.

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT
This exemptionrequest will permit Mainlight Productions, LLC to operate its sUAS commercially for the purpose ofaerial filming andphotographing 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 organizationsthat are already using, and seeking to use, sUASs for these purposes with a legal and safe option. This will benefitthe public with the controlled operation ofsUASs and increase integration into the NAS. Granting the presentpetition 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 oftheUnited States. Itwill also allowbetterviews for weddings, graduations, open air events, and any other entertainment baseduse that would require the use ofan sUAS. Additionally, use ofthe DJI Phantom 3 sUAS will decrease congestion ofthe NAS, reduce pollution, and provide significantbenefits to the economy.

The integration ofsUASs into the NAS will not only replace traditionally more expensive options or approaches, itwill enable workto be done and decisions to be made in ways that
were simply impossible to do previously. The commercial deployment ofsmall unmanned aircraft systems offers the public a new, highly efficient and relatively inexpensive platform for collecting, analyzing and utilizing**dat~** 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 withthe FAA's continuing mission, and result in safe operating practices that are consistently applied and continuously improved. For its pal11:, Mainlight Productions, LLC recognizes the important

3 

### I MainlightProductions, LLC Petition for Exemption under Section 333December 15, 2015

role itplays in educating the public and building awareness ofboththe promise and precautions that accompanythe commercial deployment ofthis new and excitingplatform.
The sUAS utilized byMainlightProductions, 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 ofexemption would allow Mainlight Productions, LLC to contribute to the reduction ofmanned aircraft neededto performthe aerial acquisition ofdata, video and photographic content and subsequently reduce the volume ofmanned aircraft in the NAS. Conducting aerial acquisitions with the DJI Phantom 3 sUAS, instead ofmanned aircraft, will greatly benefit the public bydrasticallyreducing the levels ofair 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 mostviable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typicallyutilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Phantom 3 sUAS, while reducing the carbon footprint ofaerial acquisitions, also sharply reduces noise pollution, as the sUAS is propelledbybattery powered electric motors, rather than an internal combustion engme. By using the DJI Phantom 3 sUAS to perform aerial acquisitions, the substantial risk to life and property in the air and onthe ground, which is usually associated withtraditional manned aircraft flight operations, will be substantially reduced or completely eliminated. The DJI Phantom 3 sUAS (weighing approximately 2.82 withbattery and propellers attached and a its dimensions of23.2" diagonal withpropellers), has less physical potential for collateral damage to life and property onthe ground, and in the air, compared to the manned aircraftthat typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of34 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 ofagencies, companies and organizations with significant operating capital. The granting ofthis exemption will enable MainlightProductions, LLC to change this by deploying its sUAS in ways that make aerial photography and other sUAS services accessible and affordable to a significantly largerportion ofindividuals, organizations and businesses. The many newforms ofaerial content would have immediate and directbenefits 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 ofthe pilot in charge (PIC), visual observer (VO), sensor operator (SO) and the client representative working withthe Mainlight Productions team.

4 MainlightProductions, LLC Petition for Exemption under Section 333December 15, 2015

In seekingthis 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 ofthe DJI Phantom 3 sUAS, the pilot certification requirements, and the specific operating limitations. The specifications ofthe DJI Phantom 3 sUAS demonstrate its safe characteristics. The DJI Phantom 3 sUAS does not create a hazardto users oftheNAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. Many ofthe functional capabilities and features ofthe DJI Phantom 3 sUAS enable itto be operated in ahighly controlled, precise and safe manner.
The DJI Phantom 3 sUAS autonomous flight and navigation modes enable itto remain within a defined operational area. Also, the DJI Phantom 3 sUAS maybe operated inbothmanual and fully autonomous flight modes. A complete description ofthe flight and navigational modes of the DJI Phantom 3 sUAS is provided onpages 12-16 and 45-50 oftheDJI Phantom 3 User Manual.
The DJI Phantom 3 sUAS includes automatic return-to-home-point or hover functionality in the event ofloss ofthe control link or navigation. When the control ink is lost, the DJI Phantom 3 sUAS will remain stationary, in flight, for 3 seconds ormore. If, after 3 seconds, the DJI Phantom 3 sUAS does notreacquire 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 takeoffposition and shutdown.
Whether helping to protectthe public, inspecting infrastructure, conducting site and land surveys or acquiring aerial imagery and video, Mainlight Productions LLc sUAS will be providing its customers withmore accurate and timely information. Thereal-time situational
awareness and improved decision-making this achieves will enable Mainlight Productions customers and clients to communicate with and more safely serve and supporttheirrespective constituents.
Strict adherence to specific flight operations protocols (see Attachment G and H), the use ofthe DJI Phantom 3 sUAS configured with significant safety functionality, the acquisition ofan accurate understanding ofboth the flight operations area and its adjacencies using Mainlight Productions' Site Safety and Planning Template (see Attachment L), and the use ofMainlight Productions' On-Site Client Safety Briefing (see Attachment M) will provide a level ofsafety and oversightthat is in complete alignment with the FAA's mission to "providethe 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 overprivate or controlled-access property withthe property owner's or controlling authority's prior consent and knowledge. Aerial photography and video capture

5 

### I MainlightProductions,LLC Petition for Exemption under Section 333December 15, 2015

will be ofpeople who have provided their written consentto 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 areawill minimize privacy issues.
Similarto the manned aerial acquisition flight operations that have been conducted for decades, Mainlight Productions, LLC'sproposed operation ofthe DJI Phantom 3 sUAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 sUAS will be operatedunder detailed operationalprotocols designed to ensure client orproperty owner involvement as well
as local lawenforcementnotification. Flight operations will be conducted in accordance with Federal Aviation Regulations, includingthe minimum altitude requirements of 14 C.P.R.§ 91.119. MainlightProductions, LLC has developed a proprietary work-site planningtemplate (see Attachment L) that will be completed andreviewed with the client's onsite representative prior to the commencement ofany operation orproject. This detailed diagram ofthe operational environmentwill provide the PIC), VO(s), SO, and any other designated support and security personnel with a full understanding ofthe 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 ofany area or condition immediately adjacent to or near the operational
area. The will enable Mainlight Productions, LLC to acquire a detailed understanding ofthe larger geographical context surrounding the flight operations area and review relevant factors with the client beforethe commencement ofany work or service.
CONDITIONS AND LIMITATIONS
As set forth inMainlight 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, PilotFlight Log, sUAS Flight Log, Monthly Maintenance Log, Client Site Safety and Planning Template, Pre-Flight Operations On-Site Client Safety Briefing, BatteryPower Management Matrix, and Permissionto Conduct Onsite Flight Operations ConsentForm), the applicant proposes the following limitations and conditions:
1. UAS mustweigh 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 mustbe in feet AGL; 4. UAS must be operated within Visual Line ofSight (VLOS) ofthe PIC and VO; 5. All operations will utilize aVO. The VO maybe utilized as long as the PIC maintains VLOS capability and can communicate with the VO at all times;

6 I Mainlight Productions, LLC Petition for Exemption under Section 333

### December 15,2015

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 ofthe sUAS (includingremote controllers) to ensure it is in full working order and safe for flight priorto every takeoff; 8. A functional test flight mustbe performed following the maintenance, alteration orrepair ofany sUAS. Test flights will be performed bythe PIC prior to the sUAS'sreturnto service. All suchtest flights will be noted and logged inthe Monthly Maintenance Log the PIC'spersonal Pilot Flight Log and the sUAS Flight Log. 9. The operatormust follow the manufacturer's sUAS aircraft/component, maintenance, overhaul, replacement inspection and life limit requirements. The following mustbe included inthe operator's manual;
a. Actuators/Servos; b. Powerplant (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 mustpossess at minimum a light sportpilot certificate and avalid U.S. driver's license. Additionally, the PIC must meet the flight reviewrequirements specified in 14 CFR § 61.56; 11. A PIC musthave accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), aminimum of200 flight hours and 25 hours as aUAS rotorcraft pilot and at least ten hours logged as aUAS 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 offive hours as a sUAS pilot operating the make and model ofsUAS 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 withthe 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 participatingpersons must be essential and consentto 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 ofthe area except those consenting to be involved and who are necessary for the on-going operation ofthe entity being inspected or photographed;

7 I MainlightProductions,LLC Petition for Exemption under Section 333December 15,2015

18. Ifthe sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location withinthe securityperimeter ofthe flight operations area and land
orbe recovered in accordance with the operator's manual; 19. The PIC must abort the sUAS flight in the event ofunpredicted obstacles or emergencies in accordance withthe operator's manual; 20. Each operation mustbe completedwithin 20 minutes flight time or withno less than 25% batterypowerremaining, whichever occurs first; 21. The operatormust contain an Air Traffic Organization (ATO) issued Certificate ofWaiver
or Authorization (COA) priorto conducting any operations underthis grant ofexemption. This COA will also require the operatorto request aNotice to Airman (NOTAM) not more than 72 hours in advance, but no less than48 hours priortothe operation; 22. All aircraft operated in accordance withthis exemption mustbe identified by serial number, registered in accordance with 14 CFRpart 47 and have identification (NNumber) markings in accordance with 14 CFRpart 45, Subpart C. Markings must be as large as possible; 23. The operator must develop procedures to document and maintain arecord ofthe sUAS maintenance, alterations, status ofreplacement/overhaul componentparts and the total time in service ofthe sUAS; 24. Each sUAS operated under this exemption will comply with all manufacturing safety bulletins; 25. The operator will develop sUAS technician qualification criteria. Andthe criteria will be in the operator's manual; 26. The pre-flight inspections section ofthe operator's manual will include the requirement that the pre-flight inspectionwill account for all discrepancies, e.g., inoperable components, items, or equipment; 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe sUAS will comply withthe FCC or other appropriate government oversight agency requirements; 28. Atleastthree days before a scheduled flight operationthe operator ofthe sUAS affected by this exemption will submit a writtenplanofactivityto the local FSDO withjurisdiction
overthe area ofthe proposed inspection. The 3-day notification may be waived with the
concurrence ofthe FSDO. The plan ofactivities will include the following:
a. Dates and times for all flights b. Name and phone number ofthe operator for the sUAS flight operation conducted under this grant ofexemption
c. Name and phone number ofthe person responsible for the on-site operation of the sUAS d. Make, model, and serial and N-number ofsUAS to be used
e. Name and certificate number ofsUAS PIC(s) involved in the flight operation f. A statementthatthe operator has obtainedpermission from property owners and/or local officials to conductthe flight operation; the list ofthose who gave permission shall be made available to the inspector upon request g. Signature ofexemption-holder or representative

8 I MainlightProductions, LLC Petition for Exemption under Section 333December 15, 2015

h. The description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/or state over which the flight operation will be conducted and the altitudes essential to accomplish the operation
1. The documents required under 14 CPR §§91.9 and 91.203 must be available to the PIC at the ground control station ofthe sUAS any time the aircraft is operating. These documents mustbe made available to the Administrator or any law enforcement official uponrequest. 29. The sUAS mustremain clear and yield the right ofway to all othermanned operations and activities at all times (including, but not limitedto ultra-light vehicles, parachute activities, parasailing activities, hand gliding, etc.); 30. sUAS operations may not be conducted during night, as defined in 14 CPR§ 1.1 31. All operations mustbe conductedunder visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized; 32. The sUAS cannotbe operated bythe PIC from any moving device or vehicle; 33. The sUAS maynotbe 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 notbe operated in class B, C, orD airspace without written approval from the FAA. The sUAS may not operate within 5 nautical miles ofthe geographic center ofa non-towered airport as denoted on a current FAA- published aeronautical chart unless a letter ofagreement with the airport's management is obtained, and the operation is conducted in accordance with aNOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the administratorupon request; 35. Any 1) Incident, 2) Accident, or 3) Flight operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA mustbe 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 onthe NTSB website: www.ntsb.gov. Further flight operations may not be conducteduntil the incident, accident ortransgression is reviewed bythe AFS-80 and authorizationto resume operations is provided; 36. The sUAS, PIC and operatorwill comply with all applicable parts of 14 CPR including, butnot limitedto, parts 45, 47, 61, and 91.
LIST OFPROPRIETARY FLIGHT OPERATIONS, STANDARDS, PROTOCOLS AND PROCEDURES DOCUMENTATION
As noted earlier, Mainlightproductions FOPM includes all manufacturer's documentation for the DJI Phantom 3 sUAS, as well as a number offlight operations protocols, requirements and procedures Mainlight Productions, LLC considers proprietary. Together, these documents governingthe planning, management and execution ofall Mainlight Productions, LLC flight operations. The FOPM is reviewed and updated on aregular basis to ensure it is accurate, current and reflects any new FAArequirement, change ofstandard and any improvement or addition to its flight operations Mainlight Productions, LLC considers to be in its clients' and the public's best interest.

9 I MainlightProductions, LLC Petition for Exemption under Section 333December 15,2015



### REGULATIONS FROMWHICHTHE EXEMPTIONIS REQUESTED:

14 CFRPart 21 14 CFR 61.113 (a) & (b) 14 CFR 61.133 (a) 14 CFR91.7 (a) 14 CFR91.9 (b) (2) 14 CFR91.109 (a) 14 CFR91.119 14 CFR91.121 14 CFR91.151 (a) 14 CFR91.203 (a) & (b) 14 CFR91.405 (a) 14 CFR407 (a) (1) 14 CFR409 (a) (2) 14 CFR417 (a) & (b)


### 14 C.F.R. 21: Certification Procedures for Products and Parts This section outlines requirements for the issue ofdesign andproduction approvals, airworthiness certificates, and other airworthiness approvals. Mainlight Productions, LLC is awarethatifan exemption is granted as per Section 333, an airworthiness certificate wouldbe issued and a request for exemption from Part 21 is unnecessary. However, as outlinedinthe List ofLimitations and Conditions inthis application, as well as all ofthe Attachments to this application, comprising the FOPM, Mainlight Productions, LLC seeks to upholdthe same level or exceeded level ofsafety 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: Pilotin Command. CommercialPilot Privileges and Limitations. Sections 61.113 (a) & (b) limitprivate pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraft to have aprivate pilot's license rather than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot andpassengers, the sUAS is remotely controlled withno living thing onboard. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth inthe FOPM. The level ofsafety providedby the requirements included inthe FOPM exceeds that providedby a single individual holding a commercialpilot's certificate operating a conventional aircraft. Therisks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplatedby Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceeds the present level ofsafety achievedby 14 C.F.R. §61.113 (a) & (b).

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### I Mainlight Productions,LLC Petition for Exemption under Section 333December 15, 2015

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness. The regulationrequires that no personmay operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, shouldthis exemptionbe granted, no FAAregulatory standard will exist for determining airworthiness. Giventhe size ofthe aircraft and the requirements contained in the FOPM for maintenance and use ofsafety checklists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil AircraftFlight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) Forwhich an Airplane orRotorcraft Flight Manual is notrequired by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane orRotorcraft 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 onboard, but because there is no room orcapacity to carry such an item onthe aircraft.

14 C.F.R. § 91.109 (a): Flight Instruction Section 91.109 provides that no personmay 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 remotelypiloted aircraft, bytheir design do nothave fully functional dual controls. Flight control is accomplishedthrough the use ofa control box that communicates with the aircraft viaradio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less thanthe minimums prescribed, providedthe person operatingthe helicopter complies with any route or altitudes prescribed for helicopters bythe 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, ornot more than 200 above an elevated platform from which filming is planned, an exemptionmay be needed to allow such operations. As set forth herein, except for the limited conditions stated inthe Manual, the UAS will never operate at higher than 400 AGL. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheirpre-obtained consent. The equivalent level ofsafety will be achieved giventhe size, weight and speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner orlocal officials. Because ofthe advance notice to the property owner and participants in the

11 I Mainlight Productions, LLC Petition for Exemption under Section 333December 15, 2015

activity, all affected individuals will be aware ofthe planned flight operations as set forth in the FOPM.



### 14 C.F.R. 

### § 91.121 Altimeter Settings This regulation requires eachperson operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, butinstead a GPS altitude read out, an exemption is needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the FOPM, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight.



### 14 C.F.R. 

### § 91.151 (a): FuelRequirements for Flightin VFR Conditions This regulationprohibits an individual from beginning "aflight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed

- (1) Duringthe day, to fly after that for at least 30 minutes; or (2) Atnight, to fly after that for at least45 minutes." The battery poweringthe sUAS provides approximately 18 minutes of powered flight. To meetthe 30-minute reserve requirement in 14 CFR § 91.151, sUASs flights would be limitedto approximately 10 minutes in length. Given the limitations on the sUAS proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight ornight VFR conditions is reasonable. Limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemptionwill be granted. An equivalent level ofsafety canbe achieved by limiting flights to 20 minutes or 25% ofbattery power whichever is reached first. This restriction wouldbe 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 regulationprovides inpertinentpart: (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 personmay operate a civil aircraft unless the airworthiness certificaterequired byparagraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin orcockpit 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 onboardpilot. As such, there is no ability or place to carry certification and registration documents orto display them onthe sUAS. Anequivalent level ofsafety will be achievedbykeeping these documents at the ground control point where the PIC flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS.



### 14 C.F.R. 

### § 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & 

### (b): MaintenanceInspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as

12 

### I MainlightProductions,LLC Petition for Exemption under Section 333December 15, 2015

prescribed inpart 43 ofthis chapter

..." and others shall inspect ormaintainthe aircraft in compliance withPart 43. Giventhatthese section and Part 43 apply onlyto aircraft with
an airworthiness certificate, these sections will not apply to the applicant. The operator pursuantto the FOPM will accomplishmaintenance. An equivalent level ofsafety will be achievedbecausethis sUAS is very limited in size and will carry a small payload and operate onlyinrestricted areas for limitedperiods oftime. Ifmechanical issues arise the sUAS can land immediately and will be operating from no higherthan 400 feet AGL. As provided inthe FOPM, the operatorwill ensure thatthe sUAS is in working orderpriorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar withthe aircraft andbest suited to maintainthe aircraft in an airworthy conditionto provide the equivalent level of safety.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 MainlightProductions, LLC submits that grant ofthis exemption application advances the Congressional mandate in Section 333 ofthe Reform Actto accelerate the introduction of sUASs into the NAS ifit canbe accomplished safely. This law directs the Secretary of Transportation to considerwhether certainUASs may operate safely inthe NAS before completion ofthe rulemakingrequired under Section 332 ofthe Reform Act. Inmakingthis determination, the Secretary is requiredto determine whichtypes ofsUASs do not create a hazardto users ofthe NAS, thepublic, orpose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability;
• Operation ofthe UAS inclose proximityto airports and populated areas; and
• Operation ofthe UAS withinvisual line ofsight ofthe PIC.

ReformAct§ 333 (a) (1). Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establishrequirements for the safe operation of such aircraft inthe national airspace system." Id. § 333 (c).

The Federal AviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 ofthe Act, from the requirementthat all civil aircraft musthave a current Airworthiness certificate and those regulations requiring commercialpilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement ofa regulationprescribed under subsection (a) or (b) ofthis section or any ofsections 4470244716 ofthis title ifthe Administrator finds the exemptionis inthe public interest.

The grant ofthe requested exemption is inthe public interest based onthe clear direction in Section 333 ofthe Reform Act; the additional authority inthe Federal Aviation Act, as

13 I MainlightProductions, LLC Petition for Exemption under Section 333December 15, 2015

amended; the strong equivalent level ofsafety surrounding the proposed operations; andthe significantpublic benefit, including enhanced safety and cost savings associated withuse of UASs for aerial videography/photography, the reduction or elimination ofunregulated operators, and the safe integration ofUASs. Accordingly, the applicantrespectfully requests thatthe FAA grantthe requested exemptionwithout delay.
CONCLUSION

As set forth herein, MainlightProductions, LLC seeks an exemptionpursuantto 14 C.F.R. § 11.61 and Section 333 oftheFAAModernization and Reform Act of2012 from the requirements of14 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), whichwill permit safe operation ofthe sUAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial imagery over small, defined operational
areas ofthe United States. Approval ofthe exemption allowing commercial operations ofMainlightProductions, LLC sUAS will increase safety by permitting an operatorto conduct a service safely by adhering to the prescribed guidelines. The exemption will also encourage the education ofsUAS operators and the adoption ofFAA guidelines and approval for commercial sUAS operations as pertains to Mainlight Productions, LLC employees and contractors. Itwill allow Mainlight Productions, LLCto provide a service thatbenefits the public andlocal businesses. Itbenefits the public through a higher level ofsafety ofsUAS operations and through a smooth integration of sUASs into theNAS. Having a pilot-owned business bridges the gap betweenthe advancement ofsUAS technology and the currentpractices and operations inthe NAS and withthe FAA. This assists the FAAwith its mission ofpromoting aviation whilepreserving safety ofaviators, the public andproperty. The sUAS operated by MainlightProductions, LLC satisfies the criteria setforth in§ 333 ofthe Reform Act- size, weight, speed, operating capabilities, operationwithinvisual line ofsight, and national security- and showing an equivalent level of safetyto manned aircraft flights through appropriate pilot certification and safety-focused standards ofoperation. This provides more than adequatejustificationfor the grant ofthe requested exemptions allowing commercial operations. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public by allowing Mainlight Productions, LLC to safely, efficiently and economically operate the sUAS commercially withinthe NAS.

Respectfully,

Bryan Guzman Mainlight Productions, LLC 

# f-1-----f**v~** 

# /1--...____

14 I MainlightProductions, LLC Petition for Exemption under Section 333December 15, 2015

Attachments: Mainlight Productions, LLC

- certificate offormation. Mainlight Productions, LLC -Employee Identification Forms

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

### NEWJERSEY DEPARTMENT OF THE TREASURY DIVISION OF REVENUE AND ENTERPRISE SERVICES
CERTIFICATE OF FORMATION MAIN LIGHT PRODUCTIONS LLC 

### 0450035844

The above-named DOMESTIC LIMITED LIABILITY COMPANY was duly filed in accordance with New Jersey State Law on 12/08/2015 and was assigned identification number 0450035844. Following are the articles that constitute its original certificate. 1. Name: MAIN LIGHT PRODUCTIONS LLC 

### 2. Registered Agent: ANTHONY B GORGA 

### 3. Registered Office: 315 CLOSTER DOCK ROAD 1ST FL CLOSTER, NEW JERSEY 07624 

### 4. Business Purpose: PHOTOGRAPHY SERVICES 

### 5. Duration: PERPETUAL 

### 6. Effective Date of this Filing is: 12/08/2015 

### 7. Members/Managers: CHRISTOPHER A GORGA' 315 CLOSTER DOCK ROAD CLOSTER, NEW JERSEY 07624

BRYAN J GUZMAN 128 E MADISON AVENUE DUMONT, NEW JERSEY 07628 

### 8. Main Business Address: 315 CLOSTER DOCK ROAD CLOSTER, NEW JERSEY 07624 

### Signatures: ANTHONY B GORGA AUTHORIZED REPRESENTATIVE

Continued on next page

... Page 1 of 2

### NEW JERSEY DEPARTMENT OF THE TREASURY DIVISION OF REVENUE AND ENTERPRISE SERVICES
CERTIFICATE OF FORMATION MAIN LIGHT PRODUCTIONS LLC 

### 0450035844

CertificateNumber : 4007168441

Verify this certificate online at https:1/www**1.state.~i.**us/TYTR

_StandingCert!JSP!Verijj•_CERTjsp INTESTIMONY WHEREOF, I have hereunto setmyhandand affixedmy Official Seal 8th day of December, 2015

FordM. Scudder ActingState Treasurer

Page 2 of 2**~'iii\**

# IRS DEPARTMENT OF THE TREASURY**~~m** INTERNAL REVENUE SERVICE CINCINNATI OH 45999-0023

MAIN LIGHT PRODUCTIONS LLC CHRISTOPHER A GORGA MBR 315 CLOSTER DOCK RD CLOSTER, NJ 07624 Date of this notice: 12-08-2015 Employer Identification Number: 81-0762043
Form: SS-4
Number of this notice: CP 575 B

For assistance you may call us at: 1-800-829-4933

IF YOU WRITE, ATTACH THE STUB AT THE END OF THIS NOTICE.

WE ASSIGNED YOU AN EMPLOYER IDENTIFICATION NUMBER Thank you for applying for an Employer Identification Number (EIN)

. We assigned you EIN 81-0762043. This EIN will identify you, your business accounts, tax returns, and documents, even if you have no employees. Please keep this notice in your permanent records. When filing tax documents, payments, and related correspondence, it is very important that you use your EIN and complete name and address exactly as shown above. Any variation may cause a delay in processing, result in incorrect information in your account, or even cause you to be assigned more than one EIN. If the information is not correct as shown above, please make the correction using the attached tear off stub and return it to us. Based on the information received from you or your representative, you must file the following form(s) by the date(s) shown.
Form 1065 04/15/2016
If you have questions about the form(s) or the due date(s) shown, you can call us at the phone number or write to us at the address shown at the top of this notice. If you need help in determining your annual accounting period (tax year), see Publication 538, Accounting Periods and Methods.
We assigned you a tax classification based on information obtained from you or your representative. It is not a legal determination of your tax classification, and is not binding on the IRS. If you want a legal determination of your tax classification, you may request a private letter ruling from the IRS under the guidelines in Revenue Procedure 2004-1, 2004-1 I.R.B. 1 (or superseding Revenue Procedure for the year at issue). Note: Certain tax classification elections can be requested by filing Form 8832, Entity Classification Election. See Form 8832 and its instructions for additional information.
A limited liability company (LLC) may file Form 8832, Entity Classification Election, and elect to be classified as an association taxable as a corporation. If the LLC is eligible to be treated as a corporation that meets certain tests and it will be electing S corporation status, it must timely file Form 2553, Election by a Small Business Corporation. The LLC will be treated as a corporation as of the effective date of the S corporation election and does not need to file Form 8832.
To obtain tax forms and publications, including those referenced in this notice, visit our Web site at www.irs.gov. If you do not have access to the Internet, call 1-800-829-3676 (TTY/TOO 1-800-829-4059) or visit your local IRS office.(IRS USE ONLY) 5758 12-08-2015 MAIN B 9999999999 SS-4

IMPORTANT REMINDERS: 

### * Keep a copy of this notice in your permanent records. This notice is issued only one tbme and the IRS will not be able to generate a duplicate copy for you. You may give a copy of this document to anyone asking for proof of your EIN. * Use this EIN and your name exactly as they appear at the top of this notice on all your federal tax forms. * Refer to this EIN on your tax-related correspondence and documents.
If you have questions about your EIN, you can call us at the phone number or write to us at the address shown at the top of this notice. If you write, please tear off the stub at the bottom of this notice and send it along with your letter. If you do not need to write us, do not complete and return the stub.
Your name control associated with this EIN is MAIN. You will need to provide this information, along with your EIN, if you file your returns electronically. Thank you for your cooperation.

Keep this part for your records. CP 575 B (Rev. 7-2007)

Return this part with any correspondence so we may identify your account. Please correct any errors in your name or address. CP 575 B
9999999999

Your Telephone Number Best Time to Call DATE OF THIS NOTICE: 12-08-2015 ( )

INTERNAL REVENUE SERVICE CINCINNATI OH 45999-0023 1.1••1.1.1.1.1••1.1••1.1••11•••11•••••1.1••11.1.1••1 EMPLOYER IDENTIFICATION NUMBER: 81-0762043 FORM: SS-4 NOBOD

MAIN LIGHT PRODUCTIONS LLC CHRISTOPHER A GORGA MBR 315 CLOSTER DOCK RD CLOSTER, NJ 07624