Imagefiction, Inc. June 22, 2015

Eric Brightfield

121 W. Wacker Suite 1510

Chicago, IL 60601

+1 (312) 726 0818 ext. 201

eric@imagefiction.com

www.Imagefiction.com

Attn:

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave

SE Washington, DC 20590

Re: 

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

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. Part 

61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 

91.203 (a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam,

I, Eric Brightfield, owner of Imagefiction, Inc., hereby agree to abide by all 

regulations pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

and 14 C.F.R. Part II. I am hereby applying for an exemption from the Federal Aviation 

Regulations to allow commercial operation of these sUASs, so long as such operations are 

conducted under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

 Imagefiction, Inc. is a conceptual architectural visualization company in Chicago that 

produces photo-realistic computer renderings, 3D visuals and virtual reality animations for 

the top architectural, real estate and development companies in the country. Founded in 

1997, it is a studio of artists, animators and visionaries with a common goal of providing 

successful 3D/2D solutions to the architectural and real estate development communities. 

I attended the Kansas City Art Institute and graduated in 1983 with a Bachelor of Fine Arts 

degree and decided to focus on architectural illustration and starting my career at PGAV 

in Kansas City before moving to Chicago in 1985 and becoming the Director of Graphics 

for the 100 year old architectural firm of Holabird & Root. After a decade at Holabird & 

Root, I started an in-house division of Holabird & Root named ImageFusion. The demand 

for the new computerized imaging techniques grew rapidly and the market pushed the 

decision to separate and become a new firm named Imagefiction, Inc. in 1997. During the 

ensuing 18-year span of Imagefiction, Inc., the firm has continued to develop and employ 

new and varied methods of helping their audience visualize proposed new construction and 

repurposed real estate. No tool in that 18 year history has been as powerful as the UAV 
technology has been to our process of being able to easily and quickly attain a high 

resolution base photograph of any site or building from any height or angle to provide us 

with an accurate reference point. Before the use of the UAV technology, team members 

would spend countless hours chasing down dead ends of trying to gain access to rooftops, 

windows or rickety fire escapes to attain that elusive raised perspective base photo. Our 

team members have had dangerous experiences climbing up rickety and rusted fire escapes 

and walking on rotted 100 year old rooftops trying to get an aerial perspective. Because of 

our long relationship with important clients, we have been called upon to create images for 

very important public and institutional clients. Imagefiction, Inc. created the aerial 

illustrations that President Obama personally presented to the International Olympic 

Committee in Copenhagen, Denmark on October, 2nd, 2009 for the 2016 bid as well as the 

majority of all images presented to the governing bodies of the World Cup in a bid for the 

2022 World Cup in October, 2010. More recently Imagefiction, Inc. has been responsible 

for all of the illustrations and renderings demonstrating the 5 year, $500M renovation to 

historic Wrigley Field for the Chicago Cubs. The use of UAV technology was key to our 

success in creating aerial illustrations that were easy to understand by the viewing public 

for such a large project involving an area and scope that would not be able to be illustrated 

from eye level views.

Imagefiction, Inc. proposes to use two sUASs: our custom Harris H15 radial 

octocopter made by Harris Aerial LLC in Orlando, FL (8 arms, 8 brushless motors) as well 

as the DJI Inspire 1 quadcopter (4 arms, 4 brushless motors). Both sUASs weigh less than 

55 lbs. including payload. They are designed to operate under normal conditions at a speed 

of no more than 50 knots and have the capability to hover and move in the vertical and 

horizontal planes simultaneously. Both sUASs are equipped with GPS and an auto-return 

function allowing the sUAS to return to the predetermined safe landing area upon loss of 

control, out of range deviation, and/or preconfigured low levels of power supply. Magnetic 

interference that can cause loss off GPS signal can be monitored through a mobile Ground 

Station application, as well as a Windows-based Ground Station software equivalent. The 

sUASs will operate only in line of sight and will operate with a controlled environment: a 

closed-set area of a residential or commercial listing or a closed-set special event. Such 

operations will insure that the sUASs will “not create a hazard to users of the national 

airspace system or the public.” (Reform Act Section 333 (b)).

 Imagefiction, Inc. requests that the publication and comment procedures be waived 

in accordance with 14 C.P.R.§ 11.87 which states: 

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of 

my petition for exemption? 

The FAA may not publish a summary of your petition for exemption and request comments 

if you present or we find good cause why we should not delay action on your petition. The 

factors we consider in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent.

(b) Whether the relief requested is identical to exemptions granted previously. 

c) Whether our delaying action on your petition would affect you adversely. 
d) Whether you filed your petition in a timely manner. 

Corresponding to the above sub-sections, Imagefiction, Inc. has good cause to request the 

FAA to waive the comment period and not delay action on the petition because: 

(a) Imagefiction, Inc. would not set any precedent. Exemption #'s 11359, 11358, and 

11425 are all previously granted petitions to “allow the petitioner to operate an 

unmanned aircraft system (UAS) to conduct aerial photography and video.” 

Imagefiction, Inc. agrees to abide by the same limitations set forth by these 

exemptions.

(b) This petition for exemption is requesting relief identical to the above-mentioned three 

petitioners. The regulations that Imagefiction, Inc. is seeking relief from were chosen 

based directly upon the FAA's chart included in the exemptions mentioned above. 

This was done so that the FAA could waive the comment period and rapidly grant 

this petition. Furthermore, much of the petition below is copied directly from the 

petitions of the three petitioners.

(c) Delaying the granting of this petition would adversely affect the public, the FAA, and 

Imagefiction, Inc.. Both the Public and the FAA would be better served by the FAA 

quickly granting this petition and thereby freeing up limited FAA resources and 

allowing FAA inspectors to dedicate their time and attention to much higher 

priorities. Moreover, Imagefiction, Inc. is eagerly seeking to be exempt for 

commercial operations and is adversely affected by the above listed regulations. 

(d) The petition has been filed in a timely manner. 

 As described in more detail below, the requested exemption would permit the 

operation of small, unmanned, and redundant sUAS’s under controlled airspace conditions 

that are 1) limited to the Pilot in Command’s (PIC) visual line of sight (VLOS) 2) predetermined and pre-inspected 3) compliant with all government agency regulations, 

including but not limited to the FCC 4) would safely provide innovation and superior 

affordability to commercial photography/videography and emissions sensory applications.

The specific section or sections of 14 CFR from which we seek an exemption:

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 (b) 

• 14 C.F.R. 61.113 (a) & (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b) (2) 

• 14 C.F.R. 91.103 

• 14 C.F.R. 91.109 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151 (a) 

• 14 C.F.R. 91.203 (a) & (b) 

• 14 C.F.R. 91.405 (a) 
• 14 C.F.R. 407 (a) (1) 

• 14 C.F.R. 409 (a) (2) 

• 14 C.F.R. 417 (a) & (b)  

Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

 This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rule making required under 

Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UASs do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of the following: 

• The UAS’s 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 operator. 

Reasons Why Imagefiction, Inc.’s Exemption Will Not Adversely Affect Safety or 

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

• The sUAS will weigh less than 55 lbs.

• Flights will be operated within line of sight of a pilot and/or observer.

• Flights will be terminated at 15% battery power reserve should that occur prior to

the 30 minute limit.

• Flights will be operated at an altitude of no more than 400 feet AGL or, not more

than 200 feet above an elevated platform for which filming is planned.

• Minimum crew for each operation will consist of the sUAS Commercial Pilot, the

Visual Observer, and the Camera Operator.

• The sUAS will only operate within a confined sterile closed-set area with a set 

safety perimeter, the boundaries of which will be determined by production 

personnel and the sUAS PIC based on the site-specific filming activities and speed 

of the sUAS required for the operation, and coordinated with the jurisdictional FAA 

FSDO and local government officials as applicable.

• The PIC will have a minimum of 50 logged flights and/or 50 total hours of flight 

experience.

• We will not operate the sUAS in Class A, B, C, or D airspace without written 

approval from the FAA and local government officials as applicable..

• We will not operate within 4 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that 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 will be made available to the 

Administrator upon request; 

• During operation of the sUAS, signs will be posted warning the public that: 

“Caution: Small Unmanned Aircraft Operation in Progress”; or equivalent

• We will pilot our sUAS through remote control only by visual line of sight, keeping 
the sUAS within 500 feet of the operator at all times, until further increases in flight 

distance have been approved by the FAA

• Our sUAS has GPS-controlled Failsafe, a flight safety feature whereby it gains 

altitude and hovers before slowly returning to home to land. The aircraft also will 

enter this failsafe procedure if the signal between the PIC’s Tx and the Rx on the 

aircraft is lost, or manually engaged by the operator.

• The iOSD (intelligent on-screen display) device on-board the aircraft actively 

records and analyzes flight data and other sources of information and streams it to 

the PIC’s first-person view monitor, thus enhancing overall safety; 

• Before each flight we will assess the environment and will only proceed to operate 

in reasonably safe environments that are controlled and are away from power lines, 

airports and populated areas; 

• We conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance; 

• We will always obtain all necessary permissions prior to operation. 

• We will put forth our best effort to cooperate with regulatory bodies and will 

eagerly contribute to future improvements and development in UAS and UAS 

infrastructure. 

A Summary: 

The FAA May Publish in the Federal Register: 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed.

A) 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 

 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements 

for procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). 

The size, weight and enclosed operational area Imagefiction, Inc.’s sUAS permits 

exemption from Part 21 because our sUAS meets (and exceeds) an equivalent level of 

safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft 

from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

sUASs from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. 

Imagefiction, Inc.’s UAS meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the sUASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight 

manual delineating areas of where safety can be defined. The FAA has previously issued 
exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our sUAS utilizes 

electronic global positioning systems with a barometric sensor, and altitude information 

will be provided to the pilot via a digitally encoded telemetric datalink to a real-time 

display. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required certifications and 

registrations by Imagefiction, Inc.. 

B) 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My sUASs are, by 

definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which 

to mark certain words or phrases. Further, two-inch lettering is difficult to place on such 

small aircraft with dimensions smaller that minimal lettering requirement. Imagefiction, 

Inc. will mark the sUAS in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that the PIC, 

or anyone assisting the PIC as a spotter will see the markings. The FAA has previously 

issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700. 

C) C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. 

§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations.

 Imagefiction, Inc. can achieve an equivalent level of safety as achieved by current 

Regulations. The PIC will have a current Medical and will meet the flight review 

requirements specified in 14 CFR § 61.56. 

D) 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Our sUAS will never 

operate at an altitude greater than 2 feet AGL, only in safe areas away from the public and 

traffic. Given the small size and weight of the sUAS, its maneuverability and speed profile, 

we can achieve an equivalent level of safety. 

E) 14 CFR § 91.151(a) requires a thirty (30) minute fuel reserve for flight in VFR 

conditions. Since maximum flight time is limited to battery capacity, and is less than 30 

minutes for our sUAS, we will operate our sUAS for no longer than ten (10) to fifteen (15) 

minutes on a full charge. A full charge would allow for a flight time of at least twenty (20) 

minutes, providing a 25% to 50% safety margin. The FAA has previously issued 

exemptions for manned aircraft to operate at less than the minimums prescribed in 14 CFR 

§ 91.151(a), including Exemption Nos. 2689, 5745, and 10650. In addition, similar UASspecific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

Visual Flight Rules (VFR) conditions. 
F. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): 

Maintenance Inspections. The above- cited Regulations require, amongst other things, 

aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter. . . ” 

To comply with this regulation, the PIC, before each mission, will check the 

manufacturers’ internet service pages, and ensure applicable software and hardware is up 

to date as required, and ensure compliance with any safety bulletins posted. In addition, 

the Operators Manual as provided by the sUAS manufacturer will be revised to include 

specific operating procedures and limitations to comply with the exemptions sought as 

described (see appendix A). The revised Operators Manual will be in possession of the 

crew during operation of the sUAS, and must be made available to the Administrator or 

any law enforcement official upon request. 

In summary, Imagefiction, Inc. seeks an exemption from the following Regulations: 14 

C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 61.113 (a) & (b); 14 C.F.R. §91.7 

(a); 14 C.F.R. §91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 

14 C.F.R. § 91.121; 14 C.F.R. §91.151(a); 14 C.F.R. § 91.203(a) and (b); 14 C.F.R. § 

91.405 (a);14 C.F.R. § 91.407 (a)(1); 14 C.F.R. §91.409 (a)(2); and, 14 C.F.R. § 91.417(a) 

& (b) to commercially operate Imagefiction, Inc.’s small unmanned vehicle/lightweight 

unmanned aircraft vehicle in aerial photography and videography operations as well as 

client demonstrations. 

Imagefiction, Inc. will utilize safety protocols and the implementation of a flight operations 

manual that exceeds currently accepted means and methods for safe flight. Imagefiction, 

Inc. will conduct formal collection of information of its operation of the sUAS, which will

be shared with the FAA, and will contribute to the enhancement of the FAA's internal 

efforts to establish protocols for complying with the FAA Modernization and Reform Act 

of 2012. Imagefiction, Inc.’s operation of the sUAS, weighing less than 55 pounds and 

traveling at low speeds within limited controlled areas will provide an equivalent level of 

safety as that achieved under current FARs. Accordingly, Imagefiction, Inc. respectfully 

requests that the FAA grant our exemption request. 

Respectfully submitted, 

Eric BrightField

Imagefiction, Inc.

Tel.: +1 (312) 726-0818
Appendix A

Operator’s Manual

(Safety protocols, sUAS configuration, operating procedures)
PRE-FLIGHT SAFETY PROTOCOL

✓ Check batteries with voltmeter to insure fully charged and ready for use.

✓ Inspect batteries for damage or defects that may affect proper operation.

✓ Inspect propellers are mounted correctly.

✓ Inspect propellers for cracks, chips or damage that may result in sudden loss of propulsion or

uncontrolled flight.

✓ Inspect dampening absorbers are in good condition; not broken or worn.

✓ Camera lens cap has been removed.

✓ Micro SD card has been inserted.

✓ Gimbal is functioning properly.

✓ Check weather forecast for wind advisory or other conditions that may adversely impact

flight.

✓ Check predetermined flight area forTFR,restrictions, etc.

✓ Check for NOTAMs for flight area.

✓ Contact respective airport towers to receive advice of estimated time of flight, estimated

flight duration,flight location, estimated maximum altitude of flight and any other pertinent

information.

✓ If required,inform local FAA FSDO

✓ Inspect flight area for:

• vicinity of medical helipads/heliports

• vicinity of light poles

• vicinity of trees

• flocks of birds that may cause interference and potential flight impact

• vicinity of any elevated obstructions that may pose potential flight hazard

• vicinity of roadways with moderate to heavy traffic that can be distracted

• public gatherings that may attract viewers

• optimal point of control for best sight of sUAS while in flight

✓Takeoff and landing:

• Inspect area for best and safest point of takeoff and landing

• Set GPS failsafe home location to predetermined safe area

• If in a subdivision or an area that is within 150 feet of residential street, post warning

sign(s) to inform bystanders - “Attention!Aerial Photography in Progress - Remain

Back 150 Feet. ThankYou.”

FLIGHT PROTOCOL

✓Takeoff and land from same predetermined safe area.

✓ Remain alert to birds, aircraft, and curious public and approaching vehicles.

✓ PIC orVisual Observer will avoid any distractions during flight.

✓ Restrict flight to minimal altitude sufficient to acquire needed results.

✓ Remain prepared for emergency landing at all times.

✓ Pay attention to flight time and battery life percentage.

✓ Land sUAS and shut down propulsion immediately following landing.
POST-FLIGHT PROTOCOL

(a) Disconnect battery(ies) to prevent accidental activation of propulsion system.

(b) Secure sUAS in a safe location.

(c) Remove all warning signs from public access areas.

EMERGENCYor SUSPECTED HAZARD

Immediately land the sUAS at the safest and closest ground location if:

• the PIC and/or theVisual observer is being distracted from focusing on the flight and/or 

following safety protocols..

• a manned aircraft is heard or seen in vicinity of the sUAS.

• a sudden change in weather (thunderstorms and/or convective activity).

• birds enter the proximity of the flight.

• any sudden unsafe event that can cause collision, distraction or interruption of full aircraft 

control.
1

Harris H15 

Octocopter
2

1. Futaba 14SG Functions ............................................................. 3

2. Component Inspection ............................................................. 5

3. Calibration .................................................................................. 6

4. DJI A2 Flight Controller .............................................................7

5. Linking A2 with Futaba Tx ........................................................ 8

6. LED Indicator .............................................................................. 9

7. Disclaimer ....................................................................................10

8. Take-off Checklist.........................................................................11
3

TRIM Shifts the center point of the control stick’s axes. 

 No need to adjust these.

 Ensure all values are at ZERO

SA: Mode

UP - GPS

CNTR - ATT

DOWN - Manual

SB: IOC

Not Assigned

SC: Cruise Control

SD: Auxilliary

Not Assigned

LD: Gains

Shown @ 100%

Rotate right for 100%+

SG: GEAR

DOWN – Release

UP – Retract
4

SE: Blank

SF: FAILSAFE

DOWN – Standby

UP – Go Home

SG: GEAR

DOWN – Release

UP – Retract

SH: Blank
5
Source: DJI A2 Manual 6

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Source: DJI A2 Manual 7
8

Source: DJI A2 Manual
9

Source: DJI A2 Manual
10
11

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