Immanuel Production Group

281 Lynn St.

Oviedo FL. 32765

Office: 1888­854­0958 Fax: 321­207­0252

Email: Dondi@immanuuelproductiongroup.com

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. 21; 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) & (b); 14

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

(a) & (b).

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

Act) and 14 C.F.R. Part 11, Immanuel Production Group LLC, operator of Small

Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial videography and

photography for the motion picture, television, and commercial videography industry for

closed set filming, hereby applies for an exemption from the listed Federal Aviation

Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such

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

established by the FAA as required by Section 333.

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

small, unmanned and relatively inexpensive sUAS under controlled conditions in the

NAS that is 1) limited 2) predetermined 3) controlled as to access. Approval of this

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s

(the FAA Administrator’s) responsibilities to “...establish requirements for the safe

operation of such aircraft systems in the national airspace system.” Section 333(c) of

the Reform Act.

The name and address of the applicant is:

Immanuel Production Group, LLC. /(IPG)

Attn: Alfred Dondi Sanchez (MGR.)

Ph: 321­207­0252

Email:Dondi@immanuelproductiongroup.com

Address: 281 Lynn St.

Oviedo,Fl. 32765
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 rulemaking

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.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may

operate safely in the national airspace system, the Secretary shall establish

requirements for the safe operation of such aircraft in the national airspace system.” Id.

§ 333 (c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority by its terms includes exempting civil aircraft, as the term is

defined under §40101 of the Act, that includes sUASs, from the requirement that all civil

aircraft must have a current airworthiness certificate.

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

prescribed under subsection (a) or (b) of this section or any sections 44702­44716 of

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701

(f) See also 49 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1).

Immanuel Production Group’s (IPG) exemption request would permit its operation of

lightweight, unmanned (remotely controlled in line of sight) UAS's in tightly controlled

and limited airspace. Predetermined, specifically marked areas of operation, sectioned

off locations will allow IPG to operate within current safety parameters as well as new

ones being implemented. As identified, similar lightweight, remote controlled UAS's are

legally operated by amateurs with no flight experience, safety plan or controls in place

to prevent catastrophe. IPG will dictate precise and repeatable preflight planning,

decision making, and operator risk mitigation procedures to mitigate risk to personnel

and property.
Granting IPG’s request comports with the Secretary of Transportation's (FAA

Administrator's) responsibilities to not only integrate UAS's into the national airspace

system, but to" ... establish requirements for the safe operation of such aircraft systems

[UAS's] in the national airspace system" under Section 333 of the Reform Act. Further,

IPG will conduct its operations in compliance with the protocols described herein or as

otherwise established by the FAA.

The Extent of Relief Immanuel Production Group Seeks and the Reason It Seeks Such

Relief:

IPG submits this application in accordance with the Reform Act, 112 P.L. 95 §§

331­334, seeking relief from any currently applicable FAR's operating to prevent IPG

contemplated commercial inspections, research and other flight operations within the

national airspace system. The Reform Act in Section 332 provides for such integration

of civil unmanned aircraft systems into our national airspace system as it is in the

public's interest to do so. IPG lightweight UAS's meet the definition of "small unmanned

aircraft" as defined in Section 331 and therefore the integration of SFR lightweight

UAS's are expressly contemplated by the Reform Act. IPG would like to operate its

lightweight UAS's prior to the time period by which the Reform Act requires the FAA to

promulgate rules governing such craft. The Reform Act guides the Secretary in

determining the types of UAS's that may operate safely in our national airspace system.

Considerations include:

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be

operated near airports or populated areas; and, Whether the UAS will be operated by

line of sight.

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for

Immanuel Production Group.

IPG UAS's uses primarily multi counter­rotating propellers for extreme balance, control

and stability. They each typically weigh less than 55 pounds, including camera or other

equipment. Each of IPG’s small unmanned aircraft is designed to primarily hover in

place and operate at less than a 50 knot maximum speed. They are capable of vertical

and horizontal operations but operate only within the line of sight of the remote control

pilot. In addition to the remote control pilot, IPG uses a camera operator, such that, at

minimum, two IPG personnel govern the safe flight of an IPG aircraft at all times.
Utilizing battery power and no combustible fuels, flights generally last between fifteen to

twenty minutes. IPG does not operate its UAS's with less than twenty five percent

battery capacity. Safety systems in place include a GPS mode that allows IPG’s UAS's

to hover in place if

communication with the radio control pilot is lost and then slowly descend the UAS at

twenty five percent battery capacity. Further, IPG’s fleet is programmed, in some

instances, to slowly follow a predetermined set of waypoints to return to a safety point if

communications are lost or battery drops below twenty five percent.

IPG’s operation of its fleet of small unmanned aircraft will not "create a hazard to users

of the national airspace system or the public." 112 P. L. 95 § 3 3 3 (b). Given the small

size and weight of IPG UAS's, combined with their operation in cordoned off and

well­controlled areas, IPG ‘s UAS’s fleet falls within Congress's contemplated safety

zone when it promulgated the Reform Act and the corresponding directive to integrate

UAS's into the national airspace system. Indeed, IPG UAS's have a demonstrable

safety record and do not pose any threat to the general public or national security. The

FAA has the authority to issue the exemption to IPG pursuant to the Federal Aviation

Act, 85 P.L. 726 (1958), as amended (the "Act").

Commercial and Public Benefits Granting IPG exemption request furthers the public

interest. First, Congress has already pronounced that it is in the public's interest to

integrate commercially flown UAS's into the national airspace system, hence the

passing of the Reform Act. Second, IPG conducts research into safe UAS operations

every time it flies one of its UAS's. Flight data, visual inspections, recorded observations

and flight analyses are compiled to further enhance current safety protocols. Allowing

IPG to log more flight time directly relates to its research and its ability to further

enhance current safety measures. Third, the public has an interest in reducing the

danger associated with current aerial inspection methods, namely, resorting to

physically climbing high or compromised structures to inspect.

Granting IPG exemption request substantially furthers the public's interest in ways

known and currently unknown. Permitting IPG to immediately fly within the United

States furthers advancements in publicly usable technologies or advancements in

equipment available to law enforcement personnel and first responders with state of the

art equipment that does not cost millions of dollars.

Reasons Why IPG Exemption Will Not Adversely Affect Safety Or How The Exemption

Will Provide a Level of Safety At Least Equal To Existing Rule:
IPG exemption will not adversely affect safety. Quite the contrary, for the various

reasons stated, permitting IPG to log more flight time will allow IPG to innovate and

implement new and as of yet undiscovered safety protocols.

IPG UAS's weigh less than 55 pounds complete with cameras and sensors

IPG only operates its UAS's below 400 feet;

IPG UAS's only operate for 15­45 minutes per flight;

IPG lands its UAS's when they reach 25% battery power;

IPG remote control pilots operate SFR UAS's by Visual Line of Sight (VSOL)

IPG remote control pilots have video backup should they somehow lose sight of the

UAS; SFR staffs each flight with a remote control pilot and camera operator;

IPG UAS's have GPS flight modes whereby they hover and then slowly land if

communication with the remote control pilot is lost or battery power is below 25%;

IPG actively analyses electronic flight data and other sources of information to

constantly update and enhance safety protocols;

IPG only operates in secured areas that are strictly controlled, are away from airports

and populated areas;

IPG conducts extensive briefings prior to flight, during which safety carries primary

importance; IPG will always obtains all necessary permissions and permits prior to

operation;

IPG provides a level of safety at least equal to existing rules, and in nearly every

instance, greater than existing rules. It is important to note that absent the integration of

commercial UAS's into our national airspace system, helicopters are the primary means

of aerial photography. While the safety record of such helicopters is remarkably

astounding, it is far safer to operate a battery powered lightweight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board

and IPG only operates in specific areas away from mass populations.
Second, there is no fuel on board a UAS and thus the potential for fire or explosions is

greatly diminished.

Third, the small size and extreme maneuverability of IPG UAS's allow our remote

control pilots to avoid hazards.

Fourth the IPG UAS will allow the replacement of helicopters or other small aircraft to

conduct similar work in a safer more affordable and environmentally friendly manner.

Finally, given their small size and weight, even when close enough to structures or

property to capture required images, IPG UAS's present a marked increase in safety

over traditional larger aircraft. Accordingly, IPG UAS's have operated and will continue

to operate at and above current safety levels.

Equivalent level of safety

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR ₴ 91.203 (a) (1)

14 C.F.R. 45.23 (b) Display of marks; general.

Due to the size and nature of the UAS, it would be impossible to comply with the

marking requirements. The equivalent level of safety will be provided to mark the UAS

as “Experimental” that is clearly visible to the operator, pilot, or observer. The FAA has

issued the following exemptions to this regulation: Exemption No’s 10700, 8738, 10167,

and 10167A.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non­commercial operations. Because the

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

equivalent level of safety of current operations by requiring the pilot operating the

aircraft to have completed a UAS flight training course specific to IPG’s operations

before flying a UAS. A minimum of 40 hours instructional ground and 10 hours of

supervised flight time will be required of any operator prior to commercial application or

use. Unlike a conventional aircraft that carries a pilot and passenger the UAS is a

remotely controlled with no living occupant or cargo. They are of operation is controlled

and restricted, and all flights are planned and coordinated in advance. the risks

associated with the operations of the UAS are so diminished from the level of risk

associated with the commercial operations contemplated by part 61, that allowing

operations of the UAS as requirements with a pilot who has met the minimum

requirements exceeds the present level achieved by 14 CFR 61.113 (a) & (b).
14 CFR 91.7 (a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. As there are no airworthiness certificates issued for the UAS

aircraft, should this exemption be granted, no FAA regulatory standard will exist for

determining airworthiness. Given the size, of the UAS and requirements contained in

the operation manual for use, safety, and maintenance, as well as the use of safety

checklists prior to each flight, as set forth, an equivalent level of safety will be provided.

14 CFR 91.9 (b) (2): Civil aircraft Flight manual, marking and placards.

Given the UAS size and configuration, there is no ability to place or carry a flight manual

on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual that the

ground control point where the pilot flying the UAS will have immediate access to it. The

FAA has issued the following exemptions to this regulation: Exemption No’s 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR 91.103 Preflight Actions

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

insure safety of flight. An exemption is needed from this requirement as the pilot will

take a separate list of preflight actions, including checking for better flight weather

conditions, takeoff and landing clearances, and other actions specified in the IPG

preflight checklist. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft that is being used for

flight instruction unless that aircraft has fully functional dual controls
By design the UAS and remotely piloted aircraft of this configuration 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 previously

approved exemptions for aircraft without fully funcitonlinal dual controls. See exemption

No’s 5778K and 9862A. The equivalent level of safety provided by the fact that neither a

pilot more passenger will be carried in the aircraft, the ability to control the UAS via

radio signal from the control, and by the size and speed of the aircraft.

14 CFR 91.121 Altimeter Settings

An equivalent level of safety will be achieved by the operator by using a GPS altitude

readout and proper safety checklist and preflight planning confirming the altitude of

launch site prior to flight

14 CFR 91.151 (a) VFR Fuel requirements for flight in VFR

An equivalent level of safety will be achieved by limity flights to 30 minutes or enough

battery reserve to ensure the UAS lands at the ground control point with at least 20%

battery power remaining (as determined by on board monitoring system and the pilot).

Furthermore the UAS can be programed to safety descend and land automatically in the

event of loss of communications or battery level is exceeded. Similar exemptions have

been granted to other operations, including exemptions 2689F, 5745, 10673, and

10808.

14 CFR 91.203(a) and (b): Carrying civil aircraft certification and registration

The UAS fully loaded weighs no more than 10lbs and is operated without an onboard

pilot. Therefore the is no ability to place or carry the certification and registration

documents or display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot of the UAS will have immediate access to them, the extent

they are applicatnle to the UAS. The FAA has issued numerous exemptions to this

regulation such as Exemption No’s 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and

10700.

14 CFR 91.405 (a): 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

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

certificate, these sections will not apply to the IPG UAS. Maintenence will be
accomplished hty eh operator pursuant to the flight manual and operating handbook. An

equivalent level of safety will be achieved because these small UAS are limited in sizes,

complexity, and will carry only a small payload to operate for specific limited time. If

mechanical issues arise the UAS can land safely immediately and will be operating no

higher than 400 feet AGL. Preflight inspection will ensure the UAS is in working order

and required maintenance will be performer. A flight and maintenance log will be kept

with the operator and maintain the aircraft in an airworthy condition to provide the

equivalent level of safety.

The Aircraftand it’s operation:

DJI­Phantom 2 and DJI­ Inspire1:

This UAS has flight control using a remote control operating the 5.728­5.85Ghz

frequency in compliance with FCC regulations.The range extender operates within a

frequency of 2412­2462MHz in accordance with FCC regulations. At any time that

communication is lost the UAS will return to it’s take off location at a height of

approximately 60 feet. The UAS locks onto multiple GPS satellites to establish a“home”

position prior to flight.

All flights will be operated within line of sight by the pilot and observer. Maximum flight

time of each event will be limited to 20 minutes or less.

Flights will always have a UAS operator and a camera operator who will control the

recording via the DJI application on a mobile device.

The DJI Phantom 2 and DJI Inspire 1​are highly successful consumer grade small

rotorcraft in the quadcopter configuration with an advertised weight of less than 44

pounds. designed primarily to carry aloft a high definition camera. It has an advertised

maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than

1200 feet per minute (6 m/s). It is powered by four electric motors with a distance

between motors of less than 14 inches (350mm) It utilizes an internal inertial measuring

unit (IMU) with integrated barometric sensor augmented with global positioning system

(GPS) to maintain its geospatial orientation and position. It is controlled primarily

through an FCC certified radio control (RC) unit. Real time video and telemetry
information is transmitted back to a ground control station allowing the operator and/or

PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC,

camera imagery, and control camera angle. It has failsafe modes of operation for either

loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to

approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry

and external lighting cues before reaching a low battery state. An automatic termination

of flight and landing will be initiated when the battery reaches a predetermined low

state. It is anticipated that flights will usually last less than 15 minutes. More information

is available at http://www.dji.com/product/phantom2visionplus

The petitioner request that in a manner similar to reference 3, he be allowed to operate

within 5 miles of an airport provided that;

“The UAS may not operate in Class B, C, or D airspace without written approval from

the FAA. The UA may not operate within 5 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 must be made available to the Administrator

upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner

is requesting a mechanism to facilitate such activities without requesting a new and

separate exemption(s) should the need arise. Operations within class B airspace are

not requested due to the lack of mode C transponder.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight

operations”. The reason for such a general and broad based request is that the

petitioner wishes to utilize a business strategy of horizontal integration and maximize

economies of scope in order to capitalize on opportunities as they may arise in the

future without the long turnaround time associated with additional exemptions. The

petitioner (Immanuel Production Group,LLC) has 24 years in the television and

professional video field and 2 and a half years of experience using UAS . The use of
this new equipment would be a great addition to existing equipment and my opinion

could be a great asset to my industry.

If you have any further questions please feel free to contact the Immanuel Production

Group, LLC at 321­207­0252 or email at info@immanuelproductiongroup.com

Respectfully submitted,

Alfred Sanchez (MGR.)

Immanuel Production Group, LLC