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U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. Washington, DC 20590 Submitted electronically by email to: 333exemptions@faa.gov or directly on the FAA website
**Petition for Exemption Under 14 CFR Section 11.81 to Allow Commercial Use of Small Unmanned Aircraft Systems (sUAS)** 

**Petitioner: Illumination Imaging, LLC.**  **Lis a Dachsteiner, Managing Member**  **1 Bittersweet Lane Stratham, NH 03885**  **Tel. 603 -**  **502 -** **4968**
**Submitted by Garry Richard**  **Lane , Esq.**  **Ransmeier & Spellman Professional Corporation P.O. Box 600**  **Concord, NH 03302 -**  **0600 Tel. 603**  **- 496**  **- 9210 (cell); 603** 
**- 41**  **0 -** **4913 (work**
**- direct line**  **) Email:**  **glane@ranspell.com**

**FAR sections Illumination Imaging, LLC.**  **seeks relief from: FAA Modernization and Reform Act of 2012, PL 112** 
**- 95 February 14, 2012, Section 333, 14 CFR Parts: 21, Subsection H**  **(Airworthiness certification); Part 61.113(a) and (b) (Private pilot privileges and limitations, specifically flying for compensation and flights incidental to business); Part 91.103(b)(2)**  **( flight**  **performance under expected values of airport slope and elev ation**  **) ; Part 91.105 (flight** 2

**members at crew stations); Part 91. 109 (flight instruction, dual controls etc.); Part 91.119**  **(minimum safe altitudes); Part 91.121 (altimeter settings); Part 91.151 (** **VFR fuel requirements); Part 91.207 (emergency locator transmi**  **tters); Part 91.405 (required maintenance); Part 91. 407 (operation after maintenance); Part 91.409 (inspections) and Part**  **91.417 (maintenance records).**

**Purpose: Illumination Imaging, LLC.**  seeks exemption in order to operate small Unmanned Aircraft System s (sUAS) for commercial purposes and to comply with FAA regulations. **Commercial purposes include:** aerial photography and videography and other sensing technology recording services, agricultural uses, aerial inspection, surveying, search and rescue assi stance, real estate, cinematography, corporate and personal videos, sporting events and other special events and gatherings. **Public interest:** Using sUAS for these commercial purposes positively affects and effects the public interest. For example , since persons are not onboard sUAS, the risks of manned flight and injury or death to persons onboard aircraft are reduced and eliminated. This would be especially true where airplanes or helicopters were being used at low altitude to accomplish the work . A mann ed helicopter might be flying in the “dead man” curve in order to capture similar images to what an sUAS could capture without risk to persons . A manned airplane might have to fly low to the ground and risk collision with towers, trees and might have no sa fe landing options were the engine to fail in flight. A manned helicopter may have insufficient altitude or forward flight speed to safely auto

- rotate in the case of engine failure

. In the event of an engine failure, the risk of a manned airplane or manned helicopter crash to persons on the ground could be substantial. By contrast, if an sUAS crashes the only likely damage will be to the aircraft itself because the aircraft will not be flown directly over persons other than the operator (and rarely if ever, over even the operator). Using an sUAS for real estate purposes, for example, to videotape the condition of shingles on a roof is much more efficient and safe than putting a person on the roof with a ladder. Similarly, an sUAS might be used to search for wasps that might have made homes for themselves in wood siding or cupolas (and in turn those wasps create risk for painters and contractors) before contractors and painters and even homeowners climb ladders and are stung by those wasps. sUAS use electric motors and do not produce any pollution during flight and even producing the electricity to charge the sUAS batteries would produce significantly less pollution in all likelihood, compared to a piston or turbine engine in manned aircraft. Although an sUAS can sound like a swarm of bees if flown at very low altitude, the noise produced by an sUAS is almost non

- existent compared to the noise produced by manned aircraft.3

Because of the reduced cost of using an sUAS for these operations (compared to the use of manned helicopters or airplanes), these services will be less expensive for persons or busi nesses seeking these services. More importantly, s ome persons or businesses will use such aerial services for the first time because of lower cost making such serv ices cost effective for those users for the first time

. Use of sUAS will help the economy by expanding economies, producing new industries etc. Further, responsible use of sUAS will likely greatly increase the interest of young persons in flight and avia tion and in turn will lead many to obtain flight and ground school training, to obtain special sUAS pilot licenses (once those have been created), perhaps obtain regular aircraft pilots’ licenses and breathe new life into small airport operators (who can o ffer ground and flight instruction and encourage people to learn to fly manned and unmanned aircraft). If sUAS offer new opportunities for FBO’s, that in turn will allow more small airports to survive and thereby enhance the national airspace system. These new young pilots may later advance to become professional pilots of larger UAV that are flown for more advanced commercial, scientific or military defense purposes. Aerial photos and video of properties for sale will better assist buyers in finding the right property and in better understanding prospective neighborhood s (including in places where use of helicopters and airplanes is not safe or practical)

. Use of sUAS for search and rescue, of course, may directly save lives and reduce injuries. **Aircraft to be used:**  **Illumination Imaging, LLC.** will use DJI Phantom III Professional sUAS. The Phantom III Professional weighs substantially less than 55 pounds, has GPS ability, reports altitude and remaining electrical charge for flight to the ground operator. The Phantom has the ability to return t o the departure point, on its own, and to land itself in the unexpected event that the electronic signal between the aircraft component and the ground controller component is lost. The DJI Phantom is commonly used in similar businesses. **Aircraft registrati on:**  The aircraft to be used will be registered in accordance with Section 44711 and Part 47 and Part 45, Subpart C. **Maintenance and inspection: Illumination Imaging, LLC.**  will require maintenance and inspections to be performed based on the requirements of the manufacturer to maintain airworthiness. All repair and maintenance will be performed by qualified personnel. **Pilots in Command and safe flying: Illumination Imaging, LLC.**  understands that for this new and exciting UAV industry to thrive and injury t o be avoided requires operators to responsibly maintain and safely fly the aircraft. **Illumination Imaging, LLC.** will require sUAS training and test flights of all Pilots in Command (“PIC”) , in safe

-to
- operate areas, before the PIC is allowed to make any co mmercial flight, and will conduct all flights in accordance with the FAA standards and regulations set forth by the exemption and /or corresponding COA if the exemption is granted.4

**Request for relief:** Petitioner, through its counsel, respectfully requests that the FAA grant the requested exemption within its authority pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) and pursuant to section 333 of the Reform Act. Respectfully, Garry Richard Lane 122 Tebbetts Road Rochester, NH 03867 On behalf of: **I llumination Imaging, LLC.**  **Lisa Dachsteiner, Managing Member 1 Bittersweet Lane**  **Stratham, NH 03885**

Submitted December 18, 2015