1

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.

Lisa 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); 603-410-4913 (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 elevation); 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 transmitters); 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 Systems (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 

assistance, 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 manned 

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 safe 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 

businesses seeking these services. More importantly, some persons or businesses will use such 

aerial services for the first time because of lower cost making such services 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 aviation 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 offer 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 neighborhoods (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 to 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 registration: 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 to 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 commercial 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:

Illumination Imaging, LLC.

Lisa Dachsteiner, Managing Member

1 Bittersweet Lane

Stratham, NH 03885

Submitted December 18, 2015