Imagination Films, LLC

Xavier Salinas

520 S Burnside Ave. Apt 9M

(817) 939-8441

Xavier@imaginationinuse.com

July 1, 2015

U.S. Department of Transportation, Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition of Imagination Films, LLC for Exemption Pursuant to Section 333 of the FAA Reform Act

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Imagination Films, LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) 

equipped to conduct aerial photography and videography, 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 333.1 

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

and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 

and 3) controlled. The proposed exemption, if granted, would allow Imagination Films, LLC to conduct 

commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333.

Imagination Films, LLC is a production company owned and run by Xavier Salinas. Mr. Salinas has been 

active in Radio Controlled Aircraft for the past 5 years with experience rotary wing aircraft. Imagination 

Films, LLC plans to exploit the capabilities of Unmanned Aerial Systems to offer a multitude of services, 

including: 

- Motion Picture Film Production/Aerial Filmmaking and Photography 

- Aerial Surveying 

- Event Photography/Videography 

- Agriculture purposes 

- Real Estate Photography/Videography

- Construction site inspections and monitoring 

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 

333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the (comprehensive) plan and rulemaking required by 

section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), 

Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if 

several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations. 
The Petitioner Requests Relief From the following regulations from which the exemption is requested: 

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113 (a) and (b) 

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

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. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 – 91. 417)

Unmanned Aircraft System sUASs are oftentimes seen as superior to helicopters due to the smaller devices, 

cheaper equipment, personnel cost, reduced noise and as such, a much smaller environmental impact which 

promotes public safety. 

We are petitioning for exemption to enable Imagination Films, LLC to operate a DJI Inspire 1 upgraded to 

the latest firmware and equipped with a three-axis camera gimbal and using a 4K camera. This sUAS has a 

built-in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from 

the operator. The Inspire 1 also has the failsafe function of the autopilot system, which means when the 

communication between the Main Controller and the transmitter is disconnected, the outputs of all 

command sticks from controller will go to the center position. If the GPS signal is good enough, the system 

will automatically trigger Return to Home and will land safely. 

Please refer to the link to the DJI Inspire 1 Instruction Manual for the performance limitations and flight 

operations. 

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf 

Please find all the appropriate specifications for the DJI Inspire 1 on the next page. 
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Aircraft

Gimbal

Model Model T600

Weight (Battery Included) Weight (Battery Included) 2935 g

Hovering Accuracy (GPS Mode) Hovering Accuracy (GPS Mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model Motor Model DJI 3510

Propeller Model Propeller Model DJI 1345

Indoor Hovering Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions Dimensions 438x451x301 mm

Model Model ZENMUSE X3

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Camera

Output Power (With Camera) Output Power (With Camera) Static: 9 W

In Motion: 11 W

Operating Current Operating Current Station: 750 mA

Motion: 900 mA

Angular Vibration Range ±0.03°

Mounting Mounting Detachable

Controllable Range Pitch: -90° to +30°

Pan: ±320°

Mechanical Range Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed Pitch: 120°/s

Pan: 180°/s

Name X3

Model Model FC350

Total Pixels Total Pixels 12.76M

Effective Pixels ective Pixels 12.4M

Image Max Size 4000x3000

ISO Range 100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed 8s  1/8000s

FOV (Field Of View) FOV (Field Of View) 94°

CMOS CMOS Sony EXMOR 1/2.3”

Lens Lens 20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes Still Photography Modes Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage 60 Mbps

Supported File Formats Supported File Formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types Supported SD Card Types Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range 0° to 40° C
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Remote Controller

Charger

Battery (Standard)

Name C1

Operating Frequency Operating Frequency 922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed) Transmitting Distance (Outdoor And Unobstructed) 2 km

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port Video Output Port USB, mini-HDMI

Power Supply Power Supply Built-in battery

Charging Charging DJI charger

Dual User Capability Dual User Capability Host-and-Slave connection

Mobile Device Holder Mobile Device Holder Tablet or Phone

Max Mobile Device Width 170mm

Output Power Output Power 9 W

Operating Temperature Range -10° to 40° C

Storage Temperature Range Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0-40° C

Battery Battery 6000 mAh LiPo 2S

Model Model A14-100P1A

Voltage 26.3 V

Rated Power Rated Power 100 W

Name Intelligent Flight Battery

Model Model TB47

Capacity Capacity 4500 mAh

Voltage 22.2 V

Battery Type LiPo 6S High voltage battery

Energy Energy 99.9 Wh
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Battery (Optional)

Vision Positioning

DJI Pilot App

Net Weight Net Weight 570 g

Operating Temperature Range -10° to 40° C

Storage Temperature Range Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range 0° to 40° C

Max Charging Power Max Charging Power 180 W

Name Intelligent Flight Battery

Model Model TB48

Capacity Capacity 5700 mAh

Voltage 22.8 V

Battery Type LiPo 6S

Energy Energy 129.96 Wh

Net Weight Net Weight 670 g

Operating Temperature Range -10° to 40° C

Storage Temperature Range Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0° to 40° C

Max Charging Power Max Charging Power 180 W

Velocity Range Below 8 m/s (2 m above ground)

Altitude Range 5-500 cm

Operating Environment Operating Environment Brightly lit (lux > 15) patterned surfaces

Operating Range 0-250 cm

Mobile Device System Requirements Mobile Device System Requirements iOS 8.0 or later

Android 4.1.2 or later

Supported Mobile Devices Supported Mobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular

iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini

3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and

iPhone 6 Plus.

* Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia

Z7 mini

*Support for additional Android devices available as testing and development

continues

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A Pre-flight inspection will be performed by the PIC in accordance with the factory instruction manual. An 

added step will be the inspection of the propellers. A propeller will be replaced if it has any nicks and 

cracks with a manufacturers authorized propeller. 

The sUAS will be maintained in accordance with the manufacturers instruction manual and only 

manufacturer's authorized replacement parts will be used. 

FCC Information 

This DJI C1 transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation is 

subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this 

device must accept any interference received, including interference that may cause undesired 

operation. The DJI C1 radio transmitter used for controlling the sUAS is wireless technology which has 

been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 

2.400GHz to 2.4835GHz frequency range. Antenna Separation Distance When operating our DJI C1 

transmitter, the PIC will maintain a separation distance of at least 5 cm between his body (excluding 

fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as 

determined by FCC regulations. 

Pilot in Command and Observer Qualifications and Duties 

The PIC will maintain at least 2 hours flying time and 3 takeoffs and landings within 30 days in the type of 

UAS utilized in operations. The PIC will have at least 50 hours total time and at least 30 hours flying 

Radio Controlled Model Aircraft of which will be 10 hours flying sUAS's. 

Training will be conducted at a local Radio Control Club flying field. Imagination Films has the ability to 

provide "dual controls" utilizing two DJI C1 transmitters with a wireless link between the transmitters. One 

transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PIC 

instructor, utilizing the master transmitter, will be at all times be able assume control of the sUAS. 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include all 

preflight preparation, in flight operation, post flight requirements, all procedures including but not limited 

to: 

Safe in flight operations Risk Mitigation to Persons and property Airfield Suitability 

The Observer must have the visual acuity to observe the sUAV and be able to communicate clearly with 

the PIC. The Observers duties are; 

- Warning the PIC of any impending obstacles in the flight path of the sUAS. 

- Warning the PIC of any deviations in the planned flight path of the sUAS. 

- Warning the PIC should any unauthorized personnel appear in the area of the planned flight. 

The Observer will have the authority to order the PIC to terminate the flight should he feel the flight cannot 

be conducted safely. 

General Operating Standards 

• Imagination Films, LLC will only operate its sUAS in line of sight of a pilot and/or observer and will 
operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the 

sUAS will "not create a hazard to users of the national airspace system or the public." 

• Before an operation of a sUAV within 5NM of an airport with a control tower, the control tower will be 

called to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the 

sUAV will be operated. The sUAS will not be operated at an altitude of over 150 feet AGL. Weather 

minimums will be 3 miles visibility and a 1000 foot ceiling. 

Before an operation of a sUAS within 5NM of a non-tower controlled, airport operators will be notified and 

the PIC will give the right of way to avoid flying in the proximity of full-scale aircraft. At no time will the 

sUAV be operated within the final approach course and the takeoff course of any runway. The sUAV will 

not be operated at an altitude of over 150 feet AGL. Weather minimums will be 3 miles visibility and a 

1000 foot ceiling. 

• Maximum flight time for each operational flight will be 25 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit. 

• The sUAV will be programmed so that it will not be operated at an altitude of no more than 400 feet 

AGL, and not more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer. 

• The sUAV operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, 

and gimbals). 

• The sUAV will operate at speeds of no more than 60 knots, can hover, and can simultaneously move 

vertically and horizontally. 

• Given the small size of the sUAV and the restricted sterile environment within which they will operate, 

our sUAV operations adhere to the Reform Act's safety requirements. 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on 

combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk 

levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a 

small payload and maximum flight time of only 20 minutes, this is offers little or no risk to national 

security. 

Low level oblique photos and video from several angles are far more effective than ground based imagery 

for displaying the characteristics of large, complex properties with several buildings and large trees. The 

applicants in the past have chartered 2-seat full- sized helicopters for this purpose, which has proven more 

costly than many potential clients have been able to afford. The benefits of reduced cost and improved 

quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real 

property. 

Additionally, we request that we be allowed to use our system to benefit first responders nearby who might 

require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all 

limitations cited in this application as we do so. 

(a) No flight will be made with a Gross weight exceeding 35 pounds; 

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no 

more than 60 knots and no further than 1 NM from the PIC; 

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by 
voice at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property owner; 

(e) All required permits will be obtained from state and local government prior to operation; (f) 

Imagination Films, LLC will not be operated over densely populated areas; (g) Imagination Films, LLC 

will not be operating over any open-air assembly of people; (h) Imagination Films, LLC will not be 

operating over heavily trafficked roads; 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Imagination Films, LLC requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the DJI Inspire 1 under either or both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft 

installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance of type 

and supplemental type certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. Since the experimental 

certificate can be used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon 

fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the 

previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters 

at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at 

least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an 

entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In 

Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will 

be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground station. Finally, we will display 

at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground 

station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point 

of origin. 
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial 

pilot privileges and limitations

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of 

an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of 

an aircraft in connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for compensation or 

hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate with a Class 

III Medical issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet 

the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 

14 CFR 91.7 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 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is 

in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is 

available to the aircrew while operating the aircraft. We request an exemption to this requirement since the 

aircraft is not only too small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that 

a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the 

aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states, "No person may operate a civil aircraft that is being used for flight instruction unless 

that aircraft has fully functioning dual controls." Training will be conducted at a local Radio Control Club

flying field. Imagination Films has the ability to provide "dual controls" utilizing two DJI C1 transmitters 

with a wireless link between the transmitters. One transmitter is designated the master transmitter and the 

other transmitter is designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all 

times be able assume control of the sUAV. 

91.119 Minimum safe altitudes

General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be 

photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer 

than 500 feet to the items listed. Operations will only be flown over property or persons where permission 

has been obtained and careful pre-planned flight path has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or 

property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, 

vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the 

exemption. 

CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need 
to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer 

to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-vFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 20 minutes. 

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 

15 minutes with a 20% reserve. Since the aircraft will never fly more than 1 NM from the point of intended 

landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this 

paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the 

word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides 

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for 

this aircraft by the FAA will be with the crew at the ground control station and available for inspection 

upon request. In order to identify the aircraft, we propose that the information found on airworthiness and 

registration certificates be permanently affixed to the aircraft via placard containing the following 

information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that 

the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours 

of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, 

checking electrical connections and updating software and firmware for the on-board computer. The 

manufacturer or their designated repair facility will perform all other maintenance. The PIC will document 

work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the 

aircraft, the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the UAS 

Imagination Films, LLC will be using the UAS in a variety of applications that generally require expensive 

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits over the 

use of full-sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced 

agriculture, film and still photography, just to name a few. Replacing significantly larger manned aircraft 

carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater 

margin of safety for the pilots and crew. By granting Imagination Films‘s requested exemptions, the FAA 

will help drive development of safe and successful commercial UAS operations and will advance the public 

knowledge base for such operations. Imagination Films, LLC is committed to promoting the UAS research 

efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial 

UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good 

cause to grant this Petition. 
Conclusion 

As pointed out in this application, all the sUAS which our company would use, under authorization by the 

US DOT-FAA, are small, light-weight devices operated within the line of sight of the Pilot-in-Command 

(PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, 

spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have 

been notified and have authorized each flight within a radius of this distance. 

All our sUAS have proven capability for controlled flight. They are devices offered for general sale on the 

market around the world and have often been used as Model Aircraft in the USA. We are certain that the 

studies conducted until now by the FAA, about Section 332, Public Law 112-95, 2014, have already 

provided you with the assurances on the airworthiness of sUAS such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and Imagination Films, LLC 

should be permitted to conduct small UAS operations in accordance with its manuals and all other 

operating parameters deemed necessary and appropriate by the FAA. The submission of this application 

and its contents is the best demonstration that indeed it is possible to pursue the authorization process so 

that some sUAS may be used for legitimate commercial activities and under reasonably safe conditions. 

Signed,

Xavier Salinas

Managing Member - Imagination Films, LLC