September 10, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Imagination Technologies, LLC for an Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012

Director: Flight Standards Service:

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

14 C.F.R. Part 11, Imagination Technologies, LLC (“Imagination Technologies”) hereby applies 

for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow 

commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or 

"UAS") for the purpose of providing aerial digital photography and videography for mapping 

during construction and design phase for real estate and construction industries as well as 

inspection for wireless towers. 

This petition for exemption is made based on information outlined in this Petition for Exemption, 

as well as the accompanying Imagination Technologies documents;

1. PIC Flight Operations Manual and;

2. Operations Manuals 

(Collectively 2 and 3 are referred to as Documents & Manuals")

3. User Guide and;

4. Flight Manual1 

(Collectively 3 and 4 are referred to as "Manufacturer's Manuals")

Imagination Technologies submits these supporting materials as confidential documents pursuant 

to 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary 

information that Imagination Technologies has not and will not share with other requesting 

parties. Additionally, these documents contain operating conditions and procedures that are not 

generally available to the public and are protected from release under the Freedom of 

Information Act, 5 U.S.C. § 552 et. seq.

For your convenience, this Petition is organized as follows:

 

1

. The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited 

to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service 

information letters and, safety/service bulletins.
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I. Description of Petitioner

II. Description of Proposed Operations

A. Aerial Digital Photography and Videography for Mapping and Inspection Services

III. Relevant Statutory Authority

IV. Imagination Technologies’ Proposed UAS Operations Meet the 

Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational 

Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

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

Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and 

Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

V1. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion

I. DESCRIPTION OF PETITIONER

Imagination Technologies, is based in Flint MI and the purpose of providing aerial digital 

photography and videography for mapping during construction and design phase for real estate 

and construction industries as well as inspection for wireless towers.. The Company’s Principal

and Chief Pilot Jason T. Gooding has been flying UAV Quadcopters as a hobby for more than 

four years without incident, spending thousands of hours flying. 
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Upon the grant of the 333 Exemption the Company’s business will specialize in photography and 

videography mapping and geospatial services for their client base. 

Imagination Technologies’staff are well trained and experienced in providing support as visual 

observers (“VO”) for the pilot in command (“PIC”) in addition to any other needed on site 

assistance.

All of the equipment owned by Imagination Technologies is of the highest quality gear and has

been able to provide these services safely and without any claims or incident. Imagination 

Technologies’ goal is to advise the perspective client that Imagination Technologies is following 

all the applicable state and federal rules to ensure the safety of the public while providing the 

client with a competitive and cost effective product.

Imagination Technologies seeks an exemption to allow for photography, videography and other 

related media products. The contact information for Petitioner is as follows:

Jason T. Gooding

Imagination Technologies, LLC

4100 Minnetonka Dr.

Linden, MI 48451

Phone: (810)771.8861

Email:jgooding@gmail.com

II. DESCRIPTION OF PROPOSED OPERATION

Imagination Technologies seeks an exemption pursuant to Section 333 of the Reform Act to 

operate the DJI Phantom 2, DJI F550 , DJI Phantom 3 and DJI Inspire (referred to IT-UAS )

(under 55lbs) for the proposed operations discussed herein below. All UAS operations will occur 

under tightly controlled conditions on private property where Imagination Technologies has 

received verifiable permission to operate from the landowner, controller or authorized 

representative. The proposed UAS operations will be conducted in accordance with the 

conditions and limitations of this Petition for Exemption and Imagination Technologies’

Operations Manuals. As detailed in Imagination Technologies’ Operations Manuals, all UAS 

operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of 

the operator, in uncontrolled airspace, and will occur at least 5 mm away from an airport 

reference point. Moreover, Imagination Technologies’ Operations Manuals incorporate redundant 

safeguards to assure the aircraft does not travel outside the controlled area of UAS operations, 

including GPS "geo-fencing" technologies.

A. Aerial Digital Photography and Videography for Mapping and Inspection 

Services

Imagination Technologies seeks to use small IT-UAS for the purpose of conducting aerial 

photography, videography, mapping and surveying services for their client base. Imagination 

Technologies has purposefully tailored its operations to meet the requirements established by the 

FAA in prior grants of exemption authorizing commercial use of UAS in the real estate industry, 

including:
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 Trudeau, Realtor® (Exemption No. 11138)

 Alon Sicherman (Exemption No. 11728)

 Sokoler Medly (Exemption No. 11341)

All UAS real estate photography and videography operations will occur on private property in a 

controlled area away from spectators and persons not involved in the recording process. In 

addition, the filming will be conducted between dawn and dusk to ensure maximum safety for 

the public and those involved in the manipulation and operation of the UAS; VFR conditions, at 

altitudes below 400' above ground level (“AGL”). 

As set forth below, Imagination Technologies’ operations provide an equivalent level of safety 

which is superior to performing the same work using conventional fixed-wing aircraft or 

helicopters.

Small UAS real estate video production is also safer than traditional manned aircraft 

performing the same function. Videographer-inspectors also frequently need to climb roof 

tops, trees, or otherwise perform elevated work, which exposes them to the risk of dangerous 

falls, electrocution or other work related injuries. In addition, depending on the nature of the 

video needed and inspection, proximity to equipment, and other mechanical hazards associated 

with industrial sites and construction facilities often involves a risk of exposure to hazardous

conditions. The use of CS-UASs mitigates these hazards and is ultimately a much safer and 

cost efficient method of performing these and most other types of inspections.

Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level 

operations present risks associated with vehicles weighing tens of thousands of pounds 

(including payload) and carrying large amounts of fuel which inherently presents significant fire 

hazards as well as exposure to other chemical contaminates. It is important to note the use of 

small UAS in this area will not only be safer and more cost effective to the perspective user or 

purchaser of the service, but the quality and expanse of acquired information will be far more 

robust given the low cost associated with its acquisition and other potential consumers an 

inexpensive product.

UAS real estate video production is more reliable, and allows for the collection, dissemination, 

and storage of visual and other sensory data with greater precision and duration at a very low 

cost. Small UASs will also be capable of accessing and inspecting areas that would otherwise be 

inaccessible or highly dangerous using conventional aircraft or other inspection methods.

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the

FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA

"to safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit 

unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is safe 

to do so based on the following considerations:

● 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 the visual line of sight of the operator.
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Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and

§§ 44702 – 44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 

(petitions for exemption).

IV. IMAGINATION TECHNOLOGIES’ PROPOSED IT-UAS OPERATIONS MEET 

THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

The small IT-UAS operations proposed by Imagination Technologies as noted above in this 

Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act 

as each of the statutory criteria and relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

A Grant of Exemption is appropriate for operations conducted using the UASs due to their size 

weight, speed, and operational capability.

 The IT-UAS utilized by Imagination Technologies has been approved for use in 

prior Section 333 Grants of Exemption from the FAA.2

 The IT-UAS weighs less than 55 pounds, including payload

 The IT-UAS will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UAS as 

specified using GPS triangulation, digitally encoded barometric altimeter, radio 

altimeter, or any combination thereof. This information will be transmitted to the pilot 

via telemetric data feed.

 The IT-UAS will have system redundancies and independent functionality to 

ensure the overall safety and predictability of the system. If connection to the remote 

control or ground control station is lost, failsafe systems will permit the UASs to 

return to a predetermined location and safely land without injury or damage.

 The radio frequencies used for operations and control of the IT-UAS comply with 

the Federal Communications Commission ("FCC") and other appropriate government 

oversight agency requirements. The operating frequency for the IT-UAS is 2.4 GHz 

frequency bands.

 

2See e.g., Grant of Exemption to Trudeau, Realtor® (Exemption No. 11138); Grant of Exemption to Alon 

Sicherman (Exemption No. 11728); Grant of Exemption to Sokoler Medly (Exemption No. 11341).
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If the same operations were conducted using a helicopter, the aircraft's take-off weight would 

likely exceed 6,000 pounds depending on payload. The difference in weight between the IT-UAS 

and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an unintended accident or 

incident. In addition, the risk to the onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in

Imagination Technologies’ Operations Manuals

Operations Manuals and the Manufacturer's Manual for the selected IT-UAS will contain all the 

procedures and limitations necessary to safely and successfully perform the operations specified 

in this Petition for Exemption. To assist the FAA in making a safety assessment of Imagination 

Technologies’ proposed operations, below is a summary of operational limitations and conditions 

that Imagination Technologies will adhere to, and which will ensure an equivalent or higher level 

of safety to operations conducted under current regulatory guidelines:

1. The IT-UAS weighs less than 55 pounds, with payload.

2. All operations shall be conducted over private or controlled-access property with 

verifiable permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be obtained 

for each scheduled flight prior to operation.

3. All UASs operated under the Grant of Exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in 

Command ("PIC") of the CS-UAS, and one or more Visual Observers ("Observer") as 

necessary to safely conduct the mission.

5. PICs shall possess at least a Sport or Private Pilot's Certificate shall possess at least a 

current Class III Medical Certificate and/or a valid and current driver’s license issued 

within the United States. The PIC will also meet the flight review requirements 

specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 

6. The IT-UAS shall be operated within VLOS of the PIC and Observer at all times. The 

PIC must use human vision unaided by any device other than corrective lenses, as 

specified on the PIC's FAA-issued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate 

verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.
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9. The additional requirements identified in the Grant of Exemption shall be added to 

the Imagination Technologies’ Operations Manuals. The Operations Manuals will be 

maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in the Grant of Exemption and

Imagination Technologies’ Operations Manuals, the conditions and limitations in the 

Grant of Exemption shall take precedence and must be followed. Otherwise,

Imagination Technologies shall follow the procedures outlined in their Operations 

Manuals.

10. Imagination Technologies may update or revise its Operations Manuals. Revisions 

will be tracked and a revised copy of the Manual will be provided to the 

Administrator upon request. Imagination Technologies will also present an updated 

and revised Operations Manuals if it petitions for extension or amendment to its 

Grant of Exemption. If an update or revision would affect the basis upon which the 

FAA grants the exemption, Imagination Technologies will seek an amendment to its 

Grant of Exemption. Imagination Technologies will contact the FAA’s UAS 

Integration Office (AFS-80) if questions arise regarding updates or revisions to the 

operating documents.

11. Imagination Technologies Operations Manuals and its Grant of Exemption will be 

available to the PIC at the ground control station anytime the IT-UAS is operating.

12. The PIC is prohibited from beginning an IT-UAS flight unless (considering wind and 

forecast weather conditions) there is enough power to fly to the first intended point of 

landing, and assuming normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the IT-UAS will be 

limited to 40 minutes or the amount of time the UAS can be flown and still maintain a 

reserve battery power of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never 

enter navigable controlled airspace without timely prior written authorization and 

approval from the FAA. In the event the structure being inspected exceeds 400 feet 

AGL, the UAS will not be operated more than 100 feet above the highest point on the 

structure, and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons. (persons other than the PIC, VO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 
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and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

16. The IT-UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. The IT-UAS may not operate within 5 nm of an airport reference point 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 Imagination Technologies COA. The letter of 

agreement with the airport management will be made available to the Administrator 

upon request.

18. Prior to each flight the PIC shall inspect the CS-UASs to confirm that it is in a 

condition safe for flight. The pre-flight inspection will account for all discrepancies, 

e.g. inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents as well as equipment updates. The PIC shall not 

operate any CS-UASs if the inspection reveals a condition that affects the safe 

operation of the IT-UAS until the necessary maintenance has been performed and the

IT-UAS is found to be in a condition for safe flight. The ground control station shall 

be included in the preflight inspection. All maintenance and alternations must be 

properly documented in the UAS’s records as required by Imagination Technologies’

Operations Manuals.

19. Imagination Technologies will timely carry out its maintenance, inspections, and 

record keeping requirements in accordance with the Operations Manuals. 

Maintenance, inspection, and alterations will be fully noted in the IT-UAS records, 

including total time in service, description of work accomplished, date completed and 

the signature of the authorized person returning the IT-UAS to service.

20. Any IT-UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics (e.g., replacement of a flight critical component) 

must timely undergo a functional test flight in accordance with Imagination 

Technologies’ Operations Manuals. The PIC who conducts the functional test flight 

must make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and IT-UAS record entry shall be included in 

the Imagination Technologies’ Operations Manuals.

21. The IT-UAS will be operated and maintained according to the Manufacturer's 

Manuals and any required manufacturer Safety/Service Bulletins and product updates.

22. Prior to the operation, a Mission Packet will be created in accordance with the 

requirements on Imagination Technologies’ Operations Manuals.

23. Imagination Technologies will obtain an Air Traffic Organization ("ATO") issued 

Certificate of Waiver or Authorization, otherwise known as a COA, prior to 
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conducting any operations under this Grant of Exemption. A NOTAM will be issued 

as required by the COA. All operations will be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies.

25. If the IT-UAS loses communication with the PIC, it will have the capability to safely

return to a pre-determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

27. The IT-UAS will have the capability to safely abort flight in the case of unpredicted 

obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate or a valid

and current state driver’s license issued within the United States. 

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 

25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS 

pilot with a similar IT-UAS type platform. This requirement can be achieved by 

flights conducted and logged as a hobbyist.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of hours pursuant to 54 

CFR § 61.51(b) as UAS pilot operating the make and model of IT-UAS to be utilized 

for operations under the exemption and three take-offs and three landing in the 

preceding 90 days.

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

special visual flight rules ("SVFR") shall not be conducted.

32. The IT-UAS shall remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, hang gliders, etc.).

33. IT-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are 

prohibited.

34. The IT-UAS will not be operated from an elevated platform or moving 

device/vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and 

control of the IT-UAS will comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.
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V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

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, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.3

Imagination Technologies seeks an exemption from several interrelated provisions of Title 14 of 

the Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting 

the requested operations using IT-UAS platforms noted above. Listed below are: (1) the specific 

sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and 

safeguards that Petitioner has established which will ensure a level of safety better than or equal 

to the rules from which exemption is sought.4

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. 

§91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met and in point of fact 

exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines that there 

are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, 

an exemption is requested.

Equivalent Level of Safety

Imagination Technologies’ use of the IT-UAS is safe when taking into account its size, weight, 

speed, and operational capability. As set forth in the description of proposed operations in 

Section IV (A), the IT-UAS weighs less than 55 pounds, including payload and will not be flown 

at a ground speed in excess of 50 knots. The IT-UAS is also equipped with safety features which 

will allow Petitioner to operate the IT-UAS safely after experiencing certain in-flight 

contingencies or failures as noted below.

6 7

 

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed pursuant to 

Sections 44701(a) and (b) and Sections 44702 - 44716).

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the exemption 

would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that 

provided by the rule from which you seek exemption.

5See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI S1000] 

has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of global positioning

system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight 

control functionality as a backup. These safety features provide an equivalent level of safety compared to a manned 

aircraft performing a similar operation."
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Additionally, the IT-UAS carries neither pilots nor passengers, carries no explosive materials or 

flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive 

and operate exclusively within the parameters stated in Imagination Technologies’ Operations 

Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the PIC 

operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. Imagination Technologies will also provide the FAA with 

advance notice of all operations via NOTAMs as required by the applicable COA. In all cases,

operation of the IT-UAS under the proposed conditions will be at least as safe as, or safer than, 

conventional rotorcraft operating with an airworthiness certificate. Lastly, the CS-UASs do not 

need a means to communicate with other aircraft or ATC, because those capabilities will be 

solely possessed by the PIC and Observer, who are not onboard the CS-UAS.

8

In addition, no 

sense-and-avoid technology is necessary for the CS-UASs because they will be operated at all 

times in VFR conditions and within VLOS of the PIC and Operator.

9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that Imagination Technologies’small CS-UASs would 

otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's 

airworthiness standards for the same reasons identified in the request for exemption from 14 

C.F.R. R. Part 21, Subpart H, supra.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

 

7See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The FM-UAS can 

be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the 

system where to go, and the system does all the flying for the operator. The AL-UAS can be operated in both semi 

and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path 

for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system 

cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in 

intelligent fault handling which allows the AL-UAS to detect a system fault while in the air and automatically fly 

back to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding pre-set 

wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any 

point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS 

position. The flight control system employs not only GPS positioning but a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not 

exceeded. Also a flight termination link – to prevent a 'fly away' or other potentially dangerous situation – is 

available to the operator."

8See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

. Id
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Imagination Technologies seeks an exemption from the aircraft marking and identification 

requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft 

or experimental or provisionally certificated aircraft, the operator must 

also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, 

the words "limited," "restricted," "light-sport, "experimental," or 

"provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by

§ 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identification (N-Number) markings in 

accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable."10

Equivalent Level of Safety

All CS-UASs flown by Imagination Technologies will bear N-number markings that are as large 

as practicable in accordance with 14 C.F.R. Part 45, Subpart C.11

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

Maintenance Inspections

Imagination Technologies seeks an exemption from the maintenance inspection requirements 

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

regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, 

e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required inspections 

...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from these 

regulations is needed because Part 43 and these sections only apply to aircraft with an 

 

10. FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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airworthiness certificate, which the UAS platforms to be operated under this grant of exemption 

will not have.( Emphasis added)

Equivalent Level of Safety

An equivalent level of safety will be achieved or exceeded because maintenance and inspections 

will be timely performed in accordance with the Manufacturer's Manual and any required 

manufacturer Safety or Service Bulletins. Further, as required by Imagination Technologies’

Operations Manuals, the PIC will conduct a pre-flight inspection of the CS-UASs and all 

associated equipment to account for all discrepancies and/or inoperable components. 

Maintenance will be performed and verified to address any conditions potentially affecting safe 

operation of the CS-UASs and no flights will occur unless, and until, all flight critical 

components of the CS-UASs have been found to be airworthy and in a condition safe for

operation. A functional test flight will be conducted following the replacement of any flightcritical components. As required by Imagination Technologies’ Operations Manuals, the PIC who 

conducts the functional test flight will make an entry in the IT-UAS aircraft records of the flight.

Imagination Technologies’ Operations Manual also includes requirements to follow the 

manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and 

life limit requirements for the following applicable components: powertrain system (powerplant), 

propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, 

camera system, electrical systems (including batteries), ground control station, hazard 

accessories, and spare parts. Further, Imagination Technologies’ Operations Manuals also include 

procedures to document and maintain a record of the CS-UAS’s maintenance, preventative 

maintenance, alterations, status of replacement /overhaul component parts, and the total time in 

service of the CS-UASs used under this Grant of Exemption. As a whole, the maintenance and 

inspection procedures required in Imagination Technologies’ Operations Manuals ensure that an 

equivalent or higher level of safety will be achieved.

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Imagination Technologies seeks exemption from 14 CFR § 61.113, which restricts private pilot 

certificate holders from flying aircraft for compensation or hire, and would also require a second 

class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any 

PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if 

the private pilot is carrying passengers or cargo for hire. In this case, while the CS-UASs will be 

operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant 

of Exemption to Astraeus Aerial, the FAA determined that the unique characteristics of UAS 

operation outside of controlled airspace did not warrant the additional cost and restrictions 

attendant with requiring the PIC to have a Commercial Pilot Certificate and Class III Medical

Certificate.12 The fulfillment of the additional requirements for a private pilot to become 

qualified as a commercial pilot would not lead to any additional safety benefits when UAS 

operations are involved. 

 

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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Equivalent Level of Safety

The restrictions Imagination Technologies has placed on its IT-UAS operations meet or exceed 

the restrictions similarly imposed on Astraeus Aerial. Imagination Technologies will operate on 

private property away from persons and property not involved in the operation. Imagination 

Technologies will also obtain an ATO issued COA prior to conducting any operations under this 

Grant of Exemption. All operations will be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Imagination Technologies will further ensure safe 

operation by requiring that any PIC be thoroughly versed not only in airspace and 

communication issues pertaining to all aircraft operators but also in the unique aspects of ITUAS flight. As set forth in the Operations Manuals, pilots will have experience not only in ITUAS operations generally but have logged flight time in the specific make and model used for 

the operations before they are permitted to participate in commercial flights on behalf of

Imagination Technologies. The pilot qualification, training, and currency requirements in the 

Operations Manuals ensure that Imagination Technologies pilots are competent and proficient in 

the CS-UASs they are operating. Imagination Technologies’ training and qualification 

requirements are consistent with those contained in prior FAA Section 333 Grants of Exemption, 

and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety to the public.

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UASs, Imagination 

Technologies seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be 

in airworthy condition to be operated. The FAA has stated that no exemption is required for 14 

C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable.13

Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance with

Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 

§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b) (2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2):

(b) No person may operate a U.S.-registered civil aircraft –

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 

 

13See Id. at 13-14, 22.
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Flight Manual, approved manual material, markings, and placards, or any combination 

thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Given the small size and configuration of the CS-UAS, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the IT-UAS because there is simply 

no room and the IT-UAS has no cabin or cockpit. As a way to comply with the code Imagination 

Technologies will maintain the documents with the PIC and make them available for inspection.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 

91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight 

manual, registration certificate, and other required documents from the ground control station 

from which he or she is operating the aircraft.14 As this FAA Office of Chief Counsel Opinion 

clarifies, the intent of the rule is to ensure the pilot has access to these key documents during 

flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has 

access to the documents at the ground control station from which he or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Imagination Technologies seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Imagination Technologies’

Operations Manuals and the Manufacturer's Manual. The PIC will perform a series of checklists 

designed to identify any defects or inoperable components in accordance with the Imagination 

 

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, 

to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18.
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Technologies’ Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, 

and Post-Flight procedures. The PIC will also be required to review weather, flight requirements, 

battery charge, landing and takeoff distance, UA performance data, and contingency landing 

areas—before initiation of flight. Imagination Technologies’ Operations Manuals and the 

Manufacturer's Manual will be kept at the ground control station and will be accessible to the 

PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

Imagination Technologies seeks an exemption from 14 C.F.R. § 91.109(a), which provides in 

pertinent part that "[n]o person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls." UASs 

and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight 

control is accomplished through the use of a device that communicates with the aircraft via radio 

communications. Accordingly, an exemption will be required for the flight instruction 

requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that Imagination Technologies intends to use, an 

equivalent level of safe training can still be performed without dual controls because no pilot or 

passengers are aboard the UAS, and as required by the Imagination Technologies’ Operations 

Manuals, all persons will be a safe distance away in the event that the UAS experiences any 

difficulties during flight instruction. Moreover, as required by the Imagination Technologies’

Operations Manuals, all flight training will be conducted in controlled and sterile environment. 

As a whole, the safety procedures provided for in Imagination Technologies’ Operations Manuals 

ensure that the proposed UAS operations provide an equivalent or higher level of safety than that 

provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Imagination Technologies requests an exemption from the minimum safe altitude requirements 

of 14 C.F.R. § 91.119(c).15 Section 91.119 prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any person, vessel, 

vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows 

for a helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed IT-UAS operation will normally need to occur 

below 400 feet AGL. In circumstances where the IT-UAS is used to inspect a structure whose 

height exceeds 400 feet AGL, the IT-UAS will not be operated more than 100 feet above the 

 

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing 

without undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS 

operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. 

See e.g., Grant of Exemption No. 11157 to Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15).
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highest point on the structure, and within 50 feet horizontally of the structure. Additionally, due 

the nature of the proposed operations, the Pilot and/or Observers(s) may need to be less than 500 

feet away from the CS-UAS.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the above noted UASs, any risk 

associated with these operations is far less than those which presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the

CS-UASs, as well as the controlled location where the operations will occur. In order to avoid 

any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below, or 

when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the 

highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the CS-UASs will be operated in a restricted area, and all 

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating 

persons, unless that person is in a position where he or she is shielded from the IT-UAS and any 

possible debris resulting from its failure. As required by the Operations Manuals, flights will be 

terminated if a nonparticipating person within 500 feet of the IT-UAS leaves a shielded position. 

Further, its operations will occur at least 500 feet away from vehicles or structures unless the 

property owner/controller timely has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and, operations near the PIC or 

Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in

Imagination Technologies’ Operations Manuals will ensure operations can be conducted without 

compromising public safety.16

K. 14 C.F.R. § 91.121: Altimeter Settings

Imagination Technologies seeks an exemption from 14 C.F.R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required to 

the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 

can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

 

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "If barriers or structures are 

present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then 

the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that 

nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave 

such protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how 

to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the 

FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the

owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a 

safety assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard."
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below17, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the 

operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude 

initiation point is established for the PIC to confirm accuracy of the onboard GPS.18

The CS-UASs that Imagination Technologies intends to use for the proposed operations will 

meet all these operational characteristics. Moreover, as required by Imagination Technologies’

Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass prior to 

each flight operation. Like prior FAA Section 333 Grants of Exemption, the CS-UASs

Imagination Technologies intends to use, and the safety mitigation procedures contained in the 

Operations Manuals, both ensure that an equivalent level of safety or greater level will be 

achieved, and a Grant of Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Imagination Technologies requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements 

for flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption 

from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, it is not

Imagination Technologies’ intention to fly the CS-UASs at night.

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved 

by prohibiting the PIC from beginning a IT-UAS flight unless (considering wind and forecast 

weather conditions) there was enough power to fly to the first intended point of landing and, 

assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this 

conclusion, the FAA considered that the UAS batteries for the IT-UAS provide approximately 50 

minutes of powered flight (with payload) and provided battery level and battery time remaining 

in minutes and seconds to the PIC.19 The FAA also considered the fact the IT-UAS operating

manual states: “start every flight with a fully charged battery in the aerial vehicle”, and that in 

 

17If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 

feet above the highest point on the structure.

18See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).

19. Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).
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the event that the IT-UAS should run low on power, the PIC will be alerted and can safely land 

the- IT-UAS as soon as possible. Like the VDOS Grant of Exemption, Imagination Technologies’

use of the CS-UAS, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved and in fact exceeded.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA 

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions 

could be achieved by prohibiting the PIC from beginning a flight with the UA unless 

(considering wind and forecast weather conditions), there was enough power to safely fly at 

normal cruising speed to the intended landing point and land the UA with 25% battery power 

remaining. Imagination Technologies will adhere to this limitation for its IT-UAS flights.

The IT-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from 

the IT-UAS to a ground-based-on-screen display.20 As required by Imagination Technologies’

Operations Manuals, the PIC will promptly fly the IT-UAS back to the home launch location or 

pre-determined abort location where it may safely land, while still maintaining a minimum of 

25% reserve battery power. Imagination Technologies submits that the procedures requiring 

flights to be safely terminated once the batteries fall below 25% capacity, combined with the 

requirement that flights only be conducted within a secure, isolated area, using a UAS weighing 

less than 55 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed 

operation will provide an equivalent or higher level of safety to the public to that provided by the 

regulations from which exemption is sought.

VI. DRUG AND ALCOHOL PROGRAM

Imagination Technologies will have policies in place to ensure that no person may participate in

CS-UASs flight operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

The public interest will be served by granting Imagination Technologies’ Petition for Exemption.

Congress has established a national policy that favors early integration of UAS into the NAS in 

controlled, safe working environments such as those proposed in this Petition. Granting this

Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the

Reform Act—the FAA Administrator's assessment of whether certain UAS may operate safely in

the NAS before completion of the statutorily required rulemaking.

The proposed IT-UAS operations in this Petition for Exemption significantly improves the safety 

and reduces risk of harm, physical injury and property damage to the public at large, the property 

owners from whom permission was granted for use by Petitioner and abutting properties, staff of 

Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those 

who may be in the local vicinity. Traditional methods of providing surveillance and modeling

 

20. The IT-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS.
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services requires location personnel to climb towers, trees, venture onto precarious roofs and 

other dangerous scenarios, perform elevated work for which the individual is neither trained nor 

equipped to perform, which exposes them to unnecessary risk of serious physical injury from 

dangerous falls or other physical mishaps. Moreover, inspectors/surveyors are often

unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations

and other hazards associated with identifying specific locations for potential recording sites to be 

used in the end product. The use of small UASs can eliminate these hazards and ultimately 

create a much safer method of performing these types of inspections creating a safer environment 

for the public as well as Imagination Technologies employees.

The use of small UASs also enhances safety and reduces risk to the surrounding public because, 

unlike manned aircraft weighing thousands of pounds, carrying crew in addition to flammable 

fuel, the UASs carry no passengers, crew or explosive fuel. Furthermore, in the unlikely event of 

an accident, Imagination Technologies’small battery powered CS-UASs presents significantly 

less danger to persons on the ground when compared to operations by conventional manned 

aircraft.21 As Petitioner's CS-UASs are battery powered, the public will also benefit from a 

reduction in harmful petroleum based emissions associated with conventional aircraft performing 

in the same functions proposed herein. Air quality will naturally be improved with the reduction 

of fuel powered vehicles. 

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UASs 

provide an additional economic tool for the aerial filming notwithstanding the industry, adding a 

greater degree of flexibility, which supplements the current capabilities offered by manned 

aircraft.22 The quality of the finished product is enhanced and provides a greater finished product 

demand which will aid the current UAS industry and provide additional jobs as the cost of 

providing the needed product is greatly reduced while reducing the difficulty with which the 

finished product is created. The demand for the current industrial product is increasing and will 

continue to increase given the enhanced flexibility of production; therefore, given the lower cost, 

owner/operators and others in the relevant industry will be more inclined to utilize the services of 

commercial UAS along with an appropriate licensed PIC’s. 

VIII. PRIVACY

All IT-UAS operations will be conducted in accordance with applicable federal, state, and local 

laws regarding privacy. All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each flight to be 

conducted.

 

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting 

aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard 

crewmembers, as necessary. The petitioner’s UAs will weigh less than 55 pounds with no onboard pilot or crew. 

The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential 

for harm to participating and nonparticipating individuals or property in the event of an incident or accident. 

risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial 

filming operation."

22See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
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IX. FEDERAL REGISTER SUMMARY

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: Petitioner seeks an 

exemption from the following rules in Title 14 of the Code of Federal Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c);

91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a) (1);

91.409(a) (1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general 

public, property owners and city structures from the substantial hazards associated with 

performing equivalent film work and aerial video production with conventional

fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

Imagination Technologies’ Petition for Exemption satisfies the criteria articulated in Section 333 

of the Reform Act of 2012 which includes weight; speed; operating capabilities; proximity to 

airports and populated areas; operation within VLOS and national security. The proposed ITUAS operations will benefit the public as a whole by improving safety and reducing risk by 

alleviating human exposure to danger while lowering the attendant related costs thereby 

increasing the demand for the finished product. In consideration of the foregoing, this Petition 

for Exemption provides the FAA with more than adequate justification for granting the requested 

exemptions allowing Imagination Technologies to use small IT-UAS s in the recorded production 

of its product.
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We thank you for your prompt consideration of our requested exemptions.

Respectfully Submitted,

Jason T. Gooding

Imagination Technologies, LLC 

7183 Windbury Ln

Flint, MI 48507

Phone: (810)771.8861

Email:jgooding@gmail.com

(The following attached items contain proprietary and commercial information exempt from 

disclosure under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a

separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments:

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. Cell tower Comps

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals