ANR Production Services, Incorporated Ovideo, FL - Section 333 Exemption Petition

December 20, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 

45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b) (2); 14 C.F.R. 

91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a)&(b); 14 

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

Dear Sir or Madam, 

Pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, 

ANR Production Services, Incorporated, an owner and operator of small unmanned aircraft systems (sUASs), 

requests to be exempted from the Federal Aviation Regulations (“FARs”) listed below so that ANR Production 

Services, Incorporated, may safely and legally operate small ultra lightweight unmanned aircraft systems (“sUASs”) 

in the national airspace (NAS) regulated by the Federal Aviation Administration (“FAA”). 

Following exemption and approval by the FAA, ANR Production Services, Incorporated will be responsible for the 

Pilot in Command (PIC) of a professionally built, camera-equipped DJI Inspire 1 and a DJI Phantom 3 Professional 

sUAS for the following applications: closed-set film operations for the motion picture, television and commercial 

productions, on-location film operations in controlled settings on private land or with property permission; 

augmentation of real-estate listing videos only with express permission of the property owner; and the creation of 

visual and topographical layout videos for state and local agency’s, educational organizations, agricultural 

inspections or building and construction zone inspections, provided that such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Granting exemption to ANR Production Services, Incorporated would permit the above specified operation of ultra 

lightweight sUASs in the NAS with limited, tightly controlled, predetermined flight plans away from the general 

public, airports, heliports, motorways or any restricted airspace. Granting a request for ANR Production Services, 

Incorporated complies with the Secretary of Transportation’s (FAA Administrator’s) instructions to integrate sUASs

into the national airspace system, as well as to “...establish requirements for the safe operation of such aircraft 

systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of 

UAS's for real estate/realtor purposes, educational videos, search and rescue, land/trusts inspections, agricultural 

field monitoring, film/video productions, closed-set motion picture film and television operation, and structure 

inspections, to aid private, state and local agencies. ANR Production Services, Incorporated will ensure enhanced 

public safety by conducting operations in compliance with the specific safety protocols and regulations established 

by the FAA. Additionally, seamlessly integrating sUASs into the NAS will increase community awareness to the 

benefits of the sUAS industry. Increased awareness and education will reveal the positive role the sUAS industry 

can play in local communities while increasing safety. 
2

2

I. Contact Information:

ANR Production Services, Incorporated

Attn: Amin Saidi

Phone: 415-559-8008

Email: amentowep@hotmail.com

Address: 4660 Misty Way

Oviedo, FL 32765

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which ANR Production 

Services, IncorporatedRequests Exemption are: 

14 C.F.R. 21;

 14 C.F.R. 45.23(b); 

14 C.F.R. 61.113 (a) & (b); 

14 C.F.R. 91.7 (a)

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

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

This exemption application is submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the 

Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace (NAS) before completion of the rule making required under Section 332 

of the Reform Act. In making this determination, the Secretary is required to determine which type of sUASs do not 

create a hazard to users of the NAS or the public or pose a threat to national security. If the Secretary determines that 

such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft inthe national airspace system.” Id. § 333 (c) (emphasis added). The Federal Aviation 

Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes 

exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUASs, from the requirement 

that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a 

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

title if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701 (f) See also 49 U.S.C. § 

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

III. The Extent of relief ANR Production Services, Incorporated Seeks and the Reason He Seeks Such Relief: 

This exemption application is submitted on behalf of ANR Production Services, Incorported in

accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent ANR Production Services, Incorporated, predetermined commercial cinematic, academic and 

other flight operations within the NAS. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. ANR Production 
3

3

Services, Incorporated will be operating, ultra lightweight sUASs that meet the definition of “small unmanned 

aircraft” as defined in Section 331 and, therefore the integration of such sUASs are expressly contemplated by the 

Reform Act. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized 

by the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. The sUAS to be operated hereunder is 55 lbs. or less fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator and under the requirements and in compliance with local public safety requirements, 

to provide security for the area of operation as is now done with conventional filming. The FAA will have advance 

notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection 

with motion picture and television production, provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by 

the sUAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: 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. Even though the sUAS will 

have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, 

cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, two-inch 

lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) 

where the pilot, observer, and others working with the sUAS will see the identification of the sUAS as 

“Experimental”. The FAA has issued the following exemptions to this regulation as Exemption Numbers 10700, 

8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Sections 61.113 (a) 

& (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the 

proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating 

the aircraft to have no less than 40 hours of flight time with the specific sUAS equipment ANR Production Services, 

Incorporated operates. The experience of the PIC will be certified by ANR Production Services, Incorporated 

through background checks and, if necessary, testing. ANR Production Services, Incorporated will maintain flight 

logs of all PICs it employs, and provide full transparency to the FAA regarding the logs and records of these PICs. 

The PIC designated for any operation will hold an FAA airman’s certificate and have at least a Class 2 medical 

certificate or valid Drivers License. The risks associated with the operation of the sUAS are so diminished from the 

level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations 
4

4

of the sUAS by a PIC meeting the standards of ANR Production Services, Incorporated (listed above) exceeds the 

present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b). Unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. Currently there are no pilot licenses that are 

specific for UAS operators, and no current FAA sanctioned pilot license of any type requires training with, and 

knowledge of, UAS equipment greater than the requirements ANR Production Services, Incorporated uses to certify 

its PICs. Therefore, the requirement of any available FAA sanctioned pilot license to operate a sUAS does not make 

a PIC a more competent operator than one meeting the requirements of ANR Production Services, Incorporated. Our 

company hopes the FAA develops a new Pilot License specific for UAS and sUAS commercial operation, one that 

sets high standards on the quality of pilots and increases the professionalism of our emerging industry. If the FAA 

does this, ANR Production Services, Incorporated’s PICs will file for these licenses. Our company would also be 

happy to work with the FAA to help develop the standards for new licenses, and any other regulations the FAA is 

developing for UAS operation. 

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil 

aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should 

this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of 

the aircraft for maintenance, and use of safety check lists prior to each flight (summaries listed below), an equivalent 

level of safety will be provided. 

Summarized Safety Checklists: 

Aircraft: All adjustment points will be checked for tightness; all motors and props will be inspected; all wiring will 

be double checked; all systems will be powered up and checked for errors. 

Battery: Confirmation will be made that batteries are fully charged and installed/connected properly. 

Calibration: Pre-flight motor/gyro calibration followed by confirmation of no errors with the flight and navigation 

systems. 

Compass Calibration: compass will be calibrated at each new location as per manufacturer’s protocols.

Transmitter: Confirm radio transmitter has sufficient charge, and is both working properly and receiving telemetry 

from the sUAS; confirm all switches are in pre-flight mode. 

Surroundings/Flight Area: Conduct one last visual inspection of the take-off surroundings and area of airspace sUAS 

will be operating in. Confirm all people in the surrounding areas are associated with the filming being done. 

Take-off Announcement: Before motors are started the PIC will announce to a designated Representative (person of 

authority) of the film crew that sUAS is ready to take-off. Only after the Representative has notified all persons 

within the surrounding areas, and confirmed to PIC that they have clearance to lift-off, will the motors be started and 

the sUAS will conduct its operation. 

Test Flight: A test flight will be conducted: after any disassembly/reassembly; after replacement of any motors or 

flight electronics; after any pre-flight or in flight equipment errors that occur not resulting from environmental 

conditions; very first thing of any commercial operations day before filming begins; if there are any concerns about 

environmental conditions and potential issues with the flight path. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person 

may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required 

by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size 

and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no 

pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where the PIC flying the sUAS 

will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.
5

5

14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in command to take certain actions before 

flight to ensure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. § 91.109: Flight instruction: Section 91.109 provides that no 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. 

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio communications. The 

FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and 

for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft, and by the size and speed of the 

aircraft. 

14 C.F.R. § 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

feet AGL, or not more than 200 feet above an elevated platform from which filming is planned, an exemption may 

be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 feet AGL 

with the exception that in circumstances where the sUAS is used to survey or photograph a structure whose height 

exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure. It 

will however be operated in a restricted area with security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. The equivalent level of safety will be achieved given the 

size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared 

to flight operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. proposed herein and the 

lack of flammable fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude operations 

of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft 

that must comply with Section 91.119. 

14 C.F.R. § 91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. 

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

individual from beginning “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.” The battery powering the sUAS provides no more than 30 minutes of powered flight. 14 C.F.R. § 91.151, 

sUAS flights would not be possible due to the reserve requirement being equal to the maximum flight time. Given 

the limitations on the sUASs proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an 

exemption from 14 C.F.R. § 91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing 
6

6

Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a 

tightly controlled area where only people and property owners or official representatives who have signed waivers 

will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151 (a) 

was intended to alleviate given the size and speed of the small UAS. Additionally, the limitations created by this 

requirement for sUAS flights would essentially make null any utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 18 minutes or 30% of 

battery power— whichever happens first. This restriction would be more than adequate to return the sUAS to its 

planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration The regulation provides in 

pertinent part: (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. The sUAS fully 

loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to 

carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have 

immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections These regulations require 

that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not 

apply to the applicant. Maintenance and inspections will be done in accordance with the sUAS Manufacturer's 

Manual, and will be performed by employees of ANR Production Services, Incorporated following the guidelines 

and practices provided to us by the sUAS Manufacturer. An equivalent level of safety will be achieved because 

these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for 

limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no 

higher than 400 feet AGL. The PIC will ensure that the sUAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the PIC is the person most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. Additional Views and Information: ANR Production Services, Incorporated has realized the amazing 

benefits sUAS equipment can provide to the film and television industries. It not only provides new cinematography 

capabilities, but also increased safety over current and past practices that used larger and more dangerous 

equipment. Our company wants to have the highest levels of safety and professionalism, and one thing essential to 

this is achieving a path to commercial licensing with the FAA. We believe this will help reduce unsafe practices, 

discourage improper uses, and improve public perception. The commercial manufacture and use of sUAS equipment 

will create more jobs for the United States and help boost the economies in many sectors, and we want to help the 

FAA in creating regulations that will allow incorporation of UAS devices into our country's airspace for commercial 

use.

IV. Reasons Why ANR Production Services, Incorporated Exemption Will Not Adversely Affect Safety Or 

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:
7

7

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and 

that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher 

level of safety to operations under the current regulatory structure because the proposed operations are conducted in 

limited areas with predetermined flight paths under the permission of the property owner or property representative. 

These limitations and conditions to which ANR Production Services, Incorporated agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh no more than 55 lbs. 

2. Flights will be operated within line of sight (VLOS) of the pilot in command (PIC) or visual observer (VO). 

3. Maximum total flight time for each operational flight will be 18 minutes or at 30% battery power reserve should 

that occur prior to the 18 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated 

platform from which filming is planned. If a structure being filmed or photographed has a height which exceeds 400 

feet AGL, the UAS will not exceed 100 feet in height above the highest point on that structure. 

5. Minimum crew for each operation will consist of the sUAS PIC, and the Visual Observer.

6. sUAS Pilot will be Pilot in Command (PIC). The PIC hold an FAA airman certificate and will have a minimum of 

40 hours of flight time with the specific sUAS equipment ANR Production Services, Incorporated operates. The 

experience of the PIC will be certified by ANR Production Services, Incorporated through background checks and, 

if necessary, testing. The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: 

PAR or PRH). ANR Production Services, Incorporated will maintain flight logs of all PICs it employs, and provide 

full transparency to the FAA regarding the logs and records of these PICs. 

7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, vehicles, 

vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation. 

8. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s production activities. It 

will be mandatory that all personnel involved with the operational duties of the flight within the boundaries of the 

safety perimeter be present for this briefing. 

9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with 

the appropriate local Flight Standards District Office. 

10. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting 

persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon 

an equivalent level of safety determination. With the advanced permission of the relevant FSDO, operations at 

closer range can be approved. 

11. PIC and Visual Observer will have been trained in the operation of the specific sUAS equipment used by ANR 

Production Services, Incorporated, and received up-to-date information on the particular sUAS to be operated. 

12. The PIC designated for any operation will have at least a Class 2 medical certificate or valid Drivers License. 

13. Visual Observer and PIC will at all times be able to communicate by voice, or radio. 

14. Written and/or oral permission from the relevant property holders or property representatives will be obtained. 

15. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire or other appropriate government agencies. 

16. If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS will have the capability to 

return to a pre-determined location within the Security Perimeter and land autonomously. 

17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of 

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of the rule making required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which 

types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of 

the following: 

• The UAS’s size, weight, speed, and operational capability; 
8

8

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 If the Secretary determines that such vehicles “may operate safely in the national airspace system, 

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

§ 333 (c) The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes 

sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator 

may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or 

any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. § 

44701 (f) See also 49 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1). ANR Production Services, 

Incorporated sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal 

conditions at a speed of no more than 40 knots and have the capability to hover, and move in the vertical and 

horizontal plane simultaneously. They will operate only in line of sight and will operate only within a predetermined 

and closed off property area under the permission of the property representative. Such operations will ensure that the 

sUAs will “not create a hazard to users of the national airspace system or the public” as per the Reform Act Section 

333 (b). Given the small size of the sUASs involved and the restricted sterile environment within which they will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. 

Also due to the size of the sUASs and the restricted areas in which the relevant sUASs will operate, approval of the 

application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for movie and commercial videography 

operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay.

V. How granting ANR Production Services, Incorporated Exemption will Benefit Public as a Whole

The economic potential of the rapidly developing UAS industry is extraordinary. Technological advancements have 

created devices that were unthinkable as early as 5 years ago. Unfortunately this developing science has put 

advanced technology into the hands of untrained individuals. Further development of the sUAS industry is 

dependent upon safe integration into the NAS. It is imperative that responsible operators lead by example in this 

developing industry in order to maintain the safest national airspace system in the world. When operated 

responsibly, unmanned aircraft systems pose significantly less threat to persons and property than traditional 

manned aircraft due to their size and lack of combustible material onboard. Congress has already proclaimed that it 

is in the public’s best interest to integrate commercially flown sUASs into the NAS. The film and television industry 

is an ideal application of sUAS technology. sUASs are ideal in this industry in that they create less environmentally 

damaging emissions, are less disruptive locally and pose significantly less threat to persons and propery than 

traditional aircraft. Granting exemption to ANR Production Services, Incorporated will ensure more qualified, 

responsible UAS operation in the NAS and can enhance the economic impact of the developing sUAS and ancillary 

industries as a whole.

********* 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: Applicant seeks an exemption from the following rules: 

14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 

91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 
9

9

91.417 (a) & (b) to operate commercially a small unmanned vehicle (50 lbs or less) in motion picture, television, 

and commercial operations. Specifically, ANR Production Services, Incorporated is seeking 333 exemption for 

closed-set film operations for film and television productions, on-location film or television operations on private 

land or with property permission; aerial video support for films and commercials in controlled environments; 

augmentation of real-estate listing videos; and the creation of visual and topographical layout videos for state and 

local agencies, educational organizations, agricultural inspections or building and construction zone inspections. The 

sUASs will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights. The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than 

conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. 

All flights will occur over private or controlled access property with the property representative or owner’s prior 

consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have 

agreed to be in the area where filming will take place. All flights will occur in accordance with any state or local 

laws regarding privacy. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and 

national security – provide more than adequate justification for the grant of the requested exemptions allowing 

commercial operation of applicant’s sUAS equipment in the motion picture, television, and commercial production 

industry.**********

Traditionally, aerial filming for the television and film industries has relied primarily on the use of traditional 

aircraft. These larger combustible-fueled aircraft pose significant risk to the crew, passengers and the public in 

general due to their inherent dangers and the proximity of use to participants. Small unmanned aircraft are ideal for 

the television and film industries because of the same reasons they do not pose significant threat to the public. UASs 

do not carry combustible fuel, they have a lighter impact on the environment, are less disruptive, smaller, more 

maneuverable and safer than conventional video and photographic aircraft. When operated responsibly, a sUAS 

utilizes lower altitudes within visual line of sight of the PIC in a predetermined airspace. These protocols further 

reduce the risk of personal injury or property damage. Since sUASs are unmanned, risk to pilots and crew are 

practically impossible. In many ways sUASs are ideal for the film and television industries and they will be 

responsible for enhancing production value in unexpected ways. As this technology becomes more ubiquitous sUAS 

operation needs to be regulated effectively. The rapid development of sUAS technology has made the need for 

effective legislation more pertinent. The sUAS industry needs qualified, responsible operators to lead by example to 

help ensure safe integration into the NAS. Granting a 333 exemption for ANR Production Services, Incorporated 

will reduce the reliance on traditional large aircraft for aerial video work and guarantee safe integration of additional 

sUASs into the NAS, further reducing risk and enhancing public safety.

Respectfully submitted, 

ANR Production Services, Incorporated 

Attn: Amin Saidi

Address:4660 Misty Way 

Ovideo Florida

32765

phone: 415.559.8006

email: amentowep@hotmail.com
10

10

Appendix A – List of Unmanned Aircraft Systems UAS

Make & Model Description Serial # Registration # N-# Weight

DJI Inspire 1 4 rotor electric pending N-333PV requested 7 lbs

 Unmanned aircraft

 System UAS

DJI Phantom 3 4 rotor electric pending N-444PV requested 4 lbs

 Unmanned aircraft 

 System UAS

Operating Frequencies: Transmitter: 2.400 ~ 2.483 GHz

Video Feed: 5.725 ~ 5.825 GHz

1. DJI INSPIRE 1 - The operation of the DJI INSPIRE 1 system is as follows.

1. Build Materials - Carbon Fiber, Aluminum, Plastic & internal electrics

2. Motor Configuration - The DJI INSPIRE 1 has a quadcopter configuration

3. Payload - The DJI INSPIRE 1 flies it’s own light-weight integrated camera. Total weight- 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, and/or chips. 

Replace if propeller is questionable. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller.

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.

2. DJI Phantom 3 - The operation of the DJI Phantom 3 system is as follows.

1. Build Materials - Plastic, Aluminum and internal electrics.

2. Motor Configuration - The Phantom 3 has a quadcopter configuration.

3. Payload - The Phantom 3 it’s own integrated camera. Total Weight- 4lbs

4. Maintaining the Phantom 3

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, and/or chips. 

Replace if propeller is questionable. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.
11

11

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.

Appendix B - Personal Protocols/Controls/Flight Manual Protocols and Controls 

Refer to the separate ANR Production Services, Incorporated Motion Picture and Television 

Flight Operations Manual for all field safety protocols.

Appendix C UAS Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and illustrated parts 

catalogs. These manuals may be attached to the docket when submitted. Information regarding design, aircraft 

performance, fail-safe features, operating limitations, normal and emergency procedures, and maintenance and 

inspection procedures is contained within the manuals and supplemental information documents listed below:

1. DJI Inspire 1 Manual V1.0

2. Inspire 1 Maintenance Manual v1.0

3. Intelligent Flight Battery Safety Guidelines v1.4

4. Inspire 1 Safety Guidelines

5. Phantom 3 Professional Manual V1.0

6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)

For more information or questions about these documents please contact:

Amin Saidi 

ANR Production Services,

4660 Misty Way

Oviedo, FL 32765

415-559-8006