UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERALAVIATION

ADMINISTRATION WASHINGTON, DC

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

Part 11, Stephen Roy Mann, owner and operator of MannMade Digital Video, requests to be exempted 

from the Federal Aviation Regulations (FARs) listed below, so that Stephen Roy Mann may operate small 

UAS commercially in airspace regulated by the FAA, as long as such operations are conducted within and 

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

Submitted on August 6, 2015

Stephen Roy Mann

DBA MannMade Digital Video

12 April Lane

Westford, MA 01886
NAME	AND	ADDRESS	OF	THE	PETITIONER

The name and address of the Petitioner and point of contact is:

Stephen Roy Mann

DBA MannMade Digital Video

12 April Lane

Westford, MA 01886

Email: steve@mmdv.com

INTRODUCTION AND INTERESTS OF THE PETITIONER

The petitioner, Stephen Roy Mann has over 20 years of experience in Photographic and Video 

Technology. He has over 4 years recreational and hobby experience in all aspects of sUAS operations and 

is very familiar with the safety requirements for piloting a small UAS and can perform all the required 

maneuvers safely. All operations will be performed with the public’s safety and right to privacy

safeguarded at all times.

Further, Stephen Roy Mann holds an FAA-issued Commercial Pilot Certificate with IFR rating and a 

Certified Flight Instructor certificate. 

The objective of Stephen Roy Mann's aerial video and Photography operations is to provide high quality 

imaging for a variety of commercial, public, and residential uses, primarily targeting:

Construction sites before, after and during

Appraisals

Real-estate marketing

Aerial acquisitions used for inspections of public and private structures.

Search and Rescue operations

Cinematic photography.

As described below, the requested exemption would permit the operation of light weight (less than 55 lbs. 

total takeoff weight) small UAS under controlled conditions for commercial use by the PIC. All flights 

will be conducted in daylight keeping the PIC in direct line of sight (VLOS) of the small UAS at all times 

thereby enhancing safety.
BACKGROUND

Stephen Roy Mann seeks an exemption to operate sUAS systems manufactured by DJI of Shenzhen, 

China for compensation or hire within the NAS. The DJI Phantom series of aircraft are vertical take off 

and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing a 2.4 GHz 

Remote Control system. The Phantom series has a maximum gross weight of less than 10 pounds 

including the GoPro Hero4 camera and Zenmuse H3-3D gimbal, and a maximum airspeed of 

approximately 33 knots. Appendix A exhibits the DJI Phantom aircraft specifications typical of the model 

planned for use under this exemption.

The DJI Phantom series of aircraft has four plastic rotors; powered by sealed Lithium Polymer batteries to 

power the electric motors and on-board electronics

The DJI Phantom UAS that will be operated by Stephen Roy Mann will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked 

in accordance with 14 CFR Part 45, Identification and Registration Marking. Markings will be as large as 

practicable per §45.29(f).3

THE	SPECIFIC	SECTIONS	OF	14	CFR

FROM	WHICH	STEPHEN	ROY	MANN	SEEKS AN	EXEMPTION

Petitioner, Stephen Roy Mann, pursuant to the provisions of the Federal Aviation Regulations

(14 CFR §11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate 

the DJI Phantom series of UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 CFR §§

21(H) Airworthiness Certificates,

91.203(a) and (b) Civil aircraft: Certifications required,

91.405(a) Maintenance required,

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration,

91.409(a)(1) and (a)(2) Inspections,

91.417(a) and (b) Maintenance Records,

61.23(a) and (c), Medical certificates: Requirement and duration,

61.101(e)(4), Recreational pilot privileges and limitations,

61.113(a) and (b), Private pilot privileges and limitations: Pilot in command,

61.133(a), Commercial pilot privileges and limitations. Privileges,

61.315(a), What are the privileges and limits of my sport pilot certificate?,

91.7(a) Civil aircraft airworthiness,

91.119(c), Minimum safe altitudes: Over other than congested areas,

91.121, Altimeter Settings,

and 91.151(b) Fuel requirements for flight in VFR conditions.
The	extent	of	relief	Stephen	Roy	Mann	seeks	and

the	reason	Stephen	Roy	Mann	seeks	the	relief	

14 CFR Part 21(H)

In accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 USC § 

44704, and in consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Stephen Roy Mann's operation of DJI Phantom series of UAS meets 

the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 CFR Part 21, Subpart H.

14 CFR §91.203(a) and (b); §91.405 (a); §91.407(a)(1); §91.409 (a) (1); §91.409 (a) (2); §91.417 (a) & 

(b)

Accordingly, Stephen Roy Mann requests relief from Sections 91.203(a) and (b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that

only apply to aircraft with an airworthiness certificate.

Stephen Roy Mann submits that the requested relief is proper since an equivalent level of safety will be 

ensured. Stephen Roy Mann will use experienced personnel or technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the DJI Phantom series of Instruction Manual). Furthermore,

Stephen Roy Mann will document and maintain all maintenance records for the DJI Phantom series of

UAS operated under this requested exemption.

14 CFR §61.23(a) and (c)

Stephen Roy Mann requests relief from Sections 61.23(a) and (c) to allow any operator that holds an 

FAA-issued pilot’s certificate to operate a UAS under this exemption with a U.S. issued driver’s license, 

in lieu of an FAA-issued medical certificate. Relief from §61.23(c) is requested allow sport pilot 

certificate holders to operate a UAS with a U.S. issued driver’s license under this exemption.

14 CFR §61.101(e)(4); §61.113 (a) & (b); §61.133 (a); §61.315 (a)

Relief from certain requirements of Section 61.101(e)(4), entitled Recreational pilot privileges and 

limitations, Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, 

Section 61.133(a), entitled Commercial pilot privileges and limitations. Privileges and Section 61.315(a), 

entitled What are the privileges and limits of my sport pilot certificate? is requested by Stephen Roy Mann 

to the extent necessary to allow a Pilot in Command (PIC) holding a Recreational, Sport Pilot or higher 

level certificate, and who has demonstrated that the PIC is able to safely operate the DJI Phantom series of

UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.
14 CFR §91.7 (a)

Stephen Roy Mann seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom series of UAS do not require an airworthiness certificate in accordance with 14 CFR Part 21, 

Subpart H. As such, Stephen Roy Mann submits that he will ensure that the DJI Phantom series of UAS

are in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with 

the operating documents (i.e., DJI Phantom series of Instruction Manual- See Appendix B), and that the 

aircraft are in a condition for safe flight.

14 CFR 91.119 (c)

Stephen Roy Mann seeks an exemption from the requirements of Section 91.119 (c), entitled Minimum safe 

altitudes: Over other than congested areas. As Stephen Roy Mann will only operate small UAS at or 

below 400 AGL. They will be operated over a predefined space that has been previously reviewed for 

any hazards. Onsite visits will be conducted to verify no dangers to the craft, PIC or the public exist. 

Permission will be obtained from the site occupants before flying a UAS in the predefined space. 

Compared to flight operations of conventional and traditional aircraft or rotorcraft operating below 500

AGL with flammable fuel, small UAS operations present a far smaller risk to the public and therefore an 

equivalent level of safety.

14 CFR §91.121

Stephen Roy Mann also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom series of UAS do not have a typical barometric pressure altimeter on board 

but utilizes a barometric pressure sensor that provides altitude information that will be provided to the 

PIC via a radio communications telemetry data link to the GCS for active monitoring of the flight path 

and altitude above the takeoff point. The DJI Phantom series of UAS altimeter is be set on the ground 

before each flight to zero feet AGL rather than the local barometric pressure or field altitude. This altitude 

information, combined with Stephen Roy Mann's operation of the DJI Phantom series of UAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

14 CFR §91.151 (b)

Additionally, Stephen Roy Mann seeks an exemption from the requirements of Section 91.151(b), entitled

Fuel requirements for flight in VFR conditions. Stephen Roy Mann submits that safety will not be affected 

by operation of the DJI Phantom series of UAS during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery capacity to fly for a total duration of 

approximately 15 minutes for the intended typical photo mission and, assuming normal cruising speed, to 

fly after that for at least 2.5 minutes for recovery and landing. The DJI Phantom series of UAS will be 

programmed to automatically return to the launch point when the battery reaches 30% capacity, and to 

land in place if the battery capacity reached 25%.
THE	REASONS WHY	GRANTING	STEPHEN	ROY	MANN’S REQUEST WOULD

BE	IN THE	INTEREST TO	THE	PUBLICAS AWHOLE.

Granting the present Petition will further the public interest by allowing Stephen Roy Mann to safely, 

efficiently, and economically perform professional low altitude aerial video and photography over certain 

areas of the United States.

The Public Will Benefit From Decreased Congestion Of The NAS.

Conducting aerial acquisitions with the DJI Phantom series of UAS instead of manned aircraft will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional

aerial video and photography flight operations. By using battery power and electric motors, the DJI

Phantom series of UAS produce no air pollution, and is the environmentally conscious alternative to the 

internal combustion engine aircraft that are typically utilized for aerial video and photography while 

burning leaded aviation fuel. The DJI Phantom series of UAS, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UA's are propelled by battery powered electric 

motors, rather than an internal combustion engine.

The risk to life and property in the air and on the ground associated with traditional manned aircraft flight

operations, will be completely eliminated because there is no flight crew on board, the light weight of the 

DJI Phantom series of UAS and with no combustible fuel on board there is significantly less potential for 

collateral damage to life or property on the ground, and in the air

Performing aerial video and photography operations with the DJI phantom series of UAS will 

benefit the economy.

In addition to being safe and efficient, the DJI Phantom series of UAS are also an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom series 

of UAS will allow United States based companies, like Stephen Roy Mann's to remain competitive and 

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to remain competitive. 

Operating the battery powered DJI Phantom series of UAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such flexibility 

without the high operational cost of a traditional manned aircraft.

There are no privacy issues

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Stephen 

Roy Mann's proposed operation of the DJI Phantom series of UAS will not implicate any privacy issues. 

Specifically, the DJI Phantom series of UAS will be operated only in compliance with an Aerial

Operations Manual developed by Stephen Roy Mann which requires property owner involvement, and in 

accordance with the Federal Aviation Regulations, including the altitude requirements of 

14 CFR §91.119(d) Minimum Safe Altitudes.
The	Reasons Why	Granting The	Exemption Would	Not AdverselyAffect	Safety;

How The	Exemption Would	ProvideA Level Of	SafetyAt	Least	Equal To

That	Provided	By The	Rules From Which	Stephen	Roy	Mann Seeks	Exemption.

The DJI Phantom series of UAS meet the conditions of the FAA modernization and reform act of 2012 

(FMRA) Section 333 which provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, Stephen Roy Mann's operation of the DJI Phantom series of UAS meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 

14 CFR § 21(H).

The specifications of the DJI phantom series of UAS demonstrate its safe characteristics.

The DJI Phantom series of UAS do not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering its size, weight, speed, and operational capability. The 

technical specifications of the DJI Phantom series of UAS are attached as Exhibit A.

The DJI phantom series of UAS can incorporate autonomous flight and navigation modes to constrain the 

UAS to remain within a defined operational area.

The DJI phantom series of UAS are designed for automatic return to launch point in the event of loss of the 

control link or navigation. When the Control Link is lost for three seconds, the DJI Phantom series of UAS 

will assume that the Control Link is lost and the UAS will ascend to the pre-programmed return altitude 

then return to the launch position via GPS, then descend to the takeoff position and shut down.

A complete description of the Failsafe Functions of the DJI Phantom series of UAS are described in pages 

22 through 28 of the DJI Phantom 2 User Manual. Significant text is attached as Appendix C.

The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR

§21.16 entitled Special Conditions, Stephen Roy Mann requests that the FAA prescribe special conditions 

for the intended operation of the DJI Phantom series of UAS, which contain such safety standards that the 

administrator finds necessary to establish a level of safety equivalent to the rules that Stephen Roy Mann 

seeks exemption. Such special conditions will permit safe operation of the UA's for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for compensation or hire. 
A Summary That	Can	Be Published	In The	Federal Register stating:

The	Rules	From Which	Stephen	Roy	Mann Seeks	Exemption:

Stephen Roy Mann seeks exemption from the requirements of 14 CFR Part 21(H), 91.203(a) & (b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b), 61.23(a) & (c), 61.101(e)(4), 61.113(a) & 

(b), 61.133(a), 61.315(a), 91.7(a), 91.119(c), 91.121, and 91.151(b)

A Brief Description Of The Nature Of The Exemption Stephen Roy Mann Seeks:

This exemption will permit Stephen Roy Mann to commercially and safely operate an Unmanned Aircraft

System (UAS) for the purpose of conducting aerial video and photography over certain areas of the 

United States.

CONCLUSION

As discussed in detail above, Stephen Roy Mann will operate the DJI Phantom series of UAS safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national

security. Therefore, Stephen Roy Mann seeks an exemption pursuant to 14 CFR §11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI

Phantom series of UAS commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial video and photography over certain areas of the United States. By granting this Petition, 

the FAAAdministrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Stephen Roy Mann to 

safely, efficiently, and economically operate the DJI Phantom series of UAS commercially within the 

NAS.

Dated: August 10, 2015

Respectfully submitted,

Stephen Roy Mann
APPENDICES:

A – Phantom Series UAS General Specifications

B – Phantom Series UAS operating Manuals

C – Failsafe and Autonomous Safety Features of the DJI Phantom series of UAS
APPENDIX A- Phantom Series UAS General Specifications

Specifications of the typical UAS that will be used with this exemption:

General Features Multifunctional Quad-rotor System

H3-3D Gimbal Support

25min Flight Time & Smart Battery

Auto Return-to-Home & Landing

Advanced Power Management

Intelligent Orientation Control (IOC)

Self-tightening Propeller

Video Downlink Support

CAN-Bus Expansion Module

Aircraft Weight (Battery & Propellers Included) 1000g

Hover Accuracy Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

Max Flight Speed 15m/s, 33MPH

Diagonal Length 350mm

Flight Time 25mins

Take-Off Weight ≤1350g

Operating Temperature -10°C ~ 50°C

Supported Battery DJI Smart Battery

DJI Smart Battery Type 3S LiPo

Capacity 5200mAh, 11.1V

Charging Environment Range 0°C to 40°C

Discharging Environment Range -20°C to 50°C

2.4GHz Remote Control Operating Frequency 2.4GHz ISM

Communication Distance (Open Area) 1000m

Receiver Sensitivity (1%PER) -97dBm

Working Current/Voltage 120 mA@3.7V

Battery Working Current/Capacity 3.7V, 2000mAh
APPENDIX B – Phantom Series UAS operating Manuals

Types of aircraft to be flown:

DJI Phantom Series

• Technical manuals are all currently available online at the following URLs:

 Phantom 1: http://www.dji.com/product/phantom/download

 Phantom 2: http://www.dji.com/product/phantom-2/download

 Phantom 2Vision+ : http://www.dji.com/product/phantom-2-vision-plus/download

 Phantom 3 : http://www.dji.com/product/phantom-3/download
APPENDIX C – Failsafe and Autonomous Safety Features of the DJI Phantom series of UAS

Source: http://download.dji-innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

6.4 Failsafe Function

The aircraft will enter Failsafe mode when the connection from the remote controller is lost. The flight 

control system will automatically control the aircraft to return to home and land to reduce injuries or 

damage. The following situations would make the aircraft fail to receive a signal from the remote 

controller and enter Failsafe mode:

(1) The remote controller is powered off.

(2) The remote controller is powered on but the S1 is toggled in the position triggering the Failsafe (this 

must have been configured in the PHANTOM 2 Assistant Software).

(3) The aircraft has flown out of the effective communication range of the remote controller.

(4) There is an obstacle obstructing the signal between the remote controller and the aircraft, essentially

reducing the distance the signal can travel.

(5) There is interference causing a signal problem with the remote controller.

In a Failsafe situation, if less than 6 GPS satellites are found for more than 20 seconds, the aircraft will 

descend automatically.

6.5 Low Battery Capacity Warning Function

The low battery capacity warning alerts users when the battery is close to depletion during flight. When it 

appears, users should promptly fly back and land to avoid accidental damage. The PHANTOM 2 has two 

levels of low battery capacity warning. The first appears when the battery has less than 30% power and 

the second appears when it has less than 15% power.

(1) When battery power drops below 30% and LED indicator will blink red slowly.

(2) At lower than 15% the LED indicator will blink red rapidly, the PHANTOM 2 will also begin to 

descend and land automatically. After it has landed, keep the throttle stick at its lowest point or execute 

CSC.

(3) There is a hidden third low battery threshold in addition to the 1st and 2nd level warnings. This uses 

10.65V as its threshold. Both this voltage threshold and the 2nd Level Low Battery Warning will trigger 

auto-landing.
6.6 Flight Limits Function

All UAV (unmanned aerial vehicle) operators should abide by all regulations from such organizations at 

ICAO (International Civil Aviation Organization) and per country airspace regulations. For safety 

reasons, the flight limits function is enabled by default to help users use this product safely and legally. 

The flight limits function includes height, distance limits.

In Ready to Fly status, height, distance limits works together to restrict the flight. In Ready to Fly (nonGPS) status, only height limit works and the flying height restricted to be not over 120m.

(1) The default parameters in the Assistant Software is compliant within the definitions of class G ruled 

by ICAO. (Refer to Airspace Classification to get more details). As each country has its own rules, make 

sure to configure the parameters to comply with these rules too, before using the PHANTOM 2.

Max Height & Radius Limits

The Max Height & Radius restricts the flying height and distance. Configuration can be done in the 

PHANTOM 2 Assistant. Once complete, your aircraft will fly in a restricted cylinder.
6.7 Flight Limits of Special Areas

Special areas include airports worldwide. All special areas are listed on the DJI official website. Please 

refer to http://www.dji.com/fly-safe/category-mcfor details. These areas have been divided into category

A and category B.