September 1, 2015

Antonio L. Manning, BA, RP, GMP M & A Phantom Events & Productions 3028 Rochester │ Detroit, Michigan 48206 (517)

- 512

- 1624 (Personal) │ (517)

- 881

- 6380 (Office) antoniomanning@live.com

United States Department of Transportation
- Federal Aviation Administration (FAA) Docket Management System 1200 New Jersey Avenue, Southeast Washington, District of Columbia 20590
Subject: Exemption Request
- Section 333 of the Federal Aviation Administration

Reform Act of 2012

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in

the matter of the petition of DOUGLAS TRUDEAU 2) FAA Exemption No. 11136, Regulatory Docket No. FAA

– 2014

– 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. 11080, Regulatory Docket No. FAA

- 2014

- 0355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam , In accordance with the FAA’s Guidelines for Subm itting a Petition for Exemption under
section 333 of the FAA Moderniza tion and Reform Act of 2012, I Antonio Lavon Manning,
referred to here in after as the “ P etitioner ” , request exemption from the following sect ions of Title 14, Code of Federal Regulations §§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 ; (a)(1); 91.409(a)(2); 91.417(a) & (b).Page 2 of 8

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Avi ation Administration ( F AA) for the purposes of aerial photography,
cinemat ography, videography, mapping, c rop surveying, inspections and other flight operations
tha t could be performed safely and more cost effectively with the use of small UAS at l ow altitude within the U.S. natio n al airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the aut horizatio n and p ermission of clients or
their authorize d agents in order to facilitate c ommerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such ope rations are conducted within and under the
conditions outlined here in or as may be est ablished by the FAA as required by Section 333. The
conditions identified and proposed by the petitioner are drawn from references 1

- 3. 

### The FARs
The petitioner seeks exemption from the above mentioned FARs for the following

reasons; 61.113(a) & (b); The petitioner requests re l ief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or g r eater) certificate. Any pilots operating under this exemption would be required to co m ply with any conditions as set forth and in a similar fas hion
to the previously granted exemptions. 91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations
conducted closer than 500 feet to the gr o und may require that the UA be operated closer than
500 f eet to essential persons, or objects that w ould not be possible without additional rel ief. The petitioner requests modifi c ation, waiver or exemption and clar ification concerning the terms “congested area s ” and “densely populated”. The petitioner request s waiver for this condition toPage 3 of 8

allow reasonable and responsible operations in areas of sub divisions and neighborhoods if required.
91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since
the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor
for altitude information. 91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relie f has been granted for man n ed aircraft to operate at less than the prescribed

m inim ums, including Exemption Nos. 2689,5745, and 10650. In addition, similar UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS prov i des battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information prov ided in the operating
documents discusses procedures regarding remaining battery power management. Those
documen ts contain a condition in which the PIC will initiate a landing pr oced ure when battery remaining reaches a specified level. Given the limitat ions on proposed operations and the location of those prop osed operations, The FAA fo und that a reduced minimum powe r reserve for flight in daytime VFR conditions was reasonable.
91 .405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in
Exem ption 11138 (DOUGLAS TRUDEAU), t he pet itioner proposes to inspect and ensure that
the UAS is i n a condition for safe flight i n accordance with the operating documents. The FAA
foun d that adherence to the petitioner’s operating documents and the conditions and limitations specified, describing th e requirements for maintenance, inspe ction, and recordkeeping, were
sufficient to e nsure that safety would not be adversely affected. 

### Th e UASPage 4 of 8

The DJI Phantom 3 Professional 4K is by the DJI Corporation. DJI manufactures a range of products including flying cameras (ex. Inspire and Phantom series), flying platforms, flight controllers for multi rotors, accessories for helicopters, camera g imbals (aerial, handheld) and ground stations. These products are for industrial, professional and amateur use. DJI makes professional and amateur flight controllers intended for multi

- rotor stabilization control of various platforms or heavy payloads in aerial photography. In addition to the main A2 main controller model (intelligent orientation, landing, home return), there are the IMU (damper module), the GPS

- Compass Pro Plus (high end antenna, satellite receiver), the PMU (voltage alarm) and the LED bl uetooth indicator (smartphone connectivity).
The Phantom Series has evolved into an integrated flying system with aircraft, camera,
Wi

- Fi connectivity, a controller and the pil ot’s mobile device. These quadcopters are mainly intended for aerial cinematography and photography applica tions. The Phantom 2 Vision+ features a camera and a gimbal system manufactured by DJI. It is capable of taking 14 Megapixel still shots and recording hig h definition (1080p) video. In comparison, the DJI Phantom 3 Professional, the latest Phantom model to be released can shoot 4K resolution video
and ta ke 12MegaPixel still photos. Details regarding the height, weight, and composition of the craft are outline in the graph belo w.

Model Phantom

1 Phantom

2 Phantom 2 Vision Phantom

2 Vision+ Phantom

FC40 Phantom 3 Professional Phantom 3

AdvancedPage 5 of 8

Diagonal wheelbase (cm) 0.35 0.35 0.35 0.35 0.35

— — Height (m) 0.19 0.19 0.19 0.19 0.19

— — Power consumption (W) 3.12

— — — 3.12

— —

Take

- off weight (kg) < 1 < 1.3 1.18 1.284 < 1.2

— — Max speed (m/s) 10 15 15 15 10 16 16
Endurance (min) — 25 25 25 10 23 23
Rate of climb/descend (m/s) 6 6/2 6/2 6/2 6 5/3 5/3
Operating temperature (°C) - 10 to 50

- 10 to 50

— — - 10 to 50 0 to 40 0 to 40Page 6 of 8

* Source: DJI Corporation



### Risk M itigation
The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions and Limitations
section a nd believes that the procedures s p ecified therein are reasonable and will be utilized in
order to manage and mitigate r i sk and ensure public safety. A prefl ight checklist will be developed and employed to e n sure that the UA airworthiness w ill be verified before launch.
Airworthiness will b e maintained by performance of routine i nspections before each flight, maintaining flight and maintenance logs to record ti me on failure

- prone components. The petitioner req uest that in a manner similar t o reference 3, he be allowed to operate
within 5 miles of an airport provided that; “The UA may not operate in Cl ass B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non

towered airport 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 operator’s COA. The lette r of agreement with the airport managemen t must be made available to the Administrator upon request.” Operations within 5 miles of an airport are not anticipated t o be routine but the petitioner
is requesting a mechanism to fac ilitate such activities without requesting a new and separate exemption(s) should the need arise. Operati o ns within class B airspa ce are not requested due t o the lack of mode C transponder.
Public interest
Use of the UAS in lieu of a manned aircraft woul d enhance safety and reduce the

e nvironmental impact as compared to similar operations co nducted with manned airc raft of greater pro portions, ca rrying a crew and flammable fue l . Additionally, use of the UAS in order toPage 7 of 8

facilitate commerce could lead to econo mic growth. Operations for this petition will enable

serv ice for property owners or thei r designees seek ing an enhanced perspectiv e for
characte ristics, amenities, and benefit s of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and
enha nce personal photography. Crop surveying appli c ations could lead to decreased use of pesticides a nd fertilizer and conservation of w ater as well as increased crop y ields and decreased costs. Aerial surveying and ins pections can increase work site efficiency, i mprove volume tric
estimations and reduce ris ks. The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observe r will be

u tiliz ed

. Flight data including UA flight tim e, Control Unit operation time , incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use of U AS as part of thi s application. This data may be submitted
to F AA via traditional means, e.g. COA M onthly Reports, or other means as required.
Conclusion The petitioner is requesting this exempt ion for the purposes of “aerial photography,
cinemat ography, videography, mapping, c rop surveying, inspections and other flight operations”.
The reason for such a general a nd broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time
associa ted with additional exemptions

. The petitioner's business model is based on the id ea of offering ad hoc small UAS services to individuals or comp anies who wish to emplo y these services as a safe,Page 8 of 8

effec tive, and legal o ption to enhance their business or hobby. The petitioner’s

own market research shows pent up demand for these servic es currently exists in the real

estate market and ot her markets are just beginning to em erge. The petitioner has identified universities and other ag encies that could benefit from the operation requested in this application. A quick internet search will show that many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA aut horization. The petitioner has refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to ob tain the capability to offer th o se services while remaining in compliance. The petitioner has over 5 years’ experience in event management, logistics, and security operations. Additionally, the petitioner has taken over 15 classes through independent study with the Federal Emergency Management Agency (FEMA) within the United States Department of Homeland Security (DHS). The petitioner is very familiar with the safety protocols and fully intends to work with and cooperated with law enforcement and government agencies at the local, state, and federal level to ensure safety and privacy concerns when operati ng this device.
Thank

- you for your time, consideration, and prompt attention of this application.

Respectfully submitted,

Antonio Lavon Manning, BA, RP, GMP, CTA Senior Consultant & Co

- Owner M & A Phantom Events and Productions, LLC
Director

- Marke ting, Public & Governmental Relations and Corporate Compliance Manning, Hatchett, & Associates Consulting Group, LLC