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 Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I Antonio Lavon Manning, 

referred to hereinafter as the “Petitioner”, request exemption from the following sections 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).

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In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations 

that could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations 

will be performed only at the request of and with the authorization and permission of clients or 

their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses

of small unmanned air systems. So long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 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 relief in order to facilitate the utilization of 

pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this 

exemption would be required to comply with any conditions as set forth and in a similar fashion 

to the previously granted exemptions.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated closer than 

500 feet to essential persons, or objects that would not be possible without additional relief. The 

petitioner requests modification, waiver or exemption and clarification concerning the terms 

“congested areas” and “densely populated”. The petitioner requests waiver for this condition to 

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allow reasonable and responsible operations in areas of subdivisions 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 relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, 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 provides battery power remaining in percent to the PIC. The UA batteries 

provide approximately 25 minutes of powered flight. Information provided in the operating 

documents discusses procedures regarding remaining battery power management. Those 

documents contain a condition in which the PIC will initiate a landing procedure when battery 

remaining reaches a specified level. Given the limitations on proposed operations and the 

location of those proposed operations, The FAA found that a reduced minimum power 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

Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that 

the UAS is in a condition for safe flight in accordance with the operating documents. The FAA 

found that adherence to the petitioner’s operating documents and the conditions and limitations 

specified, describing the requirements for maintenance, inspection, and recordkeeping, were 

sufficient to ensure that safety would not be adversely affected.

The UAS

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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 gimbals (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 bluetooth indicator (smartphone connectivity).

The Phantom Series has evolved into an integrated flying system with aircraft, camera, 

Wi-Fi connectivity, a controller and the pilot’s mobile device. These quadcopters are mainly 

intended for aerial cinematography and photography applications. 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 high definition (1080p) video. In comparison, the DJI 

Phantom 3 Professional, the latest Phantom model to be released can shoot 4K resolution video 

and take 12MegaPixel still photos. Details regarding the height, weight, and composition of the 

craft are outline in the graph below. 

Model Phantom 

1

Phantom 

2

Phantom 

2 Vision

Phantom 

2 Vision+

Phantom 

FC40

Phantom 3 

Professional

Phantom 3 

Advanced

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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 40

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* Source: DJI Corporation

Risk Mitigation

The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be utilized in

order to manage and mitigate risk and ensure public safety. A preflight checklist will be 

developed and employed to ensure that the UA airworthiness will be verified before launch. 

Airworthiness will be maintained by performance of routine inspections before each 

flight, maintaining flight and maintenance logs to record time on failure-prone components. 

The petitioner request that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that;

“The UA may not operate in Class 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 nontowered 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 letter of 

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

upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner 

is requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption(s) should the need arise. Operations within class B airspace are not requested due to 

the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to 

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

service for property owners or their designees seeking an enhanced perspective for 

characteristics, amenities, and benefits 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 

enhance personal photography. Crop surveying applications could lead to decreased use of

pesticides and fertilizer and conservation of water as well as increased crop yields and decreased 

costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric 

estimations and reduce risks. The petitioner will provide clients with photographic data for these 

purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be

utilized. Flight data including UA flight time, 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 UAS as part of this application. This data may be submitted 

to FAA via traditional means, e.g. COA Monthly Reports, or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations”. 

The reason for such a general and 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 

associated with additional exemptions.

The petitioner's business model is based on the idea of offering ad hoc small UAS 

services to individuals or companies who wish to employ these services as a safe,

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effective, and legal option to enhance their business or hobby. The petitioner’s 

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

estate market and other markets are just beginning to emerge. 

The petitioner has identified universities and other agencies 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 authorization. The 

petitioner has refrained from engaging in commercial use of the UAS.

The primary purpose of seeking this exemption is to obtain the capability to offer those 

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 operating 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- Marketing, Public & Governmental Relations and Corporate Compliance

Manning, Hatchett, & Associates Consulting Group, LLC

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