May 18, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

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

Manderbach (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an exemption 

from the Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial imaging and 

video of real property (listed real estate, private properties, golf courses, resort properties) and events 

(weddings, festivals, receptions, parties & concerts).

Applicant 

Jason Manderbach 

6720 S. Eberhart Ave. 

Clare, MI 48617 

Aircraft Type & Specifications: 

Make: DJI 

Model: Phantom 3 Advanced 

Weight: 2.82 LBS 

Diagonal Size: 23.22 IN

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) and (b) 

Extent of relief, and purpose:

14 CFR Part 21 subpart H 

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed, and limited operating area associated with the 

aircraft to be utilized, I request exception. In the restricted environment and under the conditions 

proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an 

airworthiness certificate without said restrictions. 

14 CFR 91.7 (a) 

As there will be no airworthiness certificate 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 list prior to each flight an equivalent level of safety will be 

provided. 
14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There 

is no room, capacity, or pilot on board to adequately carry flight manual. A equivalent level of safety 

will be maintained by keeping the flight manual at ground control point where the pilot will have 

immediate access to it. 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. 

Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing 

and takeoff distances, along will all of those found in attachment "DJI Pilot Training". An equivalent 

level of safety will be provided by preflight protocol) to properly match the machine. 

14 CFR 91.109 

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

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

equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, 

and by the speed and size of the aircraft. 

14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills. 

14 CFR 91.121 

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe 

an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live 

flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS 

altitude indicator. 

14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry 

certificate and registration documents on the aircraft. There is no room, capacity, or pilot on board to 

adequately such documents. An equivalent level of safety wili be achieved by keeping these 

documents, to the extent they are applicable to the UAS, at the ground control point where pilot has 

immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) 

Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not 

apply to this applicant. As a safety precaution, operator will perform preflight inspections and ensure 

UAS is in working condition before initiating each flight. 

Jason Manderbach is seeking relief from all FARs above preventing applicant from conducting aerial 

photography and video of real property and events taken at levels less than 400ft. The UAS to be used 

is a DJI Phantom 3 Advanced. At 2.82 pounds, the weight of the UAS meets the definition of "small 

unmanned aircraft" found in section 331 "The Reform Act". The maximum speed of the UAS is 33.5 mph. 

The UAS is battery powered with no combustible fuels onboard. Maximum flight time for this particular 

UAS is 25 minutes battery life, and all flights to be terminated with 25% battery life remaining. Given 

the size, weight, speed, and limited operating area associated with the aircraft to be utilized I find this 

exception to be reasonable with an equivalent, or greater, level of safety to be reached by the 

operator. 

Safety 

Please see attachment "DJI Pilot Training" for safety precautions I use for every flight. 

Additionally:
• I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the airport 

manager has been made.

• I land my UAS prior to manufacturer recommended minimum level of battery power.

• I pilot my UAS through remote control by line of sight.

• My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and then 

slowly lands if communication with the remote control pilot is lost.

• I actively analyze flight data and other sources of information to constantly update and enhance 

safety protocols.

• I conduct extensive pre-flight inspections to ensure aircraft functionality. 

• I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort 

flights in the event of potential danger. 

Public Interest 

The use aerial imagery made possible with the use of a UAS is a dynamic marketing resource for real 

estate, hospitality and event clientele. It allows them to provide their customer viewpoints only 

available from an elevated position. This type of imagery when combined with a great marketing 

strategy boosts revenues and stimulates local, regional and national economies. It can also indirectly 

benefit other businesses in the area by encouraging tourism. Through the use if a UAS, aerial imagery 

can now be captured much more efficiently and cost effectively than traditional aviation methods 

saving time, fuel, emissions and possibly even human life in the event of a mechanical failure. 

Thank you for your consideration. 

Jason Manderbach