United States Department of Transportation

Federal Aviation Administration

800 Independence Ave., SW

Washington, DC 20591

Petition For Exemption

Parts of certain Title 14 CFRs in regards to Section 333 of the FAA Modernization and 

Reform Act of 2012 Concerning Unmanned Aerial Systems (UAS)
To whom it may concern:

This letter is a request for exemption from a number of Title 14 CFRs that relate to the 

commercial operation of “unmanned aerial systems” (UAS). The following will be 

included in this request: Name of and information on the Petitioner; Executive 

Summary of the Petitioner summarizing the rules the Petitioner seeks exemption from 

and the reasons the exemptions would serve the public good; Specific Title 14 CFRs to 

which an exemption is sought; the extent & reasons for the requested exemptions; 

reasons why safety would not be compromised.

Personal Information:

Name: Greg R. Manuel (hereafter referred to as “Petitioner”)

Company: The Sandner Group Claim Management

Address: 1491 S. Bell School Road, Rockford IL 61108

815-708-6322

Manuelg@sandnergroup.com

The Petitioner was born on January 15, 1962 and currently resides in Rockford IL. He 

is the Manager of the Loss Control Department for the Sandner Group Claim 

Management. The Sandner Group Claim Management is a third party claims 

administrator for public school intergovernmental cooperatives. The petitioner seeks 

authorization to perform commercial UAS operations for the purpose of conducting

hazard and loss control inspections on public schools and other school district owned 

property.

The Petitioner is an F.A.A. licensed Private Pilot, Airplane Single Engine Land with an 

Instrument rating.

The Petitioner intends to use a DJI Phantom 2 Vision model P330D. This UAS has not 

been operated commercially and will not be operated commercially until an exemption 

to the current rules in Section 333 is granted.

The Title 14 CFR exemptions that this request includes are: 61.113(a) & (b); 91.7(a); 

91.119(a); 91.121; 91.151(a); 91.407(a)(1) & (2); 91.417(a) & (b). Reasons for each 

request are cited below.

Public Good

Aerial photography for geographical awareness and property inspection has been in use 

for many years with manned fixed wing aircraft and helicopters. For public school 

districts however the cost is prohibitive and the altitudes used do not allow for up close 
detail inspection photography. Having low cost UAS available for property inspections 

will enable public school districts to more effectively manage property maintenance 

needs and budget more effectively for roof repair or replacement. Granting this 

exemption to the petitioner would allow him to provide this service at a much lower 

cost, with better results obtained. Further, the small UAS being utilized will pose no 

threat to the public given its small size and lack of combustible fuel when compared to 

larger manned aircraft. 

Description of UAV to be deployed under requested exemptions

Petitioner currently owns a DJI Phantom 2 model P330D. The petitioner intends to use 

the Phantom 2 as the primary UAS in the commercial applications described herein. 

The Phantom 2 is a quad copter that can take off and land vertically. It weighs 

approximately 3 lbs. and has a maximum airspeed of approximately 25 knots. This UAS 

uses lithium polymer batteries which have approximately 20 – 25 minutes of total 

charge time. This gives this UAS approximately 15 minutes of flight time with sufficient 

remaining battery charge to land safely. 

Preflight

The petitioner will always follow procedures outlined in the UAS operator’s manual as to 

proper preflight inspection of all hardware, software, environment and any other factors 

needed to ensure a safe flight.

FCC Information

The UAS being deployed here is a DJI Phantom 2 model P330D. The remote control 

operates on a frequency of 5.728 GHz – 5.85GHz. Published FCC range is 800 m (2624 

ft.) with a sensitivity of -93dbm.

PIC Qualifications

As stated above the Petitioner holds an FAA Private Pilot certificate with Instrument 

rating. The Petitioner has been an active and current pilot for more than 35 years and 

possesses expert knowledge of the National Airspace System. The petitioner also has 

many years of experience operating radio controlled model aircraft as a hobby and has 

operated the Phantom UAS as a hobbyist. The Petitioner will be the Chief Pilot for all 

company UAS operations and expects to be the PIC for all company operations 

performed. 

Description of Intended Commercial Operations

Petitioner intends to utilize the UAS to perform aerial property inspections of public 

school districts. This work will be done with full permission of the subject school 
district. Flight operations will be restricted to flights directly over the property that has 

granted permission. 

UAS Operating Parameters

The UAS being deployed in these exemption request can fly at a speed of approximately 

25 knots. However, given the intended use described here, this speed will never be 

necessary. Much slower speeds are preferred to collect the photographic material 

needed.

Flight operations will not be conducted when students are present outside the building 

being photographed.

Petitioner agrees to never fly the UAS outside of VLOS and also agrees to only fly UAS 

during daylight hours in visual meteorological conditions, at altitudes below 200 feet 

AGL and clear of clouds.

The UAS will not be operated within 5 nautical miles of an airport as denoted on a 

current FAA published aeronautical chart.

The UAS being deployed with these exemption requests has the capability of using GPS 

signals to return to its initial point of takeoff if connection with the radio control link is 

lost.

The Petitioner agrees to yield right of way to all manned aviation activities at all times.

Exemption Requests

The following is a list of Title 14 CFR’s which the Petitioner seeks exemption. Please 

note that the Petitioner has used Exemption No. 11583 issued to Thomas Raniere, Flite 

Video LLC (Regulatory Docket No. FAA-2015-0453) as a reference.

Rule 61.113 – Private Pilot Previleges and Limitations

The Petitioner holds a FAA Private Pilot certificate that does not allow operation for 

compensation or hire. Regarding these limitations it seems that Exemption No. 11062 

issued to Astraecus has allowed this exemption previously and is also noted in the 

Trudeau exemption no. 11138.

Rule 91.7(a) Civil Aircraft Airworthiness

There is no current FAA regulatory standard for determining airworthiness of UAS and 

there is no certificate currently available for UAS airworthiness. Petitioner seeks an 
exemption from this rule by ensuring that the UAS is in an airworthy condition based on 

compliance with the operating documents prior to every flight. Flight manual and other 

important documents will be kept in a location to allow them to be readily accessed by 

the PIC at all times.

Rule 91.119(c) Minimum Safe Altitudes

91.119 prescribes safe altitudes for the operation of civil aircraft, but it allows 

helicopters to be operated at lower altitudes in certain conditions. Petitioner seeks an 

exemption from this rule as Petitioner will only operate the UAS in a range from ground 

level up to but not exceeding 200’ (AGL) and will only operate in areas where flight can 

be safely conducted with no undue risk to the public. The Petitioner asserts that given 

the size, weight, maneuverability and speed of the UAS, an equivalent or higher level of 

safety will be achieved than is possible with manned helicopters. 

Rule 91.121 Altimeter Settings

In light of the very short range, local and short duration of unmanned flights intended 

by UAS operation, the Petitioner does not believe this rule can be applied. All flights 

will be conducted below 200’ (AGL).

Rule 91.151(a) Fuel Requirements for Flight In VFR Conditions

Petitioner seeks relief from this rule due to the UAS being deployed is battery operated 

and the requirements under this rule are not applicable. The UAS in question has First 

Person Vision (FPV) capabilities which transmits certain telemetry to a monitor where 

the PIC can monitor certain aspects of the flight including battery level. A typical 

battery for a Phantom 2 Vision Model P330D will last 20 – 25 minutes before total 

exhaustion. Certain battery level warnings are set where the PIC will know when the 

battery state is at 30% and 15% remaining charge levels. This will normally allow a 

flight of 12 – 15 minutes with sufficient remaining battery charge to allow a safe return 

and landing. Flights will always begin with a fully charged battery.

Rule 91.405(a) Maintenance Required, 91.407(a) Operation After 

Maintenance, Preventative Maintenance, Rebuilding or Alteration; 

91.409(a)(2) Inspections: 91.417(a)(b) Maintenance Records

Petitioner seeks relief from these rules due to it being an alternate inspection 

requirement of 91.409(a)(2). The Petitioner will inspect and ensure UAS is in a 

condition for safe flight and adhere to all operating documents.
Supplemental Information

The Petitioner has provided the following information to support these requests for rule 

exemptions:

Phantom 2 Vision Operation Manual, March 21, 2014 Revision

Closing

The Petitioner believes that exemption from the above listed Title 14 CFRs is warranted 

given Petitioner’s background as a Private Pilot with 35+ years of accident free 

experience as pilot in command, the nature of and type of use that the UAS will be 

utilized for, and the size and weight of the UAS being deployed itself.

The safety precautions the Petitioner has described in this Petition for Exemption will 

assure safe, hazard free operation that will benefit public school districts.

Sincerely,

Greg R. Manuel

Sandner Group Claim Management

Rockford, IL 

815-708-6322