United States Department of Transportation 7/13/2015

Docket Operations 1200 New Jersey A ve.SE West Building Ground Floor Room W12

- BO Washington DC 20590 Re: Exemption Request Pursuant To Section 3 3 3 of the FAA Reform Act of 2012
Dear Sir or Madam: I am writing pursuant to the FAA Modernization and Reform Act of 2012 (the "Reform Act”) ) And the procedures contained in 14 C.F .R. 11, to request that Martin Manning , owner and operator of a DJI Phantom 3 Professional; (Serial # P76DCE19014117 ) UNMANNED AIRCRAFT SYSTEMS (UAS), and a transportable ground station. The PHANTOM 3 Professional is referred to as a quad

- copter with the maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by b atteries. The Phantom has a maximum airspeed of 36 MPH and to be exempted from the Federal Aviation Regulations (FAR's) listed below. The exemption is needed in order to operate a small lightweight unmanned aircraft system (UNMANNED AIRCRAFT SYSTEMS (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). These operations will be Conducted within and under the conditions outlined herein or as may be established By the FAA as required by Section 333.§1 1.8 I. The following aspects of Section 333 of the FAA Modernization and Reform Act of2012 should be considered. The following information is submitted to meet the requirement of the above act. **1. Name and address:**   Martin Manning  PO Box 1491 Sumner, Wa 98390  Office: 253
- 826
- 1087  Email: m2drone@gmail.com **2. The Specific Sections of Title 14 of the Code of Federal Regulations from**  **w hich**  **Martin Manning requests e** **xem ption are:**  14 C.F.R. § 91.7(a) 14 C.F.R. § 91.119 14 C.F.R. § 91.121 14 C.F.R. § 91.151 14 C.F.R. § 91.405 (a), 91

- 407 (a) (1,2), 91

-409 (a) (1,2), 91

- 417 (a) (b) 14 C.F.R. § 61.23 (a) (c) 14 C.F.R. § 61.101 (e) (4, 5) 14 C.F.R. § 61.113 (a) 14 C.F.R. § 61.115 (a) 14 C.F.R. 

### § 91.203 (a) and (b) 14 C.F.R. 

### § 45.2.3:
**3. The extent of**  **relief you seek, and the reason you seek relief:** Martin Manning , respectfully submits this request in harmony with the Reform Act, 112 P.L. 95 §§ 331
- 334, pursuing reprieve from any currently applicable FARs operating to preclude me, Martin Manning intende d use is saleable aerial cinematography in video or still format within the Greater Seattle/Tacoma region to real estate company/s for heightened visual listings or other legal businesses that need supplementary visual photography or video. The Reform Act in Section 332 provides for such incorporation of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do so. Martin Manning’s, DJI Phantom 3 Professional (Serial # P76DCE19014117 ) quad

copter small UNM ANNED AIRCRAFT SYSTEMS (UAS), meets the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of my ultra

- light weight UNMANNED AIRCRAFT SYSTEMS (UAS) is expressly considered by the Reform Act. Martin Manning would like to operate his DJI Ph antom 3 Professional (Serial# 76DCE19014117 ) ultra

- light weight UNMANNED AIRCRAFT SYSTEMS (UAS). P rior to the time period, by which the Reform Act requires theFAA to broadcast rules governing such craft. The Reform Act guides the Secretary in defining the types of UNMANNED

AIRCRAFT SYSTEMS (UAS)'s that may operate safely in
. **Exemption r**  **equest for Martin Manning**  **Pursuant To Section 3 3 3**  **of the FAA Reform Act of2012 our national airspace**  **system;** Considerations include: The wei ght, size, speed and overall capabilities of the UNMANNED AIRCRAFT SYSTEMS (UAS)'s; whether the UNMANNED AIRCRAFT SYSTEMS (UAS) will be operated near airports o r heavily populated areas; and whether the UNMANNED AIRCRAFT SYSTEMS (UAS) will be operated by line of sight. My DJI Phantom 3 Professional (Serial # P76DCE19014117 ) UNMANNED AIRCRAFT SYSTEMS (UAS) operates four (4·) counter

- rotating propellers for stability, control and steadiness. My UNMANNED AIRCRAFT SYSTEMS (UAS) is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds well below the maximum 55 pound limit); including camera with gimbal. Operation of the UNMANNED AIRCRAFT SYSTEMS (UAS) preceding flight and post flight must be operated in a check list format and that safety is paramount with each flight. My **DJI** Phantom 3 Professional (Serial # P76DCE19014117 ) is designed to hover in place via GPS and operate in less than a 25 mph wind. Martin Manning operates this UNMANNED AIRCRAFT SYSTEMS (UAS) with safety, stability and fear of detrimental financial loss in mind and will not fly in winds exceeding 15 mph
. Built in safety systems include a GPS mode that allows my UNMANNED AIRCRAFT SYSTEMS (UAS) to hover in place when radio controls are released by hands . This is the safest, most dependable and unwavering mode to prevent accident and hazard. When pilot communication is lost UNMANNED AIRCRAFT SYSTEMS (UAS) is designed to slowly descend to point of origination. The UNMANNED AIRCRAFT SYSTEMS (UAS) has a function that instantaneously video records once communication is lost. I do not and will not operate my UNMANNED AIRCRAF T SYSTEMS (UAS) near airports, h ospitals or helipads, and do not will not operate near areas where general public is one hundred (100) yards dep ending on location, conditions and weather. Martin Manning is constantly on alert for any manned aircraft and prepared to either avoid and shall yield the right

- of

- way to all aircraft and operate in a manner to avoid any type of collision hazard with respect to persons on the ground or property and to and/terminate instantly to the nearby and safest ground point should a manned aircraft approach my location or suspect manned aircraft may approach near my location, My DJI Phantom (Serial # P76DCE19014117 ) UNMANNED AIRCRAFT SYSTEMS (UAS) is capable of vertical and horizontal operations, and are flown only within my line of sight of me. As 

### the Remote controlled pilot The UNMANNED AIRCRAFT SYSTEMS (UAS) is operation under the power of a battery power rather than combustible fuels, flights generally last between ten 10 to15 minutes, with an altitude under two hundred ( 200 ) feet. **4. How r equest**  **will benefit the p ublic**  **as a whole :**  In
- flight videography for topographical awareness and real estate marketing or any legal business utilizing aerial photographs or video has been around for an extensive period of time and accomplished with manned fixed wing aircraft and helicopters. For the small budget businessper son the expense of such aerial videography is cost proh ibitive and depriving, many others such as the small business person from exposing such an in

- valuable advertising tool. Manned aircraft exposes a superior hazard to the public through conceivable catastrophic crashes, causing loss to property and or life. UNMANNED AIRCRAFT SYSTEMS (UAS) pose no such hazards due its size, speed and nonexistence of flammable fuels and therefore significantly reduces any potential threat to the public or environment. **5. Reasons why exemption wil** **l not adversely affect safety or how the exemption will provide a level of safety a t**  **least e qual**  **to existing r ule:**  Martin Manning’s safety protocols will enhance safety; and requested exemption will not adversely affect safety. In addition I, submit the following representations of enhancements to current aerial videography and photography for real estate or any legal business requiring photographic images: **DJI Phantom 3 Professional;** Serial Number: P76DCE19014117 weighs less than 5 pounds complete with DJI Factory installed camera. The Phantom 3 Professional + firmware programmed for a maximum 300 feet above ground level and 1000 feet radius distance are limited distance for maintaining Visual sight line of operation. Most intended operation will only re quires range of 25

- 125 above ground level and less than 200 feet lateral distance from Pilot in command. Exemption Request for Martin Manning Pursuant To Sections 333 of the FAA Reform Act of 20l2 Current firmware upgrades for:  Main Controller  GP S  Receiver  Battery  CameraCurrent Physical upgrades:  DJI factory Prop Guards 1. Will always obtain all essential permissions prior to operation and postings a warning sign reading "Attention Use of Quad Rotor Drone for Aerial Photography in progress

- Remain Ba ck 125 feet"; 2. Will conduct operations under strict personal and flight safety protocols and constantly strive to update and enhance safety protocols; 3. Will conduct extensive pre

- flight inspections and protocol, during which safety carries principal importance; No payloads other than gimbaled camera; 4. Will only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; 5. Will pilot my UNMANNED AIRCRAFT SYSTEMS (UAS) through remote control only by line of sight; 6. Will only operate my UNMANNED AIRCRAFT SYSTEMS (UAS) with a height limitation set for a maximum of 300 feet above ground level ( Operating

- 25% inside the 4·00 foot permissible ceiling set by the FAA Modernization and 7. Reform Act of20l2); 8. Will land my UNMANNED AIRCRAFT SYSTEMS (UAS) prior to manufacturer recommended minimum level of battery power; 9. Will employ the GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost and continues to record flight as per manufacture settings; 10. Will maintain records specific to retain until the work is repeated or superseded by other work for one year after the work is accomplished. 11. Will maintain records and shall retain and when/if transferred with the aircraft at the time the aircraft is sold. 12. Will list or denote in records a list of defects furnished to a registered owner or operator shall be retained until defects are repaired and the aircraft is approved for return service. Martin Manning’s operating procedures exceed existing rules. First, the possible loss of life is lessened because UNMANNED AIRCRAFT SYSTEMS (UAS)'s do not carry pilots or passengers on board and I only operate my UNMANNED AIRC RAFTSYSTEMS (UAS) safely in the direct detailed areas of operation versus fixed wing or helicopter requires travel to the region of need. Second; there is no fuel on board an UNMANNED AIRCRAFT SYSTEMS (UAS) and thus the probability for fire or explosions is significantly diminished. Lastly, the small size and extremely maneuverability of my UNMANNED AIRCRAFT SYSTEMS (UAS) allow me to remotely pilot away from hazards quickly and safely. Exemption Request for Martin Manning Pursuant To Section 333 of the FAA Reform Act of 2012 A Summary the FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14· C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14· C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.20.'3(a) ( 1). The size, weight and enclosed operational area of my, Martin Manning , UNMANNED AIRCRAFT SYSTEMS (UAS) permits exemption from Part 21 because my UNMA NNED AIRCRAFT SYSTEMS (UAS) meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. 

### § 44·701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UNMANNED AIRCRAFT SYSTEMS (UAS)'s from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Martin Manning’s current and projected UNMANNED AIRCRAFT SYSTEMS (UAS)'s request exemption from the following CFR’s 14 C.F.R. § 91.7(a) P rohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.119 Minimum safe altitudes; (c) Martin Manning will not fly above 200 feet in altitude. 14 C.F.R. § 91.121 Altimeter settings; Regarding altimeter settings is N/A as my UNMANNED AIRCRAFT SYSTEMS (UAS) utilizes electronic global positioning systems with a barometric sensor.14 C.F.R. § 91.151

Fuel requirements for flight in VFR conditions. (a) (1) No flights will be at night. 14 C.F.R. § 91.405 (a), 91

- 407 (a) (1,2), 91

-409 (a) (1,2), 91

- 417 (a) (b) Maintenance required , Alterations, Inspections, Maintenance records; (a) These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Martin Manning ’s UNMANNED AIRCRAfT SYSTEMS (UAS). However, as a safeguard I inspect my UNMANNED Aircraft SYSTEMS (UAS) beforehand and afterward e ach flight to ensure safe and efficient working conditions. No alterations from factory condition will take place. All maintenance records will be kept and documented for accurate inventory of replacement OEM parts. 14 C.F.R. § 61.23 (a) (c) Medical certi ficates requirement and duration; This is for passenger carrying aircraft. Martin Manning will not be a passenger or carrying passengers on his UNMANNED Aircraft SYSTEMS (UAS), therefore is N/A. 14 C.F.R. § 61.101 (e) (4 , 5 ) Recreational pilot privileges and limitations; For compensation for hire and in furtherance of business; Martin Manning will be taking photos and videos for compensation. 14 C.F.R. § 61.113 (a) Private pilot privileges and limitations: Pilot in command; UNMANNED AIRCRAFT SYSTEMS (UAS)'s, this Regulation is N/A, no pilot certificate is applicable (no carrying passengers)
14 C.F.R. § 61.115 (a) Balloon rating limitations; The UNMANNED AIRCRAFT SYSTEMS (UAS)'s that Martin Manning will flying is a DJI Phantom 3 Professional drone aircraft. It is a quad copter with 4 engines and 4 propellers. This rule does not apply to Martin Manning’s aircraft. 14 C.F.R. 

### § 91.203 (a) and (b) Civil aircraft; Certificates; P rovides for the carrying of civil aircraft certifications and registrations. They are N/A for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Martin Manning. 14 C.F.R. 

### § 45.2. 3: Marking of the Aircraft. Applica ble Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UNMANNED AIRCRAFT SYSTEMS (UAS) are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Furthermore , two - inch lettering would make it difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UNMANNED AIRCRAFT SYSTEMS (UAS) i s in the largest possible lettering by placing the word "EXPERIMENTAL" on its f uselage for identification. Respectively submitted; Martin Manning