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 batteries. 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 which Martin Manning requests 

exemption 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 intended 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) quadcopter small UNMANNED 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 Phantom 3 Professional (Serial# 76DCE19014117) 

ultra-light weight UNMANNED AIRCRAFT SYSTEMS (UAS). Prior to the time period, by which the Reform Act requires the 
FAA 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 request for Martin Manning Pursuant To Section 3 3 3 of the FAA Reform Act of2012 our national airspace 

system;

Considerations include: The weight, size, speed and overall capabilities of the UNMANNED AIRCRAFT SYSTEMS (UAS)'s; 

whether the UNMANNED AIRCRAFT SYSTEMS (UAS) will be operated near airports or 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 AIRCRAFT SYSTEMS (UAS) near airports, hospitals or 

helipads, and do not will not operate near areas where general public is one hundred (100) yards depending 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 request will benefit the public 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 businessperson the expense of such aerial videography is cost prohibitive 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 will not adversely affect safety or how the exemption will provide a level of safety at

least equal to existing rule:

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 requires 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

 GPS

 Receiver

 Battery

 Camera
Current 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 Back 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

AIRCRAFT SYSTEMS (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 UNMANNED

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)

Prohibits 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 each 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 certificates 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;

Provides 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.

Applicable 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) is in the largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage for identification.

Respectively submitted;

Martin Manning