J~.PJ.rnpire:lnc: ·.:'· : 

J.9?~t~~n. M,---~.ann;'7nfe~ser .... 

15102 Dickens St. #203 ;_:_, 

Sherman Oaks, CA 91403 

.i_mde~pire@gmail.com 

June 24, 2015. ;.!" 

FAA . .. ~.! ~!. :. ~-; : .. :· 

U.S. DE;pqrtment of Transportation 

Docket Operations 

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West Building, Ground Floor, Room W12-140 

1200 New Je;rsey Avenue, SE 

Washington, DC 20590 

RE: Docket Number FAA-2015-0150 

Dear Sir-or Ma,dam, . ,, 

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Pursuant to Section 333 of the FAA modernization and Reform Act of 2012 (the Reform 

Ac~)and 14 CF.R. Part 11, JMD Empire Inc. hereby applies for an exemption from the listed 

Federal Aviation Regulations (FARs) to allow business use (commercial operation) of its UAS's, 

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. 

I'm submitting my Petition for Exemption for Unmanned Aircraft Systems operations. 

I've been flying single engine planes accompanied with instructors since 1995 acquiring over 60 

flight hours. I'm currently training to complete my FAA private pilot license which will be 

obtained at the end of August 2015. I take the operation of UAS very serious and I understand 

the safety precautions that need/will take place before, during & after every flight. With my 

clear understanding of FAA rules, awareness of operational and restrictive airspace and soon to 

be FAA private pilot license holder, and my attitude of safety first, before, during & after every 

flight, I should be granted an exemption. 

I recognize the importance of extreme privacy as I've been jn situations where I have 

had to adhere to an environment based on such privacy. I also understand the extreme 

importance of highly confidential information due to my licenses in the Real Estate and 

Financial industries. 
My request for a waiver of FAA Section 333 is to operate a UAS for 11Commercial 

purposes". To record digital video data and other aerial photography data for private owners of 

real estate; construction sites to assist in the promotion of their parcel of land for disposition 

and sale and other promotional purposes in addition to TV /Commercials and Films; and all work 

for hire. Any complaint by any member of the public complaining of invasion of privacy will 

instantly be honored resulting in immediate termination of aerial operations. 

I'm currently seeking exemption of: 

Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 61.113{a) and (b), 

61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 

91.319(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). If I have erroneously 

omitted any other relevant section or, overstated and relevant section for my intended 

operations, please feel free to suggest the missing or overstated section(s). 

Suggested Public Federal Register Summary: 

11The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) 

under the new FAA /{Summary Grant" approach, announced April gth, 2015 

http://www.faa.gov/news/updates/?newsld=82485 that will help speed up Section 333 

exemption approvals for many commercial UAS operators prior to finalizing the small UAS 

proposed rules published this past February. 

It is my understanding that the FAA will still review each Section 333 petition 

individually. However, I am hoping that the agency will accept my particular petition, and 

include it in the next summary grant, and issue me an exemption on the presumption that the 

FAA "already granted a previous exemption similar to this request". 

Apparently, the new interim policy includes the granting of a Certificate of Waiver or 

Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 

exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight 

Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain 

distances away from airports or heliports such as 5 nautical miles from an airport having an 

operational tower; or 3 NM from an airport with a published instrument flight procedure, but 

not an operational tower; or 2 NM from an airport with a published instrument flight 

procedure. It is also understood that the /{blanket" 200 foot COA allows flights anywhere in the 

country except restricted airspace and other areas, such as major cities, where the FAA 

prohibits UAS operations. 
Description of UAS 

I will be using a DJI Phantom 3 http://www.dji.com/product/phantom-3/spec and a DJI 

Inspire 1 http://www.dji.com/product/inspire-1/spec. In the event a loss of communications 

occurs the craft will rise up vertically to a safe height before beginning an automatic return to 

home function. The control signal may be reconnected in flight and the pilot can take over safe 

operations again if communication is reestablished. However in case of a GPS failure the craft 

will be able to be manually flown to a safe landing by the pilot. The craft operated electrically, 

carries no flammable fuel, has an integrated GPS pilot system, provides location information 

along with height AGL, speed, battery life, has programmed no-fly zones for controlled airports, 

and provides direction of travel distance from the pilot. 

Flight Operations 

I'm aware of conducting safe flight operations and planning flight paths that minimize 

any over flight of crowds. Operations will not occur under IFR conditions. Once battery level 

reaches 30 percent flight(s) will end. All preflight and post-flight checklists and UAS 

examinations will help detect any abnormalities prior to flight and after flight. Any UAS unable 

to satisfy safety checklists will be removed from service until the issue can be resolved. 

Granting this request would not adversely affect safety since operations would be in 

accordance with current UAS rules. 

Section 333 Compliance and Appropriateness: 

Based on the size of the craft, experience of the pilot and operational goals, this request 

appears to be well suited for approval using the current criteria outlined in Section 333 of the 

FAA Modernization and Reform Act of 2012 (including new interim policies) 

Respectfully, 

,::/:··./. ./·z---~~7·····7 ... ·-- ~---== ~~ C.-~·-· 

/·"'"~,,;1· ~-· 

Jonathan M. Dannenfelser 

JMD Empire Inc. 

15102 Dickens St. #203 

Sherman Oaks, CA 91403 

818-822-3853 

imdempire@gmail.com