### 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

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West Building, Ground Floor, Room W12-140 1200 NewJe;rsey Avenue, SE Washington, DC 20590 RE: Docket Number FAA-2015-0150 Dear Sir-or Ma,dam, .,, ·:_::";:. (' { ;; ' ·' ; 0;:: A·"f.:..,

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Pursuant to Section 333 ofthe FAA modernization and Reform Act of2012 (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 underthe 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 currentlytrainingto complete my FAA private pilot license which will be obtained at the end ofAugust 2015. Itake the operation of UAS very serious and I understand the safety precautionsthat need/will take place before, during 

### & after everyflight. With my clear understanding of FAA rules, awareness ofoperational and restrictive airspace and soon to be FAA private pilot license holder, and my attitude ofsafetyfirst, before, during 

### & after every flight, I should be granted an exemption. I recognize the importance ofextreme 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 awaiver 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 oftheir parcel of land for disposition and sale and other promotional purposes in addition toTV/Commercials and Films; and all work for hire. Any complaint by any memberofthe public complaining of invasion of privacy will instantly be honored resulting in immediate termination ofaerial operations. I'm currently seeking exemption of: Section of 14CFR: 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) underthe 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 priorto finalizingthe small UAS proposed rules published this past February. It is my understandingthatthe FAA will still review each Section 333 petition individually. However, Iam hopingthatthe agency will accept my particular petition, and include it in the next summary grant, and issue me an exemption on the presumption thatthe FAA "already granted a previous exemption similar tothis request". Apparently, the new interim policy includes the granting ofa Certificate ofWaiver or Authorization (COA) forflights at or below 200 feet to any UAS operatorwith a Section 333 exemption for aircraftthat weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line ofsight (VLOS) ofthe 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 airportwith a published instrumentflight procedure, but not an operational tower; or2 NM from an airport with a published instrumentflight procedure. It is also understood thatthe /{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 Iwill 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 ofcommunications occurs the craft will rise up verticallyto asafe 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 ifcommunication is reestablished. However in case ofaGPS failure the craft will be able to be manuallyflown to asafe landing bythe 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 oftravel distance from the pilot. Flight Operations I'm aware ofconducting safe flight operations and planningflight paths that minimize any overflight ofcrowds. Operations will not occur under IFR conditions. Once battery level reaches 30 percentflight(s) will end. All preflight and post-flight checklists and UAS examinations will help detect any abnormalities priortoflight and afterflight. Any UAS unable to satisfy safety checklists will be removed from service until the issue can be resolved. Grantingthis 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 ofthe craft, experience ofthe pilot and operational goals, this request appears to be well suited for approval using the current criteria outlined in Section 333 ofthe FAA Modernization and Reform Act of2012 (including new interim policies) Respectfully,

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... ·--**~---== C.-~·-·** **/·"'"~,,;1· ~-·**  Jonathan M. Dannenfelser JMD Empire Inc. 15102 Dickens St. #203 Sherman Oaks, CA 91403 818-822-3853 imdempire@gmail.com