1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 1

Brian D. Manis

Manis Brand Creative Inc

1285 Brookside Dr.

Germantown, TN 38138

January 11, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Petition for the exemption of Aerial Video and Photography using UAV 

CONCERNING COMMERCIAL OPERATION OF THE DJI PHANTOM 3 ADVANCED

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21; 91.7 (a);91.9 (b) 

(2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 

91.409 (a) (2);91.417 (a) & (b); 61.113 (a) & (b).

Dear Sir or Madam: 

I, Brian D. Manis, owner of Manis Brand Creative Inc and an owner of a small unmanned aircraft 

(DJI Phantom 3 Advanced), am writing Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, hereby applies to seek exemption 

to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography of Real Estate Properties (for homeowners, realtors, home 

builders, home contractors and / or home inspectors for real estate marketing and inspection 

of home exteriors) as well as filming of special events, film sets, scripted and unscripted 

television sets commercially under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access 4) during daylight hours and 5) would provide safety 

enhancements to client’s already safe operations in airspace regulated by the Federal Aviation 

Administration (“FAA”) in accordance with FAA UAS Regulations & Policies. 

The name and address of the applicant is: 

Brian Manis

Manis Brand Creative Inc

1285 Brookside Dr.

Germantown, TN 38138

Email: brian.manis1@gmail.com

Website: manisbrand.com
1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 2

Mr. Manis is a 20 year veteran of the film and television industry, has worked in all areas of 

production and has produced feature films such as Garfield 1 and 2, Dr. Dolittle 3, 4, and 5 and 

Gulliver’s Travels. In his current position at Manis Brand Creative, Mr. Manis’ mission is to 

provide his clients with high quality digital content for television, film and the web for

commercial, personal and non-profit multi-media projects. In addition, Manis Brand Creative 

provides expertise and knowledge in all aspects of production and provides clients with 

advanced technologies and solutions that will increase productivity and efficiency. Manis 

Brand Creative provides high quality aerial photography and videography for a variety of 

commercial, public and residential uses, specifically in the areas of:

• Commercial filming for motion picture, television and web

• Real Estate Videography and Photography 

• Wedding Videography and Photography 

• Land survey, appraisals 

• Roof Inspections 

• Construction sites 

Regulations from which the exemption is requested: 

14 CFR Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 

C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 

CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) 61.113 (a) & (b).

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national 

airspace system (NAS) before completion of the rulemaking required under Section 332 of the 

Reform Act. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

Mr. Manis seeks exemption to operate The DJI Phantom 3 Advanced, a vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UAV) with a Ground Control Station (GCS) utilizing 

electronic controls and monitoring systems. The DJI Phantom 3 Advanced has a maximum 

gross weight of approximately 3 pounds, and a length of 16 x 16 inches, height of 8 inches, 

and a maximum speed of approximately 32 knots. The DJI Phantom 3 Advanced is equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 Advanced will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

The applicant proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate with the limitations listed herein. These limitations provide 
1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 3

for at least an equivalent or even higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to the 

already safe movie and television filming operations conducted with conventional aircraft. 

These limitations and conditions to which Manis Brand Creative agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

Reform Act Section 333 (b). 

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 10-12 minutes. Flights will be 

terminated at 30% battery power reserve should that occur prior to the 20 minute 

limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 

feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot/Camera Operator and a 

Visual Observer.

6. The UAS will only operate within a confined “Sterile Area” and requires the establishment of 

a “Security Perimeter” for the flight operations area. 

7. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s 

production activities. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be present for this briefing. 

8. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office. 

9. The operator will obtain the consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation, and this 

radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required by Section K of the Manual. 

10. Pilot and observer will have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated. 

11. Observer and pilot will at all times be able to communicate by voice. 
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12. Written and/or oral permission from the relevant property holders will be obtained. 

13. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

14. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

15. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. These safety enhancements, which already apply to civil aircraft operated in 

connection with motion picture and television production, provide a greater degree of safety 

to the public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Finally, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the UAS, due to its 

size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load. 
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14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires that when marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the 

identification of the UAS as “Experimental.” The FAA has issued the following exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

Further markings include the use of flashing green LED illumination on the underside of the 

sUAS frame, which stands at contrast against a blue or white sky. 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance 

and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an 

equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft (2) For which an Airplane or Rotorcraft 

Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a 

current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but also because there is no room 

or capacity to carry such an item on the aircraft. 
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The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure 

the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the 

aircraft an exemption will be needed. The Pilot in command will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact 

that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of 

the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority 

to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from 

which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, he UAS will never operate at higher than 400 AGL. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 
1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 7

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than 

the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional aircraft operating 

at or below 500 AGL in the video production industry. In addition, the low-altitude operations 

of the sUAS will ensure separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes.” 

The battery powering the sUAS provides approximately 20-25 minutes of powered flight. To 

meet the reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10-12 minutes in length. Given the limitations on the UAS’s proposed flight area 

and the location of its proposed operations within a predetermined area, a longer time frame 

for flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting sUAS flights to 10-12 minutes would greatly reduce the utility for which 

the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 15 

minutes or 30% of battery power whichever happens first. This restriction would be more than 

adequate to return the sUAS to its planned landing zone from anywhere in its limited 

operating area. 
1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 8

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it 

the following: (1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the extent 

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. 

A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 

9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 

of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook as referenced in the 

Manual.(See Sections L and Q) An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator 

will ensure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 
1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 9

14 C.F.R. §61.113 Private pilot privileges and limitations: Pilot in command.

These regulations require that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however Mr. Manis can achieve an equivalent level of safety as 

achieved by current regulations because his UAS fully loaded weighs no more than 55 lbs, 

carries no passengers, and is operated without an onboard pilot. In addition, while having a 

pilot’s license would be helpful, a pilot license will not ensure remote control piloting skills. 

The Pilot in command will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. In addition, Mr. Manis has flown numerous practice flights in remote areas as a hobbyist 

simulating flights for future commercial use to gain familiarization with the performance of the 

UAS and control box under different weather conditions. The risks of operating a UAS are far 

less than the risk levels inherent in the commercial activities outlined in 14 CFR part 61, et seq., 

thus Mr. Manis requests an exemption from § 61.113 Private Pilot Privileges and Limitations: 

Pilot in command.

PRIVACY 

All flights will occur over controlled access property with the property owner’s prior consent 

and knowledge. Filming will be of people who have also consented to being filmed or 

otherwise have agreed to be in the area where filming will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security – provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s UAS in the motion 

picture and television industry pursuant to the Manual appended hereto. 

PUBLIC BENEFIT

Granting the present Petition will further the public interest by allowing Brian D. Manis to 

safely, efficiently, and economically perform aerial video and photography of real estate, 

special events, film sets, property, and landscape over certain areas of the United States. 

Use of the DJI Phantom 3 Advanced will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 3 

Advanced are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery and an 

exemption allowing the use of a DJI Phantom 3 Advanced would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the 

safety of life and property in the air and on the ground. In addition, The DJI Phantom 3 
1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 10

Advanced does not require an airport to takeoff or land, thereby reducing the number 

of manned aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public will Benefit from the Efficiency of the DJI Phantom 3 Advanced. By using 

battery power and electric motors, the DJI Phantom 3 Advanced produces no air 

pollution, and is the most viable environmentally conscious alternative to the internal 

combustion engine aircraft that are typically utilized for aerial video and photography, 

that burn approximately 8-10 gallons per hour of leaded aviation fuel. 

3. The Public Will Benefit From The Less Noise Pollution. The DJI Phantom 3 Advanced, 

while reducing the carbon footprint of aerial operations, also eliminates noise 

pollution, as the UAS are propelled by battery powered electric motors, rather than an 

internal combustion engine and will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. 

4. The Public Will Benefit by a Safer Flight. By using the DJI Phantom 3 Advanced to 

perform aerial operations, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, 

will be substantially reduced. The DJI Phantom 3 Advanced has no crew members 

located onboard the aircraft, has a maximum gross weight of approximately 3 pounds, 

which has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations weighing at least 4,000 pounds or more. 

ECONOMIC BENEFIT

Performing Aerial Video and Photography Operations With The DJI Phantom 3 Advanced Will 

Benefit The Economy because the DJI Phantom 3 Advanced is an economical alternative to 

using manned aircraft to conduct similar aerial operations. Continued use of the DJI Phantom 

3 Advanced will allow United States based small businesses, like Manis Brand Creative, to 

remain competitive and contribute to growth of the U.S. economy. The DJI Phantom 3 

Advanced is one such technology that allows companies greater operational flexibility without 

the high operational cost of a traditional manned aircraft and it continued use will provide 

greater job stability to employees and contractors, and increased local, state and federal tax 

revenues which will ultimately contribute to growth of the U.S. economy. 

CONCLUSION

As set forth herein, Applicant, Brian D. Manis seeks an exemption from the following rules: 14 

C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.409 (a) (2); 91.417 (a) & (b); and 61.113 (a) & (b) to operate commercially a 
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small unmanned vehicle (55lbs or less) in aerial photography and videography, motion picture, 

television operations over certain areas of the United States.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing Brian D. Manis to safely, efficiently, and economically operate the DJI 

Phantom 3 Advanced commercially within the NAS. 

In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of 2012, Section 333, Brian D Manis respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R. §21, subpart H; 14 C.F.R 

45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 

91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2); 91.417 (a) & 

(b); and 61.113 (a) & (b), and permit Brian D. Manis to operate the DJI Phantom 3 Advanced

commercially for the purpose of conducting aerial video and photography of Real Estate 

Properties (for homeowners, realtors, home builders, home contractors and / or home 

inspectors for real estate marketing and inspection of home exteriors) as well as filming of 

special events, film sets, scripted and unscripted television sets and landscape over certain 

areas of the United States. 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

This exemption will permit Brian D. Manis to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography of Real Estate Properties, 

filming of special events, film and commercial sets, scripted and unscripted television sets.

Respectfully Submitted by,

Brian D. Manis

Manis Brand Creative Inc

1285 Brookside Dr.

Germantown, TN 38138

Email: brian.manis1@gmail.com

Website: manisbrand.com