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

R E: 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 Regulati ons 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 oper ate 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 inspecti on 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.com1285 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

p roduction 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 televisi on, film and the web for commercial, personal and non

- profit mu lti

- 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 a nd 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, appr aisals

• 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 i n 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,

a nd 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, Regist ration 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 provide1285 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 convent ional 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 w ill 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. Flig hts 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 act ivities. 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
requeste d 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
radi us 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 up

to

- date information on the particular UA S to be operated.

11. Observer and pilot will at all times be able to communicate by voice.1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 4 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 withi n 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 oper ation 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.1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 5 14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regula tion requires that w hen marks include only th e 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 ca bin, 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, a n 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 t he 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 UA S 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 c ontrast 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 dete rmining 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, unl ess 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.1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 6 The equiva lent 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, 87 38, 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 fli ght manuals will not be provided for the aircraft an e xemption 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 initiatio n 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.

s U ASs 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 w ill 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 th an 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 alt itudes 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 wh ere 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 flight1285 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

appropr iate 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, conf irming 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

c onditions 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. Give n 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 owner s 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 happ ens first. This restriction would be more than adequate to return the sUAS to its planned landing zo ne 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 onb oard 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 flyin g 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, 9797 A, 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 se ction 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.(S ee 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 la nd 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 performe d. 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 non

commercial 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 o perated 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 i ncluding 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 fo r 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.

Satis faction 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 j ustification 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 pub lic 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.

U se of the DJI Phantom 3 Adva nced 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 31285 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 B enefit from the Efficiency of the DJI Phantom 3 Advanced. By using battery power and electric motors, the DJI Phantom 3 Advanced produce s no air pollution, and is the most viable environmentally conscious alternative to the internal combustion engine aircr aft 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 footprin t 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 pollutio n 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 airc raft, 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 typica lly conduct similar operations weighing at l east 4,0 00 pounds or more

.

ECONOMIC BENEFIT

Performing Aerial Video and Photography Op erations 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 gro wth 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 e mployees 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 a1285 Brookside Dr. Germantown, TN 38138 | www.manisbrand.com | 310.497.3433 | brian.manis1@gmail.com 11 small unmanned vehicle (55lbs or less) in aerial photography a nd 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 economic ally operate the DJI Phantom 3 Advanced commercially within the NAS.

I n 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
P etition 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 fi lming of special events, film sets, scripted and unscripted television sets and landscape over certain areas of the United States.

SUMMARY THAT CAN BE PU BLISHED 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 unscrip ted 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