March 14, 2016 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, SE 

Room W12-140, West Building Ground Floor 

Washington, D.C. 20590-0001 

Subject: Petition to the FAA for Amendment to Docket No. FAA-2015-0717 

Land Bros Aerial Photography, L.L.C. 

Dear Sir or Madam 

Land Bros Aerial Photography, L.L.C. hereby submits to the Federal Aviation Administration an exemption 

petition for additional aircraft system coverage. LandBros Aerial Photography, L.L.C. requests to operate 

eleven additional aircraft systems (UAS) that are currently not covered in Docket No. FAA-2015-0717. 

This letter provides requested information as listed in the FAA's "Public Guidance for Petitions for 

Exemptions Filed under Section 333" as described as of this date at the FAA website at 

https:/ fwww. faa.govjuasjlegislative_programs/section_333/how to file a_petition/ 

Purpose for the Amendment: 

LandBros Aerial Photography, L.L.C. desires to utilize additional unmanned aircraft systems (UAS), herein 

described, to accomplish aerial photography of industrial and commercial facilities. These aircraft 

systems include: 

• DJI Phantom 4 

• DJI S1000 

• DJI Agras MG-1 

• DJIInspire 

• Trimble UX5 

• Trimble UX5HP 

• Trimble ZX5 

• Tuffwing- UAV Mapper 

• 3DR Solo 

• 3DR Iris+ 

• Aeryon Labs - Aeryon Skyranger 

Contact Information: 

LandBros Aerial Photography 

PO Box 840240 

New Orleans, LA 70184 

Office: 225-366-7005 

Mobile: 225-803-6642 

Email: danny.landry@landbros.com 

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1. Aircraft Descriptions: 

a. Aircraft Description: DJI Phantom 4 

Design and Operational Characteristics: 

• LandBros Aerial Photography, L.L.C. plans to additionally operate a DJI Phantom 4 

comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a quad-copter design with gross weight (battery and propellers included) of 1380 

g (3.0423 lbs.). 

• The Phantom 4 has an integrated camera for capturing aerial sti ll photographs and 

videos. 

• It is equipped with four rotors that are driven by battery-powered electric motors. 

Maximum airspeed is 44.73 mph. 

• The Phantom 4 includes a Failsafe Function. It activates if the Remote Control is 

powered off, the Phantom 4 has flown outside effective control range, the signal 

between the Phantom 4 and the Remote Control is blocked, or if there is 

interference causing a signal problem. When activated, the Failsafe Function 

automatically flies the Phantom 4 back to the Home Point (the start location) and 

lands it. If GPS mode is not active, the Failsafe Function will execute a controlled 

descend and automatic landing. 

• Through the Phantom 4 Assistant software, each flight operation will be 

programmed with a maximum radius distance and maximum altitude from the 

Home Point such that the flight control system will limit operations to within the 

confines of the property to be surveyed for Land Bros or Land Bros' Clients. 

b. Aircraft Description: DJI SlOOO 

Design and Operational Characteristics: 

• LandBros Aerial Photography, L.L.C. plans to additionally operate a DJI 51000 

comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a octo-copter design with gross weight (battery and propellers included) of 7900g 

(17.4171bs.). 

• The 51000 has a Sony A7r or Panasonic GH4 camera for capturing aerial still 

photographs and videos. 

• It is equipped with eight rotors that are driven by battery-powered electric motors. 

Maximum airspeed is 35 mph. 

• The 51000 includes a Failsafe Function. It activates if the Remote Control is 

powered off, the 51000 has flown outside effective control range, the signal 

between the 51000 and the Remote Control is blocked, or if there is interference 

causing a signal problem. When activated, the Failsafe Function automatically flies 

the 51000 back to the Home Point (the start location) and lands it. If GPS mode is 

not active, the Failsafe Function will execute a controlled descend and automatic 

landing. 

• Through the 51000 Assistant software, each flight operation will be programmed 

with a maximum radius distance and maximum altitude from the Home Point such 

that the flight control system will limit operations to within the confines of the 

property to be surveyed for Land Bros or Land Bros' Clients. 

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c. Aircraft Description: DJI Agras MG-1 

Design and Operational Characteristics: 

• LandBros Aerial Photography, L.L.C. plans to additionally operate a DJI Agras MG-1 

comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a octo-copter design with gross weight (battery and propellers included) of 2250 g 

(4.96 lbs.). 

• The Agras MG-1 has an integrated camera for capturing aerial still photographs and 

videos. 

• It is equipped with eight rotors that are driven by battery-powered electric motors. 

Maximum airspeed is 49.2 mph. 

• The Agras MG-1 includes a Failsafe Function. It activates if the Remote Control is 

powered off, the Agras MG-1 has flown outside effective control range, the signal 

between the Agras MG-1 and the Remote Control is blocked, or ifthere is 

interference causing a signal problem. When activated, the Failsafe Function 

automatically flies the Agra s MG-1 back to the Home Point (the start location) and 

lands it. If GPS mode is not active, the Failsafe Function will execute a controlled 

descend and automatic landing. 

• Through the Agras MG-1 Assistant software, each flight operation will be 

programmed with a maximum radius distance and maximum altitude from the 

Home Point such that the flight control system will limit operations to within the 

confines of the property to be surveyed for Land Bros or Land Bros' Clients. 

d. Aircraft Description: DJIInspire 1 Pro 

Design and Operational Characteristics: 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a DJIInspire 1 Pro 

comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a quad-copter design with gross weight (battery and propellers included) of 3400g 

{7.5 1bs.). 

• The Inspire 1 Pro has a integrated camera for capturing aerial still photographs and 

videos. 

• It is equipped with four rotors that are driven by battery-powered electric motors. 

Maximum airspeed is 40 mph. 

• The Inspire 1 Pro includes a Failsafe Function. It activates if the Remote Control is 

powered off, if the Inspire 1 Pro has flown outside effective control range, the signal 

between the Inspire 1 Pro and the Remote Control is blocked, or if there is 

interference causing a signal problem. When activated, the Failsafe Function 

automatically flies the Inspire 1 Pro back to the Home Point (the start location) and 

lands it. If GPS mode is not active, the Failsafe Function will execute a controlled 

descend and automatic landing. 

• Through the Inspire 1 Pro Assistant software, each flight operation will be 

programmed with a maximum radius distance and maximum altitude from the 

Home Point such that the flight control system wi ll limit operations to within the 

confines of the property to be surveyed for Land Bros or Land Bros' Clients. 

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e. Aircraft Description: Trimble UXS 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a Trimble UXS 

comprised of an unmanned aircraft and a transportable ground station . This aircraft 

is a fixed wing design with gross weight (battery and propellers included) of 2500g 

(S.Sibs.). 

• The Trimble UXS has an integrated camera for capturing aerial sti ll photographs and 

videos. 

• It is equipped with one battery powered motor. Maximum airspeed is 50 mph. 

• The UXS includes a Failsafe Function. It activates if the control unit is powered off, 

the aircraft has flown outside effective control range, the signal between the aircraft 

and the control station is blocked, or if there is interference causing a signal 

problem. When activated, the Failsafe Function automatically flies the aircraft back 

to the Home Point (the start location) and lands it. 

• Through the UXS control unit, each flight operation will be programmed with a 

maximum radius distance and maximum altitude from the Home Point such that the 

flight control system will limit operations to within the confines of the property to 

be surveyed for Land Bros or Land Bros' Clients. 

f. Aircraft Description: Trimble UXSHP 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a Trimble UXSHP 

comprised of an unmanned aircraft and a transportable ground station . This aircraft 

is a fixed wing design with gross weight (battery and propellers included) of 2900g 

(6.4 lbs.). 

• The Trimble UXSHP has an integrated camera for capturing aerial still photographs 

and videos. 

• It is equipped with one battery powered motor. Maximum airspeed is 53mph. 

• The UXSHP includes a Failsafe Function. It activates if the control unit is powered 

off, the aircraft has flown outside effective control range, the signal between the 

aircraft and the control station is blocked, or if there is interference causing a signal 

problem. When activated, the Failsafe Function automatically flies the aircraft back 

to the Home Point (the start location) and lands it. 

• Through the UXSHP control unit, each flight operation will be programmed with a 

maximum radius distance and maximum altitude from the Home Point such that the 

flight control system will limit operations to within the confines of the property to 

be surveyed for Land Bros or LandBros' Clients. 

g. Aircraft Description: Trimble ZXS 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a Trimble ZXS 

comprised of an unmanned aircraft and a transportable ground station . This aircraft 

is a hexa-copter design with gross weight (battery and propellers included) of SOOOg 

{lllbs.). 

• 

• 

• 

The Trimble ZXS has an integrated camera for capturing aerial still photographs and 

videos. 

It is equipped with six rotors that are driven by battery-powered electric motors . 

The ZXS includes a Fa ilsafe Function. It activates ifthe control unit is powered off, 

the aircraft has flown outside effective control range, the signal between the aircraft 

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and the control station is blocked, or if there is interference causing a signal 

problem. When activated, the Failsafe Function automatically flies the aircraft back 

to the Home Point (the start location) and lands it. 

• Through the ZXS control unit, each flight operation will be programmed with a 

maximum radius distance and maximum altitude from the Home Point such that the 

flight control system will limit operations to within the confines of the property to 

be surveyed for Land Bros or LandBros' Clients. These performance limitation 

requirements are included in the UAS Operating Procedures contained in Appendix 

A herein. 

h. Aircraft Description: Tuffwing UAV Mapper 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a Tuffwing UAV 

Mapper comprised of an unmanned aircraft and a transportable ground station. 

This aircraft is a fixed wing design with gross weight (battery and propellers 

included) of 2000g (4.4 lbs.). 

• The Tuffwing UAV Mapper has an integrated camera for capturing aerial still 

photographs and videos. 

• It is equipped with one battery powered motor. Maximum airspeed is 44.7 mph. 

• The Tuffwing UAV Mapper includes a Failsafe Function. It activates if the control 

unit is powered off, the aircraft has f lown outside effective control range, the signal 

between the aircraft and the control station is blocked, or if there is interference 

causing a signal problem. When activated, the Fai lsafe Function automatically flies 

the aircraft back to the Home Point (the start location) and lands it. 

• Through the Tuffwing UAV Mapper control unit, each flight operation will be 

programmed with a maximum radius distance and maximum altitude from the 

Home Point such that the flight control system will limit operations to within the 

confines of the property to be surveyed for Land Bros or Land Bros' Clients. 

i. Aircraft Description: 3DR Solo 

Design and Operational Characteristics: 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a 3DR Solo 

comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a quad-copter design with gross weight (battery and propellers included) of 1800g 

(3.9 1bs.). 

• 

• 

The 3DR Solo has an integrated camera for capturing aerial sti ll photographs and 

videos. 

It is equipped with four rotors that are driven by battery-powered electric motors . 

Maximum airspeed is 55 mph. 

• The 3DR Solo includes a Failsafe Function. It activates if the Remote Control is 

powered off, if the 3DR Solo has flown outside effective control range, the signal 

between the 3DR Solo and the Remote Control is blocked, or if there is interference 

causing a signal problem. When activated, the Failsafe Function automatically flies 

the 3DR Solo back to the Home Point (the start location) and lands it. If GPS mode is 

not active, the Failsafe Function will execute a controlled descend and automatic 

landing. 

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• Through the 3DR Solo Assistant software, each flight operation wi ll be programmed 

with a maximum radius distance and maximum altitude from the Home Point such 

that the flight control system will limit operations to within the confines of the 

property to be surveyed for LandBros or Land Bros' Clients. 

j. Aircraft Description: 3DR Iris+ 

Design and Operational Characteristics: 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a 3DR Iris+ 

comprised of an unmanned aircraft and a transportable ground station. This aircraft 

is a quad-copter design with gross weight (battery and propellers included) of 1282g 

(2.81bs.). 

• The 3DR Iris + has an integrated camera for capturing aerial still photographs and 

videos. 

• It is equipped with four rotors that are driven by battery-powered electric motors. 

Maximum airspeed is 40 mph. 

• The 3DR Iris+ includes a Failsafe Function. It activates if the Remote Control is 

powered off, if the 3DR Iris+ has flown outside effective control range, the signal 

between the 3DR Iris+ and the Remote Control is blocked, or if there is interference 

causing a signal problem. When activated, the Failsafe Function automatically flies 

the 3DR Iris+ back to the Home Point (the start location) and lands it. If GPS mode 

is not active, the Failsafe Function will execute a controlled descend and automatic 

landing. 

• Through the 3DR Iris+ Assistant software, each flight operation will be programmed 

with a maximum radius distance and maximum altitude from the Home Point such 

that the flight control system will limit operations to within the confines of the 

property to be surveyed for Land Bros or Land Bros' Cl ients. 

k. Aircraft Description: Aeryon Labs- Aeryon Skyranger 

Design and Operational Characteristics: 

• Land Bros Aerial Photography, L.L.C. plans to additionally operate a Aeryon 

Skyranger comprised of an unmanned aircraft and a transportable ground station. 

This aircraft is a quad-copter design with gross weight (battery and propellers 

included) of 2400g {5.3 lbs.). 

• 

• 

The Aeryon Skyranger has an integrated camera for capturing aerial still 

photographs and videos. 

It is equipped with four rotors that are driven by battery-powered electric motors . 

Maximum airspeed is 40 mph. 

• The Aeryon Skyranger includes a Failsafe Function. It activates if the Remote 

Control is powered off, if the Aeryon Skyranger has flown outside effective control 

ra nge, the signal between the Aeryon Skyranger and t he Remote Control is blocked, 

or if there is interference causing a signal problem. When activated, the Failsafe 

Function automatically flies the Aeryon Skyranger back to the Home Point (the start 

location) and lands it. If GPS mode is not active, the Failsafe Function will execute a 

controlled descend and automatic landing. 

• Through the Aeryon Skyranger Assistant software, each flight operation wi ll be 

programmed with a maximum radius distance and maximum altitude from the 

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Home Point such that the flight control system will limit operations to within t he 

confines of the property to be surveyed for Land Bros or Land Bros' Clients. 

2. Procedures for Ensuring UAS Is In a Condition Safe for Flight 

Preflight Checks: 

At a minimum, the fo llowing items will be checked prior to initiating any operation. (See 

Appendix A in this document for detailed procedures, Land Bros Aerial Photography, 

L.L.C. Operating Procedure V1.2.1 7.28.15) 

• Operations must be in daylight hours and under visual meteorological 

conditions (VMC). 

• Area to be surveyed is defined on a plot plan drawing with path offlight and 

altitudes for each leg of the flight clearly marked . 

• Flight path is at least 500ft. from all non-participating persons, vessels, 

vehicles and structures unless protective barriers or structures are present, 

or permission is granted or such operations present no hazard to the Pilot in 

Command, the Visual Observer, trainees, and other essential persons. 

• Flight plan and schedule has been reviewed with site leadership and 

communicated to all Land Bros Aerial Photography, L.L.C. and Client 

personnel in the area. 

• Remote control, smart battery, range extender, and ground station monitor 

are fully charged. 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Propellers are mounted correctly . 

Damping absorbers are in good condition, not dry-rotted or worn . 

Anti-drop kits have been mounted correctly . 

Micro-SO card has been inserted . 

Gimbal(as applicable) is functioning as normal. 

Compass has been calibrated . 

Flight radius and altitude limits have been set . 

Assistant software has been set not to exceed 200ft. AGL altitude, and 

radius limited to the property boundaries of Land Bros or Land Bros Client 

site. 

The Visual Observer (VO) is stationed at the required initial observation 

point according to the flight plan and in view of the Pilot in Command (PIC) 

and has means for continual verbal communication. 

There are no inoperable components . 

All site required safety permits are approved in in possession of the PIC. 

Motor(s) can start and function as normal. 

Flight indicator lights on the aircraft verify that the Home Point is set to 

current location. 

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• Record the Preflight Check, date and sign, and file it in the Equipment 

Inspection and Maintenance Record Book. 

3. Description of Intended UAS Operations 

• Operations will be restricted to Class G airspace unless a site specific Civil Certificate of 

Authorization(COA) and accompanying Letter of Agreement( LOA) have been granted. 

• No operations will occur within 5 miles of a non-towered airport reference point as 

denoted on a current FAA-published aeronautical chart, unless a letter agreement with 

the airport's management is obtained, and the operation is conducted in accordance 

with a Notice to Airman (NOT AM) as required by the Certificate of Waiver or Operation 

(COA). 

• The DJI Phantom 4, DJI S1000, DJI Agras MG-1, DJ I Inspire, Trimble UXS, Trimble UXSHP, 

Trimble ZXS, Tuffwing - UAV Mapper, 3DR Solo, 3DR Iris + and the Aeryon Labs Aeryon 

Skyranger will be utilized to survey industrial and commercial facilities. The use of small 

unmanned aircraft systems provides more immediate and thorough information than is 

presently available by other means. Expense for scaffolding, rental of manned aircraft, 

rental of equipment, and lost time is saved . Safety is improved by reducing fa ll risk for 

workers and reducing potent ial for manned aircraft accidents. 

• Altitude and distance limits will be entered into the DJI Phantom 4, DJI S1000, DJI Agras 

MG-1, DJIInspire, Trimble UXS, Trimble UXSHP, Trimble ZXS, Tuffwing- UAV Mapper, 

3DR Solo, 3DR Iris + and the Aeryon Labs Aeryon Skyranger assistant software prior to 

commencement of flight. This will restrict the operation to Land Bros Client property. 

The Failsafe Function integral with the DJI Phantom 4, DJISlOOO, DJI Agras MG-1, DJI 

Inspire, Trimble UXS, Trimble UXSHP, Trimble ZXS, Tuffwing- UAV Mapper, 3DR Solo, 

3DR Iris+ and the Aeryon Labs Aeryon Skyranger will assure this aircraft stays within 

the area deemed safe for operation. 

• Industrial facilities of the type mentioned above have strict safety procedures, which 

must be satisfied. Land Bros' respect for compliance with these procedures is vital to 

assuring positive Client relationships and continuing business. All safety procedures for 

personnel wi ll be strictly adhered to as well as all laws and regulat ions. 

4. Proposed Speed, Altitude, Visibility and Distances 

• Speed: 

• The DJI Phantom 4, DJ I S1000, DJI Agras MG-1, DJI Inspire, Trimble UXS, Trimble 

UXSHP, Trimble ZXS, Tuffwing - UAV Mapper, 3DR Solo, 3DR Iris+ and the 

Aeryon Labs Aeryon Skyranger is capable of a maximum speeds as listed in 

Section 1 of this document. In order to conserve power, and thereby maximize 

flight time, and to assure good quality still photographs and video, the DJI 

Phantom 4, DJ I S1000, DJI Agras MG-1, DJ I Inspire, Trimble UXS, Trimble UXSHP, 

Trimble ZXS, Tuffwing - UAV Mapper, 3DR Solo, 3DR Iris + and the Aeryon Labs 

8 
Aeryon Skyranger will be operated at a slow speed along the flight path, 

typically 2m/s (4.47 mph) or below. Higher speeds may be used from time to 

time when traversing a section of the property of no interest and not included in 

a given study. 

• Altitude: 

• Altitudes below 200ft. AGL are adequate for the complete ra nge of facilities and 

structures to be surveyed. The integral Flight Control System will be set to limit 

the altitude to always be below that level. 

• Distance: 

• The integral Flight Control System will be set to limit the radial distance from 

the Home Point (point of flight commencement) such that t he DJI Phantom 4, 

DJI S1000, DJI Agras MG-1, DJIInspire, Trimble UXS, Trimble UXSHP, Trimble 

ZXS, Tuffwing - UAV Mapper, 3DR Solo, 3DR Iris+ and the Aeryon Labs Aeryon 

Skyranger will stay within the boundary of the property lines. The PIC will 

operate the equipment to assure those limits are not reached and will 

maneuver the DJI Phantom 4, DJI S1000, DJI Agras MG-1, DJIInspire, Trimble 

UXS, Trimble UXSHP, Trimble ZXS, Tuffwing- UAV Mapper, 3DR Solo, 3DR Iris+ 

and the Aeryon Labs Aeryon Skyranger to follow t he preplanned flight path 

within the property boundaries. 

• The DJI Phantom 4, DJI S1000, DJI Agras MG-1, DJIInspire, Trimble UXS, Trimble 

UXSHP, Trimble ZXS, Tuffwing - UAV Mapper, 3DR Solo, 3DR Iris + and the 

Aeryon Labs Aeryon Skyranger will not be operated less than 500 feet below or 

less than 2,000 feet horizontally from a cloud when visibility is less than 3 

statute miles from the PIC. 

• Operations will be aborted immediately if t he PIC encounters unpredicted obstacles or 

emergencies. Safe descent and landing procedures wi ll be fo llowed in accordance with 

operating documents. 

5. Description of the Area of Intended Operations 

• As described in "3. Description of Intended UAS Operations", the DJI Phantom 4, DJI 

S1000, DJI Agras MG-1, DJIInspire, Trimble UXS, Trimble UXS HP, Trimble ZXS, Tuffwing 

- UAV Mapper, 3DR Solo, 3DR Iris+ and the Aeryon La bs Aeryon Skyranger operation 

will be restricted to Land Bros Client property and not taken into public areas. Land Bros 

and Client personnel on the site will be made fu lly aware of the operation prior to 

commencement of operations. 

6. Proximity of Airports 

• 

• 

Operations will be restricted to Class G airspace . 

No operations will occur within 5 miles of a non-towered airport reference point as 

denoted on a current FAA-published aeronautical chart, unless a letter agreement with 

t he airport's management is obtained, and the operation is conducted in accordance 

9 
with a Notice to Airman (NOT AM) as required by t he Certificate of Waiver or Operation 

{COA). 

7 . Operation within Visual line-of-Sight (VLOS) 

• In addition to the PIC, all operations will include a Visual Observer (VO). The VO will 

assure that the OJI Phantom 4, DJ I 51000, OJI Agras MG-1, DJI Inspire, Trimble UXS, 

Trimble UXSHP, Trimble ZXS, Tuffwing- UAV Mapper, 3DR Solo, 3DR Iris+ and the 

Aeryon Labs Aeryon Skyranger are always within their visual line-of-sight (VLOS), as well 

as the PIC's, at all times. The VO and the PIC will be able to communicate verbally at all 

times utilizing two-way radios avai lable at Land Bros Client sites. 

8. Procedures for Preflight Safety Assessment 

• Prior to each flight, the PIC will inspect the OJI Phantom 4, OJI S1000, OJ I Agras MG-1, 

DJ I Inspire, Trimble UXS, Trimble UXSHP, Trimble ZXS, Tuffwing - UAV Mapper, 3DR 

Solo, 3DR Iris+ and the Aeryon Labs Aeryon Skyranger, including t he ground control 

station, in accordance with the Preflight Checklist (see "2. Procedures for Ensuring UAS 

Is In a Condition Safe for Flight"). lfthe Preflight Check indicates any unsafe conditions 

or a non-functioning safety-critica l part, the flight will not commence until the needed 

maintenance is performed and a satisfactory Preflight Check can be completed. All 

maintenance and alterations performed will be documented and filed in the Equipment 

Inspection and Maintenance Record Book. 

9. Notifications 

• As required, a Notice to Airmen (NOT AM) will be requested not more than 72 hours in 

advance and not less than 24 hours prior to an operation. 

• In addition, any notifications required by the FAA Flight Standards District Office will be 

made. 

10. Certificate of Waiver or Authorization (COA) 

• Prior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Operation (COA) will be obtained for the aircraft(s). Each aircraft will be 

identified with its serial number, registered in accordance with 14 CFR part 47, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. 

Markings wi ll be as large as practicable. 

11. Public Benefit 

• Granting this petition would continue to benefit the public in the following ways: 

• Public Safety: Common practice for industrial faci lity construction projects and 

periodic site-wide industrial facility visual assessment involves utilization of 

manned aircraft. The potential risk to life and property is order of magnitudes 

10 
less for use of a small unmanned aircraft system as compared to conventional 

aeria l photography by manned fixed wing aircraft. 

• Industrial Safety: In order to accomplish inspections of difficult to access areas 

at high elevations requires either erection of scaffolding or lifting personnel by 

crane in protective enclosures to view the subject of interest. Fall protection 

gear and compliance with OSHA rules governing such work is crucial for life 

safety. The ultimate protection, however, would be to not involve personnel in 

such activity and instead complete this work with an unmanned aircraft system. 

• Energy Savings and Environmental Protection: Reduction of frequency of 

manned aircraft used to do aerial photography and surveys for construction 

sites and industrial facilities result s in burning less fuel thereby saving energy 

and reducing emissions of combustion gases. 

• Increase in Quality of Data: Higher resolution media provided by the aircraft 

systems noted in this petition for amendment, will be used to further excel the 

industry through 3D mapping of commercial and industrial facilities, creating a 

more efficient and safe workplace. 

• Increased Safety: Higher safety precautions by using updated technology 

including more efficient and safer aircraft systems. This includes flight data 

exporting, more precise position tracking and updated safety features( return to 

home, battery monitoring, and on-screen control). 

• Reasons Safety Not Adversely Affected and Is At Least Equivalent to Existing Rule 

• 

• The key features of the proposed DJI Phantom 4, DJ I S1000, DJ I Agras MG-1, DJI 

Inspire, Trimble UXS, Trimble UXSHP, Trimble ZXS, Tuffwing - UAV Mapper, 3DR 

Solo, 3DR Iris+ and the Aeryon Labs Aeryon Skyranger unmanned aircraft 

system that assure that safety to the public and safety of the National Airspace 

System (NAS) is not adversely affected are the following: 

• Credentials and training for the Pilot in Command (PIC), along with 

detailed operating procedures, assure that t he level of competency 

required for successful and safe flight operations is achieved. 

• The built-in Flight Control System, which includes a Failsafe Function, 

assures immediate return to the Home Point and safe landing under 

• 

failure scenarios, thereby preventing injury or damage. 

Visual Line-of-Sight (VLOS) operation provided by the PIC and the Visual 

Observer (VO), and their ability to communicate verbally at all times, 

assures ful l operational control. 

Detailed operations and maintenance procedures, including a Preflight Checklist, 

provide assurance of mechanical integrity and full functioning of DJI Phantom 4, DJ I 

51000, DJI Agras MG-1, DJ I Inspire, Trimble UXS, Trimble UXSHP, Trimble ZXS, Tuffwing 

- UAV Mapper, 3DR Solo, 3DR Iris+ and the Aeryon Labs Aeryon Skyranger unmanned 

aircraft system prior to commencement of any operation. 

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SUMMARY FOR PUBLICATION IN FEDERAL REGISTER 

Petition for Amendment 

Docket No.: FAA-2015-0717 

Petitioner: Land Bros Aerial Photography, L.L.C. 

Description of Relief Sought: The petitioner is seeking an amendment to Exemption No. 11681 under 

Docket No. FAA-2015-0717 to utilize eleven additional unmanned aircraft system s (UAS), listed below, 

to accomplish higher quality aerial photography, surveys and assessments of industrial and commercial 

facilities. Additional aircrafts: 

• DJI Phantom 4 

• DJI 51000 

• DJI Agras MG-1 

• DJI Inspire 

• Trimble UXS 

• Trimble UXSHP 

• Trimble ZXS 

• Tuffwing- UAV Mapper 

• 3DR Solo 

• 3DR Iris+ 

• Aeryon Labs - Aeryon Skyranger 

Daniel P. Landry 

Owner 

LandBros Aerial Photography, L.L.C. 

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