Feb 17 16 05:48p Jory Lannes

1/26/2016 

### U.S. DepartmentofTransportation,Docket Operations Ground Floor, Rm.W12-140 1200New Jersey Ave, SE Washington, DC 20590 8478646171

Jory Lanncs 2336 Praire Evanstoon IL 60201 T: 847 733 7705 

### Jory@Lannesgroup.com 

### p.2

Regarding: .FAA Exemption Rulemaking Section 333 ofthe FAAReform Act and Part 11- 14 C.F.R. 

### § 45.23(b); 14 C
.. F.R. Part21; 14 C.F.R.6l.113(a) 

### & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.15l(a); 91.203(a) 

### & (b) 9lA05(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) 

### & (b) DearSiror Madam: Lannes Group Inc., is requesting exemption from the Federal Aviation Regulations ("FARs") listed below and pursuant to the FAAModernization and Reform Act of2012 andthe procedures contained within 14 C.FR. 11. in orderto commercially operate a small. ultra lightunmanned aircraft system ("UAS"), specifically the following UAS platforms will 

### be used: DJI Phantom 

### III DJI Phantom 

### III Pro
Attachment 1 lists the technical specifications for each ofthe previously listed UAS(s). The Pilot In Command (PIC) will hold either an airline transport, commercial, private,recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by 

### a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. Lannes Group Inc., would like to expand its operations, and wishes to add the followng photography/videography services.

• Real Estate • Home Inspections Specilically, it wishes to provide aerial imaging to its customers in need ofaerialphotography/vidcography. With the advancementofInternettechnology and consumer adoption of shopping forproperties online,the demand for high-resolution aerial graphics and video is unprecedented. In addition, it wishes to be able toFeb 17 16 05:48p Jory Lannes 8478646171 p.3
perform property {primarilyroof) inspections via UAS. All UAS pertinent safety andrisk management measures 

### as specified in the FAA's Risk Management Handbook shall be complied with. A grant ofthe exemption request, by the FAA, would permitoperation ofultra lightweight and unmanned UAS to operate in predetermined areas away from the generalpublic, airports, heliports and vehicular

### traffic. primarily overindividual properties/communities for the purpose ofrecording real-estate listings (photo/video). In summary and in accordance with this request ofexemption request as authorized and outlinedby the FAA under Section 333(c) ofthe Reform Act specified for use ofUAS' for "Real Estate" purposes,Lannes Group Inc. will adhere to all FAAregulations at 

### all times and shallconduct all flight operations in strict compliance and safety protocols as mandated and required byregulations and best practices. Respectfully, werequest the grantofexemption to operate ultra light weight,remote controlled UAS's for commercial purposes as described in this request and as allowable by law. This grant ofexemption will allow the company to offer such services to private and govemement entities who have little to no experience piloting UAS's buthave a need to get images that are only possible from 

### a UAS in order to compete within an ever demanding technology driven market. Lannes Group Inc. submits that this application has been prepared by Jory Lannes (owner ofLanncs Group Joe.) and not an attorney using his personal knowledge ofexisting FARs as well as utilizing excerpts from other similar applications and assistance from Mile High Drone Services. Consequently,

### ifJory Lannes has unintentionally omitted anyrelative FARs, Lannes Group Inc., humbly request an opportnnity to submit to those accidentalomissions. The essence ofthis applicationis to declare that, Lannes Group Inc. meets and ex.cceds the FAA's expected competency for piloting the listed UASs for commercial purposes and that the UAS that we specified earlier meets andexceeds the safety requirements 

### as set forth by the Secretary ofTransportation thereby prompting the request for COAunder Section 

### 333. 

### 1. ContactInformation: Lannes Group Inc. Attn: Jory Lannes 2336 Praire Evanstoon IL 60201 

### 847 733 7705 Jory@Lannesgroup.com 

### 2. The Specific section(s) of 14 C.F.R. seeking an exemption from are: 14CFR2l; 14 C.P.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 

### 91,et seq.; 14 CFR

### 407 (a) 

### (1 ); 14 CFR 

### 409 (a) (2); and, 14 CFR

### 417 (a) & 

### (b). 

### 3. Theextent and 

### reason ofrelief: Lannes Group Inc., is seeking relieffrom existing FARs that currently prohibit theuse of UASs from operating commercially 

### lor the purpose ofaerial photography/videography in accordance with the FAA Modernization and Reform Act of2012 

### J12 P.L. 95 § 331-334. The Reform Act Subtitle B: Unmanned Aircraft Systems- (Sec. 332) "Requires the Secretary to develop a plan to accelerate safely the integration by September 30, 2015, ofcivil unmanned aircraft systems (UAScs,or drones) into the national airspace system." The company humbly requests that it be allowed to commercially operate the listed UASs during the time period the FAAis further establishing rules andregulations governing the operations ofsuchcraft.Feb 17 16 05:48p Jory Lannes 8478646171 

### p.4

The Secretary ofTransportation has been askedby Congress to, among other things, considerwhether certain unmanned aircraft systems may operate safely in the national airspace systembefore completion oftheru.lemaking required under Section 332ofthe Reform Act In making this determination, the Secretary 

### is required to determine which types of UASs do not create 

### a hazard to users ofthe KationalAirspace System or the public or pose a threat to national security in light ofthe following: The UAS's size, weight, speed, and operational capability; Operation ofthe UAS in closeproximity to airports and populated areas; and Operation ofthe UAS within visual line ofsight (VLOS) ofthc Pilot and VO Accordingly, all flights will be conducted by a PIC and aVO in accordance with FAAPolicy 

### N 8900.227 Section 14 

### "Operational Requirements for UASs" and with the following restrictions: All aircraft will be made with a UA Gross weight oflcss than 55 pounds All flights 

### will occur only during daylight hours. All flights will occur at orbelow 400 

### feet AGL 5 nautical miles from an airport having an operational control tower: or 

### 3 NM from an airport with a published instrument tlight procedure, but not an operational tower: or 2 NM from an airport without a published instmmcntJiight procedureor an operation tower; or 

### 2NM from 

### a heliport with a published instmment night procedure. For safety, no flight with winds over 10 mph. Flight only in GPS mode that allows UAS to hover in place when radio controls are released. All operations to be conducted in GPS mode only. 

### 4. How the request

### will benefitthe public as a whole: Aerial photography is becoming a critical component ofthe way 

### a company docs business. Aerial photography viaUAS allows people to geta vantagepointthat never used to bepossible 

### or economically feasible. It

### is much too dangerous and expensive to hire 

### a manned aircraft to take many aelial images thereby making the UAS option more cost effective and safer. There simply 

### is not enough UAS Pilots to cover the demand for these images, which is leading to unlicensed UAS operators which ultimately results in untrained and unqualified operators. 

### 5. Reasons why the exemption would 

### not adversely 

### affect safety; orhow the exemption would provide a level for safety at least equalto the existingrule: An exemptionwould not adversely affect saJety because this application applies only to aircraft characteristics and applications within FAA specif1ed limitations. These limitations provide for atleast an equivalent safety standard. However,the experience o[

### a certificated rated pilot allows him/her to utilize his/her experience in UAS operations thereby exceeding safety and improving airspace operations by allowing aerial imaging clients to choose an pilot thatknows how to pilot ar. aircraft safely and within regulated limits. In addition, byproviding unmanned services to the market place, there will be less ofa demand for manned operations, which will provide for safer and quieter residential aerial photography. In addition. inspecting roofs via UAS 

### will reduce the riskofpersonal injury because people who no longer have to walk on roofs which is inherently dangerous. As previously stated, all flights will be conducted by a PIC and aVO in accordance with FAAPolicy N 8900.227 Section 14 

### "OperationalRequirements for UASs" and with the following restrictions: All aircraft will be made with a UAGross weight ofless than 55 pounds All flights will occur only during daylighthours.Feb 17 16 05:49p Jory Lannes 8478646171 p.5

All !lights 

### will occur at orbelow 400 feet AGL 5 nautical miles from anairport having an operational control tower; or 3 NM from an airport with a published instrument !lightprocedure,but not an operational to,ver: or 2 NMfrom an airport without a published instrument !lightprocedure or an operation tower: or 2 NM from a heliport with a published instrument flight procedure. Extensive, pre-flightbriefings arc requiredbetween the PIC and the VO. A flight plan is required prior to each !light. All aircraft operations must be conducted within manufacturer recommended specifications. All site permissions must be obtainedprior to flight. 

### 6. Asummary the FAA maypublish in the FederalRegister: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals andTheLike. 14 C.P.R. 21, SubpartH, entitled Airworthiness Certificates, sets forthrequirements for procurement of necessary airworthiness certificates in relation to FAR §91 .203(a)(l).The size, weight and enclosed operational area ofthe listed CASspermitexemption from Part 21 because the listed UASs meets (and exceeds) an equivalent level of safety pursuant to Section 333 ofthe ReformAct. The FAAis authorizedto exempt aircraft from the airworthiness certificaterequirement under both the Act {49 U.S.C. 

### §44701 (f)) and Section 333 ofthe Reform Act. Both pieces oflegislation permitthe FAAto exempt UAS's from the airworthinec;s certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and densepopulations.The current and projected UAS's meet or exceed each ofthe elements. 14 C.P.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplatedby the FARs, this Regulation is inapplicable.
14 C.ER. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no onboardpilots
or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such manuals on location with the Pilot. The FAAhas previouslyissued exemptions to this regulation in Exemption Nos. 8607,8737,8738,9299,9299A. 9565,9565B, 10167, 10167A, 10602,10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as all UAS utilizes electronic global positioning systems with a barometric sensor. 14 C .F.R. § 91.203 (a) and (b) provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations with the Pilot.
14 C.F.R. § 45.23: Marking ofThe Aircraft. Applicable Codes ofFederalRegulation require aircraft to bemarked according to certain specifications. The listed UASs are, by defini6on,unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. f<urther, two-inch lettering is difficult to place on such small aircraft with dimensions smallerthat minimal lettering requirement. The FAAhas previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167Aand !0700. 14 C.F.R. § 61.113: Private PilotPrivileges and Limitations: PIC. Pursuant to 14 C.F.R. 

### §§ 61.113 (a) 

### & (b), private pilots are limited to non-commercial operations. The PIC can achieve an equivalent level ofsafety as achieved by current Regulations because the listedFeb 17 16 05:49p Jory Lannes 8478646171 p.6

UASs 

### do notcarry any pilots or passengers. Further, the PIC possess an FAApilot certificate, which helps his remote control piloting skills and factors in his experiencein assessing any flight risks. The risks attended to the operation ofthe listed UASs arc far less than the risk levels inherentin the commercial activities outlined in 

### 14 

### C.F.R. § 

### 61, et seq. Thus, allowing the PIC to operate the listed UASs and meet and exceed current safety levels in relation to 

### 14 C.F.R.

**~61.113** (a) & 

### (b). 14 C.P.R. 91.119: Minimum Safe Altitudes. 

### 14 C.F.R. § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. 

### It allows helicopte.rs to be operated at lower altitudes in certain conditions. The listed UASs will neveroperate at an altitude greater than 400 ft AGL. The PICwill also operate the listed UASs 

### in safe areas away from public and traffic, providing a .level ofsafety at least equivalent to 

### orbelow those in relation to minimum 

### safe altitudes. Given the size,weight, maneuverability and speed ofthe listed UASs, an equivalent or higher level of safety 

### will be achieved. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): .Ylaintcnanee Inspections. The abcve-cited Regulations require, amongst other things, aircraft owners and operators to ·'have [the] aircraft inspected 

### as prescribedin subpart 

### E ofthis part and shall betweenrequired inspections, except
as provided

### in paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter. .. '' These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to the listed UASs. However, 

### as a safety precaution the UAS which will be used willbe inspectedbefore and after each flight.


### In Summary: LannesGroup Inc., respectfully request that theFAA grantthe exemptionrequest and further volunteer any information gathered during flights in the event the FAA is interested in live field data. Lannes Group Inc., agrees and attests to adhere to any further limitations the FAAimposes, now or 

### in the future. Satisfaction of the currentcriteriaprovidedin Section 

### 333 ofthe Reform Actof2012- 

### size, weight, speed, opera6ng capabilities,proximity to airports and populated areas and operation within visual line of sight and national security

- provide more than adequatejustificationfor the grant oftherequested exemptions allowing commercial operation ofthe listed 

## uASs for commercial purposes. Lannes Group Inc.looks forward to supportthe FAA and UAS community in its questto establishproperregulations and protocols for the safe introduction ofunmanned aircraftinto the national airspace.

Jory Lannes Lanncs Group Inc. 2336 Praire Evanstoon IL60201Feb 17 16 05:50p Jory Lannes 8478646171



### Attachment I 

### DJI Phantom Ill (http:f/www.dji.com/product!phantom-3-standard/info)

Weight (including battery) 1216 g Max Ascent Speed 5 mfs 

### Max Descent Speed 3 

### m!s Max Speed 16 

### m!s (ATTI mode, no wind) Max Service Ceiling Above Sea Level6000 m (Software altitude limit: 120m above takeoffpoint) Max Flight Time Approximately 25 minutes Operating Temperature O(C) 

### to 40(C) Navigation system Built-in GPS


### DJI Phantom III Pro (bttp:lfwww.dji.comlproduct/phantom-3/spec)

Weight (Including Battery And Propellers): 1280 g Diagonal Size (Including Propellers): 590 mm Max Ascent Speed: 5 m!s Max Descent Speed: 3 m!s Hover Accuracy
• Vertical:+/- 0.1 m (when Vision Positioning is ac-tive) or+/- 0.5 m • Horizontal: 

### +1- 1.5 m Max Speed: 16m/s (ATTI mode, no wind) Max Altitude Above SeaLevel: 6000 m Operating Temperature: O(C) 

### to 40(C) GPS Mode: GPS/GLONASS p.7