FROM:

Lance Houston, J.D., LL.M.

D/B/A Lance Houston Photography, Inc. 709 Maple Street, #2

Fall River, MA 02720

Tel: (617) 420-2372

Email: lancehouston@hotmail.com

Web: www.lancehouston.com

TO:

DOCKET OPERATIONS

ROOM W12140 OF THE WEST BUILDING GROUND FLOOR

1200 NEW JERSEY AVENUE, SE. WASHINGTON, DC, 20590

Regulatory Docket No. FAA-2015-3202

PETITION FOR EXEMPTION OF:

Lance Houston Photography, Inc.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14

OF THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 11295)

Submitted October 27, 2015

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I. The Reasons Why Granting Lance Houston Photography, Inc.'s Request

Serves The Public Interest; & How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Lance Houston

Photography, Inc. to safely, efficiently, and economically perform aerial video and

photography of real estate, social events and civic landscape over certain areas of the

United States. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of

the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the

benefits of Lance Houston Photography, Inc.'s proposed operation of the DJI Phantom 3

UAS will be realized without implicating any privacy issues.

● The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial

imagery. By reducing the amount of manned aircraft needed to perform aerial

acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS 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.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced.

The DJI Phantom 3 UAS do not require an airport to takeoff or land. Likewise, a

reduction of manned aircraft conducting aerial video and photography missions would

result in fewer aircraft that must be handled by air traffic control during the ground,

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

● The Public Benefits From The Safety And Efficiency Of The DJI Phantom 3 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft,

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. By

using battery power and electric motors, the DJI Phantom 3 UAS produce no air

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

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial

video and photography, while burning approximately 20-30 gallons per hour of leaded

aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery

powered electric motors, rather than an internal combustion engine.

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