July 28, 2015

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 LandBros Aerial Photography, LL.C.

Dear Sir or Madam LandBros Aerial Photography, LLC. hereby submits to the Federal Aviation Administration an exemption petition for additional aircraft system coverage. LandBros Aerial Photography, L.L.C. requests to operate two 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 Ecemptions Filed under Section 333" as described as of this date at the FAA website at https://www.faa.gov/uas/legislative proerams/section 333/how to file a petition/

Purpose for the Amendment: LandBros Aerial Photography, L.LC. desires to utilize two additional unmanned aircraft systems (UAS), herein described, to accompfish aerial photography of industrial and commercial facilities. These aircraft systems include the DJI Phantom 3 Professional and the DJI S900.

Contact Information: LandBrosAerial Photography PO Box 840240 New Orleans, LA 70184 Office: 225-366-7005 Mobile: 225-803-6642 Email: dannv.landrv@la n dbros.com1. Aircraft Descrlption: DJI Phantom 3 Professional
Design and Operational Characteristics: • LandBros Aerial Photography, L.L.C. plans to additionally operate a DJI Phantom 3 Professional 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 1280 g (2.822 Ibs.). • The Phantom 3 Professional 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 35mph. • The Phantom 3 Professional includes a Failsafe Function. It activates if the Remote Control is powered off, the Phantom 3 Professional has flown outside effective control range, the signal between the Phantom 3 Professional and the Remote Control is blocked, or if there is interference causing a signal problem. When activated, the Failsafe Function automatically flies the Phantom 3 Professional 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 3 Professional 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 LandBros or LandBros' Clients. These performance limitation requirements are included in the UAS Operating Procedure contained in Appendix A herein.

Manufacturer's Documentation: Detailed manufacturer's design information (current to this date) is contained the in the following manuals in the appendices at the end of this document:
• Appendix B— Phantom 3 Professional Specifications
• Appendix C— Phantom 3 Professional Quick Start Guide
• Appendix D— Phantom 3 Professional User Manual
• Appendix E— Phantom Pilot Training Guide

2. Aircraft Description: DJI 5900 Design and Operational Characteristics: • LandBros Aerial Photography, L.L.C. plans to additionally operate a DJI S900 comprisedof an unmanned aircraft and a transportable ground station. This aircraft is a hexa

### copter design with gross weight (battery and propellers included) of 6800g (14.991 Ibs.).

~• The S900 has a Sony A7r or Panasonic GH4 camera for capturing aerial still photographs and videos. • It is equipped with six rotors that are driven by battery-powered electric motors. Maximum airspeed is 35 mph. • The S900 includes a Failsafe Function. It activates if the Remote Control is powered off, the S900 has flown outside effective control range, the signal between the S900 and the Remote Control is blocked, or ifthere is interference causing a signal problem. When activated, the Failsafe Function automatically flies the S900 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 S900 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.tawithin.the confines of the property to be surveyed for LandBros or LandBros' Clients. These perFormance limitation requirements are included in the UAS Operating Procedure contained in Appendix A herein.

Manufacturer's Documentation: Detailed manufacturer's design information (current to this date) is contained the in the following manuals in the appendices at the end of this document:
• Appendix F—S900 & Flight Controller Specifications
• Appendix G—S900 Flight Controller Quick Start Guide
• Appendix H —S900 User Manual

3. Procedures for Ensuring UAS Is In a Condition Safe for Flight
Preflight Checks: At a minimum, the following items will be checked prior to initiating any operation. (See Appendix A in this document for detailed procedures, LandBros 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 of flight and altitudes for each leg of the flight clearly marked. • Flight path is at least 500 ft. 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 LandBros 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-SD card has been inserted. • Gimbal is functioning as normal. • Compass has been calibrated. • Flight radius and altitude limits have been set with the Phantom 3 Professional and S900 Assistant software, not to exceed 200 ft. AGL altitude, and radius limited to the property boundaries of LandBros or LandBros 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. • AII site required safety permits are approved in in possession of the PIC. • Motors can start and function as normal. • Flight Indicator Lights on the aircraft verify that the Home Point is set to current location. • Record the Preflight Check, date and sign, and file it in the Equipment Inspection and Maintenance Record Book.

4. 

### Radio Frequency (RF) Spectrum for Control: DJI Phantom 3 Professional
The Remote Control ground station operating frequency is 2.400 — 2.483 GHz and is FCC compliant with communication distance in an open area of 2000m.
Operating Frequency 2.400

— 2.483 GHz Communication Distance (open area) FCC Compliance: 2000m Receiver Sensitivity (1%PER) -101dBm +2 sBm Transmitter Power FCC Compliance: 20 dBm Working Voltage 1.2A @7.4V Built-in LiPo Battery Working CurrentJCapacity 7.4V, 6000mAh

S. 

### Radio Frequency (RF) Spectrum for Control: DJI 5900
The Remote Control ground station operating frequency is 2.400 — 2.472 GHz and is FCC compliant with communication distance in an open area of 800m.
Operating Frequency 2.400 — 2.472 GHzCommunication Distance (open area) FCC Compliance: 800m Receiver Sensitivity (1%PER) -150 dBm +2 sBm Transmitter Power FCC Compliance: 30 dBm Working Voltage 4.8A @6V Built-in NiMH Battery Working Current/Capacity 6V, 1800mAh

6. Description of Intended UAS Operations
• 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 the airport's management is obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the Certificate of Waiver or Operation (COA). • The Phantom 3 Professional and S900 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 fall risk for workers and reducing potential for manned aircraft accidents. • As described in "2. Procedures for Ensuring UAS Is in a Condition Safe for Flight", altitude and distance limits will be entered into the Phantom 3 Professional and S900 Assistant software prior to commencement of flight. This will restrict the operation to LandBros Client property. The Failsafe Function integral with the Phantom 3 Professional and S900 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. LandBros' respect for compliance with these procedures is vital to assuring positive Client relationships and continuing business. AII safety procedures for personnel will be strictly adhered to as well as all laws and regulations.

7. Proposed Speed, Altitude, Visibility and Distances
Speed: The Phantom 3 Professional and S900 is capable of a maximum speed of 15m/s (35 mph). In order to conserve power, and thereby maximize flight time, and to assure good quality still photographs and video, the Phantom 3 Professional and S900 will be operated at a slow speed along the flight path, typically 2m/s (4.47 mph) or below.

FjHigher 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 200 ft. AGL are adequate for the complete range 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 the Phantom 3 Professional and S900 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 Phantom 3 Professional and S900 to follow the preplanned flight path within the property boundaries.
The Phantom 3 Professional and S900 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 the PIC encounters unpredicted obstacles or emergencies. Safe descent and landing procedures will be followed in accordance with operating documents.

S. Description of the Area of Intended Operations
As described in "5. Description of Intended UAS Operations", the Phantom 3 Professional and S900 operation will be restricted to LandBros Client property and not taken into public areas. LandBros and Client personnel on the site will be made fully aware of the operation prior to commencement of operations.

9. 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 the airport's management is obtained, and the operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the Certificate of Waiver or Operation (COA).

10. 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 Phantom 3 Professional and S900 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 available at LandBros Client sites.11. Procedures for Preflight Safety Assessment
Prior to each fiight, the PIC will inspect the Phantom 3 Professional and S900, including the ground control station, in accordance with the Preflight Checklist (see "2. Procedures for Ensuring UAS Is In a Condition Safe for Fiight"). If the Preflight Check indicates any unsafe conditions or a non-functioning safety-critical part, the flight will not commence until the needed maintenance is performed and a satisfactory Preflight Check can be completed. AII maintenance and alterations performed will be documented and fifed in the Equipment Inspection and Maintenance Record Book.

12. Notifications
As required, a Notice to Airmen (NOTAM) will be requested not more than 72 hours in advance and not less than 48 hours priorto an operation. In addition, any notifications required by the FAA Flight Standards District Office will be made.

13. Certiflcate of Waiver or Authorization (COA)
Prior to conducting any operations, an AirTraffic Organization (ATO) issued Certificate of Waiver or Operation (COA) will be obtained for each aircraft. Services will start with one aircraft, with additional units added as needs for operations increase over time. 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 will be as large as practicable.

PUBLIC BENEFIT Granting this petition would continue to benefit the public in the following ways:
Public Safety: Common practice for industrial facility construction projects and periodic site-wide industrial facility visual assessment involves utifization of manned aircraft. The potential risk to life and property is order of magnitudes less for use of a small unmanned aircraft system as compared to conventional aerial photography by manned fixed wing aircraft.
• Industrial Safety: In order to accompiish inspections of difficuit to access areas at high elevations requires either erection of scaffoiding 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 uitimate protection, however, would be to not involve personnel in such activity and instead compiete 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 industriai facilities results in burning less fuel thereby saving energy and reducing emissions of combustion gases.
increase in Quality of Data: Higher resofution 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 industriai facifities, creating a more efficient and safe workpiace.

• Increased Safety: Higher safety precautions by using updated technofogy inciuding more efficient and safer aircraft systems. This inciudes 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 Phantom 3 Professional and S900 unmanned aircraft system that assure that safety to the pubiic and safety of the National Airspace System (NAS) is not adversefy affected are the following:
• Credentials and training for the Pilot in Command (PIC), along with detailed operating procedures, assure that the 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 verbaily at ail times, assures fuil operationai controi.
• Detailed operations and maintenance procedures, including a Preflight Checklist, provide assurance of inechanical integrity and full functioning of Phantom 3 Professional and S900 unmanned aircraft system prior to commencement of any operation.

E3SUMMARY FOR PUBLICATION IN FEDERAL REGISTER

Petition for Amendment

Docket No.:FAA-2015-0717
Petitioner: LandBros 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 two additional unmanned aircraft systems (UAS), the DJI Phantom 3 Professional and DJI S900 to accomplish higher quality aerial photography, surveys and assessments of industrial and commercial facilities.

Respectfully

Daniel P. Landry Owner LandBros Aerial Photography, L.L.C.