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/legislativeproerams/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 ndbros.com 
1. 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 comprised 

of an unmanned aircraft and a transportable ground station. This aircraft is a hexacopter 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 GHz 
Communication 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. 

Fj 
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 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. 

E3 
SUMMARY 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.