September 15, 2015 Application for Section 333 sUAS Exemption

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To the FAA UAS Integration Office:

In regards to the Federal Aviation Administration’s duties to regulate aircraft, airmen, 

and airspace, and to promote safe operations of such, Land Ventures, LLC., requests an 

exemption to the Federal Aviation Regulations under the Section 333 exemption 

program.

Land Ventures, LLC., is a sole-proprietorship under the operational control of Philip 

Land, an ATP-rated pilot and Mississippi-licensed real estate agent. Land Ventures (the 

“operator” or “company”) intends the commercial operation of a small unmanned aerial 

system to capture still photographs and motion videos. The primary use will be for real 

estate marketing and evaluation of both residential and commercial properties. In 

addition, the operator intends to conduct aerial site surveys (clients may include real 

estate developers, builders, property managers, hunters, conservationists, etc.) or other 

aerial photograph/video recording that clients may desire (private events such as 

weddings, parties, sporting events, etc.).

To accomplish these ends, the operator requests exemption from multiple sections of 

the 14th Code of Federal Regulations. This request is motivated by the growing demand 

for images captured from angles that only UAVs can provide. Land Ventures seeks to 

ensure that such an option is provided to the public at large by a person or company 

with the skills and knowledge to conduct these types of operations in compliance with 

Federal and state regulations and with the safety of manned aircraft and bystanders as 

the top priority.

A summary of this request suitable for publication in the Federal Register is provided in 

Appendix A. Appendix B provides the manufacturer’s information regarding the design, 

aircraft performance, and fail-safe features. Manufacturer-supplied manuals and safety 

information is also attached.
September 15, 2015 Application for Section 333 sUAS Exemption

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Land Ventures, LLC.

Philip E Land, Owner

117 Apple Blossom Dr.

Brandon, MS 39047

601-209-1339

philiplandrealtor@gmail.com

Background and Professional Information:

Land Ventures, LLC., is a sole-proprietorship founded in September of 2015 to provide 

liability protection and a business bank account for Mr. Land’s various enterprises, 

including professional pilot services and, if approved, commercial sUAS operations.

Philip Land graduated from Delta State University in Cleveland, MS, in 2003 with a BS 

in Aviation/Flight Operations. As a Certified Flight Instructor, Mr. Land taught 

students for a year and a half before being hired by Pinnacle Airlines/NWAirlink in 

Memphis, TN, in 2005. Within 2 years, Mr. Land upgraded to captain with a firstattempt pass on his initial CRJ2 type rating check ride, going on to become type-rated as 

Pilot in Command on the Lear 40/45 jets. Having given up full-time professional flying, 

he is current and active in a locally-based PA-31-350 flying as the main pilot for the 

owner and his family. Now, as a full-time real estate agent, Mr. Land is seeking to grow 

his business and reputation by offering services no other agent in the area can match –

aerial photos and videos of houses being marketed.

FAA Airline Transport Pilot, certificate number 2771433

FAA Certified Flight Instructor with Instrument rating (expired), certificate number 

2771433CFI

FAA First Class Medical

PIC Type Ratings: CRJ2, LJ45

Mississippi Class B Commercial Driver License with Passenger Vehicle, School Bus, and 

Motorcycle endorsements

Mississippi Real Estate Salesperson License, license number S-49656

Over 6,600 hours total flight time including approximately 5,000 hours as PIC

Intentions:

 Provide real estate seller-clients an unmatched marketing strategy for their 

house, business or property by including aerial imaging

 Provide event planners, wedding coordinators, local photographers, local 

marketing firms, athletic directors, and other clients with a unique opportunity to 

stand out in their respective fields through the use of sUAS-captured videos or 

photographs

 Provide hunters, timber managers, farmers, conservationists and other clients 

with the ability to see large or hard-to-access areas quickly and conveniently to 

aid in increasing yields, managing infestations, tracking animal 

movements/feeding patterns/population counts, etc.
September 15, 2015 Application for Section 333 sUAS Exemption

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The regulatory basis for approving this request is found in §333 of the FAA 

Modernization Act. The FAA may also grant an exemption under 49 U.S.C. §44701(f) if 

it is determined that such an exemption is in the public interest.

Public Interest:

Aside from the wildly-growing world of social-media-shared pictures and videos, there 

is a legitimate consumer need for sUAS commercial services. As described in the 

operator’s “Intentions” listed above, the public may benefit from services offered. 

Benefit may come in gaining access to data unavailable by other means or in reduced 

financial burden for obtaining data due to ease of access and/or reduced time-onlocation relative to conducting a ground-based study. As it relates to general aerial 

photography, the public benefits in gaining new angles for recording important 

moments, whether that is a wedding or a child’s first soccer goal or any other event a 

client wants captured from the air.

Area of Operations:

The primary area for conducting commercial flight operations will be the areas 

surrounding the Jackson International Airport (KJAN) to a radius of approximately 

20nm. This primary region covers the real estate business of Mr. Land. To 

accommodate the tertiary purposes of this exemption, the exemption should allow 

flights operated in the rest of the state of Mississippi in order to serve the agricultural, 

timber, and hunting/conservation markets which are spread all across the state.

Focus areas would include neighborhoods in and around the cities of Brandon, Pearl, 

Flowood, Ridgeland, and Madison. At no time would the company expect to have a 

broad approval to operate in any airspace, whether the flight is conducted in the 

primary area or elsewhere in the state – in all cases, the company expects to give 

advance notice of each planned flight operation via the Notices to Airmen program and, 

as appropriate, via Air Traffic Control and/or airport operators.

The central portion of Mississippi, where the vast majority of flying will occur, is mostly 

flat-to-gently-rolling land. Potential hazards would include the local airports, public 

and private (for a partial list, see Appendix C), and the associated air traffic in the 

surrounding airspace; transmission towers; trees; and persons and buildings on the 

ground.

Level of Safety:

There is no peer to sUAS operations for determining whether an equivalent level of 

safety can be achieved. Some may argue that the appropriate standard is that for model 

aircraft, noting that their operations, if conducted for recreational purposes, would fall 

completely within the allowable operations for model aircraft. It is difficult to argue that 

there is sufficient correlation between model operations governed by the Academy of 

Model Aeronautics and the ones considered by Land Ventures. At the same time, it is 
September 15, 2015 Application for Section 333 sUAS Exemption

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clear that equivalency cannot be established with traditional, manned civil aircraft 

because the design and use profiles between traditional aircraft and sUAS are far too 

different. As such, it makes more sense to focus on why the contemplated operations 

would not adversely affect safety.

Granting an exemption will not adversely affect safety, either of manned aircraft or of 

persons and property on the ground. The operator expects to conduct sUAS operations 

over client-owned or -controlled property during daylight hours and at altitudes well 

below what would normally pose a risk to manned aircraft. Additionally, the vehicle(s) 

selected weighs very little, operates in line-of-sight conditions, and is powered by 

batteries (rather than volatile fuels).

The nature of the work anticipated by the operator would require that the vehicle be 

flown at relatively low altitudes and airspeeds. Land Ventures expects that in most 

instances, the sUAS can be flown at or below 200 feet AGL, and in all cases at or below 

500 feet AGL. Accordingly, the risk of interference with another aircraft is minimal. 

The operator does plan to conduct sUAS operations in close proximity to some airports 

(including KJAN, KMBO, and a handful of private airports/airparks). In the event an 

operation needs to be conducted inside the surface area of a towered airport or less than 

the normal FAA-prescribed distance from an airport, the operator will issue a NOTAM 

and will coordinate with the ATCT or airport operator as appropriate to conduct the 

operation in a safe and legal manner or to abort and attempt the operation at another 

time when the flight can be made safely. The primary consideration in attempting such 

operations is avoiding interference with manned operations/operators in order to 

maintain their safety.

Allowing Land Ventures to commercially operate a sUAS may also prevent unauthorized 

or unsafe UAS operations by people without the knowledge or training to fly within the 

confines of the regulations by providing a legal and safe alternative. Such services may 

also prevent people from doing “whatever is necessary” to get their perfect angle or shot, 

preventing potential injury, again by providing a safe alternative.

All operations will be conducted in day VFR conditions, with a minimum ceiling of 

1,000 feet reported at the nearest reporting station or 1,500 feet by the PIC’s best 

judgment if no reporting station is within a reasonable distance (appox. 15nm). 

Additionally, all operations will be conducted by visual line of sight with the PIC or 

visual observer (if required) always able to see the aircraft in accordance with the FAA’s 

“unaided” requirement, and the PIC and VO (if required) will maintain voice 

communications, either directly or via cell phone/two-way radio. For Land Ventures’ 

operations, a VO shall be required for any flight where the PIC believes VLOS may be 

lost during the course of the flight or during any flight near a gathering of people (e.g., a 

wedding). The operator does request exemption from FARs regarding operation of an 

aircraft near people and property due to the primary nature of the business. In 
September 15, 2015 Application for Section 333 sUAS Exemption

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conducting flights for purposes of aerial photography of properties listed for sale, it 

would be impossible to maintain distance requirements in most cases (over a home 

listed in a neighborhood, for example); however, at all times the aircraft will be flown in 

the airspace above property owned or controlled by the client or over publicly-accessible 

areas (sidewalks, public roads, etc.) and not over the property of anyone other than the 

client, nor will it be flown within 10 feet horizontally from any building, person, or 

vehicle on the ground. In the case of event photography/videography, it would also be 

impossible to maintain separation from persons on the ground. However, precautions 

to prevent injury in the event of failure of the aircraft would be taken, especially having a 

VO assist the PIC in tracking the vehicle to ensure that it is not flown directly over 

persons on the ground, or within 10 feet horizontally of any person on the ground, or 

near any object that may present a hazard to the vehicle or that may cause damage to it. 

Considering the small size, light weight, and extremely limited range of the aircraft 

selected, the operator believes that these measures provide a level of safety for persons 

and property on the ground as well as manned aircraft equal to or greater than the FARs 

provide for operating manned aircraft (particularly rotary-wing aircraft). If the need 

arises to fly within the minimum 10-foot horizontal distance of a person or a building 

not under the control of the client, the persons involved and/or the owner/controller of 

the property or building in question shall be given notice of the operational 

requirements and shall provide written consent for such operations. If written consent 

is not received, the operation shall not be conducted.

Training Requirements:

Understanding that any other category of aircraft would have defined aircrew-training 

requirements, the operator expects to establish minimum qualifications for anyone who 

may operate a sUAS on behalf of the company. The following qualifications are 

proposed for anyone acting as PIC prior to flying any commercial operation on behalf of 

Land Ventures, LLC.:

 Hold at least a Sport Pilot certificate with a valid state-issued driver license or a 

Recreational/Private Pilot certificate with a valid third class medical; in lieu of 

this requirement, a pilot who meets future sUAS pilot qualifications that may be 

published by the FAA shall be allowed to operate aircraft on behalf of the 

company

 Log a minimum of 5 hours of flight time on the specific model to be flown

 Log a minimum of 10 takeoffs and landings within the preceeding 90 days

 Log instruction and observation in operating the aircraft near buildings and 

obstructions
September 15, 2015 Application for Section 333 sUAS Exemption

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 Log practice using all available flight modes and camera modes for the aircraft to 

be flown

 Log practice in emergency procedures including, but not limited to, loss of radio 

communication with the aircraft, loss of visual contact with the aircraft, loss of 

communication with a visual observer, failure of one or more control systems on 

the aircraft; this requirement shall include annual recurrent practice and, if 

necessary, training to proficiency

Anyone acting as a visual observer on behalf of the company must be a qualified PIC 

acting as observer OR have received a minimum of 2 hours training in tracking the 

aircraft, communicating aircraft position to the PIC, and emergency procedures.

Aircraft:

Land Ventures intends to utilize commercially-available equipment in its sUAS 

operation. The aircraft are DJI-brand Phantom 3 and Inspire 1 vehicles, which are 

already familiar to the UAS Integration Office through the approval of multiple Section 

333 Exemptions approved for operators of these aircraft. These aircraft are 

operationally similar with radio control units that are nearly identical in function and

with flight characteristics that are very similar. The Phantom 3 aircraft are rated by the 

manufacturer as being created for “beginners and first-time pilots”, meaning that they 

are simple to operate with many fail-safe features that enhance safety. The Inspire 1 is

classified for use by professionals. The Phantoms are less than 14 inches across from 

corner to corner and weigh less than 3; the Inspire aircraft are less than 23 inches 

diagonally and weight less than 6.5 pounds. Maximum flight time is approximately 18-

25 minutes with a maximum speed of approximately 31-42 knots. Both aircraft feature 

a return-home function if contact with the controller is lost and also feature a returnhome button on the controller so that the PIC can, if still in radio contact, immediately

command the aircraft to return “home” to the launch location or another safe area preprogrammed for the flight should conditions dictate. Full manufacturer specifications 

on these aircraft are provided in Appendix B.

Operating Procedures and Limitations:

1. The PIC shall conduct a preflight visual inspection of the aircraft and a controlsystems check prior to each takeoff, except that training or proficiency flights 

may operate with an inspection/check prior to only the first takeoff so long as the 

subsequent flights are made consecutively and the aircraft is not left unattended 

at any time.

2. Anyone participating in company flights (including pilots, instructors, observers, 

and anyone else relevant to the operation) will participate in a pre-flight briefing 

covering the flight(s) to be flown prior to the first takeoff. Briefing items shall 

include, but not be limited to, planned flight path; safe landing areas; observer 
September 15, 2015 Application for Section 333 sUAS Exemption

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positioning if applicable; hazards; areas that must be avoided to maintain 

clearance from persons on the ground; any other consideration briefing 

participants deem necessary for a safe and successful flight.

3. Prior to any scheduled sUAS flight as contracted by any party, the operator must 

record a plan of activities and a copy provided to the client (emailed electronic 

copies shall suffice). The plan of activities must include at least the following: 

a. Dates and times for all flights

b. Name and phone number of the operator for the UAS operations 

conducted under this exemption

c. Name and phone number of the person responsible for the on-scene 

operation of the UAS (generally, the PIC)

d. Serial or registration number of UAS to be used

e. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the flight

f. A description of the flight activity, including a written description of any 

area over which flight will be conducted and the altitudes essential to 

accomplish the operation.

4. Any consent forms that may be required for a flight shall be attached to the plan 

of activities and these documents shall be maintained with the PIC for the 

duration of the associated flight activity and shall be available for inspection by 

any FAA inspector or law enforcement official. These documents shall be 

maintained at the office of the operator thereafter.

5. Any other required documentation, including but not limited to aircraft 

registration, a copy of the approved exemption, a copy of the approved COA, a 

copy of these operating procedures and limitations, and any other documents 

required by the administrator, shall accompany the PIC during any flight activity 

and shall be available for inspection upon request by any FAA inspector or law 

enforcement official.

6. At all times, the sUAS aircraft operated by or on behalf of Land Ventures shall 

remain clear of or yield right of way to any manned flight operation, including but 

not limited to ultralight, glider, parachute, and powered aircraft operations.

7. Written authorization shall be obtained prior to any flight from the property 

owner or someone exercising control over the property.

8. Weather conditions affecting sUAS operations shall include:

a. Daytime VFR flight only; Special VFR is not permitted due to inability to 

meet the requirements of FAR 91.157(b)(4)(ii)
September 15, 2015 Application for Section 333 sUAS Exemption

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b. At least 1sm flight visibility in Class G airspace or at least 3sm flight 

visibility in any other class of airspace (flight visibility is as defined in FAR 

91.157(c)(2))

c. Ceiling no lower than 1,000 ft or, if no reporting station is nearby, 1,500 ft 

in the PIC’s best estimation

d. Cloud clearance requirements of a minimum of 500 feet below any cloud; 

a minimum of 2,000 feet horizontally from any cloud; and no aircraft shall 

be allowed to operate above any cloud

e. No flights shall be permitted in any precipitation

f. Maximum wind for any flight is 12 knots or, if no reporting station is 

nearby, 10 knots in the PIC’s best estimation

g. OAT as reported at the nearest reporting station must be within the 

manufacturer’s operating temperature limits; if no reporting station is 

nearby, the nearest Weather.com temperature reading shall be 

substituted. If the Weather.com temperature is used, the aircraft shall not 

be operated if the reported temperature is within 2 degrees Celsius of the 

manufacturer’s limits.

h. For the purpose of weather-related limitations, a reporting station is 

considered nearby if it is within 15nm of the flight location and any airport 

with an operational AWOS/ASOS system shall be considered a reporting 

station

9. The on-screen display on the PIC’s control unit displays, among other things,

altitude information. The PIC shall operate the aircraft within the following 

altitude restrictions:

a. Within the surface area of an airport with an operating control tower, at or 

below 500 feet AGL subject to approval of the controlling ATC facility for 

each flight;

b. Within 3 nautical miles of a public airport without an operating control 

tower, at or below 200 feet AGL. Any flight operating in such an area shall 

operate under a Notice to Airmen and with at least 24 hours prior notice to 

the operator of the airport;

c. All other areas, at or below 200 feet AGL except that a flight may operate 

at or below 500 feet AGL if a NOTAM has been issued for that flight;

d. At all times, aircraft shall be operated in a manner consistent with the 

approved FAA exemption and COA.
September 15, 2015 Application for Section 333 sUAS Exemption

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Altitude information shall be checked and verified operational prior to initiating 

any flight activity.

10. The PIC, or a VO in coordination with the PIC, shall maintain unaided visual 

contact with the aircraft at all times (in accordance with published FAA 

guidelines).

11. Except for flights conducted near gatherings of persons on the ground, if a flight 

is to be conducted in a location the PIC determines will allow VLOS for the 

duration of the flight without the PIC changing position, no VO shall be required 

(ex. 1, shooting video of an outdoor wedding in a large open area requires a VO 

due to the crowd of people; ex. 2, taking aerial photos of a house on behalf of a 

client, the location of which allows the PIC to maintain VLOS at all times, does 

not require a VO; ex. 3, taking aerial photos of a large house and property which 

has obstructions to LOS requires a VO unless the PIC plans and executes multiple 

flights, each of which can be conducted with unrestricted VLOS). If at any time 

after takeoff on such a flight the PIC determines that VLOS cannot be maintained 

he shall land the aircraft and either:

a. Re-plan the flight to comply with the VLOS requirement, including 

splitting the mission into multiple flights if necessary, or

b. Postpone the mission until a qualified VO is present to assist the PIC

12. The aircraft will automatically descend and land if battery level drops to a 

factory-predetermined level. This is outside the control of the PIC; however 

measures will be taken to ensure that the aircraft is returned safely to the landing 

site with a minimum of 3 minutes flight time remaining before reaching the autoland battery level.

13. No takeoff shall be initiated unless battery flight time remaining before auto-land 

is at least 6 minutes longer than the required mission flight time reasonably 

anticipated by the PIC.

14. The aircraft has the capability to stream live video back to the PIC during flight. 

No flight shall be conducted unless streaming video is operational and utilized, 

except that training flights may be operated with this feature disabled in order to 

simulate abnormal or emergency conditions.

15. If communication between the controller and the aircraft is severed, the aircraft 

will automatically land at a pre-programmed location or at the departure point if 

another location is not programmed; the PIC will determine a safe landing 

location and program that, if other than the departure point, prior to 

commencing any flight operation, including training operations.
September 15, 2015 Application for Section 333 sUAS Exemption

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16. In the event of an emergency of any sort or if conditions beyond the PIC’s control 

warrant an immediate return to landing, the PIC shall initiate the vehicle’s 

automatic return-home function.

17. Aircraft may not be operated or controlled from any moving platform; the PIC 

must remain essentially stationary while the aircraft is in flight except that the 

PIC may take a few steps in any direction to maintain VLOS with the aircraft 

provided the aircraft is put into an automatic hover-hold mode prior to the pilot 

moving. If the pilot requires more than approximately 4-5 steps to maintain 

VLOS, the provisions of number 8 above shall apply.

18. Any maintenance procedure or repair work performed on the aircraft shall be 

documented in an aircraft maintenance log (AML). If any part affecting aircraft 

operation or flight characteristics is repaired or replaced, a function check flight 

shall be performed in a safe location and noted in the AML prior to returning the 

aircraft to service.

19. Manufacturer-recommended or -required maintenance intervals, service 

bulletins, and/or safety-related recommendations shall be followed if such exist. 

In any event, the aircraft shall be disassembled, thoroughly inspected for 

damage/excessive wear, re-assembled and a function check flight performed 

prior to the first scheduled revenue flight each calendar month. This inspection 

process shall be noted in the AML.

20.Any incident or accident involving aircraft operated by or on behalf of Land 

Ventures, LLC., must be reported in accordance with FARs.

Regulatory Provisions from which the Operator requests exemption:

14 C.F.R. §21 Subpart H

14 C.F.R. §45.27

14 C.F.R. §45.29

14 C.F.R. §61.101

14 C.F.R. §61.113

14 C.F.R. §61.315

14 C.F.R. §91.9(a)

14 C.F.R. §91.103(b)(2)

14 C.F.R. §91.105

14 C.F.R. §91.109

14 C.F.R. §91.119

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. Subpart E

Extent of Requested Exemptions with Reasons:

FAR 21 Subpart H – the operator seeks full exemption from all requirements for 

applying for and receiving an airworthiness certificate for the aircraft being operated. 
September 15, 2015 Application for Section 333 sUAS Exemption

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Due to the extremely small physical size, very low weight, lack of passenger-carrying 

capability, day-VFR-only VLOS operational restrictions, and other considerations, and 

because the aircraft do not fit into any existing category as defined in the FARs, the 

operator believes that there is no reason to require an airworthiness certificate. The 

operator requests a blanket exemption from any other section of the FARs that 

references a requirement to have, carry, or obtain an airworthiness certificate.

FAR 45.27 – the operator seeks exemption from the registration number marking 

locations described in this section. Due to the construction of the aircraft to be utilized, 

it is impractical to place registration markings in a position to be visible from the side. 

The operator seeks an exemption allowing registration markings to be placed in 

whatever location on the aircraft provides the best in-flight visibility of the registration.

FAR 45.29 – the operator seeks exemption from the registration marking size 

requirements of this part. Due to the very small size of the aircraft, it is not possible to 

attach even a single 12-inch-high letter or number. The operator requests an exemption 

to allow the largest markings practicable to be placed on registered aircraft.

FAR 61.101, 61.113, 61.315 – the operator seeks full exemption from the compensation 

limitations placed on pilots with Sport, Recreational, or Private Pilot certificates. For 

the foreseeable future, Mr. Land will be the sole operating pilot-in-command with an 

ATP certificate and valid first-class medical. However, in the future, the need may arise 

to employ additional pilots to fill demand for services and pilots holding lower levels of 

certificates should still be able to operate the company's sUAS aircraft competently and 

safely and, therefore, should be allowed to operate them on behalf of the company for 

compensation.

FAR 91.9(a) – the operator seeks exemption from this section on the basis of the 

manufacturer not providing an FAA-approved Aircraft Flight Manual for the aircraft 

being used. In addition, the operator seeks blanket exemption for any other regulation 

which references AFM data or limitations. Operating limitations, procedures, and 

inspections are included in this application for exemption which will provide safety 

equivalent to or better than that found in standard aircraft’s AFMs.

FAR 91.103(b)(2) – exemption is sought to this part due to the limited scope of 

operations by the company and the exceptionally small size and weight of the aircraft 

and the fact that no passengers or cargo can be carried onboard the aircraft.

FAR 91.105 – the operator seeks full exemption from this part due to lack of 

crewmember seats onboard the aircraft. There is no crewmember station on the 

aircraft.

FAR 91.109 – the operator seeks full exemption from the requirements of this section on 

the basis of there being no controls on the aircraft and on the basis that the aircraft is 

designed to be flown easily by pilots with no prior experience. Training can be 
September 15, 2015 Application for Section 333 sUAS Exemption

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conducted simply by an instructor observing and advising new pilots as they fly the 

aircraft in a location that will provide safety to non-participants from the aircraft and 

pilot (a large, private field, for example).

FAR 91.119 – the operator seeks to be treated as a helicopter under Part 91.119(d) or 

exempted from Part 91.119 altogether for the purposes of flying in areas where 

compliance as any other aircraft category would be impossible. Safety of persons and 

property on the ground will not be adversely affected due to the small size and low speed 

and weight of the aircraft to be used and because of company restrictions and 

procedures described previously.

FAR 91.121 – the operator seeks full exemption from this part on the basis that the 

aircraft does not have an altimeter

FAR 91.151 – the operator seeks full exemption from this part due to the electric motors 

and battery power of the aircraft to be flown and due to the fact that the battery power 

available is less than the minimum flight time requirements listed in this part. This is 

not an issue for safe operation of the aircraft due to their short-distance radio control 

system and the nature of their use which does not require them to fly for very long.

FAR 91 Subpart E – the operator seeks exemption from Subpart E in its entirety. 

Because the aircraft does not fit into any FAA-defined category, is very small, has few 

components, and some of the aircraft do not have a factory-prescribed maintenance 

program or maintenance manual, it would be burdensome to attempt to comply with 

this Part. It would also be impractical to expect an Airframe & Powerplant mechanic to 

be able to repair or inspect the aircraft being utilized. The company believes that 

conducting thorough preflight visual inspections with regular flight tests in accordance 

with the operating specifications and limitations listed above and adherence to any 

maintenance recommendations that may be provided by the manufacturer should be 

sufficient in determining the airworthiness of the aircraft. Additionally, the company 

believes that repairing or replacing damaged parts with factory-authorized parts (with 

accompanying function test flights as appropriate) is sufficient to maintain the aircraft 

in safe, flying condition. Substitution of the company's operating specifications and 

limitations listed above for FAR 91 Subpart E should cover preventative maintenance, 

repair maintenance, inspections, maintenance/function check flights, and recordkeeping requirements on any aircraft that does not have a factory-approved 

maintenance program or manual.
September 15, 2015 Application for Section 333 sUAS Exemption

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Appendix A

Summary for Publication in the Federal Register

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register should the FAA determine that publication is needed.

Petitioner: Land Ventures, LLC.; operated by Philip E Land, owner

Codes of Federal Regulation Affected:

FAA Modernization Act Section 333

14 C.F.R. §21 Subpart H

14 C.F.R. §45.27

14 C.F.R. §45.29

14 C.F.R. §61.101

14 C.F.R. §61.113

14 C.F.R. §61.315

14 C.F.R. §91.9(a)

14 C.F.R. §91.103(b)(2)

14 C.F.R. §91.105

14 C.F.R. §91.109

14 C.F.R. §91.119

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. Subpart E

Description of Relief Sought:

Petitioner seeks relief in whole or in part from these requirements in order to conduct 

sUAS operations over client-owned or -controlled property during daylight hours. The 

nature of operations anticipated by the applicant requires that the sUAS be flown at 

relatively low altitudes and near persons or structures along the path of the sUAS. At no 

time will the aircraft be flown higher than 500 feet above the ground or in any manner 

contrary to the safety of bystanders or manned aircraft. Accordingly, the risk to others 

is very low.
September 15, 2015 Application for Section 333 sUAS Exemption

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Appendix B

Specifications of each make and model of aircraft

operated by Land Ventures, LLC.

DJI Inspire 1

Aircraft:

Weight (Battery & Propellers included): 6.5 lb

Hover Accuracy (GPS Mode) Vertical: 1.6 ft

Horizontal: 8.2 ft

Max Pitch Rate 300°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 984 ft/min 

Descent: 787 ft/min

Max Flight Speed 42 kt

Max Altitude 14,761 ft

Max Wind 19 kt

Dimensions 17.25 x 17.75 x 11.85 in

Flight Time 18 mins

Operating Temperature -10°C ~ 40°C

Supported Battery DJI Smart Battery

Battery:

Type TB47 / TB48

Capacity 4500mAh, 22.2V / 5200mAh, 

22.8V

Charging Environment Range 0°C to 40°C (both types)

Operating Environment Range -10°C to 40°C (both types)

Remote Control:

Operating Frequencies 5.725~5.825 GHz

2.400~2.483 GHz

Communication Distance (open area) 6,561 ft

EIRP 13dBm@5.8GHz, 

20dBm@2.4GHz

Output Power 9 Watts
September 15, 2015 Application for Section 333 sUAS Exemption

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DJI Phantom 3 Advance

Aircraft:

Weight (including battery) 2.7 lb

Diagonal Size 13.8 in (excluding propellers)

Max Ascent Speed 984 ft/min

Max Descent Speed 590 ft/min

Max Speed 31 kt (ATTI mode, no wind)

Max Altitude Above Sea Level 19,600 ft

Max Flight Time Approximately 25 minutes

Operating Temperature 0°C to 40°C

Navigation system Built-in GPS

Wi-Fi Video Link:

Operating Frequency 2.400 GHz – 2.483 GHz

Max Transmission Distance FCC: 0.54 nm/3,280 ft; CE: 0.27 nm/1,640 ft

(aircraft's altitude at 400 feet)

Transmitter Power (EIRP) FCC: 27 dBm; CE: 20 dBm

Power Spectral Density 5.69mW/MHz

Remote Control:

Operating Frequency 5.725 GHz – 5.825 GHz

Max Transmission Distance FCC: 0.54 nm/3,280 ft; CE: 0.27 nm/1,640 ft

(altitude at 400 feet)

Operating Temperature 0°C to 40°C

Battery 2600 mAh LiPo 18650

Transmitter Power (EIRP) FCC: 19 dBm; CE: 14 dBm

Working Voltage 600 mA @ 3.7V

Charging Port Micro USB

Battery:

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Max Flight Time Approximately 25 minutes 

Operating Temperature -10°C to 40°C

Max Charging Power 100 W
September 15, 2015 Application for Section 333 sUAS Exemption

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Appendix C

Public and Private Airports within the 

Primary Operations area of Land Ventures, LLC.

KJAN – Jackson-Evers International Airport

KMBO – Madison Bruce-Campbell Field

KHKS – Hawkins Field

KJVW – John Bell Williams Airport

Mohr Private Airstrip (SE of KJAN)

Falcon Private Airstrip (S of KJAN)

Dogwood Acres Private Airstrip (SW of KJVW)

Root Hog Private Airstrip (NW of KHKS)

Slobovia Private Airstrip/Fly-In Community (NW of KHKS)

Cloud 9 Private Airstrip (NW of KMBO)

Eagle Crest Private Airstrip (NE of KMBO)

Supplejack (NE of KMBO)

Woodbridge Private Airstrip/Fly-In Community/Glider Club (E of KMBO)

Mach 1 Private Airstrip (E of KMBO)

Harrell Field Private Airstrip/Ultralight Club (NE of KMBO)

Payne Private Airstrip (E of KJAN)

Mr. Land is familiar with many of these airports, including the private airstrips, and is 

familiar with many of the operations common at the public and private airports listed. 

He feels confident of his ability to operate a sUAS near these areas while maintaining 

the safety of the pilots flying manned aircraft in the area.
September 15, 2015 Application for Section 333 sUAS Exemption

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Attachments:

Phantom 3 User Manual

Phantom 3 Safety Guide

Phantom 3 Battery Safety Guide

Inspire 1 User Manual

Inspire 1 Safety Guide

Inspire 1 Battery Safety Guide

Inspire 1 Maintenance Manual