September 1 5 , 2015 Application for Section 333 sUAS Exemption

1 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

“ o perator” or “company” ) intends the co mmercial 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 cond uct 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 14 th Code of Federal Regulations. This request is motivated by the growing demand for images captured from angles that only UAVs can provide. Land Ventures s eeks 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 byst anders 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. Manuf acturer

- supplied manuals and safety

information is also attached.September 1 5 , 2015 Application for Section 333 sUAS Exemption

2 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 grad uated 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 first

attempt 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 an d 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 Mississ ippi 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 tot al flight time including approximately 5,000 hours as PIC

Intenti ons:

 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 othe r 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 1 5 , 2015 Application for Section 333 sUAS Exemption

3 The r egulatory b asis for approving this request is found in §333 of the FAA

Modernization Act. The FAA m ay 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

- on

location 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 approximate ly

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,
timb er, 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 t o 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 li st, 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 isSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

4 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 m inimal. 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 nece ssary” 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 f eet by the PIC’s best judgment if no reporting station is within a reasonable distance (appox. 1 5 nm). 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 a ccordance 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 believ es 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 t he business. InSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

5 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 airc raft 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 horizontall y 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 airc raft 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 we ll 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 opera tion 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 ho urs 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
obstructionsSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

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

 Log practice in emergency procedures incl uding, 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 airc raft position to the PIC, and emergency procedures.

Aircraft:

Land Ventures intends to utilize commercially

- available equipment in its sUAS

o peration. 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 the se 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 enhan ce 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 contr oller is lost and also feature a return

home 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 pre

programmed for the flight should conditi ons 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 control

syst ems 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 sha ll include, but not be limited to, planned flight path; safe landing areas; observerSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

7 positioning if applicable; hazards; areas that must be avoided to maintain clearance from persons on the ground; any other consideration briefing participants deem necessa ry 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 tim es 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. S erial or registration number of UAS t o 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 sha ll 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 r equest 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 th e requirements of FAR 91.157 (b)(4)(ii)September 1 5 , 2015 Application for Section 333 sUAS Exemption

8 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 report ing 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 temper ature 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

ma nufacturer’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 t ower, 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 suc h an area shall operate under a Notice to Airmen and with at least 24 hours pri or 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 1 5 , 2015 Application for Section 333 sUAS Exemption

9 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 fligh ts 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 ou tdoor 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 photo s 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 V LOS 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 th e PIC

12. The aircraft will automatically descend and land if battery leve l 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 auto

land 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 vid eo 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 1 5 , 2015 Application for Section 333 sUAS Exemption

10 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 maintai n 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 perfo rmed 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, t he 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 acci dent involving aircraft operated by or on behalf of Land Ventures, LLC., must be reported in accordance with FARs.

Regulator

y 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 ai rcraft being operated.September 1 5 , 2015 Application for Section 333 sUAS Exemption

11 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 a s 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 FAR s that references a requirement to have, carry, or obtain an airworthi ness 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 regist ration 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 opera ting 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 s ize 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 experie nce. Training can beSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

12 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

– th e operator seeks to be treated as a helicopter und er 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 grou nd 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 minimu m 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 o perator seeks exemption from Subp art 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 burde nsome 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 inspection s wi th 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 f actory

- 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 sho uld cover preventative maintenance, repair maintenance, inspections, maintenance/function check flights, and record

keeping requirements on any aircraft that does not have a factory

- approved maintenance program or manual

.September 1 5 , 2015 Application for Section 333 sUAS Exemption

13 

## Appendix A

Summary for Publication in the Federal Register

Pursuant to 14 C.F.R. Part 11, the followi ng 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. Sub part 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 appli cant requires that the sUAS be flown at relatively low a ltitudes 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 o r manned aircraft. Accordingly, the risk to others is very low.September 1 5 , 2015 Application for Section 333 sUAS Exemption

14 

## 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
Dime nsions 17.25 x 17.75 x 11.85 in Flight Time 18 mins Opera ting Temperature

- 10°C ~ 4 0°C Supported Battery DJI Smart Battery

Battery:

Type TB47 / TB48 Capacity 4500 mAh, 22.2 V / 5200mAh,
22.8 V Charging Environment Range 0 °C to 40 °C (both types) Operating Environment Range

- 1 0 °C to 4 0 °C (both types)

Remote Control:

Operating Frequenc ies 5.725~5.825 GHz 2.400~2.483 GHz Communication Distance (open area) 6,561 ft

EIRP 13dBm@5.8G Hz

, 20dBm@2.4G Hz Output Power 9 WattsSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

15 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 A ltitude 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 Dist ance FCC: 0.54 nm/3,280 ft ; CE: 0.27 n m /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 FC C: 0.54 nm/3,280 ft ; CE: 0.27 n m /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 WSeptember 1 5 , 2015 Application for Section 333 sUAS Exemption

16 

## Appendix C

Public and Private Air ports 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 Airstri p (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, incl uding 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 1 5 , 2015 Application for Section 333 sUAS Exemption

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