To :

FAA Brittany Newton Program Analyst,

Airmen an d Airspace Rules Divisio n

From : Jason Thomas LBT Residential Design 3596 Maple Ave. Suite C

Zanes ville, OH 43701

RE: Further in formation req uested on December 22

, 2015 for Docket ID: FAA

- 2015

- 4733

Th e Reasons Wh y Granting LBT Residential Design ’ s Request Would Be In The Public Interest; That Is, How I t Would Benefit The Public As A Whole.

Granting the Petition will further the pub lic interest by allowing LBT Residential Design to safely, efficiently, and e conomically perform ae rial surveys and photography of facilities , real property, special events, precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections

, and landscape over certain areas of t he United States. Additionally, use of the DJI Ph a ntom UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to th e ec onomy. Nota bly, the benefits of LBT Residential Design ’ s proposed ope ration of the DJI Ph antom UAS will be realized without implicating any privacy issues.

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

Th e DJI Phantom UAS is battery powered and serve s as a safe, efficient, environmentally friendly, and

economical alt ernative to the manned aircraft traditionally utilized to obtain aerial imagery. B y reducing

the amount of manned aircraft needed to perform aerial acquisitions, an exemption allo wing the use of a DJI Phantom UAS would reduce the a mount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the numbe r of manned aircraft operating in the NAS, congestion around airports caused by arriving and depa rting aircraft will be reduced. The DJI Phantom UAS do es not require an airport to

takeoff or land. Likewise, a reduction of manned aircraft conducti ng aerial video and photography

missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Ef ficiency Of The DJI Phantom UAS

. Conducting aerial acquisitions with the DJI P hantom UAS

, instead of manned aircraft, will greatly benefit the pub lic by drastically reducing the levels of air and noise pollution generated during tra ditional aeri al photography flight operations. By using battery pow er and electric motors, the DJI Phantom UAS produce ’ s no air po llution, and is the most viable environmentally conscious al ternative to the cab in class, six cylinder internal combustion engine aircraft that are typicall y utilized fo r aerial photography, while burning approximately 20

- 30 gallons per hour o f leaded aviation fuel. The DJI Phantom UAS , while reducing the ca

rbon footprint of aerial acquisitions, also elimin ate s noise pollution, as the UAS is propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom UAS to per form aerial acquisitions, the substantial risk to life and property in

the air and on the ground, which is usually associated with traditional manned aircraft flight op erations,

will be subs tantially reduced. Aside from the lack of flight crew members located onboard the aircraft,

the DJI Phant om UAS (weighing appro ximately 2 poun ds 13 ounces, at maximum gross weight with alength of 16 in ches and width of 16 inch es and with no fu el on board), has less physical potential for

collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of

app roximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography O perations With The DJI Phantom UAS Will

Benefit The Economy. In addition to being safe and efficient, the DJI Phantom UAS is also an economical alternative to using

manned air craft to conduct similar aerial operations. As such, operation of the DJI Ph antom UAS will

allow United States ba sed companies, like LBT Residential Design , to re main competitive and contribute

to the growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ( “ EPA ” ) regulatory actions phasing out leaded aviation fuels, U.S.

ow ned and operated companies must adopt new and alternative technology in order to re main competitive. Operating the battery powered DJI Phantom UAS is one such technology th at not only allows companies greater operational flexibility c ompared to manned aircraft, but provides such flexibility without the high operation al cost of a traditional manned aircraft. By operating the DJI Ph antom UAS , companies suc h as LBT Residential Design , can remain competitive and profitable, and therefore, provide greater job stability to employ ees and contractors, which will ultimately contribute to the growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom UAS

, provides a stable workforce that increases consumer spend ing; improves local, state, and federal tax revenues; and allows companies to invest in research and developmen t in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conduc ted for decades, LBT

Residential Design ’s proposed operation of the DJI Phantom UAS Aircraft will not implicate any privacy issues. Specifically, the DJI Phantom UAS Aircraft will be operated only in compliance with operating

docu ments (i.e., the LBT Residential Design Aerial Operations Manua l, Monthly Maintenance Log, and

DJI Phantom UAS Aircraft Instruction Manual) which requires property owner involvement as well as

local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

If you have any qu est ions or require any additional i nformation

, plea se do not hesitate to contact me

.

Regards

,

Jason Thomas