To:

FAA

Brittany Newton

Program Analyst,

Airmen and

Airspace Rules Division

From:

Jason Thomas

LBT Residential Design

3596 Maple Ave. Suite C

Zanesville, OH 43701

RE: Further information requested on December 22, 2015 for Docket ID: FAA-2015-4733

The Reasons Why Granting LBT Residential Design’s Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole.

Granting the Petition will further the public interest by allowing LBT Residential Design to safely, 

efficiently, and economically perform aerial 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 the United States. Additionally, use of the DJI Phantom UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of LBT Residential Design’s proposed operation of the DJI Phantom UAS will be 

realized without implicating any privacy issues.

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

The DJI Phantom UAS is battery powered and serves as a safe, efficient, environmentally friendly, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing 

the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 

DJI Phantom UAS would reduce the amount 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 number of manned aircraft operating in the NAS, congestion around airports caused by 

arriving and departing aircraft will be reduced. The DJI Phantom UAS does not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting 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 Efficiency Of The DJI Phantom UAS.

Conducting aerial acquisitions with the DJI Phantom UAS, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated during traditional aerial

photography flight operations. By using battery power and electric motors, the DJI Phantom UAS

produce’s no air pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial photography, while 

burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom UAS, while 

reducing the carbon footprint of aerial acquisitions, also eliminates 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 perform 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 operations, 

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

the DJI Phantom UAS (weighing approximately 2 pounds 13 ounces, at maximum gross weight with a 
length of 16 inches and width of 16 inches and with no fuel 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 

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

3. Performing Aerial Video and Photography Operations 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 aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom UAS will 

allow United States based companies, like LBT Residential Design, to remain 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. 

owned and operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Phantom UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom UAS, companies such as LBT Residential Design, can remain competitive 

and profitable, and therefore, provide greater job stability to employees 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 spending; improves local, state, and federal tax revenues; and allows companies to invest in 

research and development 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 conducted 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 

documents (i.e., the LBT Residential Design Aerial Operations Manual, 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 questions or require any additional information, please do not hesitate to contact me.

Regards,

Jason Thomas