## UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _____________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

LATUS LABS

, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS

61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a),

91.407(a ) ( 1), 91.409(a ) ( 1) & (a ) ( 2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF

DJI PHANTOM 3 AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on February 18, 2016

Robert Latus, Owner

Latus Labs

, LLC

Tel: +1 (870) 834

- 6521

Email: rlatus@latuslabs.com2 | P a g e TABLE OF CONTENTS

GLOSSARY OF ABBREVIAT IONS

................................ ................................ ................................ ................................ .......... 3

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ................................ ................................ ............... 4

AIRCRAFT MODELS IN THIS PETITION

................................ ................................ ................................ ................................ . 4

BASIS FOR PETITION

................................ ................................ ................................ ................................ ........................... 4

A. NAME AND ADDRESS OF PETITIONER

................................ ................................ ................................ ............................ 5

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHI CH LATUS LABS, LLC SEEKS EXEMPTION

................................ ............ 5

C. THE EXTENT OF RELIEF LATUS LABS, LLC SEEKS AND THE REASON LATUS LABS, LLC SEEKS THE RELIEF

....................... 7

D. THE REASONS WHY GRANTING AERIAL PERSPECTIVE LLC’S REQUEST WOULD BE IN THE PUBLIC INTEREST

.............. 8

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ....... 8

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

................................ ................................ ................ 11

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVILABLE TO SUPPORT LATUS LABS, LLC ’ S R EQUEST

.... 11

CONCLUSION

................................ ................................ ................................ ................................ ................................ ...... 12

APPENDIX A

– PRE

- FLIGHT CHECKLIST

................................ ................................ ................................ ............................... 13

APPENDIX B

– POST

- FLIGHT CHECKLIST

................................ ................................ ................................ ............................. 14

APPENDIX C

– ATTACHED FILE

– USER’S MANUAL DJI PHANTOM 3

................................ ................................ .................. 14

APPENDIX D

– ATTACHED FILE

– USER’S MANUAL DJI INSPIRE 1

................................ ................................ ...................... 143 | P a g e GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform A ct of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing4 | P a g e Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11.

I, Robert Latus, Owner of Latus Labs, LLC , am seeking exemption from the requirements of 14 C.F.R §§ , 91.7(a), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), 61.113(a), 91.119(c), 91.121, 91.151(b), to operate Unmanned

Aircraft Systems pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption wil l

permit Latus Labs, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting

photography and videography within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Latus Labs, LLC provides its clients with expe rtise and knowledge in advanced technologies and solutions to increase

efficiency, productivity and effectiveness

. The objective of Latus Labs, LLC aerial video and photography operations is to

provide high quality imaging for a variety of commercial, publ ic, residential and governmental uses, specifically targeting:

• Internet Marketing

• P ublic and P rivate Event Coverage

• Construction sites before and after

• Real

- estate marketing

• I nspections of public and private structures.

• Search and Rescue operations

AIRCRAFT MODELS INCLUDED IN THIS PETITION

Latus Labs, LLC seeks an exemption to operate DJI systems for compensation or hire within the NAS.

The DJI Phantom 3 and DJI Inspire 1 are similar in operational capability, size, speed

, and weight . Each UAS is ba ttery

powered with electric motor which performs vertical takeoff and landing (VTOL). These UAS also share the same fail safes

which helps prevent loss of control and fly away scenarios.

Max Speed Max Weight Size Mission Time

DJI Phantom 3 36 mph 2.8 l bs. 23 in x 23 in 23 Minutes

DJI Inspire 1 49 mph 6.5 lbs. 22 in x 23 in 18 Minutes

Operations manuals for each of the UAS’s will be included in this petition. All UAS’s operated by Latus Labs, LLC will be

registered in accordance with 49 U.S.C 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration

, and marked in accordance with 14 C.F.R Part 45, Identification and Registration Markings.

BASIS FOR PETITION

Petitioner, Latus Labs, LLC , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate the DJI Phantom 3 and the DJI Inspire 1 quad copter in the National

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its

operation, Latus Labs, LLC operation of the DJI Phantom 3 and the DJI Inspire 1 UAVs meets the conditions of FMRA Section

333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Latus Labs, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b), as these sections set forth requirements for main tenance that only apply to aircraft with an airworthiness certificate.5 | P a g e Latus Labs, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. Latus Labs,

LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the

UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance

Log, and Instruction Manuals). Furthermore, Latus Labs, LLC will document and mai ntain all maintenance records for the

DJI Phantom 3 and the DJI Inspire 1 UAVs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in

command, is requested by Latus Labs, LLC to the exte nt necessary to allow a Pilot in Command (PIC) holding a student

pilot, private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by

meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 and

the DJI Inspire 1 quad copter UAVs in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Lat us Labs, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 and the

DJI Inspire 1 UAVs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Latus Labs, LL C su bmits that they will ensure that the DJI Phantom 3 and the DJI Inspire 1 are in an airworthy condition,

prior to every flight, by d etermining that the UAVs are in compliance with the operating documents

. (i.e., Monthly

Maintenance Log, Instruction Manu als), and that the aircraft are in a condition for safe flight.

Additionally, Latus Labs, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements

for flight in VFR conditions. Latus Labs, LLC submits that safety will n ot be affected by operation of the DJI Phantom 3 and

the DJI Inspire 1 UAVs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with

enough battery power to fly for a total duration of approximately 25 minutes t o the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 5 minutes.

Latus Labs, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI

Phantom 3 and the DJI Inspire 1 UAVs will not have a typical barometric altimeter onboard. However, altitude information

of the DJI Phantom 3 and the DJI Inspire 1 UAVs will be provided to the PIC via Global Positioning System (GPS) equipment,

and radio communications

In ac cordance with 14 C.F.R. § 11.81, Latus Labs, LLC provides the following information in support of its petition for

exemption:

A. Name and Address of the Petitioner.

The name and address of the Petitioner is:

Latus Labs, LLC

2311 West 8 th Street

Russellville, AR 72801

Point of contact for Latus Labs, LLC

Robert Latus

Phone: +1 (870) 834

- 6521

Email: rlatus@latuslabs.com

B. The specific sections of 14 C.F.R from which Latus Labs, LLC seeks exemption.

1. Latus Labs, LLC seeks exemption from The Requirements of Section 61.113(a).

Section 61.113(a), entitles Private pilot privileges and limitation s : Pilot in command, subsection (a) prescribes

the following, in relevant part:6 | P a g e

(a) No person who hold a private pilot certificate may act as pilot in command of an aircraft that is carrying

passengers of property for compensation or hire; nor may that person, for compensation or hire, act as pilot

in command of an aircraft.

2. Latus Labs, LLC seeks exemption from The Requirements of Section 91.7(a).

Section 91.7, entitles Civil aircra ft airworthiness , subsection (a) prescribes the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Latus Labs, LLC seeks exemption from The Requirements of Section 91.119(a).

Section 91.119, entitled Minimum safe altitudes : General, subsection (c) prescribes the following, in relevant part:

(c) Except when necessary for takeoff or landing, no person may operate an aircraft over other than congested

areas below 500 feet above the surface, except over open water or spars ely populated areas. In those cases,

the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

4. Latus Labs, LLC seeks exemption from The Requirements of Section 91.121.

Section 91.121, entitled Altimeter setting , s ubsection (a) prescribes the following, in relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude of flight level of that aircraft, as the

case may be, by reference to an altimeter that is set, when operating

–

1. Below 18,000 f eet MSL, to

–

i. The current reported altimeter setting of the station along the route and within 100 nautical miles of

the aircraft.

ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current

reported altimeter sett ing of an appropriate available station; or

iii. In the case of an aircraft not equipped with a radio, the elevation of the departure or an appropriate

altimeter setting available before departure.

5. Latus Labs, LLC seeks exemption from The Requirements of Secti on 91.7 ( b ).

Section 91.7, entitled Fuel requirements for flight in VFR conditions , subsection (b) prescribes the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast

weather conditions) there is enough fuel to fly to the first point of intended landing and assuming normal

cruising speed, to fly after that for a least 20 minutes.

6. Latus Labs, LLC seeks exemption from The Requirements of Section 91.405(a).

Section 91.405(a), entitled Maintenance required , subsection (a) prescribes the following:

Each owner of operator of an aircraft

– (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required

inspections, expect as provided in paragraph (c) of this secti on, have discrepancies repaired as prescribed in

part 43 of this chapter [.]

7. Latus Labs, LLC seeks exemption from The Requirements of Section 91.407 (a ) ( 1)

. Section 91.407, entitled Operation after maintenance

, preventative maintenance

, rebuilding, or alt eration

, subsection (a) (1) prescribes the following:

(b) No person may operate any aircraft that has undergone maintenance, preventative maintenance, rebuilding,

or alteration unless

1. It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

8. Latus Labs, LLC seeks exemption from The Requirements of Section 91.409 (a ) ( 1) and 91.409(a ) ( 2)

.7 | P a g e

Section 91.409, entitled Inspections , subsection (a) prescribes the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the

preceding 12 calendar months, it has had

–

1. An annual inspection in accordance with part 43 of this chapter and has been approved for return to

service by a person authorized by § 43.7 of this chapter; or

2. An inspection for the issuance of the airworthiness certificate in accordance with part 21 of this chapter.

9. Latus Labs, LLC seeks exemption from The Requirements of Section 91.417 (a) and 91.417(b)

. Section 91.417, entitled Maintenance records , subsection (a) and (b) prescribes the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall

keep the following records for the periods specified in paragraph (b) of this section:

1. Records of the maintena nce, preventive maintenance, and alteration and records of the 100

- hour, annual,

progressive, and other required or approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an airc raft. The records must include

–

i. A description (or reference to data acceptable to the Administrator) of the work performed; and

ii. The date of completion of the work performed; and

iii. The signature and certificate number of the person approving the aircraft fo r return to service.

2. Records containing the following information:

i. The total time in service of the airframe, each engine, each propeller, and each rotor.

ii. The current status of the life

- limited parts of each airframe, engine, propeller, rotor, and applianc e.

iii. The time since last overhaul of all items installed on the aircraft which are required to be overhauled

on a specified time basis.

iv. The current inspection status of the aircraft, including the time since the last inspection required by

the inspection pro gram under which the aircraft and its application are maintained.

v. The current status of applicable airworthiness directives (AD) and safety directives including, for each,

the method of compliance, the AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next action is required.

vi. Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe

and currently installed engines, rotors, propell ers, and appliances.

(b) The owner of operation shall retain the following records for the periods prescribed:

1. The records specified in paragraph (a) (1) of this section shall be retained until the work is repeated or

superseded by other work or for 1 year aft er work is performed.

2. The records specified in paragraph (a ) ( 2) of this section shall be retained and transferred with the aircraft

at the time the aircraft is sold.

3. A list of defects furnished to a registered owner or operator under § 43.11 of this chapt er shall be retained

until the defects are repaired and the aircraft is approved for return to service.

C. The extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks the relief.

1. Extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks relief from section 61.113(a).

Relief from Section 61.113(a) entitled Private pilot privileges and limitations: Pilot in command, is requested to

the extent necessary to allow a PIC holding a private pilot or higher level certificate, as w ell as a current and valid

airman medical certificate, and who has met certain training and currency requirements, to conduct the proposed

UAS flight operations for compensation or hire.

Latus Labs, LLC submits that an equivalent level of security will be maintained no PIC will be allowed to operate a

UAS unless that PIC has demonstrated, through training that the PIC is able to safely operate the aircraft during8 | P a g e

normal procedures, abnormal procedures and emergency procedures which include evasive maneuver ing and

maintaining appropriate distance from people, vessels, vehicles, and structures.

Forth more Latus Labs, LLC submits that all flights of the UAS conducted by the PIC pursuant to the grant of this

Petition (1) will be incidental to Latus Labs, LLC b usiness; and (2) will not carry passengers or property for

compensation or hire.

2. Extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks relief from section 91.7(a).

Latus Labs, LLC will ensure that the UAS is in an airworthy condition based upon its compliance with the operating

document prior to every flight and as stated in the conditions and limitations below.

Therefore, Latus Labs, LLC seeks the requested relief because the proposed UAS do not require airworthiness

certification in accordance with 14 C.F.R Part 21, Subpart H

3. Extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks relief from section 91.191(a).

L atus Labs, LLC will ensure all UAS’s flight stay below the 500 feet AGL with the new regulations gui delines that

state UAS can only operate under 400 feet AGL.

4. Extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks relief from section 91.121(a).

Latus Labs, LLC UAS’s are equipped with a barometer and GPS equipment, which ensures tha t a ground level

pressure setting be established prior to each flight, and provides the PIC with altitude information of the UAS,

above ground level (AGL) on the controller display.

Therefore, Latus Labs, LLC seeks the requested relief because the propose d UA does not utilizes a typical

barometric altimeter that may be set as contemplated by Section 91.121.

5. Extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks relief from section 91.7(b)

. Due to the flight time duration of the UAS ba ttery

, Latus Labs, LLC seeks the requested relief, because without an

exemption from Section 91.151(b), Latus Labs, LLC will not be able to perform many of its practicality operations.

6. Extent of relief Latus Labs, LLC seeks and the reason Latus Labs, LLC seeks relief from section 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Since sectio n(s) 91.405(a), 91.407(a ) ( 1), 91.409(a ) ( 1 ) & (a ) ( 2), and 91.417(a) & (b) only apply to airworthiness

aircraft

, Latus Labs, LLC seeks requests relief from these sections because UAS do not require an airworthiness

certification.

Latus Labs, LLC will perform maintenance, alternation on the UAS as prescribed by the manufacturer’s

documentation where applicable, or b y returning the aircraft to manufacturer for repairs, when maintenance is

not recommended.

D. Reason why granting Latus Labs, LLC’s request would be in the public interest.

Using a UAS in lieu of a manned aircraft would enhance safety and reduce the environment al impact as compared

to similar operation s conducted with manned aircraft, carrying a crew and flammable fuel. Operations for this

petition will enable services for propert y owners to seek an enhanced perspective of their desired photographic

subjects that cannot be displayed through ground level videography/photography. Aerial photography is a

valuable marketing tool that can lead to increased commerce and enhance personal photography.

The petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an

i ndependent contractor.9 | P a g e

Flight data including UA flight time, Control Unit operation time, incident, accident, and details concern ing any

deviations from normal operations will be available to FAA for use in collecting data regarding the use of UAS as

part of this application.

E. Reasons why granting Latus Labs, LLC’s request would not adversely affect safety.

1. Reasons why the DJI Phant om 3 , DJI Inspire 1 UAS’s meets the conditions of the FAA Modernization and Reform

Act of 2012 (FRMA) Section 333.

Latus Labs, LLC UAS’s meet the conditions of the Section 333 based on the aircrafts size, weight and speed.

Therefore not requiring an airwor thiness certification in accordance with the 14 C.F.R Part 21, subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth

requirements for considering whether a UAS will create a hazard to users of th e NAS or the public, or otherwise

pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

– Notwithstanding any other requirement of this subtitle, and not later than 180 days after the

date of ena ctment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion of the plan and rulemaking required

by section 332 of this Act or the guidance req uired by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

– In making the determination under subsection (a), the Secretary

shall determine, at a minimum

— (1) Which types of unmanned aircraft systems, if any, as a result of their size , weight, speed, operational

capability, proximity to airports and populated areas, and operation within visual line of sight do not create a

hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) Whet her a certificate of waiver, certificate of authorization, or airworthiness certification under section

44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified

under paragraph (1).

(c) Requirements for Safe Operation.

– If the Secretary determines under this section that certain unmanned

aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for

the safe operation of such aircraft systems in the na tional airspace system.

In seeking this exemption, Latus Labs, LLC submits that the included UAS’s can operate safely in the NAS pursuant

to FMRA Section 333, as demonstrated by: (a) the characteristics of these UAS; (b) the pilot certification

requiremen t; and (c) the specific operating limitations.

A. DJI Phantom 3

, DJI Inspire 1

i. Safety Features

In the event of a loss of link, the aircraft will follow a user

- selected procedure. The aircraft will proceed to the

“home” position, which is set by the PIC prior to flight and can be changed in flight if necessary, at a set altitude.

If link is not regained, the aircraft will initiate a de s cent and land at the designated “home” position.

If the GPS solution is lost during flight, the PIC will still have full control of the aircraft and can maneuver it back

to “home” for a safe landing. As the PIC always flies the UAS in visual line of sight, it is immediately apparent if

this situation occurs.

DJI Intelligent Flight Batteries have many built in safeguar ds to prevent battery failures in flight. These include

battery level displays, electronic monitors to monitor things like temperature and amperage, and battery

history information. These features in addition to electrical safeguards on the aircraft like L ow Battery “Return

to Home” ensure an aircraft will never lose electrical power in flight.

A complete description of the operation and specifications of DJI Phantom 3 , DJI Inspire 1 is provided in the

Operator Manuals included with this petition.10 | P a g e

2. Flight Operations of the DJI Phantom 3, DJI Inspire 1 UAS’s are limited to the line of sight of a certificated pilot

in command with a visual observer.

Latus Labs, LLC will only utilize visual observers who are trained on appropriate FAA rules and regulations req uired

to perform their duties. The Latus Labs, LLC Flight Operation Manual describes how visual observers will be

trained.

3. Flights of the DJI Phantom 3, DJI Inspire 1 UAS’s will be conducted to specific operating limitations.

1) The UA must operate at an al titude of no more than 400 feet above ground level.

2) The UA may not exceed speeds of 87 knots. Under no circumstances will the UA exceed the operating

airspeed recommended by the aircraft manufacturer.

3) Motion picture and television filming in closed

- set is not permitted.

4) The UA must be operated within a visual line of sight of the PIC at all times.

5) All operations must utilize a visual observer.

6) Prior to each flight, the PIC will conduct a pre

- flight inspection to determine the UAS is in a condition for

safe flight.

7) Each UAS operated under this request will comply with all manufacturer safety bulletins.

8) Any UAS that has undergone maintenance will be undergo a functional test flight performed by the PIC and

VO.

9) Operator will conduct day light flights under VMC conditions.

10) Latus Labs, LLC will not operate UA’s within 5 nautical miles of an airport, unless a letter of agreement with

the airport’s manager has been obtained or otherwise permitted by a COA issued to Latus Labs, LLC.

11) If a UAS loses communication or loses its GPS signal, the UA will be able to return to a pre

- determined

locations

12) Latus Labs, LLC will not permit any PIC to operate UAS’s unless the PIC demonstrates the ability to safely

operate the UAS in a manner consistent with how the UAS will be ope rated under this request.

13) All operation will be conducted in accordance with Air Traffic Organization

- issued COA.

14) UAS will not be operated from any moving device or vehicle.

15) UA’s will remain clear and give way to all manned aviation operations and activiti es at all times.

16) All operations will be conducted over private or controlled

- access property with permission from the

property owner/controller or authorized representative.

17) Any incident, accident, or flight operation that transgresses the lateral or verti cal boundaries of the

operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office

within 24 hours. Accidents will be reported to the National Transportation Safety Board per instructions on

the NTSB website

.

4. Prev iously granted relief of Section 61.113(a)

As in Exemption No. 11109, Latus Labs, LLC will not allow any PIC to operate the UAS unless that PIC has

demonstrated through the UAS training and currency requirements that the PIC is able to safely operate the

UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles, and structures.

5. Previously granted relief of Section 91.7(a)

The FAA has previously granted re lief from Section 91.7(a), specific to UAS, in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11112, 11136, 11138).11 | P a g e

6. Previously granted relief of Section 91.119(c)

The FAA has previously granted relief from Section 91.119(c), specific to UAS, in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11 066, 11067,

11080, 11109, 11110, 11112, 11136, 11138).

7. Previously granted relief of Section 91.121

The FAA has previously granted relief from Section 91.121, specific to UAS, in circumstances similar, in all

material respects, to those presented herein ( e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11112, 11136, 11138).

8. Previously granted relief of Section 91.7 (b)

The FAA has previously gr anted relief from Section 91.7 (b), specific to UAS, in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138).

9. Previously granted relief of Sectio n(s) 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), And 91.417(a) & (b)

Since each UAS will be inspected as prescribed by the manufacturer’s maintenance manual, Latus Labs, LLC will

maintain the equivalent level of safety established by Sections 91.405( a), 91.409(a)(1), and 91.409(a)(2). A copy

of each aircraft’s Operator’s Manual, which contain descriptions and procedures for all maintenance of the

system, are included with this request. Additionally, the FAA has previously granted relief from Section

9 1.151(b), specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138). These previous

exemptions granted by the FAA concerning Sec tion 91.151 establish that safety is not adversely affected when

the technical characteristics and operating limitations of the UAS are considered.

F. Summary that can be published in the federal register.

Latus Labs, LLC seeks exemption from the requiremen ts of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121,

91.119(a), 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

G. Any additional information, view, or arguments available to support Latus Labs, LLC’s request.

I am fully aware of the preflight safety checks and procedures i ndic ated in the operation manual of the DJI Phantom

3 and the DJI Inspire 1 

### and intend to implement preflight safety checks and utilize the safety te chnology provided

with these units

. I intend to be ful ly aware of my surroundings at all times and to only fly the unmanned aircraft

within a visual line of sight and only in Visual Flight Conditions.

I understand the health and safety regulations for PIC’s and will be the only operator under this exemption.

All flights will occur over private or controlled access property with the property owner's prior consent and

knowledge.

H. If you want to exercise the privileges of your exemption outside the United States, you must state the reason.



### I have no intention of using this exemption outside the United States12 | P a g e C ONCLUSION



### The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, videography,

mapping

, inspections and other flight operations”. The petitioner's business mo del is based on the idea of offering

ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and

legal option to enhance their business or hobby. Although mapping and inspections are included in this re quest, the

primary objective will be aerial videography and photography.

Sincerely,

Robert Latus

Latus Labs, LLC

2311 West 8 th 

### Street

Russellville , AR 7280113 | P a g e APPENDIX A

– PRE

- FLIGHT CHECKLIST



### 1. Charge flight batteries

2. Charge range remote controller

3. Charge smartphone/tablet

4. Check/adjust props & anti drop kit

5. Remove lens cap and gimbal clamps

6. Insert/ reformat M irco

- SD card.

7. Move antenna to vertical position

8. Power on remote controller

9. Power on flight battery

10. Power on smartphone or tablet and link to airc raft (DJI GO App)

11. Check gimbal and camera angle

12. Calibrate compass

13. Check rear LED indicators

14. Check 6+ satellites (DJI GO App)

15. Wait for GPS signal to lock with “Ready to Fly” Status

16. 

### Scan flight environment.14 | P a g e APPENDIX B

– POST

- FLIGHT CHECKLIST

1. Turn off video recording

2. Power off flight battery

3. Power off remote controller

4. Power off smartphone or tablet

5. Replace gimbal clamp and lens cap.

APPENDIX C ATTACHED FILE

– USER’S MANUAL DJI PHANTOM

APPENDIX D ATTACHED FILE

– USER’S MANUAL DJI INSPIRE