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Suggested language for a LAANC request

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I am in need of suggested language for a LAANC request to operate at 150 in a 100 feet FAM limit (class B). Here's past attempt (rejected).
How can I improve my justification??? Any help much appreciated:

"The building I am required to image is 2.5 NM from the end of xxxxxxxx runway 8-26 threshold, offset at a 30 degree angle north. There are buildings downtown immediately to the North and East higher than the 150 feet I am requesting. I have been a Commercially Certificated Airman since 1970 and highly experienced in airport traffic operations. Held a Remote Pilot Certificate since 2016.

A visual observer will be available to assist in visually monitoring air traffic and I will monitor xxxx tower on xxx.x during the operation. DAYLIGHT OPERATION ONLY."
 
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I am in need of suggested language for a LAANC request to operate at 150 in a 100 feet FAM limit (class B). Here's past attempt (rejected).
How can I improve my justification??? Any help much appreciated:

"The building I am required to image is 2.5 NM from the end of xxxxxxxx runway 8-26 threshold, offset at a 30 degree angle north. There are buildings downtown immediately to the North and East higher than the 150 feet I am requesting. I have been a Commercially Certificated Airman since 1970 and highly experienced in airport traffic operations. Held a Remote Pilot Certificate since 2016.

A visual observer will be available to assist in visually monitoring air traffic and I will monitor xxxx tower on xxx.x during the operation. DAYLIGHT OPERATION ONLY."
They may not give you 150 ft if you are that close to the runway path no matter what you say but something I could suggest is saying something to the effect that you will check ATIS before starting your operation to ensure that planes are taking off towards your direction and you will not fly if they are landing in that direction.

The most high risk authorization I ever received they made me check ATIS to make sure planes were taking off towards my end of the runway. The idea was that planes stay lower longer when landing than they do when taking off.

Also reduce the size of the area you are requesting. They look at the height you are requesting and the size of the airspace.

I’ve found that your chances of getting approval are for manual authorizations depend highly on the FAA guy at the airport making the decisions. I’ve had guys that are great and really flexible and I’ve had some tell me the facilities map heights are there for a reason and they won’t approve operations below those heights which is of course bs.

It’s really stupid but it’s actually easier to get say 100 ft in a 0 zone then 150 feet in a 100 ft zone because it’s just too easy for them to tell themselves they aren’t preventing you from flying at all, just keeping you from flying as high.
 
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They may not give you 150 ft if you are that close to the runway path no matter what you say but something I could suggest is saying something to the effect that you will check ATIS before starting your operation to ensure that planes are taking off towards your direction and you will not fly if they are landing in that direction.

The most high risk authorization I ever received they made me check ATIS to make sure planes were taking off towards my end of the runway. The idea was that planes stay lower longer when landing than they do when taking off.

Also reduce the size of the area you are requesting. They look at the height you are requesting and the size of the airspace.

I’ve found that your chances of getting approval are for manual authorizations depend highly on the FAA guy at the airport making the decisions. I’ve had guys that are great and really flexible and I’ve had some tell me the facilities map heights are there for a reason and they won’t approve operations below those heights which is of course bs.

It’s really stupid but it’s actually easier to get say 100 ft in a 0 zone then 150 feet in a 100 ft zone because it’s just too easy for them to tell themselves they aren’t preventing you from flying at all, just keeping you from flying as high.
Appreciate the input. Have received multiple opinions in other forums, some allege clearance in -0- grid (right on the flight path."
2.5 NM 30 degrees off axis is well outside the IFR Approach plate path. As a manned aircraft pilot I totally understand the abundance of caution. But you got to appreciate the silly factor. My building is surrounded by higher buildings...
 
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Appreciate the input. Have received multiple opinions in other forums, some allege clearance in -0- grid (right on the flight path."
2.5 NM 30 degrees off axis is well outside the IFR Approach plate path. As a manned aircraft pilot I totally understand the abundance of caution. But you got to appreciate the silly factor. My building is surrounded by higher buildings...
I never said it wasn’t silly lol. Totally agree but this is the FAA we’re talking about. They don’t treat sUAS pilots the same way they treat other other pilots. All rational thought is thrown out the window.
 
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It’s actually most likely, ATC at the airport that is denyng it.

How big was the radius you requested?
1/10 nm That’s typically what I asked for.

I can get away with calling ATC at my local airport And asking them to approve it - they know me so I can get them

ATC can’t approve the flight directly you still need the auth . But it can’t hurt to get them on your side.
 
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In your request, focus on safety and alternates if something goes wrong. For example, you have return to home set, altitude limitations set in DJI Go 4 not to exceed approved height, the “kill” stick position is available to ground the aircraft in all situations, you will have multiple VOs to monitor air traffic, etc. sometimes we take these standard safety items for granted, but someone at the FAA will need to explain to higher-ups why they granted the auth if something goes sideways.
I have had multiple requests of this type approved only to 100’, though I had asked for 150’. But I was mapping 20+ acres and it was only at a single Class B airport.
 
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Limit your operations area to just what you need. Be sure to include mentions of lost link settings, RTH, VLOS, cell phone availability to the tower, etc. I just did a traffic study in a 0 altitude zone that was close enough to a class C to see the tower. I asked for 200' and got a COA for 100'. That flight got rained out so I submitted the exact same app again for the next week and got a COA for 200'. It just depends on who reviews your app.
 

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