Regarding Contact Information for Petitioner:

Legacy Farms and Ranches of NC, LLC

Gardner Reynolds

7980 Arco Corporate Drive, Ste 105

Raleigh NC 27617 

919-785-4272

greynolds@fmrealty.com

Regarding specific exemptions for which Legacy Farms and Ranches of NC LLC is petitioning:

Legacy Farms and Ranches of NC, LLC respectfully requests exemption from the requirements of 

Title 14 of the code of Federal Regulations including Sections 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) concerning 

commercial operation of DJI Phantom 4 UAS according to Section 333 of the FAA Modernization 

and Reform Act of 2012 (PUBLIC LAW 112-95). We respectfully request this exemption in order to 

commercially operate an unmanned aircraft system (UAS) mostly within a 16-county area around the 

“Triangle” in North Carolina, specifically avoiding the airspace managed by Raleigh-Durham 

International Airport (RDU)

Regarding Extent of Specific Relief Sought:

Relief from Section 61.113(a) and (b) 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 well as a current and valid airman medical certificate, and who has met certain flighthour and currency requirements, to conduct the proposed UAS flight operations for compensation or 

hire.” Further relief from medical certification regulations are also herewith requested.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft 

does not carry passengers or property for compensation or hire. 

Regarding the Unmanned Aircraft System:

1. We will safely operate the UAS to minimize risk to the NAS and to persons and property on the 

ground. The “drone” for which we request exemption is an Approved Model (see FAA-2007-3330-

0007) DJI Phantom 4 Quadcopter (Serial# 07DDD4F0B105970) which has been adapted specifically 

to hold a portable Go-Pro camera and which includes a 3-Axis Gimbal. The craft weighs 

approximately 10 lbs., will only be operated during daytime Visual Flight Rules (VFR) conditions 

and within visual line of sight (VLOS) of its pilot, and will stay well away from airports or heliports.

2. Procedures for operating the proposed UAS include battery testing, LED indicator testing, 

equipment controls verification, and short flight testing within 30 feet of stationary pilot. 

Maintenance of the aircraft involves parts checks before and after flights and parts replacement by 

original equipment manufacturer. Flight Logs and Maintenance Logs will be kept.

3. RF spectrums used as part of the controller mechanism from pilot to craft are described in the craft 

Flight Manual (company website link for downloadable file provides file too large for FAA upload: 

https://dl.djicdn.com/downloads/phantom_4/en/Phantom_4_User_Manual_en_v1.2_160328.pdf ). 

Please note that this equipment complies with Federal Communications Commission (FCC) as stated 

in this manual.
Regarding the Unmanned Aircraft Pilot In Control:

4. As a 30-years-experienced audio/visual producer, the pilot of this particular UAS has thoroughly 

studied the flight and equipment manuals and has approximately ten hours of flight time with this 

particular UAS. It is not usual that the pilot would engage visual observers, but if so, their roles 

would be to ensure the craft never escapes the subject property boundaries as marked on the ground.

5. Petitioners requests exemption from medical certification of the PIC(s) directly responsible for the 

operation of the UAS. 

Regarding Benefits to the Public 

6. As a licensed real estate broker in the State of North Carolina, this petitioner would propose use of 

UAS to photograph client properties in order to list them for sale. The landowner of a listing would 

engage this petitioner to video and photo their real estate in order to document current trees, crops 

and/or conditions, attract more buyers and present their property more competitively in the 

marketplace. This drone footage saves thousands of dollars in expense of flying manned craft with 

much more expensive gear to capture similar footage, which helps the public at large save money in 

the due diligence process of evaluating real estate.

Regarding the Operation of the Unmanned Aircraft 

7. Please refer to the referenced User Manual regarding maximum operating speed, altitude, 

minimum flight visibility and distance from clouds. It is the petitioner’s intent never to fly the UAS 

if prevailing weather is not clear and dry enough for high-quality photography.

8. Petitioner intends to use the UAS in predominantly rural areas, over large parcels of real estate, 

and often without other people or even structures anywhere in sight of the attached camera. The 

aircraft would not be flown over people taking pictures/videos without their consent or knowledge 

and would not present a threat to personal safety, security, or privacy.

9. Petitioner does not intend to operate in the proximity of any airports, in accordance with the 

statutory mandate under Section 333 regarding proximity to airports. 

10. Petitioner intends to operate the UAS exclusively within physical visual line-of-sight (VLOS), in 

accordance with the statutory mandate under Section 333(b)(1). 

11. Petitioner will always conduct a preflight safety risk assessment to determine that the UAS is in a 

condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can be completed safely. 

Please refer to the DJI Phantom 4 Operations Manual.

12. If petitioners ever has the opportunity to conduct operations which have existing requirements to 

notify Flight Standards District Offices (FSDOs) prior to operations – such as motion picture and 

television filming, or pipeline and powerline patrol – petitioner affirms coordination in this regard for 

the proposed flights. As a previous member of Screen Actors Guild and having several years of 

experience in front of and behind a commercial camera, the petitioner understands this type of 

coordination and agrees to comply. However, this is highly unlikely and is not the intended use of 

the UAS.
13. Petitioner understands the FAA intends to require a Certificate of Waiver or Authorization 

(COA) from the FAA Air Traffic Organization prior to conducting operation(s) in the NAS. Upon 

submittal of this docket filing, petitioner will obtain the docket number and apply for that certificate. 

It is also understood that the aircraft must be registered, and petitioner has registered this specific 

UAS with FA3NN3PYE7 as the approved registration number marked on the craft.