U.S. Department ofTransportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

July 20, 2015 

Re: Legion571, LLC - Petition for Exemption to Operate Unmanned Aircraft 

Systems Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95 

(2012) ("Section 333") and the general exemption authority of the Federal Aviation 

Administration ("FAA") under 49 U.S.C. § 4470l(f), Legion571 , LLC ("Petitioner") hereby 

petitions for exemptions from Federal Aviation Regulations listed below. 

Contact: Legion571, LLC @: 

Michael J. Donaldson 

25062 Mineral Springs Circle 

Stone Ridge, VA 201 05 

Phone: 571-221-8126 

Email: mike@! iving5 71 .com 

The Petitioner requests exemption from the following rules: 

14 CFR, Part 21 , Subpart H; 

14 CFR, 61.113(a) & (b); 

14 CFR, 91.7(a); 

14 CFR, 91.9(b) (2); 

14 CFR, 91.103(b)(1 and 2); 

14 CFR, 91.105; 

14 CFR, 91.109; 

14 CFR, 91.119; 

14 CFR, 91.121 ; 

14 CFR, 91.151 (a); 

14 CFR, 91.203(a) & (b); 

14 CFR, 91.405(a); 

14 CFR, 91.407(a)(l); 

14 CFR, 91.409(a)(2); and, 

14 CFR, 91.417(a) and (b). 

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Petition Summary 

Petitioner requests an exemption that would allow the commercial operation of small, unmanned 

aircraft systems ("UAS") weighing less than 55 pounds for the purpose of aerial photography 

and video, aerial real property inspections and participation in search and rescue operations in 

conjunction with law enforcement personnel. 

• Aerial Photography and Video would include such activities as: producing images for 

marketing real estate and other products. 

• Aerial Photography and Video Inspections would include such activities as: utility or 

other high-risk to inspect locations. 

• Search and Rescue would include such activities as: Amber, Senior and Blue Alerts. 

The requested exemptions should be granted because the operation of small UASs, pursuant to the 

conditions outlined below, will provide an equal or superior level of safety as Congress intended. 

Petitioner's UAS are small and will operate at slow speeds, close to the ground, away from 

airports in low-risk, low-population environments. The Petitioner's UAS (OJI Phantom 3) 

weighs less than 3 pounds, which is thousands of pounds lighter than a conventional aircraft. 

Petitioner's UAS will operate within line of sight ofthe Pilot in Command and Visual Observer. 

The Petitioner's UAS will carry no passengers, has enhanced safety measures (like a 

GPS-Enabled "goefence") and will operate under the specific guidelines and recommendations of 

the FAA and the UAS Manufacturer. 

According to the Consumer Electronics Association, the global market for consumer UAVs will 

approach $130 million in revenue in 2015, increasing by more than 50 percent from 2014; with 

unit sales of consumer UAS expected to approach 425,000, an increase of 65 percent. Including 

accompanying services, the market for drones could exceed $1 billion in just five years' time. 

Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption without 

delay. 

Petitioner's UAS 

At the time of this writing, the Petitioner's UAS is a on Phantom 3 Professional. 

An important new flight feature on the Phantom 3 is the addition of Vision Positioning, which 

allows the UAS more safely when low to the ground. With Vision Positioning, the Phantom 3 

uses visual and ultrasonic sensors to scan the area beneath the drone to determine its location and 

guide its flight. 

Safety is also enhanced because the Petitioner's UAS works with GLONASS satellites (Russia's 

version of GPS) in addition to standard GPS satellites. More satellites means faster signal 

acquisition and that it will more reliably stay locked during flight. 

The on Phantom 3 Professional also has a simple to use "return borne" feature, simply press a 

button on the controller and the Phantom will return to the Pilot in Command (PIC). 

Petitioner's UAS use a radio frequency spectrum for operation and control that complies with the 
Federal Communications Commission ("FCC") requirements. The FAA has already granted 

Section 333 exemptions for the DJI Phantom 3 Professional (see Grant of Exemption 12042). 

For additional information, please refer to the attached manual from Dn. 

Petitioner's UAS will be identified by serial number, registered in accordance with 14 CFR Part 

47, and have identification (N-Number) markings in accordance with 14 CFR Part 45, Subpart C. 

Markings will be as large as practicable in accordance with § 45.29(f). 

The DJI Phantom 3 Professional, as of this writing, is one of the safest and easiest UASs to 

operate. 

Flight Conditions and Operations 

The UAS will be flown in airspace under 400 feet above ground level and under controlled 

conditions. The majority of the Petitioner's UAS operations are expected to occur below 150 feet 

above ground level. 

If Petitioner intends to operate within five (5) miles of any active landing strip or airport, 

Petitioner will follow FAA procedures and notifying the FAA in advance of operation and when 

operation is complete. 

The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour) or at an 

airspeed greater than the maximum UAS operating airspeed recommended by the aircraft 

manufacturer. 

Petitioner will follow the procedures for start-up set forth in the manual for each UAS. 

Additionally, Petitioner will perform a site inspection before each flight to determine additional 

measures that may be necessary to safely operate the UAS. 

The UAS will be operated within visual line of sight of the PIC at all times. This requires the PIC 

to be able to use human vision unaided by any device other than corrective lenses, as specified 

on the PIC's FAA- issued airman medical certificate or U.S. driver's license. 

All operations will utilize a Visual Observer (YO). The UAS will be operated within the visual 

line of sight of the PIC and YO at all times. The YO and PIC must be able to communicate 

verbally at all times. The PIC and VO will be in constant communication through at least one 

(1) of the following methods: cellular phone communication (constant open call during flight); 

two-way radio communication; or verbal communication. Petitioner will further perform a 

pre-flight communications check to make sure the PIC, visual observer, and UAS can remain in 

contact. 

The DJI Phantom 3 Professional User's Manual states (page 56) the following: This device 

complies with part 15 of the FCC Rules. The User's Manual also states (page 53) that the UAS 

operating frequency of the Controller is 2.400 GHz-2.483 GHz. 

Lastly, Flight and maintenance records will be documented using Kittyhawk, a professional 

flight logging program for specifically designed for UASs. 
Public Interest 

Petitioner's UAS business will provide aerial photography and video services to a wider group of 

consumers than current fixed wing and helicopter aerial photography businesses. Petitioner's 

UAS business will make aerial photography and video affordable to middle and lower class 

consumers. 

One of Petitioner's proposed uses of the UAS under this application is for search-and-rescue 

missions. Petitioner will pursue contracts with local law enforcement agencies for UAS 

operations. Very few law enforcement agencies in Virginia and Maryland can afford to 

maintain fixed-wing aircraft and helicopters. The Petitioner's UAS will be able to aid and 

support search efforts for a fraction of the cost, risk, and resources. Petitioner's UAS 

capabilities, in cases such as an Amber, Senior and Blue Alerts, is a valuable asset to public 

safety personnel and society as a whole. 

Aircraft and Equivalent Level of Safety 

Petitioner agrees to the following FAA limitations and conditions with conducting its 

commercial UAS operations: 

• All UAS will weigh no more than 55 pounds. 

• All UAS will be operated within line of sight of the PIC and visual observer. 

• The maximum total flight time for each UAS flight will conclude upon the earlier of 

thirty (30) minutes or until25% ofUAS battery remains. 

• The UAS will be operated at an altitude of no more than 400 feet above ground level. 

• The minimum crew for each UAS flight will be the PIC and one visual observer. 

• The crew for each operation will at all times be able to communicate by voice or through 

radio or cellular devices. 

• Written or oral permission will be obtained from the landowners or their authorized 

agents of the land over which all flights will occur. 

• All UAS will have the capability to abort a flight in case of unexpected obstacles or 

emergencies. 

• Petitioner will follow pre-flight inspections, maintenance, and repair, to ensure that the 

UAS is in a condition for safe flight, established by the UAS manufacturer and detailed 

in the UAS Operator's Manual. 

• All UAS will be equipped with enhanced failsafe (return-to-home) technology. 

• Petitioner will obtain an Air Traffic Organization issued Certificate of Waiver or 

Authorization ("COA'') prior to conducting any operations under this grant of exemption. 

Satisfaction of the Section 333 criteria (size, weight, speed, operating capabilities, proximity to 

airports and populated areas, operation within line of sight and national security) provides an 

adequate justification for the grant of the exemptions requested herein allowing Petitioner's 

commercial operation of UAS for the purpose of aerial photography and video, aerial real 

property inspections and participation in search and rescue operations in conjunction with law 

enforcement personnel. 

Statutory Authority for Exemption 

Section 333, in reference to 49 U.S.C. § 44704, provides a mechanism for expedited operational 

authorization for the use of safe civil UAS operations in the National Airspace System ("NAS"). 

41 nag 1,: 
Specifically, Section 333(a) states that the FAA "shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion" of final 

rulemaking. If the Secretary of Transportation determines that certain UAS "may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system. § 333(c). The FAA Administrator also has the 

general authority to grant an exemption if the Administrator fmds the exemption to be in the 

public interest. 49 U.S.C. § 44701(£). The Federal Aviation Act (the "Act") expressly grants the 

FAA the authority to issue exemptions for exempt civil aircraft, as defmed by § 40101 of the 

Act, which includes an exemption for small UAS from the requirement that all civil aircraft have 

a current airworthiness certificate. 

Conclusion 

This Petition for Exemption demonstrates the appropriate safeguards and criteria that Congress 

articulated in Section 333 regarding weight, speed, operating capabilities, proximity to airports 

and populated areas, operation within VLOS and national security concerns. The Petitioner's 

proposed UAS operations will benefit the public as a whole by reducing the risks and costs 

associated with manned aircraft performing the activities. The public would also benefit from 

Petitioner's proposed search and rescue operations. This Petition for Exemption provides the 

FAA with more than adequate justification to allow commercial operation of Petitioner's small 

UASs for the purpose of aerial photography and video, aerial real property inspections and 

participation in search and rescue operations in conjunction with law enforcement personnel. 

We appreciate your prompt consideration of our requested exemptions. Should you have any 

questions, or if you need any additional information to support the requested exemptions, please 

do not hesitate to contact the undersigned. 

Michael J. Donaldson 

25062 Mineral Springs Circle 

Stone Ridge, VA 20105 

5711225-9894 

mike@living571.com 

Attached - Dn Phantom 3 Professional Manual 

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