U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., SE Washington, DC 20590 July 20, 2015

Re: 

### Legion571, LLC

- Petition for Exemption to Operate Unmanned Aircraft Systems Pursuant to Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations
Dear Sir orMadam, Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, 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, VA201 05 Phone: 571-221-81 26 Email: mike@ ! iving571
.com
The Petit ionerrequests exemption from the following rules: 14 CFR, Part 21 , SubpartH; 14 CFR, 61.113(a) & (b); 14 CFR, 91.7(a); 14CFR, 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).

II P agePetition Summary Petitioner requests an exemption that would allow the commercial operation ofsmall, unmanned aircraft systems ("UAS") weighing less than 55 pounds for the purpose ofaerial 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 otherhigh-risk to inspect locations. • Search and Rescue would include such activities as: Amber, Senior and BlueAlerts
. The requested exemptions should be granted because the operation ofsmall UASs, pursuantto the conditions outlined below, will provide an equal or superior level ofsafety 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 lessthan 3 pounds, which is thousands ofpounds lighter than a conventional aircraft. Petitioner's UAS will operate within line ofsight ofthePilot 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 ofconsumer UAS expected to approach 425,000, an increase of65 percent. Including accompanying services, the market for drones could exceed $1 billion injustfive years' time. Accordingly, Petitioner respectfully requests that the FAA grantthe requested exemption without delay. Petitioner's UAS At the time ofthis writing, the Petitioner's UAS is a

## onPhantom 3 Professional. An important new flight feature on the Phantom 3 is the addition ofVision 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 theFederal Communications Commission ("FCC") requirements. The FAA has already granted Section 333 exemptions for the DJI Phantom 3 Professional (see Grant ofExemption 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 ofthe 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 ofthe Petitioner's UAS operations are expected to occurbelow 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 ofoperation 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 ofsight ofthe 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'sFAA- issued airman medical certificate orU.S. driver's license. All operations will utilize a Visual Observer (YO). The UAS will be operated within the visual line of sight ofthe 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) ofthe 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 ofthe FCC Rules. The User's Manual also states (page 53) that the UAS operating frequency ofthe 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 EquivalentLevel ofSafety 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 ofsight ofthe PIC and visual observer. • The maximum total flight time for each UAS flight will conclude upon the earlier of thirty (30) minutes oruntil25% ofUAS battery remains. • The UAS will be operated at an altitude ofno 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 cellulardevices. • Written or oral permission will be obtained from the landowners or their authorized agents ofthe land overwhich 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'') priorto conducting any operations under this grant ofexemption
. Satisfaction ofthe 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 ofsafe civil UAS operations 

### in the National Airspace System ("NAS"). 4 1 nag 1,:Specifically, Section 333(a) states that the FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion" of final rulemaking. Ifthe Secretary ofTransportation determines that certain UAS "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft 

### in the national airspace system. § 333(c)
. The FAA Administrator also has the general authority to grant an exemption ifthe 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 ofthe 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 adequatejustification to allow commercial operation ofPetitioner'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 ofour requested exemptions. Should you have any questions, or ifyou need any additional information to support the requested exemptions, please do not hesitate to contactthe undersigned.

Michael J. Donaldson 25062 Mineral Springs Circle Stone Ridge, VA 20105 5711225-9894 mike@living571.com

Attached

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### Dn Phantom 3 Professional Manual



### s I I' u ::

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