March 7, 2016 

US DOT-FAA 

Boo Independence Ave. S.W. 

Washington, DC 20591 

Dear FAA: 

Please find enclosed all copies of all submissions both electronic and print and please accept this 

letter as our response to your request for all information needed to process our petition for 

exemption from Section 333 requirements usually imposed on commercial pilots. Our tail 

number for our drone is N647FR. Our aircraft serial number is PH645200155 V2.0 

The specific section(s) of 14 CFR from which we seek relief include: 

• Title 14 ~ Chapter I~ Subchapter F ~Part 91, all subparts 

• Title 14 ~Chapter I~ Subchapter D ~Part 61, all subparts especially related to 

commercial operations that apply to unmanned aircraft approximately 15 pounds of 

weight 

• Title 14 ~Chapter I~ Subchapter G ~Part 119, all subparts related to commercial 

operations that apply to unmanned aircraft approximately 15 pounds of weight 

The extent of relief we seek is simply legal certification and open clearance to do our job for our 

clients, using our drone to collect high-quality pictures and video of their own homes to help sell 

their properties faster. 

Our request is in the public's interest because providing our drone photo and video service for 

real estate sales helps the public sort through exactly and only those properties which best suit 

their needs, saving many hours, dollars, and miles off the traditional real estate showing and 

purchasing process. 

Granting exemption to Legacy Farms and Ranches NC LLC would not adversely affect safety 

because we will not be flying our drone in areas that would come close to larger aircraft 

recreational or commercial, nor would our drone interfere with air traffic traditionally managed 

by regulated control towers in any of our 16 county area in central NC. 

Please grant us our exemption. Thanks for your att~ntion. 

Gardner Reynolds 

817 Mt. Vernon Church Rd . 

. ~aleigh, NC 27614 

919-749-3177 

• I 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

24 February 2016 

Mr. Gardner Reynolds 

Legacy Farms and Ranches LLC 

817 Mount V emon Church Road 

Raleigh, NC 27614 

Dear Mr. Reynolds: 

-· ~-- 800 Independence Ave .. S.W. 

Washington. D.C. 20591 

This letter is to inform you that we are unable to process your petition for an exemption. It explains 

why we cannot process your request and what you should do in the next 30 days. 

Why We Cannot Process Your Request 

We received your November 18,2015, exemption request on behalf of 

Legacy Farms and Ranches LLC filed in Docket No. F AA-2015-6306, but we are unable to process 

your request any further. Your petition does not comply with the requirements of§ 11.81 (copy 

enclosed). For us to consider the request any further, you must send us all of the following: 

• The specific section or sections of 14 CFR from which you seek relief and the extent of the relief 

you seek. 

• The reasons why granting the request would be in the public interest; that is, how it would benefit 

the public as a whole. 

• Any additional information, views, or arguments available to support your request. 

For more detailed information relating to submitting petitions for exemption, please visit 

http://aes.faa.gov/petition/index.html. This website helps the petitioner to meet Federal Aviation 

Administration (FAA) requirement outlines in § 11.81 and helps answer any questions you may have. 

What You Should Do 

If you want us to process your request any further, you must submit the requested information within 

30 days. Please note that § 11 .63( d) requires you to send your petition for exemption at least 120 days 

before the proposed effective date of the exemption. 
REGISTRATION NOT TRANSFERABLE 

UNITED STATES OF AMERICA I This certificate DEPARTMENT OF TRANSPORTATION- FEDERAL AVIATION ADMINISTRATION must be in the airCERTIFICATE OF AIRCRAFT REGISTRATION craft when operated. 

NATIONALITY AND I AIRCRAFT SERIAL NO. 

REGISTRATION -MARKS N 647FR PH645200155 V2.0 

MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT 

DJI PHANTOM VISION 2 + 

ICAO Aircraft Address Code: 52077711 

This certificate is 

issued for 

I REYNOLDS GARDNER W registration purposes 

s 817 MOUNT VERNON CHURCH RD only and is not a 

s RALEIGH NC 27614-9283 certificate of title. 

u The Federal Aviation 

E Administration does 

D not determine rights 

of ownership as 

T between private 

0 persons. 

Individual 

Aviation 

It is certified 

Administration

that the above 

, United 

described 

State.s 

aircraft 

of America, 

has been 

in accordance 

entered on 

with 

the 

the 

register 

Convention 

of the Federal 

on 0 

International Civil Aviation dated December 7, 1944, and with Title 49, United States Code, 

U.S. Department and regulations issued thereunder. 

DATE OF ISSUE January 25, 2016 

of Transportation 

Federal Aviation : . EXPIRATION DATE January 31, 2019 '~/~) ADMJ.Jjf§.J.f3f\ T.OR _.,Ac;lm.i.ojSf.r.,ati on.. _ .... .. . AC Form 8050-3 (1 0/201 0) Supersedes previous editions .. ... ; .. ~· ·· ... ... .... : ,_ .. • ... 
Regulations.gov will undergo scheduled maintenance and as a result the site will be 

unavailable Saturday February 20 from 11 :00 am through 1 :00 pm (ET). 

regulali ~V Your Voice in Federal Oedsion-MPking 

Legacy Farms and Ranches LLc·s - Exemption I Rulemaking 

This Other document was issued by the Federal Aviation 

Administration (FAA) 

For related information, Open Docket Folder ~ 

---· -·----------

Con tent 

Petition for Exemption/Rulemaking regarding Legacy Farms and 

Ranches LLC's use of UAS in the Raleigh-Durham area: 

We respectfully request an exemption from several FAA 

requirements in order to commercially operate an unmanned 

aircraft system (UAS) in our line of work mostly contained within 

a 16-county area around the "Triangle" in North Carolina, 

specifically around the airspace managed by Raleigh-Durham 

International Airport (RDU) 

Regarding the Unmanned Aircraft System 

1. The proposed UAS operation will be safely conducted to 

minimize risk to the NAS and to persons and property on the 

ground. The "drone" we use is the OJ I Phantom2 Quad copter for 

GoPro Hero kit and includes OJ I Zen muse H3-3D 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, cAnd will stay 

well away from airports or heliports as most of our photography 

work is in rural areas where farms and ranches are most 

prevalent. 

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. 

3. Please refer to the RF spectrums used as part of the 

controller mechanism from pilot to craft as described in the craft 

Flight Manual. Please note that this equipment complies with 

Federal Communications Commission (FCC) as stated in this 

manual. 

Comment Now! 

:·'·'-'···--·' .. ··--' 

ID: FAA-2015-6306-0001 

Document Information 

Date Posted: 

Nov 18,2015 

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1 Submitter Information ~ 

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Submitter Name: tl 

Gardner Reynolds f) 

'I Mailing Address·: 

817 Mount Vernon Church Road 

City: 

Raleigh 

Country: 

United States 

:.i !' State or Province: 

i 

i.J NC 

l·i ZIP/Postal Code: 

27614 

Comments 

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j Comments Received* j ,-: 

·-- --------- -·--·~--~·-· -------·--------- ~ .. --.J l 

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I This document is contained in 

·i FAA-2015-6306 
Regarding the Unmanned Aircraft PIC 

4. As a 30-years-experienced audio/visual producer, the pilot of 

this particular UAS has thoroughly studied the Phantom 2 

Quadcopter 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 visual 

observers could be engaged, 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 the Operation of the Unmanned Aircraft 

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 attract more buyers and present their property more 

competitively in the marketplace. The aircraft would not be flown 

over people without their consent or knowledge and would not 

present a threat to personal safety, security, or privacy. 

7. Please refer to the attached Operations 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 highquality photography. 

8. Petitioner intends to use the UAS in predominantly rural areas, 

over large parcels of real estate, and often without other people 

or structures anywhere in sight of the attached camera. 

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 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 SAG 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. 

Related Dockets: 

None 

Related RINs : 

None 

Related Documents: 

None 

*This count refers to the total 

comment/submissions received on 

this document, as of 11 :59 PM 

yesterday. Note: Agencies review 

all submissions, however some 

agencies may choose to redact, or 

withhold, certain submissions (or 

portions thereof) such as those 

containing private or proprietary 

information, inappropriate 

language, or duplicate/near 

duplicate examples of a mass-mail 

campaign. This can result in 

discrepancies between this count 

and those displayed when 

conducting searches on the Public 

Submission document type. For 

specific information about an 

agency's public submission policy, 

refer to its website or the Federal 

~ i 

i 

j 

, Register document. li :::Z=-=-=-··- -=--=--=-=-==:::;;;;;:::==:------·---- .j 
i 

< : 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 is in process 

of registering this specific UAS. 

Attachments (1) 

Legacy Farms and Ranches LLC's - Exemption I Rulemaking 

" '''• View Attachment: ~ 
regulati on~goV Your Voice in Federal Decision-Making 

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The Federal Aviation Administration (FAA) Other: Legacy Farms and Ranches LLC's- Exemption I 

Rulemaking 

For related information, Open Docket Folder ~ 

C~ ) Your Receipt 

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Your comment: 

Comment: 

March 7, 2016 

Dear FAA: 

In response to your letter dated Feb 24 2016, please find enclosed all 

copies of all submissions both electronic and print and please accept this 

letter as our response to your request for all information needed to process 

our petition for exemption from Section 333 requirements usually imposed 

on commercial pilots. 

Our tail number for our drone is N64 ?FR. 

The specific section(s) of 14 CFR from which we seek relief include: 

• Title 14 ~ Chapter I ~ Subchapter F ~ Part 91, all subparts 

• Title 14 ~Chapter I~ Subchapter 0 ~Part 61, all subparts 

especially related to commercial operations that apply to unmanned 

aircraft like ours, approximately 15 pounds of weight 

• Title 14 ~ Chapter I ~ Subchapter G ~ Part 119, all subparts 
related to commercial operations that apply to unmanned aircraft like ours, 

approximately 15 pounds of weight 

The extent of relief is Section 333 exemption, using our drone to collect 

high-quality pictures and video of their own homes to help sell their 

properties faster. 

Our request is in the public's interest because providing our drone photo 

and video service for real estate sales helps the public sort through exactly 

and only those properties which best suit their needs, saving many hours, 

dollars, and miles off the traditional real estate showing and purchasing 

process. 

Granting exemption to Legacy Farms and Ranches NC LLC would not 

adversely affect safety because we will not be flying our drone in areas 

that would come close to larger aircraft recreational or commercial, nor 

would our drone interfere with air traffic traditionally managed by regulated 

control towers in any of our 16 county area in central NC. 

Thank you in advance for your prompt attention. 

Uploaded File(s) (Optional) 

No files uploaded 

This information will appear on 

Regulations.gov: 

First Name: 

Gardner 

Last Name: 

Reynolds 

Mailing 

Address: 

817 Mount 

Vernon Church 

Road 

City: 

Raleigh 

Country: 

United States 

ZIP/Postal 

Code: 

27614 

This information will not appear on 

Regulations.gov: 

All information will be displayed 

on Regulations.gov