### 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 ourjob 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

• IU.S. Department of Transportation Federal Aviation Administration



### 24 February 2016

Mr. Gardner Reynolds Legacy Farms and Ranches LLC 817 Mount Vemon 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. FAA-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 ofthe 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 ofthe 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 It is certified that the above described aircraft has been entered on the register of the Federal 

# 0
Aviation Administration , United State

. s of America, in accordance with the Convention on 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

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## ... AC Form 8050
- 3 (1 0/201 0) Supersedes previous editions 

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### Regulations.gov will unde rgo scheduled maintena n ce and as a resu lt the site w i ll be u navai l able S aturday February 20 from 11 :00 am t hrough 1 :00 pm ( ET ).

# regulali**~V** Y our Voic e in Federa l O eds ion -M P ki ng 

# Legacy Farms and Ranches LLc·s

- Exemption 

# I Rulemaking

This Other document was issued by the 

### Federal A viation Administration (FAA) For related information, 

### Open Docket Folder**~**
---· 

### -·----------


## Co n 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!

:·' ·' -' ·· ·-- · '

.. ··-- ' I D: FAA-2015-6306-0001


## Docum ent Informat io n Date Posted: Nov 18,2015 :l i
i S h ow M ore D etails L9 ' ,- .. , .J

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II I! 

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1 1 

## Sub mitte r Inform ati on

## ~

:J _:;· ! 1 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


## C o mme n ts**~-- ------·---** **----- ·------,**  

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## Comments Received* j ,- :**·-- ----** **----- -·--** **·~- -~·** **-· -------·-------** **-- ~** ..

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# ~-**-- ~~~:** **~~~ io** **n** --- i 

## I This document is contained in

· i FAA-2015-6306Regarding 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. Re l ated Dock ets: None Related RINs : None Re l ated 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=-= -=-** **··- -=--=--=-=-**  ==:::;;;;;:::==:------·---- .ji 

# <**:** 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:**~**

# reg**ula ti** **on~go V**  Y our Voice i n Federal Decision- Makin g 

# Your comment was submitted**successfully~**

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

### I Rulemaking For related information, Open Docket Folder**~**

# C~**)** Your R eceipt

. -
. ..**~** .. ... :.**-..: ~---**  ... .. ......**-- ~**  --···**~** · - - -- ·.**·- ·-** **--** ..**-~---** . _ ..**-~ ~**  -·· · ...**--~·- ··** **···· ·-.-** **··· ·-**  . .... . I

. ' 

## Y

ou r Comment Tracking Number: ' 1k0-8od4..Six8 

### Your comment may be viewable on 

### Regulations.gov once the agency has reviewed it. This process is dependent on 

### agencypublic submission policies/procedures andprocessing tiJnes. Use your tracking number to find out the status of your comment.**Your** 

### email receipt was sen t successfully

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: 

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