PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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Legg Seeds, LLC

Stephen Legg, Manager

3136E 500N

Windfall, IN 46076

March 10, 2016

US Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE 

Washington, DC 20590 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act") and 14 C.F.R Part 11, Legg Seeds, LLC (LS) seeks an 

exemption from Federal Aviation Regulations (FARs) detailed below for the 

Pacesetter Unmanned Aircraft System (UAS) manufactured by Precision 

Drone (http://www.precisiondrone.com/).

The requested exemption would support an application for a commercial 

Certificate of Authorization to operate an unmanned aircraft system to 

collect aerial data to support agriculture. The Pacesetter system consists of 

a lightweight battery operated aircraft (weighing 6.2 pounds), a personal 

computer based ground control station, and associated communications 

equipment. The unmanned aircraft carries an onboard geo-referenced still 

camera that allows it to conduct precision photogrammetry and crop 

scouting at the resolutions necessary for precision agriculture. This high 

resolution imagery can direct variable seeding rates as well as the precise 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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application of fertilizer and chemicals, reducing their use, which is a 

favorable environmental outcome. Data obtained by this UAS will help 

farmers to isolate and remove potential yield restraints while also 

decreasing their input costs. Simply put, the system will be a tool to assist 

growers in the management of their crops with the latest available 

technology (measuring photosynthesis efficiency). 

By approving these exemptions, the FAA will create an economic benefit to 

those engaged in food and grain production in addition to the general 

health of the environment. Use of UAS in this process holds a cost 

advantage, as well as a functional edge over other methodologies currently 

in the marketplace (primarily manned aerial aircraft or land based 

equipment).

The aircraft will be operated in the field with both a Pilot in Command (PIC) 

and a ground based Visual Observer (VO) in accordance with FAA Policy N 

8900.227 Section 14 “Operational Requirements for UAS" with the 

following restrictions: 

• All operations will occur in Class G airspace at no more than 400' 

AGL 

• Operations will be over private property, primarily farm fields, with the 

permission of the land owner or farm operator / controller or 

authorized representative

• Permission for operations (stated above) will be obtained for each 

flight

• All required permits will be obtained from state and local government 

prior to operation 

• The aircraft WILL NOT be operated:

o over urban or populated areas 

o at air shows 

o over open-air assembly of humans 

o over heavily traveled roads 

o within 5 Nautical Miles (NM) of an airport or heliport 

• Operations will be limited to daytime hours in visual meteorological 

conditions 

• The aircraft will remain clear of and give way to all manned aviation 

operations and activities at all times.
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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• Aircraft will remain within visual line of sight at no greater than onehalf NM of the PIC 

• While the aircraft is airborne, the VO will be positioned within voice 

distance of the PIC

The PIC and VO will meet the requirements outlined in FAA Policy N 

8900.227 Section 16 Personnel Qualifications. Zach Huff will be acting as 

PIC of this aircraft. Mr. Huff possesses an FAA issued Pilot License (cert # 

3487908) and has logged more than 121 hours of flight time. The PIC and 

VO will also perform maintenance on the system and will complete a 

course of maintenance/operational instruction as part of their initial training. 

LS will purchase the Precision Drone unmanned aerial system through Ag 

Technologies, Inc. (who is acting as the UAS sales & support team and 

technical advisor & trainer in conjunction with Precision Drone). LS will 

utilize the system on their own acreage in addition to providing services 

under contract to other farmers for the purposes described in this 

application.

We believe that the combination of the aircraft's light weight, previously 

demonstrated flight performance, fully qualified flight crew, operations over 

rural agriculture areas, and strict operation under the guidelines established 

in 8900.227, the FAA can have full confidence that the operation will have 

an equivalent or greater level of safety of manned aircraft performing the 

same mission. 

The name and contact information of the applicant is: 

Legg Seeds, LLC

Attn: Steve Legg (Manager) or Monty Henderson (Assistant GM

acting as the designated administrative person overseeing this 

project)

Phone: 765.945.7919

Email: steve.legg@leggseeds.com or 

monty.henderson@leggseeds.com

Legg Seeds, LLC is wholly owned by Legg Hillcrest Farms, Inc., an

American C Corporation chartered in Indiana with no foreign ownership.
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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The regulations from which the exemption is requested are as follows: 

• 14 CFR Part 21 

• 14 CFR 91.203 

• 14 CFR 45.23, 45.29 

• 14 CFR 91.9 

• 14 CFR 61.133 

• 14 CFR 91.119 

• 14 CFR 91.121, 91.151 

• 14 CFR Subpart E (91.401- 91.417) 

• FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) 

In our review of similar successful applicants that have petitioned for 

Exemption under Section 333, we observe that the FAA has found UAS 

operations dedicated to gather aerial data for purposes such as our intent 

to be in the good of the public interest because there are minimal risks 

associated, specifically:

 No airborne passengers or crew

 No flammable fuel

 Lightweight aircraft (6.2#)

In addition, we believe that there are measurable public benefits, including 

a more efficient agricultural economy and a healthier environment due to 

the precise applications of agricultural inputs.

Legg Seeds, LLC is willing to modify or amend this application to satisfy the 

FAA / US Department of Transportation. Please do not hesitate to contact 

us with any questions or concerns. 

Sincerely,

Stephen Legg, Manager 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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APPENDICES: 

A. Exemption Request and Equivalent Level of Safety – page 6

B. Aircraft Description, Safety Features, & Operation – page 11

C. PIC & VO Qualifications – page 12

D. Make & Model of Aircraft, Aircraft Features – page 13
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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Appendix A 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Legg Seeds, LLC (LS) requests an exemption from the following 

regulations as well as any additional regulations that may technically apply 

to the operation of the Precision Drone Pacesetter: 

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness 

certificate. While the FAA continues to work to develop airworthiness 

standards for UAS, we request an experimental certificate be issued for the 

Precision Drone Pacesetter under either or both of the following provisions: 

21.191 EXPERIMENTAL CERTIFICATES 

Experimental certificates are issued for the following purposes: 

(a) Research and Development. Testing new aircraft design 

concepts, new aircraft equipment, new aircraft installations, 

new aircraft operating techniques, or new uses for aircraft 

(b) Showing compliance with Regulations. Conducting flight 

tests and other operations to show compliance with their 

airworthiness regulations including flights to show compliance 

for issuance of type and supplemental type certificates, flight to 

substantiate major design changes, and flight to show 

compliance with the function and reliability requirements of the 

regulations. 

Since the experimental certificate can be used for commercial purposes 

such as market surveys, sales demonstrations, and customer crew training, 

we would expect that an experimental certificate would permit our 

commercial purpose of precision agriculture as well. 

The aircraft will not carry persons or property, will not carry fuel, and will 

only fly under strict operational requirements. Combined with the fact that 

the aircraft weighs only 6.2 pounds we propose that the Pacesetter will be 

at least as safe, if not safer, than a conventionally certified aircraft 

performing the same mission. If an experimental airworthiness certificate is 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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not appropriate for this application, then we request an exemption of 14 

CFR Part 21, Subpart H, and the requirements for airworthiness certificate 

in general. 

14 CFR 91.203(a) & (b) Civil Aircraft; Certifications Required 

The regulation provides that an airworthiness certificate, with the 

registration number assigned to the aircraft and a registration certificate 

must be aboard the aircraft. Additionally, subparagraph (b) provides that 

the airworthiness certificate be displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew. At 6.2 pounds the Pacesetter is 

too small to carry documentation, does not have an entrance to cockpit, 

and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we 

propose that those documents deemed appropriate for this aircraft by the 

FAA be located with the crew at the ground master command station and 

immediately available at all times upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and 

registration certificates be permanently affixed to the aircraft via a placard 

or sticker with the following information: 

• Manufacturer

• Model

• Serial Number

• Tail Number

• Registered to...

• Registrants Address

• If found. Please Call...

• We would also be willing to add any additional information to this 

placard that the FAA might require. 

14 CFR 45.23 Display of Marks; general and 45.29 Size of Marks

These regulations provide that each aircraft must display 'N' and the 

aircraft's registration number in letters at least 3 inches high. Additionally, 

the aircraft must display the word 'EXPERIMENTAL' in letters at least 2 

inches high near the entrance to the cabin, cockpit, or pilot station. The 6.2-

pound Pacesetter is not large enough to meet this size of markings. We 

propose the word 'EXPERIMENTAL' the 'N' number of the aircraft be 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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displayed on both the top and the bottom of the aircraft in 1 inch letters. It is 

our belief that this lettering along with the placard discussed in the previous 

paragraph will provide all of the necessary information for the aircraft 

Additionally, if the FAA deems necessary, we are willing to display signage 

at our ground master command station designating it as such. This signage 

will be in bright 6 inch letters or larger. This will allow anyone that observes 

the aircraft and chooses to inquire as to where its point of origin is can do 

so. 

14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard 

Requirements

This regulation provides that no person may operate an aircraft unless a 

current, approved flight manual is in the aircraft. We request an exemption 

to this requirement since the aircraft is not manned and is too small to carry 

documentation. To obtain an equivalent level of safety and meet the intent 

of 91.9, we propose that a current Aircraft Flight Manual (appendix D) be 

present and available to the crew at the ground master command station 

anytime the aircraft is in, or preparing for, flight. 

14 CFR 61.133 Commercial Pilot Privileges and Limitations 

This regulation provides that the person who holds a commercial pilot 

certificate may act as pilot in command of an aircraft for compensation or 

hire provided the person is qualified in accordance with the applicable parts 

of this chapter that apply to the operation, and that we have engaged a 

qualified person to fill this vital role, thus we propose that we will meet the 

requirements of this regulation. 

14 CFR 91.119 Minimum Safe Altitudes: General

This regulation provides that over sparsely populated areas the aircraft 

cannot be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. Since we will be operating the aircraft at a maximum altitude of 

400' AGL, we cannot comply with this requirement. 

To provide an equivalent level of safety we will only operate the aircraft 

over private property with the permission of the land owner. The land owner 

will be briefed of the expected route of flight and the associated risks to 

persons and property on the ground. We maintain that due to the small size 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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of the Pacesetter, the hazard to persons, vessels, vehicles, and structures 

is not comparable to manned aircraft and should be considered in granting 

the exemption to this regulation. 

The aircraft will not be operated over congested areas nor over any open 

air assembly of persons. The aircraft will be operated at an altitude 

allowing, if a power unit fails, an emergency landing can be made without 

undue hazard to persons or property on the surface. 

14 CFR 91.121 Altimeter Settings

This regulation provides that aircraft shall maintain cruising altitudes by 

reference to an altimeter setting available within 100 nautical miles of the 

aircraft. Our aircraft will fly below 400' AGL and will not need to maintain 

hemispherical cruising altitudes in order to de-conflict with other aircraft. To 

provide an equivalent level of safety, we will set the altimeter to our aircraft 

to 0' AGL on the ground prior to every flight to ensure we can accurately 

ensure that the aircraft stays below 400' AGL at all times. Even if there 

were rapid changes in barometric pressure, it would have little effect on our 

operation since the aircraft stays airborne for only 30 minutes or less at a 

time. 

14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions 

This regulation provides that no person may begin a flight in an airplane 

under day VFR conditions unless there is enough fuel to fly to the first point 

of intended landing and to fly thereafter for at least 30 minutes. The 

Pacesetter is a battery operated aircraft and the maximum duration of a 

flight with two fully charged batteries is 30 minutes. Additionally, since the 

aircraft will never fly more than 0.5 NM from point of launch, we feel that we 

would have adequate reserve “power'' to make a safe landing at intended 

landing site. We request an exemption from this regulation. 

14 CFR Subpart E (91.401- 91.417) Maintenance, Preventative 

Maintenance, and Alterations

This regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with 

part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

'approved for return to service by a person authorized under 43.7' after 

maintenance and inspection. It is our intention that the PIC perform
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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maintenance and inspection of the aircraft and be the 'authorized person to 

approve the aircraft for return to service.’

The PIC will ensure the aircraft is in airworthy condition by conducting a pre 

and post flight inspection after every single flight. Any maintenance 

performed by the PIC will be limited to repairing small cracks, replacing a 

propeller, tightening wire connections, and updating software and firmware. 

All other maintenance and repairs will be performed by the manufacturer. 

The PIC will document work performed in accordance with 91.417. We feel 

that due to the size, weight, and simplicity of the aircraft, the PIC can 

ensure an equivalent level of safety prior to launching the aircraft on each 

flight. 

8900.227 Paragraph 16 (c)(4) PIC Medical & Paragraph 16 (e)(1) 

Observer Medical

This policy provides that both the PIC and VO must have a valid FAA 

issued second class medical certificate under part 67 in order act as PIC or 

VO. We feel requiring both crew members that are operating a 6.2-pound

aircraft at less than 400' AGL meet the same medical requirements as a 

commercial pilot carrying passengers in a large manned aircraft are 

unnecessary. 

We propose that the PIC will have and maintain a valid FAA issued second 

class medical, but that the medical requirements for the VO be lessened to 

having vision corrected to 20/20 and a valid, state issued driver's license. 

We feel that if the VO is medically licensed to operate a vehicle on the road 

they then have the medical capability to perform their duties as a VO and 

assist the PIC with identifying and avoiding other air traffic. In the very 

unlikely event that both the PIC and VO become medically incapacitated 

while the aircraft is in flight, the Pacesetter has a failsafe program that 

when battery levels reach 30% the aircraft autonomously returns to home 

point and land without any crew inputs. 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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Appendix B

AIRCRAFT GENERAL DESCRIPTION, SAFETY FEATURES, & 

OPERATION

General Description

The Precision Drone Pacesetter is a remotely controlled hexacopter that is 

capable of both manual and autonomous flight and weighs only 6.2 

pounds. It will only be operated when sufficient GPS signal is available. 

More detailed data is included in the specification information in Appendix 

D.

Safety Features

There are a number of safety features programmed into the aircraft that will 

be utilized on every flight. For example: 

• If GPS signal is lost the aircraft will return to home point and land

• If signal from the transmitter is lost the aircraft will return to home

point and land

• If battery power reaches 30%, the aircraft will return to home point 

and land

Intended Operations

This aircraft will be utilized by our company for the purpose of crop scouting 

and precision agriculture. The use of this aircraft in this industry is intended 

to allow growers to maximize yields to continue to feed a growing global 

population. In servicing this industry, the aircraft will only be used in private 

rural agriculture settings once requested by the grower and granted 

permission by the grower. As mentioned previously, operating in areas 

such as this will allow Legg Seeds to eliminate public concern for (1) 

operating over urban or heavily populated areas and (2) personal privacy 

as our operations are committed to flying over production agricultural 

farmland. 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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Appendix C

PIC & VO QUALIFICATIONS

PIC Qualifications

The qualifications of our PIC, Zach Huff.

• Private Pilot License

 Single Engine Land

• Logged 121.4 flight hours

If Mr. Huff is not available to be our PIC, we will engage another person 

who has the required skill set as described:

“A PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government.”

VO Qualifications

We propose that the minimum medical requirements be vision corrected to 

20/20 and a valid, state issued driver's license. Due to the size and weight 

of the aircraft, the greatest hazard of our proposed operation will be driving 

on roadways to the launch site. A licensed driver is medically qualified to 

operate a much larger vehicle. The 20/20 vision requirement will ensure 

that the VO can see and avoid air traffic. Given the unlikely event that both 

the PIC and VO become medically incapacitated while the aircraft is in 

flight, the Pacesetter Precision Drone aircraft will return to home point and 

land without crew intervention.

Statement of Professional Integrity

Legg Seeds will also be proactive in reporting any and all observed 

operations that are not in compliance with the current safety requirements. 

LS, along with their employees and professional associates, desire to do 

their part in assisting with the successful transition of safely incorporating 

UAS into our NAS. 
PETITION FOR EXEMPTION UNDER SECTION 333 BY LEGG SEEDS

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Appendix D

Make & Model of Aircraft, Aircraft Features

Aircraft Details

Precision Drone Pacesetter Model

Web link: http://www.precisiondrone.com/product-list/pacesetter/

Aircraft features

 Precision VisionTM & Live Feed

o Composite videos show vegetative crop health

o Real-time live feed recorded and streamed to the ground

o 1080p high-def video quality / 11mp photo quality

 Remains Stable Even in Strong Winds

o Holds GPS location and proper flight orientation

 Failsafe Return Home Feature

o If controller communication fails, drone will safely return home 

to the original take off location.

 GIS Map integration

o Using Google 3D maps

o Ability to fly without internet or Wi-Fi

 Flight Status Monitoring

o GPS location on map

o Throttle/Speed

o Battery Level

o Directional heading

o Altitude

o Pitch
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 Preplanned Scouting Route

o Designate multiple scouting locations in your route

o Save scouting routes for future use

o Ability to preset altitude, latitude/longitude and hover time for 

each scouting location

 Flight Simulation Mode

o Test your planned scouting routes

o Includes failsafe error detection and correction