November 4, 2015

Jeremy J. Skarr

9041 Secret Valley St

Las Vegas, NV 89139

702-418-4331

jeremyskarr@gmail.com

My name is Jeremy J. Skarr, pilot in command (PIC). I am an independent photographer, 

videographer, and unmanned aircraft system (UAS) operator requesting permission from the 

Federal Aviation Administration (FAA) to grant exemption from part 21 §§ 45.23(b), 61.113(a) 

and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b),

91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and(b) of Title 14, Code of Federal 

Regulations (14 CFR). 

The exemption would allow Jeremy J. Skarr to safely operate the Parrot Bebop with a 

Skycontroller (UAS) to conduct commercial UAS operations for the purpose of aerial 

photography for Real Estate, photographs, video, special events and/or occasions in a controlled 

environment that will not interfere with the safety and/or well being of individuals. By operating 

the UAS within the parameters below; which does not jeopardize the safety of the public but in 

fact protect the safety of individuals through use of a lightweight compact UAS rather than a 

manned aerial vehicle which has the potential to jeopardize the PIC, the crew, damage the 

target or object(s) being filmed, or cause serious injury to the public or parties involved.

The Parrot Bebop is a lightweight quad copter also known as a UAS that was built with safety in 

mind. It has a weight of 400g with the dimensions of: 28 x 32 x 3.6cm/11 x 12.6 x 1.4in.

This UAS is very small, lightweight and compact with an emergency mode. In the event of an 

extraordinary circumstance where the propellers come into contact with an object, the 

propellers will stop automatically to prevent any damage. The software used to run the UAS has 

country settings, that cannot be changed, that will not allow the UAS to travel above 400ft 

altitude since that is the safe height FAA has allowed for any UAV. The UAS comes with a 

controller called the Skycontroller that extends the range (ranges up 1.4mi/2km in optimal 

condition) and reliability of the connection between the UAS and controller. In a unique

occasion where there is a disconnection between the controller and the UAS, the UAS will 

automatically maintain its position without moving, giving the operator one minute to 

reconnect to the UAS; if a reconnection is unsuccessful, the UAS will automatically return to the 

location where the UAS last took off. The software used to control the UAS is called Free Flight 

which comes preinstalled onto the controller. With the Free Flight software, you have full 

control of options for safe operation. This includes max vertical speed, max rotational speed,

max altitude and max inclination. The max vertical setting allows for the vertical movement 

speed of the UAS. The max rotational speed allows for the movement speed of the yaw 

(movement along the Y-axis). Max altitude allows for the maximum height the UAS can fly; but,
the software as stated previously will only allow for a maximum of 150m which cannot be 

changed. For the intended use listed above for Jeremy J. Skarr, on average the UAS will be 

operated at the maximum altitude of 100ft and for rare occasions if the UAS needs to travel 

higher than the average it will not come close to exceeding 400ft. Max inclination is the speed 

setting which controls the degree at which the tip of the nose of the UAS will fly for a maximum 

speed of 13m/s or approx 30mph. For the intended commercial use, I have no consistent need 

to fly at that speed. 

Free Flight gives the option to change the channel for maximum connectivity between the 

Skycontroller and the UAS for less interference. The Free Flight software used to control the UAS

has a diagnostic tool to alert the operator about the current firmware on the UAS and 

Skycontroller; it also alerts the operator about motor functionality.

The Parrot Bebop (UAS) uses Wi-Fi 802.11a/b/g/n/ac for connectivity between the UAS and 

controller. The Wi-Fi antenna comes with MIMO dual-band channel 2.4 GHz and 5 GHz sending 

power up to 21dBM and signal range up 250 meters. The Parrot Bebop also contains various 

sensors to distinguish its position, height and stability which include:

 3-axes magnetometer

 3-axes gyroscope

 3-axes accelerometer

 Optical-flow sensor; Vertical stabilization camera which every 16 milliseconds, an image 

of the ground is taken and compared to the previous one to determine the speed of the 

UAS.

 Ultrasound sensor that analyzes the flight altitude up to 8 meters

 Pressure sensor

When the drone is above eight meters the UAS uses GPS+GLONASS (GNSS) to determine its 

position. All of the components of this UAS meet FCC compliance and does not conflict with any 

other government agency.

Referenced (Appendix A) below is the Wi-Fi Regulation the UAS uses on each frequency which 

complies with all US regulation:
(Appendix A) - WiFi Regulation
The UAS does not require any special training or certification to pilot. The control layout of the 

UAS consists of two sticks. One stick controls the Yaw movement and altitude height. The other

stick controls the lateral movement, forward and back movement. When both control sticks are 

idle the UAS hovers stable. The PIC will have vision comparable to a Class CM 

(Cars/Vans/Pickups, Motorcycle) Nevada licensed driver. The petitioner, also known as the PIC 

from this point forward, has over 110 successful flights. The PIC is competent and confident in 

his ability to pilot any UAS with the given manual due to an extensive background and 

experience of over 90 hours piloting 3-channel helicopters. 3-channel helicopters have very 

similar controls to UAS; except with the 3-channel helicopter the PIC is in full control of the 

helicopter and there is no computer or technology to keep the aircraft stable which makes this

UAS easier to pilot than a 3-channel helicopter. The PIC has a vast understanding of the FAA 

regulations currently in place, and frequently checks for updates and changes to regulations.

The intended operation is solely for the purpose of photography/videography of real property, 

nature, special outdoor events, or any need for aerial video and photography services as long as 

it is in a controlled or private property. The UAS would maintain a safe stabilized position in the 

air not above any human with the UAS having slight movements. Standard procedure for UAS 

during operation will be as follows: before the operation of the UAS it will be required to notify 

all affected parties regarding the operation of the UAS, the flight pattern and/or the position of 

the UAS flight. All affected parties will be aware of the UAS in use and the intended use of the 

UAS will be made clear to all parties present. All members will be informed to maintain a safe 

distance from the UAS while it is in use. If verbal contact is made by the Visual Observer (VO) to 

anyone who comes within a safe distance of the UAS it will be agreed that they comply with the 

VO commands. The VO will be responsible to relay any possible safety situations to the PIC or 

any civilian or human that comes within an unsafe distance of the UAS. Set define areas in the 

surrounding areas will be marked as unsafe zone. Any person(s) will be immediately notified by 

the PIC or VO if within an unsafe distance of the UAS. 

The UAS will be only piloting for its minimal capabilities and well within the current regulations 

of the FAA, which is flying no higher than 400ft, the UAS will remain in Visual Line of Sight 

(VLOS), will remain clear of any manned aircraft operations, not pilot within five miles of an 

airport without contacting the airport or control tower, not fly under the influence of alcohol or 

drugs, will not fly over sensitive property or infrastructure such as power stations, water 

treatment facilities, government facilities, correctional facilities, heavily traveled roadways, not 

fly under adverse weather conditions such as reduced visibility or high winds, the PIC will be 

operating in a safe environment and the operator is competent and proficient in the operation 

of the UAS, and will not conduct surveillance or photograph persons in areas where there is an 

expectation of privacy without the individuals permissions.

The UAS will majority of flight time maintains steady speeds of no faster than 5-8 meters/per 

sec (m/s) when filming outdoor social events or real property. The UAS as stated above can fly at 

maximum speed of 35mph, the only time UAS would travel this speed is in an open environment

that is controlled and sealed off with limited human contact so that it could be possible to 
capture a rare aerial aspect that could not otherwise be captured. To capture similar images it 

would require a manned vehicle such as a helicopter which would require a crew. In addition, a 

UAS does not put out any emissions, which has no affect on the environment like a helicopter 

would to achieve the same capabilities of a UAS. In a rare collision with the UAS there will be no 

casualties and no serious injuries, as opposed to risking a crew for an aerial shot that can be 

much easier captured with a UAS, and the cost to operate a UAS as opposed to the alternatives 

is much lower and reasonable.

Operations Manual for Parrot Bebop (refer to manual page 8-9 that was uploaded with the 

exemption)

Preflight Check

*Before each flight session, check the following points:

o Do not fly the Parrot Bebop Drone at night.

o Check the weather conditions. Do not fly the Parrot Bebop Drone when the

weather is rainy, snowy, or foggy.

o Ensure there is no obstacle in your flight area that could disturb piloting or 

visual

flight.

o Ensure the use of the Parrot Bebop Drone is allowed in your flight are

o Check the Wi-Fi use restrictions in your flight area. (Pg.4 of exemption)

o Ensure the propellers are correctly installed and locked. For further information, 

see

Before you begin (Pg.4 Manual)> Changing the propellers(Pg.7 Manual)

o Ensure the battery is correctly attached to the Parrot Bebop Drone. For further

Information, see Before you begin (Pg.4 Manual)> Installing the battery.

o Ensure the Parrot Bebop Drone and your Smartphone and/or tablet batteries 

are charged.

o Check the quality of the Wi-Fi range. For further information, see Settings > WiFi.