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 photogra phy for Real Estate, photographs, video, speci al 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 do es 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) bein g 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
. Th is 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 autom atically to prevent any damage. The software used to ru n the UAS has country settings, that cannot be ch anged, 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 with out mov ing, giving the operator one min ute 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 pre installed onto the controller
. With the Free Flight software, you have full control of options for safe operation. This includes m ax 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 on ly allow for a maximum of 150m which cannot be

change d. For the intended use listed above for Jeremy J. Skarr, on average the UAS will be operated at the m aximum altitu de of 100ft a nd for rare occasion s if the UAS needs to travel higher than the average it will not come close to exceed ing 400ft
. Max inclination is t he speed setting which controls the degree at which the tip of the nose of the UAS will fly for a maximum speed of 13 m/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 t he UAS for less interference. T he 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. Th e Parrot Bebop (UAS) uses Wi
- Fi 802.11a/b/g/n/ac for connectivity between the UAS and controller. The Wi
- Fi antenna come s 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 RegulationThe 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 m ovement 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 h ave vision comparable to a Class C M (Cars/Vans/Pickups, Motorcycle) Nevada license d driver
. The petitioner, also known as the PIC fro m this point forward, has over 110 successful flights . The PIC is competent and confident in h is ability to pilot any UAS with the given manual due to an extensive background and experience of over 9 0 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 stab le which makes this UAS easier to pilot than a 3
-channel h elicopter
. The PIC has a vast understanding of the FAA regulations currently in place, and frequently checks for updates and change s to regulation s . 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 a ir not above any human w ith the UAS having slight movements. Standa rd procedure for UAS during operation will be as follows : b efore the operation of the UAS it will be required to n otify all a ffected parties regarding the operation of the UAS, the flight p attern 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 ma de 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 with in an unsafe distance of the UAS. Set define areas in the surrounding areas wi ll be marked as unsafe zone. Any person(s) will be immediat ely notified by the PIC or VO if within an unsafe distance of the UAS. T he 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, n ot 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 un der adverse weather conditions such as reduced visibility or high winds, the PIC will be operating in a safe e nvironment 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 fl ight 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 tocapture 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 re quire 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 a n 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 > Wi
Fi.