U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regula tions from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) April 25, 2015 Dear Sir or Madam: As an inspector of residential properties for insurance companies, and a real estate agent representing the buyer, I often encounter situations where I cannot compl ete the required inspection. Examples are flat or nearly flat roofs and houses located close together, inhibiting a view of the roof. Homebuyers want to know what material is used on a flat roof and what condition it is in. Insurance companies are reques ting photographs as proof of the present condition of the roof of the property they are writing a policy for. Hail or wind damaged, aged, and improperly installed roofing materials pose a much greater risk for insurance com panies. Building contractors are not available for ladder inspections, and accessing the roof in such a way is risk y for bodily injury and most often just not possible. Aerial inspections completed by a very sm all and light- weight drone within a time frame of 15 minutes will provide information to the consumer that could save them thousands of dollars in repairs needed later due to leaking roofs or water damage inside their home. Such accurate roof inspections will save insurance companies huge sums in claims due to water damage. I am requesting an exemption of current rules preventing the use of model aircraft for such purposes pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FAA- 2014 - 0958 - 0001). I will use a Parrot BeBop Drone, a very small and lightweight mo del aircraft. It is approximately 14 inches in diam eter. The Parrot BeBop is really just a high - tech toy, but it has the capability to meet my inspection needs. Using this model aircraft for the inspection of residential property roofs, I will always fl y it in visual line of sight and below 100 feet of elevation. Such flights will be conducted during daytime Visual Flight Rules (VFR) conditions, and operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports as follows: 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument fli ght procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure. Spectators will not be allowed and a property owner wanting to observe the inspection will be placed 20 feet behind the operator for safe observatio n. A second person on m y flight crew will maintain such order with the public for their safety. As the launch operator, I will be responsible for ensuring the safe conduct of the launch and for ensuring public safety and the safety of property at all tim es during the conduct of such a permitted launch. Because the model weighs less than one pound, it is unlikely to cause any damage to other objects if it does com e into contact with them. A high - resistance EPP outdoor hull protects other objects from pote ntial bumps of the propellers. I have $50,000 dollars of insurance coverage for bodily harm and the same coverage for property dam age as a contractor. I am also a member of the Academ y of Model Aeronautics.The model aircraft is capable of only a short flight on its battery tim e of 22 minutes. This model aircraft is not designed or equipped to carry objects of any kind. It's sole purpose is to deliver high quality still photographs. Specifications for the Parrot BeBop Drone are included below. Thank you for your consideration and I look forward to your timely response. Alan Updyke

PA License RS276381 Real Estate Sales Person Address: 95 Kirby Ave Mountain Top, PA 18707 Em ail: alupdy

ke@gmail.com **Specif ications :**  Connectivity

Wi - Fi 802.11a/b/g/n/ac Wi - Fi antennas: MIMO dual - band with 2 double - sets of dipole antennas for 2.4 and 5 GHz Sending power: Up to 21 dBm Signal range: Up to 250 meters StructureHigh - resistance 4 Brushless Outrunner motors Glass fi ber reinforced (15%) ABS structure High - resistance EPP outdoor hull: Clip and unclip easily to adapt to indoor and outdoor flight, protects the propellers against potential bumps, can be removed to reduce wind factor Three - blade auto - block propellers in Polycarbonate with fast disassembly system Anti - vibration bumpers Speed13 m/sCameraCMOS 14Mpx, 1/2.3" "Cam era with ""Fisheye"" lens 180° 1/2,2"": 6 optical elements and 14 Mega pixels sensor Video stabilization: Digital on 3 - axes Video definition: 1920x 1080p (30fps) Photo definition: 4096x3072 px Video encoding: H264 Photo file format: JPEG, RA W, DNG Internal memory : Flash 8 GB BatteryLithium Polyme r Lithium Poly me r 1200 mAh Flight time: 22 minutes with 2 batteries included ProcessorCPU: Dual - Core Mother board:

- Parrot P7 dual - core CPU Cortex 9

- Quad core GPU

- 8Gb flash memory All fixed on a magnesium shelf that acts as electromagnetic shielding and as a radiator Operating system: Linux Developping: Open - source SDK Sensors3 - axes 3 - axes magnetometer 3 - axes gyroscope 3 - axes accelerometer Optical -flow sensor : Vertical stabilization camera (Every 16 milliseconds, an image of the ground is taken and com pared to the previous one to determine the speed of the Bebop Drone)Ultrasound sensor (Analyzes the fli ght altitude up to 8 meters)

Pressure sensor Geo - locationGNSS GNSS (GPS + GLONASS) Dim ensions28x32x3.6cm 28x32x3.6cm without the hull 33x38x3.6cm with the hull We ight400g Wi th battery, 400g without the hull and 420g with the hull