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

Regulations 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 complete 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 requesting 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 

companies.

Building contractors are not available for ladder inspections, and accessing the roof in such a way is risky for 

bodily injury and most often just not possible.

Aerial inspections completed by a very small 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 model aircraft. It is approximately 14 inches in 

diameter. 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 fly 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 flight 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 observation. A second person on my 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 times 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 

come into contact with them. A high-resistance EPP outdoor hull protects other objects from potential bumps of 

the propellers. I have $50,000 dollars of insurance coverage for bodily harm and the same coverage for property 

damage as a contractor. I am also a member of the Academy of Model Aeronautics. 
The model aircraft is capable of only a short flight on its battery time 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

Email: alupdyke@gmail.com

Specifications :

ConnectivityWi-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 fiber 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"

"Camera with ""Fisheye"" lens 180° 1/2,2"": 6 optical elements and 14 Mega pixels sensor 

Video stabilization: Digital on 3-axes

Video definition: 1920x1080p (30fps)

Photo definition: 4096x3072 px

Video encoding: H264

Photo file format: JPEG, RAW, DNG

Internal memory: Flash 8 GB

BatteryLithium Polymer

Lithium Polymer 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 

compared to the previous one to determine the speed of the Bebop Drone)
Ultrasound sensor (Analyzes the flight altitude up to 8 meters)

Pressure sensor

Geo-locationGNSS

GNSS (GPS + GLONASS) 

Dimensions28x32x3.6cm

28x32x3.6cm without the hull

33x38x3.6cm with the hull

Weight400g

With battery, 400g without the hull and 420g with the hull