September 2, 2015

Exemption No. 12713

Regulatory Docket No. FAA−2015−1094

Mr. Devyn Daniels

Chairman

Skyeography LLC

2520 65th Avenue

Sacramento, CA 95822

Dear Mr. Daniels:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 13, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Skyeography LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography and videography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Parrot Bebop.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Skyeography LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Skyeography LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Parrot Bebop when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, 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. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 13, 2015

Skyeography LLC

2520 65th Ave

Sacramento, CA 95822

(916)821-7729

Skyeography@gmail.com

My name is Devyn Daniels, Chairman and pilot in command (PIC). I am one of three owners in 

Skyeography LLC (referred to as petitioner) and I am 1 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 Title14, Code of Federal Regulations (14

CFR). The exemption would allow Skeyeography LLC to safely operate the Parrot Bebop with a 

Skycontroller unmanned aircraft system (UAS) to conduct commercial UAS operations for the purpose of 

aerial photography for Real Estate, photographs, video, special events and/or occasions in an 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 

can’t 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 Skyeography LLC, on average the UAS 

will be operated at the maximum altitude of 130ft 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 of Skeyeography we have no consistent need to fly 

at that speed. Below is a chart/map (Appendix A) of speeds and a GPS data (Appendix B) of the flight 

path of the UAS. The first chart shows the UAS never reached altitudes higher than 40m or 130ft for no 

longer than a minute, and speeds no faster than 11mph which is a typical or average flight.
 Appendix A: Appendix B:
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 C) below is the Wi-Fi Regulation the UAS uses on each frequency which complies 

with all US regulation:
(Appendix C) - 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 

stably. The PIC will have vision comparable to a Class C California licensed driver. The petitioner who I 

will refer to as the PIC from this point forward has over 100 successful flights with the UAS and total 

hours exceeding 100 plus each day exceeding that because of daily flights that occur. The PIC is 

competent and confident in his ability to pilot any UAS with the given manual due to his long and 
extensive background and experience of over 1000 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 PIC is 

also a member of the AMA which is described in the next paragraph. 

All PICs will be required to become a member of the Academy of Model Aeronautics (AMA), to insure 

operators stay up to date on all new and existing regulations and stay informed about the newest 

Aeronautics information. As a member of the AMA the PIC receives Member Insurance Benefits which 

includes a $2.5 Million Liability Umbrella, $25,000 in Medical Coverage, $1,000 Fire and Theft Coverage.

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

outdoor events or any need for our services as long as it’s 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 

am 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 

a 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 area.

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 batteries are charged.

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