September 2, 2015

Exemption No. 12713 Regulatory Docket No. FAA

− 20 15

− 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 ai rcraft system (UAS) to conduct aerial photography and videography

.

See Appendix A for the petition submitted to the FAA des cribing 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 p etitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a Parrot Bebop

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in2

consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secre tary 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

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , an d 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 collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , 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 peti tioner 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 i nterest.

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 exempt ion 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 UA S 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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

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 i ncluding 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 maximu m 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 maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r 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 thi s 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

limita tions in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.4

Otherwise, the operator must follow the procedures as outlined in its operating documents. The ope rator 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 up dated 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 FA A’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 op eration 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 mu st 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 com ponents, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

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

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 be5

operated under this exemption, including evasive and emergency maneuvers and

maintainin g 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 (traini ng, 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 m ay only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distan ce 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 symbo l 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 ma de 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 sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibited fro m 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 man ufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted 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

num ber, registered in accordance with 14 CFR part 47, and have identification6

(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 enforcem ent 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

tha t 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 nonparticipa ting 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 control led

- access property with permission from the prop erty 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 vert ical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

containe d 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.7

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 t o the local Flight Standards District Office (FSDO) with jurisdiction over the a rea 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 th e 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 permissio n 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 91.8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresApril 13 , 2015

Skyeography LLC

2520 65 th 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 o perations for the purpose of

aerial pho tography 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 . B y operating the

UAS within the para meters 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) 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 autom atically to prevent any damag e. The software used to run the UAS has country settings (that

can’t 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 moving 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 y aw ( 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 Skyeography LLC

, on average the UAS

will be operated at the m aximum altitu de of 130ft 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 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 130 ft for no

longer than a min ute, and speeds no faster than 11 mph 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 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 C) below is the Wi

- Fi Regulation the UAS uses on each frequency which complies

with all US regulation:( Ap p endix 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 m ovement and altitude height. The other stick controls

the lateral movement, forw ard and back movement. When both control sticks are idle the UAS hovers

stably

. The PIC will h ave 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 h is ability to pilot any UAS with the given manual due to his long andextensive 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 stab le which makes

this UAS easier to pilot than a 3

- channel h elicopter

. The PIC has a vast understanding of the FAA

regu lations currently in place, and frequently check s for updates and change s to regulation s

. The PIC is

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

All PIC s 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 receive s 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 control led or private property. The UAS

would maintain a safe stabilized position in the air 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 requi red to n otify all a ffected 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 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 c omes 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 immediate ly 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, Not fly under the influence of alcohol or drugs, will not fly over sensitive

property or infrastr ucture 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 en vironment 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 flig ht 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 t hat 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 req uire 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, sn owy, 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 exemptio n)

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.