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.