FLESHER SCHAFF & SCHROEDER, INC. 

2202 P!a:zn Drive. Rocklin. CA 95765 

U.S. Depmiment of Transportation, 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

November 9, 2015 

Re: FLESHER SCHAFF & SCHROEDER, INC. Exemption Petition 

Pursuant to Section 333 of the FAA Reform Act and Pmi II of the Federal Aviation; 

Regulations from: 14 CFR 21 subpmi 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; and (b); 14 CFR 91.405 (a); 14 CFR 

91.407 (a) (1) 14 CFR 91.409 (a)(!) and (2); 14 CFR 91.417(a) and (b). 

To Whom It May Concern: 

Flesher Schaff & Schroeder, Inc. hereby requests an exemption of current rules preventing the 

use of an unmanned aircraft system (UAS) for such purposes pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012 (FAA-2014-0958-0001), to permit commercial 

operation of a small UAS for aerial imagery and inspection. 

As a civil litigation law firm, Flesher Schaff & Schroeder, Inc. provides its clients with 

immediate on-call and after-the-fact services to direct and/or assist in the investigation of 

incidents which may give rise to civil liability. In many of these circumstances, the area or scene 

being investigated is large or spread out, and often rural. Essentially all of these areas are on 

private property owned by the client who retains us to conduct or assist in the investigation. 

Aerial viewing and photography of these scenes is incredibly helpful to analyze the layout and 

location of the appmienances involved, providing views which are simply not othenvise 

obtainable. Further, a 'birds-eye' view ensures we are identifying and correlating all information 

and evidence during our investigations. 

We will use a Panot Bebop Drone, a very small and lightweight UAS. It is approximately 

fomieen inches (14'') in diameter. The aircraft is operated by the Parrot Skycontroller, which 

enhances controllability and safety with its ultra-high precision joysticks, GPS geolocation and 

auto-return functions, altitude indicator, max-altitude preset, speed indicator and horizon line 

indicator. 

Using this model aircraft for the inspection of incident scenes, we will always fly it in visual line 

of sight and below four hundred feet ( 400') 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 helipmis as follows: 

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5 nautical miles (NM) from an airport having an operational control tower; 

3 NM from an airpmi with a published instmment tlight procedure, but not an 

operational tower; 

2 NM from an airport without a published instrument flight procedure or an 

operational tower; or 

2 NM fi-om a heliport with a published instrument flight procedure. 

Spectators will not be allowed and a client or co-investigator who wants to observe the 

inspection while the drone is in flight will be placed 20 feet behind the operator for safe 

observation. A second person on the tlight crew will maintain such order with the public for 

their safety. The launch operator 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. The three (3) members of Flesher Schaff & Schroeder, Inc. who will pilot the 

drone are Jacob D. Flesher (SBN 210565), Jason W. Schaff(SBN 244285) and Jeremy J. 

Schroeder (SBN 223118). 

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 ti·om potential contact of the propellers. Should a propeller come into contact with an 

object, the motor automatically stops. We have $1,000,000 dollars of Commercial General 

Liability insurance coverage. 

The model aircraft is capable of only a short flight on its battery time of approximately eleven 

(II) minutes. This model aircraft is not designed or equipped to carry a payload of any kind; it's 

sole purpose is to deliver high quality images. 

Specitlcations for the Parrot BeBop Drone are included below. 

Thank you for your consideration and we look forward to your timely response. 

Jeremy J. S hroeder 

-r-;,.t:.;::~;K SCHAFF & SCHROEDER, INC. 

2202 Plaza Drive 

Rocklin, CA 95765 

Phone: (916)500-9233 

Email: jjs@fsslawtlrm.com 

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Parrot Bebop Drone Specifications: 

Connectivity Wi-Fi 802.11 a/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 

Structure: High-resistance 

Propulsion: 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 ±1ight, 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 

Speed: 13 m/s 

Camera: CMOS 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: 1920xl080p (30fps) 

Photo definition: 4096x3072 px 

Video encoding: H264 

Photo file format: JPEG, RAW, DNG 

Internal memory: Flash 8 GB 

Battery: Lithium Polymer 1200 mAh 

Flight time: 11 minutes 

Processor CPU: 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 

Developing: Open-source SDK 

Sensors: 3-axes- 3-axes tnagnetmneter; 3-axes gyroscope; 3-axes accelermneter 

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-location GNSS 

GNSS (GPS + GLONASS) 

Dimensions: 28x32x3.6cm; 28x32x3.6cm without the hull; 33x38x3.6cm with the hull 

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

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