December, 4 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12­140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Seth Wood dba. SWOOD MEDIA

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF

FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF PARROT BEPOP

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112­95)

Seth Wood

President

Seth Wood, dba. SWOOD MEDIA

11804 Park Forest Ct

Glen Allen, VA 23059

804.491.9663 / 561.723.0087

seth@swoodmedia.com
TABLE OF CONTENTS

Page

GLOSSARY OF

ABBREVIATIONS...................................................................................3

SUMMARY.........................................................................................................................

..4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND..................................................................................................................

..4

BASIS FOR

PETITION.........................................................................................................5

NAME AND ADDRESS OF

PETITIONER.........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SWOOD MEDIA SEEKS

EXEMPTION............................................................................................................7

THE EXTENT OF RELIEF SWOOD MEDIA SEEKS AND THE REASON SWOOD

MEDIA SEEKS THE RELIEF..............................................................10

THE REASONS WHY GRANTING SWOOD MEDIA’S REQUEST WOULD BE IN THE

PUBLIC INTEREST ............................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO SWOOD MEDIA WOULD

NOT ADVERSELY AFFECT SAFETY..............................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT SWOOD MEDIA’S REQUEST..................................................25

CONCLUSION....................................................................................................................

.25

APPENDICES......................................................................................... 26

GLOSSARY OF ABBREVIATIONS
AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

SUMMARY
Seth Wood, dba. SWOOD MEDIA hereafter referred to as SWOOD MEDIA seeks

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121,

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

operate an Unmanned Aircraft System (Parrot Bepop) ​pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

SWOOD MEDIA to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial video and photography of construction sites, residential

and commercial real estate, civil landscapes and events over certain areas of the United

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

SWOOD MEDIA has for over 18 years provided their clients (which include private

sector businesses and non­profits, along with local state and federal agencies) with

expertise and knowledge in video and multimedia marketing, advertising, public

relations and training using advanced technologies and solutions. SWOOD MEDIA has

worked on thousands of productions over the past 18 years in all types of locations with

a perfect client and employee safety record. In the past we have supplied our clients

aerial video and photography using commercial aircraft. The objective of SWOOD

MEDIA and our Unmanned Aircraft System (Parrot Bepop) ​aerial operations is to provide

a more affordable, high­quality production system for a variety of governmental,

commercial, public, and residential uses, specifically targeting

• Construction sites before and after

• Community Living

• Real­estate marketing

• Agricultural

• Civic landmarks

• Special event coverage

I have safely flown small RC electric quadcopters recreationally for approximately 2 years

without incident. I also have several pilot certificate hours logged and will have a sport license

by 2/1/16.

BACKGROUND

Unmanned Aircraft Systems: Parrot Bepop, UAS

SWOOD MEDIA seeks an exemption to operate PARROT BEPOP system for

compensation or hire within the NAS. The PARROT BEPOP is vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing
electronic tablet or smart phone systems. The PARROT BEPOP has a maximum gross

weight of approximately 400g while having a diagonal dimension of 13”, a maximum

speed of approximately 31mph and a maximum flying height of 600'. The PARROT

BEPOP is equipped with four main rotors; driven by Lithium Polymer battery powered

electric motors.

The PARROT BEPOP that will be operated by SWOOD MEDIA will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and

Registration Marking.

BASIS FOR PETITION

Petitioner, SWOOD MEDIA, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate the Parrot Bepop, UAS in the

National Airspace System (NAS), and for an exemption from the requirements of 14

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

the unmanned aircraft and its operation, SWOOD MEDIA operation of PARROT

BEPOP UAS meets the conditions of FMRA Section 333 and therefore, will not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, SWOOD MEDIA requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

SWOOD MEDIA submits that the requested relief is proper since an equivalent level of

safety will be ensured. SWOOD MEDIA will use experienced personnel or technicians

to perform maintenance, alterations, or preventive maintenance on the UAS using the

methods, techniques, and practices prescribed in the operating documents (i.e.,

Monthly Maintenance Log, and PARROT BEPOP Instruction Manual). Furthermore,

SWOOD MEDIA will document and maintain all maintenance records for the PARROT

BEPOP UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by SWOOD MEDIA to the extent
necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher level

certificate, and who has demonstrated, by meeting minimum flight­ hour and currency

requirements, that the PIC is able to safely operate the Parrot Bepop UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

SWOOD MEDIA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the PARROT BEPOP UAS do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, SWOOD MEDIA submits that

they will ensure that the PARROT BEPOP UAS is in an airworthy condition, prior to

every flight, by determining that the UAS are in compliance with the operating

documents (i.e., Monthly Maintenance Log, and PARROT BEPOP Instruction Manual),

and that the aircraft are in a condition for safe flight.

SWOOD MEDIA also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the PARROT BEPOP UAS will not have a typical

barometric altimeter onboard. However, altitude information of the PARROT BEPOP

UAS will be provided to the PIC via Global Positioning System (GPS) equipment and

radio communications telemetry data link, which downlinks from the UA to the GCS for

active monitoring of the flight path. This altitude information, combined with SWOOD

MEDIA’s operation of the PARROT BEPOP UAS within visual line of sight, at or below

400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, SWOOD MEDIA seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. SWOOD MEDIA submits

that safety will not be affected by operation of the PARROT BEPOP UAS during

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR),

with enough battery power to fly for a total duration of approximately 15 minutes.

Battery power indicators are also able to show exactly how much battery power is left,

as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, SWOOD MEDIA provides the following

information in support of its petition for exemption:

A.​Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:
Seth Wood

President

Seth Wood, dba. SWOOD MEDIA

11804 Park Forest Ct

Glen Allen, VA

804­491­9663

dsc@altekmedia.com

B. The Specific Sections Of 14 C.F.R. From Which ​SWOOD MEDIA​Seeks Exemption.

1. ​SWOOD MEDIA Seeks Exemption From The Requirements Of Section 61.113(a) And

(b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC)

of an aircraft that is carrying passengers or property for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. ​SWOOD MEDIA​Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3.​SWOOD MEDIA​Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of

that aircraft, as the case may be, by reference to an altimeter that is set, when

operating­­

(1) Below 18,000 feet MSL, to­­

(i) The current reported altimeter setting of a station along the route and within 100

nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section,

the current reported altimeter setting of an appropriate available station; or
(iii) In the case of an aircraft not equipped with a radio, the elevation

of the departure airport or an appropriate altimeter setting available

before departure.

4.​SWOOD MEDIA​Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at

least 20 minutes.

5.​SWOOD MEDIA​Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this section, have

discrepancies repaired as prescribed in part 43 of this chapter[.]

6. ​SWOOD MEDIA​Seeks Exemption From The Requirements Of ​Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless­­

(1) It has been approved for return to service by a person authorized under § 43.7 of

this chapter[.]

7. ​SWOOD MEDIA Seeks Exemption From The Requirements Of Sections 91.409(a)(1)

And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had ­­

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part

21 of this chapter.

8. ​SWOOD MEDIA Seeks Exemption From The Requirements Of Sections 91.417(a) And

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods specified in

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of

the 100­hour, annual, progressive, and other required or approved inspections, as

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor,

and appliance of an aircraft. The records must include­­

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller,

and each rotor.

(ii) The current status of life­limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time

since the last inspection required by the inspection program under

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for

each major alteration to the airframe and currently installed engines,

rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of this

chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.

C. The Extent Of Relief ​SWOOD MEDIA Seeks And The Reason ​SWOOD MEDIA Seeks

The Relief.

1. Extent Of Relief ​SWOOD MEDIA Seeks And The Reason ​SWOOD MEDIA Seeks Relief

From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot

in command, is requested to the extent necessary to allow a PIC holding a private pilot or

higher level certificate, as well as a current and valid airman medical certificate, and

who has met certain flight­hour and currency requirements, to conduct the proposed

UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business or employment if: (1) The flight is only incidental to that business or

employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.

As set forth more fully below, SWOOD MEDIA submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the PARROT BEPOP

UAS unless that PIC has met certain flight­hour and currency requirements,

demonstrating that the PIC is able to safely operate either the PARROT BEPOP UAS in

a manner consistent with the operations specifications as described in this exemption,

including evasive and emergency maneuvers, as well as maintaining appropriate

distances from people, vessels, vehicles and structures.

Further, SWOOD MEDIA submits that all flights of the PARROT BEPOP UAS,

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to

SWOOD MEDIA’s business; and (2) will not carry passengers or property for

compensation or hire.

2. Extent Of Relief ​SWOOD MEDIA Seeks And The Reason ​SWOOD MEDIA Seeks Relief

From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow SWOOD MEDIA to determine that the PARROT BEPOP UAS are in

airworthy condition prior to every flight by ensuring that the UAS is in compliance with

the operating documents (i.e., SWOOD MEDIA Aerial Operations Manual, Monthly

Maintenance Log, and PARROT BEPOP Instruction Manual).

SWOOD MEDIA seeks the requested relief because the PARROT BEPOP UAS do not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Therefore, SWOOD MEDIA will ensure that the PARROT BEPOP UAS are in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and Parrot Bepop) prior to every flight, and further, determine that the

aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief SWOOD MEDIA Seeks And The Reason SWOOD MEDIA Seeks Relief

From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the PARROT BEPOP UAS, which utilize a barometric pressure sensor,

GPS equipment, and a radio communications telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). Since the FAA

requires that any altitude information concerning UAS operations be reported to air

traffic control (ATC) in feet above ground level (AGL), SWOOD MEDIA seeks the

requested relief because the PARROT BEPOP UA’s altimeter may be set on the ground

to zero feet AGL, rather than the local barometric pressure or field altitude, before each

flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to the extent necessary to comply with the applicable conditions and limitations

stated below. As more fully set forth herein, an equivalent level of safety will be

maintained since the PARROT BEPOP UAS are equipped with a barometric pressure

sensor and GPS equipment, which automatically ensures that a ground level pressure

setting will be established prior to each flight, and provides the PIC with altitude

information of the UA on the heads­up display of the GCS.

4. Extent Of Relief SWOOD MEDIA Seeks And The Reason SWOOD MEDIA Seeks Relief

From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered PARROT

BEPOP UAS during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 23 minutes. SWOOD MEDIA seeks the

requested relief because without an exemption from Section 91.151(b), the flight time

duration of the battery powered PARROT BEPOP UAS will severely constrain the

practicality of any aerial video or still photo flight operations that SWOOD MEDIA

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the PARROT BEPOP

UAS, the PARROT BEPOP operating documents, and SWOOD MEDIA’s proposed

operating limitations, ensure that SWOOD MEDIA will safely operate the battery
powered PARROT BEPOP UAS during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a

total duration of 23 minutes.

5. Extent Of Relief SWOOD MEDIA Seeks And The Reason SWOOD MEDIA Seeks Relief

From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, SWOOD MEDIA requests relief from

these Sections because the PARROT BEPOP UAS do not require airworthiness

certificates. As set forth more fully below, the PARROT BEPOP UAS meet the

conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, SWOOD MEDIA will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and

practices prescribed in the UAS operating documents (i.e., SWOOD MEDIA Aerial

Operations Manual, Monthly Maintenance Log, and PARROT BEPOP Instruction

Manual). Furthermore, SWOOD MEDIA will document and maintain all maintenance

records for the PARROT BEPOP UAS.

D. The Reasons Why Granting SWOOD MEDIA Request Would Be In The Public

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing SWOOD MEDIA

to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, events and civic landscape over certain areas of the

United States.

Additionally, use of the PARROT BEPOP UAS will decrease congestion of the NAS,

reduce pollution, and provide significant benefits to the economy. Notably, the benefits

of SWOOD MEDIA’s proposed operation of the PARROT BEPOP UAS will be realized

without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The PARROT BEPOP UAS are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial

imagery. By reducing the amount of manned aircraft needed to perform aerial

acquisitions, an exemption allowing the use of a PARROT BEPOP UAS would reduce

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as
increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced.

The PARROT BEPOP UAS do not require an airport to takeoff or land. Likewise, a

reduction of manned aircraft conducting aerial video and photography missions would

result in fewer aircraft that must be handled by air traffic control during the ground,

takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The ​PARROT BEPOP

UAS.

Conducting aerial acquisitions with the PARROT BEPOP UAS, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial video and still photography flight operations.

By using battery power and electric motors, the PARROT BEPOP UAS produce no air

pollution, and is the most viable environmentally conscious alternative to the cabin

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial

video and photography, while burning approximately 20­30 gallons per hour of leaded

aviation fuel. The PARROT BEPOP UAS, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery

powered electric motors, rather than an internal combustion engine.

By using the PARROT BEPOP UAS to perform aerial acquisitions, the substantial risk

to life and property in the air and on the ground, which is usually associated with

traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the

PARROT BEPOP UAS (weighing approximately 2.8 pounds at their maximum gross

weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less

physical potential for collateral damage to life and property on the ground, and in the air,

compared to the manned aircraft that typically conduct similar operations (weighing

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The PARROT

BEPOP UAS Will Benefit The Economy.

In addition to being safe and efficient, the PARROT BEPOP UAS are also an

economical alternative to using manned aircraft to conduct similar aerial operations. As

such, operation of the PARROT BEPOP UAS will allow United States based

companies, like SWOOD MEDIA, to remain competitive and contribute to growth of the
U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S.

owned and operated companies must adopt new and alternative technology in order to

remain competitive. Operating the battery powered PARROT BEPOP UAS is one such

technology that not only allows companies greater operational flexibility compared to

manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.

By operating the PARROT BEPOP UAS, companies such as SWOOD MEDIA, can

remain competitive and profitable, and therefore, provide greater job stability to

employees and contractors, which will ultimately contribute to growth of the U.S.

economy. Improved financial performance of U.S. companies, through commercial use

of the PARROT BEPOP UAS, provides a stable workforce that increases consumer

spending; improves local, state, and federal tax revenues; and allows companies to

invest in research and development in order to remain competitive both in the United

States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, SWOOD MEDIA’s proposed operation of the PARROT BEPOP UAS will not

implicate any privacy issues. Specifically, the PARROT BEPOP UAS will be operated

only in compliance with operating documents (i.e., SWOOD MEDIA Aerial Operations

Manual, Monthly Maintenance Log, and PARROT BEPOP Instruction Manual) which

requires property owner involvement as well as local law enforcement notification, and

in accordance with the Federal Aviation Regulations, including the minimum altitude

requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided

By The Rule From Which SWOOD MEDIA Seeks Exemption.

1. Reasons Why The ​PARROT BEPOP UAS Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

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

the unmanned aircraft and its operation, SWOOD MEDIA’s operation of the PARROT

BEPOP UAS meet the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users

of the NAS or the public, or otherwise pose a threat to national security. Specifically,

FMRA Section 333 states the following, in part:

(a) In General.­­Notwithstanding any other requirement of this subtitle, and not later than 180

days after the date of enactment of this Act, the Secretary of Transportation shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system before

completion of the plan and rulemaking required by section 332 of this Act or the guidance

required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.­­In making the determination under subsection

(a), the Secretary shall determine, at a minimum­­

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed,

operational capability, proximity to airports and populated areas, and operation within visual

line of sight do not create a hazard to users of the national airspace system or the public or pose

a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification

under section 44704 of title 49, United States Code, is required for the operation of unmanned

aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.­­If the Secretary determines under this section that certain

unmanned aircraft systems may operate safely in the national airspace system, the Secretary

shall establish requirements for the safe operation of such aircraft systems in the national

airspace system.

In seeking this exemption, SWOOD MEDIA submits that the PARROT BEPOP UAS can

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the PARROT BEPOP UAS; (b) the pilot certification requirement; and

(c) the specific operating limitations.

a. The Specifications Of The ​PARROT BEPOP UAS ​Demonstrate Its Safe Characteristics.

The PARROT BEPOP UAS does not create a hazard to users of the NAS or the public,

or otherwise pose a threat to national security considering its size, weight, speed, and

operational capability.

i. Technical Specifications Of The ​PARROT BEPOP ​UAS.

The technical specifications of the PARROT BEPOP UAS are set forth by the PARROT

BEPOP User Manual, attached hereto as Appendix A.

ii. The ​PARROT BEPOP UAS ​Global Positioning Modes Enable The UAS To Remain

Within A Defined Operational Area.
The PARROT BEPOP UAS may be operated in both manual and global positioning

flight modes. A complete description of the flight and navigational modes of the

PARROT BEPOP UAS is provided at pages 11 of the PARROT BEPOP User Manual

attached hereto as Appendix A.

iii. The ​PARROT BEPOP UAS ​Are Designed For Automatic Return To Home Point Or

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the PARROT BEPOP UAS will remain stationary, in flight,

for 3 seconds or more. If, after 3 seconds, the PARROT BEPOP UAS does not

reacquire control link data from the GCS, the UAS will assume that the Control Link is

lost and the will return to the home position (i.e., failsafe mode) via GPS, and will

descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the PARROT BEPOP UAS are set

forth at pages 12 through 14 of the PARROT BEPOP User Manual, attached hereto as

Appendix A.

iv. The ​PARROT BEPOP ​GCS And Its Operation.

A complete description of the operation and specifications of the PARROT BEPOP GCS

and flight control software is provided at pages 23 through 29 of the PARROT BEPOP

User Manual. PARROT BEPOP User Manual is attached hereto as Appendix A.

b. Flight Operations Of ​PARROT BEPOP UAS ​Is Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

SWOOD MEDIA video production staff will be the only persons to act as a pilot in

command (PIC) of the PARROT BEPOP UAS. Additionally, a safety observer will assist

him at all times during flight time.

c. Flights Of ​PARROT BEPOP UAS ​Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, SWOOD MEDIA proposes to commercially operate PARROT

BEPOP UAS for the special purpose of conducting aerial video and photography over

certain areas of United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the

following aircraft described in the operating documents, rotorcraft UAS

weighing less than 55 pounds maximum gross weight: PARROT BEPOP
Unmanned Aircraft Systems. Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting

operations for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

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

ground level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All

altitudes reported to ATC must be in feet AGL.

5. The UAS 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 FAA­issued

airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to

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

capability. The SO 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 SO can

perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with

seeing and avoiding other air traffic and other ground based

obstacles/obstructions and is not permitted to operate the camera or other

instruments.

9. The operating documents and the grant of exemption must be accessible

during UAS operations and made available to the Administrator upon request.

If a discrepancy exists between the conditions and limitations contained in the

grant of exemption and the procedures outlined in the operating documents,

the conditions and limitations contained in the grant of exemption take

precedence and must be followed. 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 upon request. The operator must also present updated and

revised documents if it petitions for extension or amendment to the grant of

exemption. If the operator determines that any update or revision would affect
the basis upon which the FAA granted the exemption, then the operator must

petition for amendment to its grant of exemption. The FAA’s UAS Integration

Office (AFS­80) may be contacted if questions arise regarding updates or

revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition

for safe flight. 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. The Ground Control

Station must be included in the preflight inspection. All maintenance and alterations

must be properly documented in the aircraft records.

11. 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. The PIC who conducts the functional test flight must

make an entry in the aircraft records.

12. The pre­flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and

the signature of the authorized person returning the UAS to service.

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

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate the UAS in

a manner consistent with how the UAS will be operated under the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from

persons, vessels, vehicles and structures. PIC qualification flight hours must be logged

in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the

operator’s PICs are permitted under the terms of the exemption. However, training

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

proficiency, and experience­building 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 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If flight

at night is required, a special request will be made at the FAA office closest to proposed

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA­published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of agreement

with the airport management must be made available to the Administrator upon request.

21. 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.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

in accordance with the operating documents.

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

weather conditions) there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the grant of

exemption. This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be

as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to

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

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

upon request.
29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

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

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

persons (persons other than the PIC, SO, operator trainees or essential 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 and/or;

b. The aircraft is operated near vessels, vehicles or structures where

the owner/controller of such vessels, vehicles or structures has granted

permission 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, and;

c. Operations nearer to the PIC, SO, operator trainees or essential

persons do not present an undue hazard to those persons per §

91.119(a).

32. All operations shall be conducted over private or controlled­access property with

permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

33. 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 (AFS­80) 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.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

SWOOD MEDIA submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the

PARROT BEPOP UAS unless that PIC has demonstrated, by meeting minimum

flight­hour and currency requirements, that the PIC is able to safely operate the

PARROT BEPOP UAS in a manner consistent with the exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.
Considering SWOOD MEDIA’s proposed area of operations, and the operating

limitations set forth­above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and

the airmanship skills necessary to safely operate the PARROT BEPOP UAS, SWOOD

MEDIA submits that the additional manned airmanship experience of a commercially

certificated pilot would not correlate to the airmanship skills necessary for SWOOD

MEDIA’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS,

in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

SWOOD MEDIA will not allow any PIC to operate the PARROT BEPOP UAS unless

that PIC has demonstrated, by meeting minimum flight­hour requirements or the

PARROT BEPOP UAS training and currency requirements, that the PIC is able to safely

operate the PARROT BEPOP UAS in a manner consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with

14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of

5 hours of those hours as a UAS pilot operating the same make and model of UAS to

be used for operations under the exemption). In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience

that was obtained in compliance with applicable regulations will ensure an equivalent

level of safety during SWOOD MEDIA’s proposed operations. The Administrator has

held that prior documented flight experience that was obtained in compliance with

applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with

a multi­rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also

have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same
make and model of UAS to be used for operations under the exemption. For

clarification, the FAA considers these minimum hour requirements to be inclusive rather

than additive; i.e. 5 hours make and model time may be included in the 10 hours of

multi­rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft

time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and

landings in the preceding 90 days (for currency purposes). The FAA finds that at a

minimum, the flight­hour requirements in Exemption No. 11062 are appropriate to

practice and build proficiency in the skills necessary to safely conduct the petitioner’s

proposed operations. The FAA also finds that prior documented flight experience that

was obtained in compliance with applicable regulations would satisfy this requirement.

Training, proficiency, and experience­building flights can also be conducted under the

grant of exemption to accomplish the required flight time. During training, proficiency,

and experience­building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, SWOOD MEDIA will ensure safe operations by not allowing any PIC to

operate the PARROT BEPOP UAS unless that PIC has demonstrated, by meeting

minimum flight­hour and currency requirements, that the PIC is able to safely operate

the PARROT BEPOP UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because

prior to every flight, SWOOD MEDIA will ensure that the PARROT BEPOP UAS is in an

airworthy condition based upon the UAS’s compliance with its operating documents and

as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS,

in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because

the altitude information of the PARROT BEPOP UAS will be provided to the PIC via

GPS equipment and a radio communications telemetry data link, which downlinks from
the UA to the GCS for active monitoring of the flight path and altitude. This altitude

information, combined with SWOOD MEDIA’s operation of the PARROT BEPOP UAS

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121. The altitude information will be generated by GPS

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation

point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the PARROT

BEPOP UAS; (2) the limitations on the proposed flight operations; and (3) the location

of the proposed flight operations. Accordingly, SWOOD MEDIA will ensure that it will

safely operate the battery powered PARROT BEPOP UAS during daylight hours in VFR

conditions, with enough battery power to fly for a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the PARROT BEPOP

UAS; the limitations on the proposed flight operations; and the location of the proposed

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as the PARROT BEPOP UAS provide

audible and visual warnings to the PIC at the GCS when the UAS experiences low

battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately 10% remaining battery power. At the critically low

battery level, the PARROT BEPOP UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted

relief from Section 91.151 specific to UAS, in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042,

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections
91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely

Affect Safety.

In seeking this exemption, SWOOD MEDIA submits that the equivalent level of safety

with regard to the regulatory maintenance and alteration requirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because SWOOD MEDIA will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and

practices prescribed in the operating documents (i.e., SWOOD MEDIA Aerial

Operations Manual, Monthly Maintenance Log, and PARROT BEPOP Instruction

Manual). Furthermore, SWOOD MEDIA will document and maintain all maintenance

records for the PARROT BEPOP UAS.

Since the PARROT BEPOP UAS will be inspected as prescribed by the operating

documents, SWOOD MEDIA will maintain the equivalent level of safety established by

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the PARROT BEPOP

User Manuals are attached hereto as Appendix A and B; a copy of the PARROT

BEPOP UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because SWOOD

MEDIA will use trained technicians to perform maintenance, alterations or preventive

maintenance on the UAS using the methods, techniques, and practices prescribed by

the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of

the PARROT BEPOP UAS will be performed by trained technicians. Maintenance will

be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not

adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of SWOOD MEDIA’s proposed operating limitations, the operating

documents, and the technical aspects of the PARROT BEPOP UAS, SWOOD MEDIA

submits that safety will not be adversely affected by granting exemption from 14 C.F.R.

Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The

FAA has previously granted relief specific to UAS in circumstances similar, in all

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.
In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, SWOOD MEDIA requests that

the FAA prescribe special conditions for the intended operation of the PARROT BEPOP

UAS, which contain such safety standards that the Administrator finds necessary to

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart

H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will

permit safe operation of the UAS for the limited purpose of conducting aerial video and

photography over certain areas of the United States for compensation or hire. FMRA

Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security;

and further, provides the authority for such UAS to operate without airworthiness

certification in accordance with any requirements that must be established for the safe

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the PARROT BEPOP UAS, since the airworthiness regulations

of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to

the novel or unusual design features of the aircraft. Section 21.16, entitled Special

Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller,

he prescribes special conditions and amendments thereto for the product. The special

conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Leading Edge’s intended operation of the PARROT

BEPOP UAS, which contain such safety standards that the Administrator finds

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part

21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which SWOOD MEDIA Seeks Exemption:

SWOOD MEDIA seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption SWOOD MEDIA Seeks:
This exemption will permit SWOOD MEDIA to commercially operate an Unmanned Aircraft

System (UAS) for the purpose of conducting aerial video and photography over certain areas of

the United States.

• Any Additional Information, Views, Or Arguments Available To Support

SWOOD MEDIA​’s​​Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if

certain UAS may operate safely in the NAS. As such, SWOOD MEDIA’s request for

exemption may be granted pursuant to the authority of FMRA Section 333 and 14

C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without

airworthiness certification.

As discussed in detail above, SWOOD MEDIA will operate the PARROT BEPOP UAS

safely in the NAS, without creating a hazard to users of the NAS, or the public, or

otherwise pose a threat to national security.

CONCLUSION

As set forth herein, SWOOD MEDIA seeks an exemption pursuant to 14 C.F.R. § 11.61

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will

permit safe operation of the PARROT BEPOP UAS commercially, without an

airworthiness certificate, for the limited purpose of conducting aerial video and

photography over certain areas of the United States. By granting this Petition, the FAA

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and

Reform Act of 2012, while also advancing the interests of the public, by allowing

SWOOD MEDIA to safely, efficiently, and economically operate the PARROT BEPOP

UAS commercially within the NAS.

WHEREFORE​, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, SWOOD MEDIA respectfully

requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading

Edge to operate the PARROT BEPOP UAS commercially for the purpose of conducting

aerial video and photography over certain areas of the United States.

Dated: December 4, 2015

Respectfully submitted,

Seth Wood
President

Seth Wood, dba. SWOOD MEDIA

11804 Park Forest Ct

Glen Allen, VA. 23059

804­491­9663 / 561­723­0087

seth@swoodmedia.com

Appendices:

A – Link to PARROT BEPOP Manual: Click on link below

http://www.parrot.com/usa/support/parrot­bebop­drone/