1



### United States of America Department of Transportation Federal Aviation Administration Washington DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: BRANDON SIDEBOTTOM FOR AN EXEMPTION SEEKING RELIEF 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 BEBOP DRONE UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

submitted on August 19th, 2015

Brandon D Sidebottom

1509 N McRae Drive Goddard, KS 67052 620-960-03202



### TABLE OF CONTENTS

pages GLOSSARY OF ABBREVIATIONS..................................................3

SUMMARY.................................................................................4

INTEREST OF PETITIONER.........................................................4

BACKGROUND..........................................................................5

BASIS FOR PETITION.................................................................5

NAME AND ADDRESS OF PETITIONER.........................................7

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BRANDON D SIDEBOTTOM SEEKS EXEMPTION..............................................7

EXTENT OF RELIEF BRANDON D SIDEBOTTOM’S AND THE REASON BRANDON D SIDEBOTTOM SEEKS THE RELIEF..........................11

REASONS WHY GRANTING BRANDON D SIDEBOTTOM’S REQUEST WOULD BE IN THE PUBLIC INTEREST.......................................14

REASON WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.....................................................................15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.28
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT BRANDON D SIDEBOTTOM’S REQUEST................29

CONCLUSION.........................................................................30

APPENDICES.........................................................................313



### GLOSSARY OF ABBREVIATIONS

AGL - Above Ground Level AOI - Area of Interest ATC - Air Traffic Control ATO - Air Traffic Organization AV - Aerial View CFR - Code of Federal Regulation 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) section 333 SO - Safety Observer SOP - Standard Operating Procedure UA - Unmanned Aircraft UAS - Unmanned Aircraft System VFR - Visual Flight Rule VLOS - Visual Line of Site VMC - Visual Meteorological Condition VTOL - Vertical Takeoff and Landing4



### SUMMARY

Brandon D Sidebottom 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 and Unmanned Aircraft System pursuant of
Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This Exemption
will permit Brandon D Sidebottom to operate an UAS for the commercial purpose of
conducting aerial video and photography for real estate, golf courses, construction
company’s, special events, film sets, landscaping and weddings over certain areas of

the United States.



### INTERESTS OF THE PETITIONER

Brandon D Sidebottom provides clients with knowledge in advanced technologies and solutions. He also provides his clients high quality content for use in their commercial, personal and non-profit multimedia projects. Brandon D Sidebottom has over 10 years of professional experience work for Country Clubs helping develop restaurant appeal and operation success including marketing threw video and photography of events in the facilities and on the course. Brandon D Sidebottom has over 2 years of recreational/hobby experience in RC Aircraft of all types, makes and models with about 1 year including Aerial Video/Photography. My objective is to provide high quality imaging in a safe way for a variety of commercial, public and residential uses, specifically targeting:



### • Real Estate



### • Golf Courses



### • Construction



### • Weddings



### • In addition to increasing public knowledge of UAS and promote safe UAS operations5



### Background UAS: Parrot Bebop Drone Brandon D Sidebottom is seeking exemption to operate PARROT systems for compensation or hire within the NAS. The Parrot Bebop Drone is a vertical takeoff and landing (VTOL) Unmanned Aircraft with Ground Control Station (GCS) utilizing electronic tablet or smart phone system. The Parrot Bebop Drone has a max gross weight of approximately pound, while having a length of12.6 inches, a width if 11 inches and a hight of 1.4 inches and a maximum speed of approximately 22 knots. The Parrot Bebop Drone is Equipped with four main rotors;driven by lithium polymer battery powered electric motors. The Parrot Bebop Drone UAS that Brandon D Sidebottom will be operating 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, Brandon D Sidebottom,pursuant to the provision of the Federal Aviation Regulation (14 C.F.R 11.61) and FMRA, Section 333, Special Rules for Certain Unmanned Aircraft Systems, herby petitions the Administration to commercially operate the Parrot Bebop Drone UAS in the NAS, and for exemption from the requirements of 14 C.F.R 61.113(a) & (b), 91.7(a), 91,151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b). In consideration of speed, weight, size and limited operating area associated with unmanned aircraft and its operation, Brandon D Sidebottom’s operation of the Parrot Bebop Drone UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R Par 12, subpart H. Accordingly, Brandon D Sidebottom requests relief from section 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. Brandon D Sidebottom submits that the requested relief is proper since an equivalent level of safety will be ensured. Brandon D Sidebottom will use experienced6

personnel or technicians to preform maintenance, alterations, or preventative maintenance on the UAS using the methods, techniques and practices prescribed in the operating documents (i.e., Monthly Maintenance log, and Parrot Bebop Drone Instruction Manual). Furthermore Brandon D Sidebottom will document and maintain all maintenance records for The Parrot Bebop Drone UAS. Relief from certain requirements of section 61.113(a) & (b), entitled Private Pilot privileges and limitations: Pilot in Command, is required by Brandon D Sidebottom to the extant necessary to allow a PIC holding a private pilot or higher level certificate, as well as an airman medical certificate and who has demonstrated, by meeting minimum flight- hours and currency requirements, that the PIC is able to safely operate the Parrot Bebop Drone UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances of people, vessels, vehicles, and structures. Brandon D Sidebottom seeks relief from section 91.7(a) Entitled Civil Aircraft Airworthiness, because the Parrot Bebop Drone UAS does not require an airworthiness certificate in accordance with 14 C.F.R part 21, Subpar H. As, such, Brandon D Sidebottom submits that he will ensure the the Parrot Bebop Drone UAS is in an Airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and Parrot Bebop Drone Instruction Manual), and that the aircraft is in a condition for safe flight. Brandon D Sidebottom is also seeking an exemption from the requirement of section 91.121, entitled Altimeter settings, as the Parrot Bebop Drone UAS will not have a typical barometric altimeter onboard. however altitude information of the Parrot Bebop Drone UAS will be provided to the PIC via GPS Equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. the altitude information, combined with Brandon d Sidebottom’s operation of the Parrot Bebop Drone UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Brandon D Sidebottom seeks exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Brandon D Sidebottom submits that safety will not be affected by operation of the Parrot Bebop7

drone UAS during daylight hours in visual meteorological conditions (VMC) under VFR, with enough battery power to fly for a total duration of approximately 7.7 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for
at least 3.3 minutes. In accordance with 14 C.F.R 11.81, Brandon D Sidebottom provides the following information in support of its petition for exemption:



### • A. name and Address of Petitioner.

The name and address of petitioner and point of contact is: Brandon D Sidebottom
1509 N. McRae Drive Goddard, KS 67052 sidebottom_b@yahoo.com
620-960-0320



### • B. The Specific Section of 14 C.F.R. From Which Brandon D Sidebottom Seeks Exemption.

1. Brandon D Sidebottom Seeks Exemption from the Requirements of Section 61.113(a) & (b) Section 61.113, entitled Private Pilot Privileges and Limitation: Pilot in command, subsections (a) & (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.8

2. Brandon D Sidebottom seeks exemption for The Requirement 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. Brandon D Sidebottom 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 the aircraft, as the case may be, by reference to an altimeter that is set, when operation- (1) Below 18,000 feet MSL, to—

(i) The current reported altitude 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 altitude settings 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. Brandon D Sidebottom Seeks Exemption from 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 first9

point of intended landing and, assuming normal cruising speed, to fly after that for at
least 20 minutes.

5. Brandon D Sidebottom Seeks Exemption from Requirements 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 infected 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. Brandon D Sidebottom Seeks Exemption from 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 person authorized under 43.7 of this chapter[.]

7. Brandon d Sidebottom Seeks Exemption from Requirements of sections 91.409(a)(1) & 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, whithin 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; or10

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

8. Brandon D Sidebottom Seeks Exemption from Requirements of Section 91.417(a) & 91.417(b). Section 91.417, entitled Maintenance records, subsection (a) & (b), states 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 the section:

(1) Records of the maintenance, preventive maintenance, and alterations and records of the 100-hour, 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 data of compassion 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 life-limited 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.11

(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 prior 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 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 Brandon D Sidebottom seeks and the Reason Brandon D Sidebottom Seeks the Relief. 1. Extent of Brandon D Sidebottom Seeks and Reason Brandon D Sidebottom Seeks Relief From Section 61.113(a) & (b). Relief from section 61.113(a) & (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 current and valid airman medical certificate, and who has met certain flight - hour 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) & (b) states 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 that12

business or employment; and (2) the aircraft does not carry passengers or property for compensation or hire. As set forth ,ore fully below, Brandon D Sidebottom submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the Parrot Bebop Drone UAS unless that PIC has met certain flight-house and currency requirements, demonstrating that the PIC is able to safely operate the Parrot Bebop Drone 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, Brandon D Sidebottom submits that all flights of the Parrot Bebop Drone UAS, Conducted by the PIC pursuant to the grant of this petition: (1) will be incidental to Brandon D Sidebottom Business, and(2) will not carry passengers or property for compensation or hire. 2. Extent of Relief Brandon D Sidebottom Seeks and the Reasons Brandon D Sidebottom Seeks Relief from Section91.7(a) Relief from Section 91.7(a), Entitled Civil aircraft airworthiness, is requested to the extent required to allow Brandon D Sidebottom to determine that the Parrot Bebop Drone UAS is in airworthy condition prior to every flight by insuring that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance Log, and Parrot Bebop Drone Instruction Manual). Brandon D Sidebottom seeks the requested relief because the Parrot Bebop Drone UAS does not require an airworthiness certificate in accordance with 14 C.F.R Part 21, subpart H. Therefore, Brandon D Sidebottom will insure that the Parrot Bebop Drone UAS in in airworthy condition based upon its compliance with the operating documents (i.e. Monthly Maintenance Log, and Parrot Bebop drone Instruction Manual) Prior to every flight, and further, determine that the aircraft is in condition for safe flight,
as stated in the conditions and limitations below. 3. Extent of Relief Brandon D Sidebottom Seeks and the ReasonBrandon D Sidebottom Seeks Relief from Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the Parrot Bebop Drone UAS, which utilize a barometric pressure13

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from UA to PIC at the ground Control Station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to ATC in feet AGL, Brandon D Sidebottom seeks the requested relief because the Parrot Bebop Drone UAS altimeter may be set on the ground to zero feet AGL, rater than a local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 C.F.R 91.121 is sought to the extent necessary to comply with the applicable conductions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the Parrot Bebop Drone UAS is 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 heads-up display of the GCS. 4. Extent of Relief Brandon D Sidebottom Seeks and the Reason Brandon D Sidebottom 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 flight of a battery powered Parrot Bebop Drone UA during daylight hours in visual meteorological conditions (VMC), under VFR, for a total duration of 7.7 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 3.3 minutes. Brandon D Sidebottom seeks the requested relief because without exemption fromSection 91.151(b), the flight time duration of the battery powered Parrot Bebop Drone UAS will severely constrain the practicality of any aerial video or still photo flight operations that Brandon D Sidebottom proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the Parrot Bebop Drone UAS, the Parrot Bebop Drone operating documents and Brandon D Sidebottom’s proposed operating limitations, ensure that Brandon d Sidebottom will safely operate the battery powered Parrot Bebop Drone UAS during daylight hours in VMC, under VFR, with enough battery power to fly for total duration of 7.7 minutes to the first intended landing and, assuming normal cruising speed, to fly after that at least 3.3
minutes.14

5. Extent of Relief Brandon D Sidebottom Seeks and the Reason Brandon D Sidebottom Seeks Relief from Section 91.405(a), 91.401(a)(1), 91.409 (a)(1) &(a)(2), and 91.417(a) & (b). Since Sections 91.405(a), 91.409(a)(1) & (a)(2) and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Brandon D Sidebottom requests relief from these sections because the Parrot Bebop Drone UAS does not require Airworthiness certificate. As set forth more fully below, the Parrot Bebop Drone UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate, Accordingly, Brandon D Sidebottom will use trained technicians to preform maintenance, alterations, or preventative maintenance on the UAS using the methods, techniques and practices prescribed in the UAS operating documents (i.e. Monthly Maintenance Log, and Parrot Bebop Drone instruction manual). Furthermore, brandon D Sidebottom will document and maintain all maintenance records for the Parrot Bebop Drone UAS. D. The Reasons why Granting Brandon D Sidebottom 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 Brandon D Sidebottom to safely, efficiently and economically preform aerial video and photography for real estate, golf courses, construction companies, special events, weddings, landscaping, and film sets over certain areas of the United States.

Additionally, use of the Parrot Bebop Drone UAS will decrease congestion of the NAS, reduce pollution and provide significant benefits to the economy. Notably, the benefits of Brandon D Sidebottom’s Proposed operation of the Parrot Bebop Drone UAS will be realized without implicating any privacy issues. 1. Decreased Congestion of the NAS Allowing operation of the Parrot Bebop Drone UAS Provides a safer alternative to the normal manned aircraft that can sometimes closedown areas because of the hight requirements and areas they are required to fly in. This decreases the congestion of manned aircraft in the NAS and also increase the safety of life and property in the air and on ground.15

2. The Safety and Efficiency of The Parrot Bebop Drone UAS. Conducting Aerial acquisitions with the Parrot Bebop Drone 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 Bebop Drone UAS will reduce air and noise pollution. In addition by using the Parrot Bebop Drone UAS vs. a Manned Aircraft, the carbon footprint can be reduces as well. 3. Performing Aerial Video and Photography operations with the Parrot Bebop Drone UAS will Benefit the Economy. In addition to being safe and efficient, the Parrot Bebop Drone UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. Because of this, operations of the Parrot Bebop Drone UAS as will allow United States based companies, like Brandon D Sidebottom’s, to remain competitive and contribute to growth U.S. economy. 4. There are no Privacy Issues Similar to the manned aerial acquisition flight operations that have been conducted for decades, Brandon d Sidebottom’s proposed operation of the Parrot Bebop Drone UAS will not implicate any privacy issues. Specifically, the Parrot Bebop Drone UAS will be operated only in compliance with operation documents which requires property owners involvement as well as local law informant notification, and in accordance with 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 Brandon D Sidebottom Seeks Exemption.

1. Reasons why the Parrot Bebop Drone UAS meets the Conditions of the FMRA Section 333 In consideration of the size, weight, speed and limited operating area associated with the UA and its operation, Brandon D Sidebottom’s Operation of the Parrot Bebop16

Drone UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate with 14 C.F.R Part 21, Subsection H. SECTION 333 provides authority for a UAS to operate without airworthiness certification and set 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. In seeking this exemption, Brandon D Sidebottom submits that the Parrot Bebop Drone UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Parrot Bebop Drone UAS; (b) The Pilot Certification requirement; and (c) the specific operating limitations. a. The specifications of the Parrot Bebop Drone UAS Demonstrated in Safe Characteristics.

The Parrot Bebop Drone 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 Bebop Drone UAS. The technical specification of the Parrot Bebop Drone UAS is set forth by The Parrot Bebop Drone User Guide and specifications from the Parrot Bebop Page of Parrots Website ( http://www.parrot.com/usa/products/bebop-drone/ ). ii. The Parrot Bebop Drone UAS Autonomous Flight and Navigation Modes Enable the UAS to Remain within a Defined Operational Area. The Parrot Bebop Drone UAS may be operated in both manual and fully autonomous flight modes. a complete description of flight and navigation modes of the Parrot Bebop Drone UAS is provided in the Pilot to the map with flight plan section of the website and page 10 of the user guide. iii. The Parrot Bebop Drone UAS is 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 Bebop Drone UAS automatically returns to its takeoff position via GPS and defend to takeoff position and shutdown. A complete description of lost connection return to home is available on page 18 of the user guide.17

b. Flight Operations of the Parrot Bebop Drone UAS is limited to line of sight of a PIC with a safety observer. Brandon D Sidebottom will only use pilots who posses a current and valid medical certificate to act as a PIC of the Parrot Bebop Drone UAS. Additionally, a safety observer will assist the pilot during flight time.

c. Flight of the Parrot Bebop Drone UAS will be conducted pursuant to specific operating limitations. In seeking this exemption, Brandon D Sidebottom proposes to commercially operate Parrot Bebop Drone UAS for the special purpose of conducting aerial video and photography over certain areas of The United States, Pursuant to the following 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 Bebop Drone UAS. 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 UA’s may not be flown at an indicated airspeed exceeding 20 knots.
4. The UA must be operated at an altitude no more than 400 feet AGL, as indicated by the procedures specified in the operating documents unless a special request is made and approved by ACT. All altitudes reported to ACT must be in feet AGL.
5. The UA must be operated withinVLOS 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.
6. The use of first person view by the PIC or Safety Observer is not permitted.
7. All Operations must utilize a safety observer. the SO may be used to satisfy the VLOS requirements as long as the PIC always maintains VLOS capability. The SO andPIC must be able to communicate verbally at all times. Electronic18

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 (AFS-80) 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.19

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 pre-flight 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 current 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. PIC20

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 experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 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 FAA-published 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.21

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 (N- Number) 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.22

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 controlled-access 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 (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board23

(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. Brandon D Sidebottom 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 Bebop Drone UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the Parrot Bebop drone UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Brandon D Sidebottom proposed area of operations, and the operating limitations set forth-above; 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 Bebop Drone UAS, Brandon D Sidebottom submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Brandon D Sidebottom’s proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to 26 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). Brandon D Sidebottom will not allow any PIC to operate the Parrot Bebop Drone UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the Parrot Bebop Drone UAS training and currency requirements, that the PIC is able to safely operate the Parrot Bebop Drone 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 a24

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 Brandon d Sidebottom’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 multi-rotor 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 multi-rotor 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 flight-hour 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 experience-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.25

Exemption No. 11138 at page 15. Accordingly, Brandon D Sidebottom will ensure safe operations by not allowing any PIC to operate the Parrot Bebop Drone UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the Parrot Bebop Drone 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, Brandon D Sidebottom will ensure that the Parrot Bebop Drone 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. 28 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 Bebop Drone 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 Brandon D Sidebottom’s operation of the Parrot Bebop Drone UAS within visual line of sight, at or below 400 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, in26

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 Bebop Drone UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Brandon D Sidebottom will ensure that it will safely operate the battery powered Parrot Bebop Drone UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 7.7 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 3.3 minutes. Here, as in Exemption No. 11109, the technical specifications of the Parrot Bebop Drone 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 Bebop Drone UAS provide audible and visual warnings to the PIC at the GCS when the UA’s 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 Bebop Drone 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).27

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, Brandon D Sidebottom 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 Brandon D Sidebottom 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., Monthly Maintenance Log, and Parrot Bebop Drone Instruction Manual). Furthermore, Brandon D Sidebottom will document and maintain all maintenance records for the Parrot Bebop
Drone UAS. Since the Parrot Bebop Drone UAS will be inspected as prescribed by the operating documents, Brandon D Sidebottom will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversely affect safety because Brandon d Sidebottom 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 Bebop Drone 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 Brandon D Sidebottom’s proposed operating limitations, the operating documents, and the technical aspects of the Parrot Bebop Drone UAS, Brandon D Sidebottom submits that safety will not be adversely affected by granting28

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, Brandon D Sidebottom requests that the FAA prescribe special conditions for the intended operation of the Parrot Bebop Drone 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 UA’s 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 Bebop Drone 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 or29

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 Bebop Drone 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). F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Brandon D Sidebottom Seeks Exemption: Brandon D Sidebottom 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 Brandon D Sidebottom Seeks: This exemption will permit Brandon D Sidebottom to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Brandon D Sidebottom’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, Brandon D Sidebottom’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 national30

security; and further, provides the authority for such UAS to operate without
airworthiness certification. As discussed in detail above, Brandon D Sidebottom will operate the Parrot Bebop Drone 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, Brandon D Sidebottom 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 Bebop Drone 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 Brandon D Sidebottom to safely, efficiently, and economically operate the Parrot Bebop
Drone UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Brandon D Sidebottom 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 Brandon D Sidebottom to operate the Parrot Bebop Drone UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Date: August 19, 2015 Respectfully submitted, Brandon D Sidebottom
1509 N McRae Dr. Goddard, KS 67052
620-960-03203132