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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

620-960-0320
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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.........................................................................31
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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 Landing
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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 

operations
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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 experienced 
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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 Bebop 
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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.
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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 first 
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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; or
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(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.
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(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 that 
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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 pressure 
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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.
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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.
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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 Bebop 
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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.
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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. Electronic 
18

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. PIC 
20

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 Board
23

(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 a
24

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, in
26

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 granting 
28

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 or
29

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 national
30

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

620-960-0320
31
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