United States Department of Trimsportatio~ 

Docket Management System · · 

1200 New Jersey Ave., SE . 

West Building Ground Floor ROOJTI W12-140 

Washington, DC 20590 ' ;· 

Re: j:xception Request in accordance to Section 333 FAA Moderniz~tion and Reform Act of 2012 • 1 ·- ' ' : •• : • ' • 

I am writing in accord~nce to Section 333 of the FAA Moder~ization and Reform Act of 2012 to request ' . ' .. ' . ~ ' .' . . . . 

that I may operate my UAV commercially in United States airspace. My desire is'to use this· UAV to · 

provide customers with an 'up-high' view of their properties, lands or projects. Other usages may 

include landscape photography and possibly event photography. 

The UAV I'm proposing to use is a Parrot Bebop Drone (hereafter in this letter called a UAV). This is a 

small device measuring 11"x12.5"x 1.5" and weighing just under 1 pound. The UAV has a top speed of 

25 knots. (http:/ /www.parrot.com/products/bebop-drone/) 

It comes equipped with a 14mp forward facing camera and four counter-rotating propellers powered by 

four brush less mo~ors.for balance, control and stability.' The Bebop Drone uses GNSS (GPS +GLbNASS), , . • I , • 

a 3-axes magnetometer, gyroscope and accelerometer, a separate down-facing cameraand an 

ultrasonic sensor for att,itude, altitude and flightcontrol. It connects to a remote control wireless at 

,2.4ghz or 5ghzconnecting byWi~Fi 802.11 a/b/g/h/ac. Tl'iis d~vice complies witli Part 15 ofthe FCC 

Rules. Operation is subject to the following two conditions: This equipment may not cause harmful 

.interference. This equipment must accept any interference received, including interference that may '. . '; . . . . 

cause ~,~n,desired operation. 

\. . . ' ~ 

As this already includes the camera (software stabilized) there is no reason for any additional payloads ' •. '·.'·: 4i:' : 

to be attached to it. Nor is it designed to handle additional payloads. This device will be used strictly for 

photography and videography, as it has been built to perform. 

This UAV utilizes a remote control known as a Skycontroller. This device uses two 36dBm antennas for 

controlling the UAV and, according to the manufacture, boasts a range of 2km. For the practical 

commercial purposes I envision for this UAV, I don't believe it will need to exceed even a quarter of that 

distance. Most operations with this UAV will involve taking to an altitude to capture photography (not 

to exceed 200agl) for property or landscape imagery. 

A tablet or cellphone is utilized for providing a first-person-view and flight information during operation. 

Essentially, the camera used to video or photography recording can be controlled and viewed through 

during fight. In unforeseeable situations where the device might fall out of sight, this view can also be 

utilized to steer the device back into line-of-sight. 

Altitude, speed, distance from remote, GPS state, and radio signal strength are relayed to the tablot or 

smartphone screen. In addition, the first-person-view also provides a kind of artificial horizon that 

conveys the performance ofthe UAV in light wind conditions. 

In most situations, a preflight checklist will consist of checking the propellers for any damage (fatigue, 

chippings, etc.) and making certain other fittings are on tight and in good condition. Only freshly 

charged batteries will be used for each flight, regardless of what their percentage was after an individual 
flight. The device will be made to sit with its motors off for several minutes after the GPS icon shows a 

steady signal to ensure a stable lock. (GPS status icon turns from red, to yellow to green depending on 

signal strength.) The sensors will be calibrated before each flight. 

For flights over new or existing homes (as requested by a customer), the UAV will only be operated 

when there are no personal in the field. (For example: Not during a period of time when construction is 

going on.) While the UAV is in flight it will remain in view. The UAV will not be flown over a two-lane 

road ifthere's constant traffic or if there are other obstructions in the flight area. It will not be flown 

over highways or people. 

An additional spotter will be called in to assist in areas where the flight may be difficult because of 

vegetation or other obstructions. 

This model UAV has roughly 10 minutes of flight time and will be brought 'home' once the battery 

reaches 25% level. It also features a 'Go Home' feature. When activated the UAV will either lower, or 

raise itself to 32ft AGL and proceed to return to its take off location. During this 'automatic' flight the 

UAV can still be controlled and overridden. The 'Go Home' feature will also activate after a short time if 

a signal is lost from the controller. 

The UAV also features an automatic motor cutoff system. If any propeller makes contact with an object, 

the drone will shut down all flight systems. This feature can also be manually activated in flight by 

pressing the 'Emergency' button. 

The Pilot in question, Miguel Santiago, has flown this model UAV recreationally for over 50 flights and 

has accrued over 5 hours of flight time. He wears corrective lenses for near-sightedness as specified by 

his driver's license. 

During commercial operations the UAV will be software limited to fly at no faster than 3 knots (1.5 m/s) 

and no higher than 200 agl (60.9 meters). Each flight will be no longer than 10 minutes with most flight 

seldom exceeding 5 minutes. Once the battery drops to 25% the drone will be made to return to its 

landing area. 

The UAV will never be operated from a moving vehicle. However, the operator may need to move 

around (on foot) to keep the UAV within visual line-of-sight and to ensure safety while it's in operation. 

The UAV will only be operated in good weather conditions, with low winds, no precipitation and only 

during daylight hours. lffor any reason an aircraft is heard or seen approaching the UAV will be made to 

land immediately. In all cases during commercial operations, permission will be granted to operate in 

properties. 

At this time I do not foresee this UAV being utilized in or near airports. Nor do I foresee this UAV being 

utilized outside of the United States. 

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under Section 

333 of the Reform Act. The legislation permit the FAA to exempt UAVs from the airworthiness 

certificate requirement in consideration ofthe weight, size, maneuverability and proximity to areas such 

as airports and population areas. The UAV I'm requesting to be exempt meets these elements. 
14 C.F.R 91.7{a) prohibits the operations of an aircraft without an airworthiness certificate. No such 

certificate is applicable in the form contemplated by the FAR. This Regulation doesn't apply. 

14 C.F.R 91.9{b){2} requires an aircraft manual in the aircraft. As there are no pilots or passengers and 

since the device is small in size this Regulation is inapplicable. A guide will be present with the remote 

flight controller. 

14 C.F.R. 91.121 regarding altimeter setting is inapplicable, as the device does not utilize an altimeter 

setting. The UAV in question utilizes GNSS for electronic global positioning and a 3-axes magnetometer, 

gyroscope and accelerometer for attitude and flight control. In addition, at 26 AGL {8 meters) or lower, 

an ultrasonic sensor provides additional altitude information electronically. 

14 C.F.R. 45.23 regarding aircraft to be marked to certain specifications. The UAV in question does not 

have a cockpit or cabin where such markings will go. In addition, the aircraft is much too small for the 

two-inch lettering. Nevertheless, the UAV will be marked contact information in several places so that 

it can be noticed. 

14 C.F.R. 61.113 regarding Private Pilot Privileges and Limitations {PIC). Private pilots are limited to noncommercial operations. In addition, pilot training may not necessarily ensure remote piloting skills of 

any particular UAV. While private pilot licensees may understand how to operate inside airspace, 

airport and navigation skills and communications, this far exceeds the intended operation of my UAV. 

Finally, the risks to the PIC operating the UAV is far less then that of the commercial activities outlined in 

14 C.F.R. 61. 

14 C.F.R. 91.119 regarding minimum safe altitudes. 14 C.F.R. 91.119 proposes safe altitudes for the 

operations of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. 

My UAV will never operate at an altitude greater than 200 AGL. In most cases, the UAV will operate in 

areas where no bystanders will be {ie: an empty field or residential yard around a home.) In areas 

where it will operate for event photography, it will do so in areas blocked off or marked and closely 

monitored by spotters. Given the size, weight, maneuverability and speed ofthis UAV, I believe safety 

can be achieved. 

In scenarios where I feel safety cannot be reasonably guaranteed the UAV will simply not be utilized. 

14 C.F.R. 91.151 regarding fuel requirements for flights in VFR conditions. The UAV uses a Lithium 

Polymer 1200 mAh battery that provides it with roughly ten minutes of flight time. The status of battery 

power is displayed in two separate places on the remote control and an alert {vibration and audible) will 

occur if the battery falls below 10%. My standard procedure is to prepare to land the UAV at 25% 

battery power. 

14 C.F.R. 91.405: Maintenance Inspections. 

The above regulations require aircraft owners and operators to 1/have [the] aircraft inspected as 

prescribed in subpart E ofthis part and shall between required inspections, except as provided in 

paragraph {c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter" 

These regulations only apply to aircraft with an airworthiness certificate. They will not apply to the UAV 

in question should its exemption be granted. 
Regardless, the aircraft will be maintained to the highest standard possible condition, including 

replacement of damaged or missing parts, software updates and constant assessment of its 

performance during flight. I believe doing this will maintain the same level of safety. 

In summary, granting me the request for exemption with this UAV will help to open a market for 

photography for construction builders and open a new world of imagery for citizenry. In the past, such 

imagery would only be possible with larger aircraft operating at low altitudes and using flammable fuel. 

The UAV I'm proposing to use does not contain fuel, is smaller, lighter and much more maneuverable 

then conventional aircraft. It is also far less distracting and disruptive to the general public then a 

hovering helicopter or a low flying fixed-wing aircraft. 

Since no one is on board UAV there is little opportunity for serious bodily injury during its operation. As 

mentioned earlier, the UAV 1 pound in weight (below the FAA mandated 55 pound limit) and has top 

speed of 25 knots. Horizontal, vertical and rotational speeds can be software limited, adding to the 

already significant level of safety already inherent to this UAV. 

While my desire is to utilize this equipment for commercial purposes, safety to people and property is 

still my upmost priority. 

I, Miguel Santiago, respectfully request that the FAA grant its exemption to my request. Thank you for 

your consideration. 

Sincerely, 

~.~ Miguel Santiago 

5306 Big Bass Drive 

Raleigh, NC 27610 

gl!]_tiago2274@_g_mail.com 

{910) 494-2274