1



### United States of America Department of T ransportation Federal A viation Administration W ashington DC

IN THE M A

TTER OF THE PETITION FOR EXEMPTION OF: THOMAS A. REEDER FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF TH E CODE OF FEDERAL REGUL A TIONS SECTIONS 61. 1 13(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 OPER A TION OF P ARROT BEBOP DRONE

AND DJI PHANTOM 3 PROFESSIONAL QUADCOPTER UNMA NNED AIRCRAFT SYSTEMS PURSUANT T O SECTION 333 OF THE F AA MODERNIZ A

TION AND REFORM ACT OF 2012 (PUBLIC L A W 1 12

- 95)

submitted on February 23, 2016
Thomas A. Reeder 5 Partridge Run Hampton, NJ 08827 201

- 852

- 2047 treeder651@gmail.com2



### T ABLE OF CONT ENTS

pages GLOSSA R Y OF ABBREVI A TIONS..................................................3

SUMMA R Y.................................................................................4

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

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

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

NAME AND ADDRESS OF PETITION ER.........................................7

SPECIFIC SECTIONS OF 14 C. F .R. FROM WHICH THOMAS A. REEDER SEEKS EXEMPTION..............................................7

EXTENT OF RELIEF THOMAS A. REEDER ’S AND THE REASON THOMAS A. REEDER SEEKS THE RELIEF.......................... 1 1

REASONS WHY GRANTING THOMAS A. REEDER ’S RE QUEST WOULD BE IN THE PUBLIC INTEREST.......................................14

REASON WHY GRANTING THE EXEMPTION WOULD NOT ADVERSE L Y AFFECT SAFETY.....................................................................15

SUMMA R Y TH A

T CAN BE PUBLISHED IN THE FEDERAL REGISTER.28

ANY ADDITIONAL INFORM A TION, VIEWS, OR ARGUMENTS AV AILABLE T O SUPPO R T THOMAS A. REEDER ’S REQUEST................29

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

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



### GLOSSA R Y OF ABBREVI A TIONS

AGL

- Above Ground Level AOI

- Area of Interest A TC

- Air T raffic Control A T O

- Air T raff ic Organization A V

- Aerial V iew CFR

- Code of Federal Regulation COA

- Certificate of Authorization F AA

- Federal A viation Administration F AR

- Federal A viation Regulation GCS

- Ground Control Station GPS

- Global Positioning System LOL

- Loss of Link NAS

- National Airspace System NO T AM

- Notice to Airman PIC

- Pilot in Command Section 333

- F

AA Modernization and Reform ACT of 2012(FMRA)

section 333 SO

- Safety Observer SOP

- Standard Operating Procedure UA

- Unmanned Aircraft UAS

- Unmanned Aircraft Syst em VFR

- V isual Flight Rule VLOS

- V isual Line of Site VMC

- V isual Meteorological Condition V T OL

- V ertical T

akeo f f and Landing4



### SUMMA R Y

Thomas A. Reeder seeks exemption from the requirements of
14 C. F .R 61. 1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 9 1. 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 F

AA Modernization and Reform Act of 2012 (FMRA). This Exemption will permit Thomas A. Reeder to operate an UAS for t he commercial purpose of conducting aerial video and photography for real estate, golf courses, construction compani e s , special events, film sets, landscaping and weddings over certain areas of
the United States.



### INTERESTS OF THE PETITIONER

Thomas A. R eeder 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. Thomas A. Reeder has over 30 years of professional exp erience work ing for Golf Course Construction Companies, owning Architectural Sheet Metal and Alucobond Panel Companies and working in the Restaurant/Banquet Ser vice Industry. Thomas A. Reeder has over 35 years of recreational/hobby experience in RC Aircra ft of all types, makes and models. Thomas A. Reeder holds a Private Pilot License with an IFR rating and will have a Commercial Pilot and CFI rating in the Summer of 2016. My objective is to provide high quality imaging in a safe way for a variety of comme rcial, public and residential uses, specifically targeting:

 Real Estate

 Golf Courses

 Construction

 W eddings

 In addition to increasing public knowledge of UAS and promote safe
UAS operati o n5



### Background
UAS: Parrot Bebop Drone

Thomas A. Reeder is seeking e xemption to operate P ARROT systems for compensation or hire within the NAS. The Parrot Bebop Drone is a vertical takeo f f and landing (V T OL) Unmanned Aircraft with Ground Control Station (GCS) utilizing electronic tablet or smart phone system. The Parrot Be bop Drone has a max gross weight of approximately 1 pound, while having a length of 12.6 inches, a width if 1 1
inches and a h e ight 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 Thomas A. Reeder 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.



### UAS: DJI Phantom 3 Professional Quadcopter

Thomas A. Reeder is also seeking exemption to operate DJI Phantom 3 systems for compensation or hire within the NAS. The DJI Phantom 3 Quadcopter is a vertical
takeo f f and landing (V T OL) Unmanned Aircraft with Ground Control Station (GCS) utilizing electronic tablet or smart phone system. The DJI Phantom 3 Quadcopter has a max gross weight of approximately 9.2 pound s , while hav ing a length of 18 inches, a
width if 1 3 inches and a height of 8 inches and a maximum speed of approximately 3 2
knots. The DJI Phantom 3 Quadcopter is equipped with four main rotors driven by lithium polymer battery powered electric motors.
The DJI Phanto m 3 Quadcopter UAS that Thomas A. Reeder 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 a nd registration marking.6



### BASIS FOR PETITION

Petitione r , Thomas A. Reeder
, pursuant to the provision of the Federal A viation Regulation (14 C. F .R 1 1.61) and FMRA, Section 333, Special Rules for Certain
Unmanned Aircraft Systems, herby petitions t he Administration to commercially operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS in the NAS, and for exemption from the requirements of 14 C. F .R 61. 1 1 3(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, Thomas A. Reeder ’ s operation of the Parrot Bebop Drone UAS and the
DJI Phantom 3 Quadcopter meets the conditions of FMR A Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C. F .R Par 12, subpart
H. Accordingl y , Thomas A. Reeder requests relief from section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) & (b), as the se sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.
Thomas A. Reeder submits that the requested relief is proper since an equivalent level of safety will be ensured. Thomas A. Reeder will use ex perienced personnel or technicians to per form 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 and the DJI
Phantom 3 Quadcopter Instruction Manual s ). Furthermore
, Thomas A. Reeder will
document and maintain all maintenance records for the Parrot Bebop Drone and the DJI
Phantom 3 Quadcopter UAS

. Relief from certain requirements of section 61. 1 13(a) & (b), e ntitled Private Pilot privileges and limitations: Pilot in Command, is required by Thomas A. Reeder to the
exte nt necessary to allow a PIC holding a private pilot or higher level certificate, as well
as an airman medical certificate and who has demonstrate d, by meeting minimum flight

- hours and currency requirements, that the PIC is able to safely operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS in a manner consistent with the7

exemption, including evasive and emergency maneuvers and maint aining appropriate distances of people, vessels, vehicles, and structures.
Thomas A. Reeder seeks relief from section 91.7(a) Entitled Civil Aircraft Airworthiness, because the Parrot Bebop Drone UAS does not require an airworthiness certificate in
accorda nce with 14 C. F .R part 21, Subpar H. As, such, Thomas A. Reeder submits that
he will ensure the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS is in an Airworthy condition, prior to every flight, by determining that the UAS is in compliance
with t he operating documents (i.e. Monthly Maintenance Log, and Parrot Bebop Drone and the DJI Phantom 3 Quadcopter Instruction Manual), and that the aircraft is in a condition for safe flight.
Thomas A. Reeder is also seeking an exemption from the requirement o f section 91.121, entitled Altimeter settings, as the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will not have a typical barometric altimeter onboard. however altitude
information of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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. T he altitude information, combined with Thomas A. Reeder ’ s operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS within visual line of sight, at or below
400 feet AGL, will ensure a level of safety equivalent to Section 91.121.
Additionall y , Thomas A. Reeder seeks exemption from the requirements of Section 91.151(b), e ntitled Fuel requirements for flight in VFR conditions. Thomas A. Reeder submits that safety will not be a f fected by operation of the Parrot Bebop drone UAS during daylight hours in visual meteorological conditions (VMC) under VFR, with enough battery pow er 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 1 1.81, Thomas A. Reeder provides the foll owing information in support of its petition for exemption:8

I. N ame and Address of Petitione r

.

The name and address of petitioner and point of contact is:

Thomas A. Reeder 5 Partridge Run Hampton, NJ 08827 201

- 852

- 2047 treeder651@gmail.c om
II. The Specific Section of 14 C. F .R. From Which Thomas A. Reeder Seeks Exemption.

A. Thomas A. Reeder Seeks Exemption from the Requirements of Section 61. 1 13(a) & (b)

Section 61. 1 13, entitled Private Pilot Privileges and Limitation: Pilot in c ommand, subsections (a) & (b) prescribe the following, in relevant part:

1. 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 th at person, for compensation or hire, act as PIC of an
aircraft.
2. A private pilot ma y , for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— a) the flight is only incidental to that business or employment; and b) the aircraft does not carry passengers or property for compensation or
hire.

B. Thomas A. Reeder seeks exemption for The Requirement of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthin ess, subsectio n (a), states the following :

1. No person may operate a civil aircraft unless it is in an airworthy condition.9

C. Thomas A. Reeder seeks Exemption from The Requirements of Section
91.121. Section 91.121, entitled Altimeter settings, subsection (A), States the following, in part : 1. 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

a) Below 18,000 feet MSL, to

—

 The current reported altitu de setting of a station along the route and within 100 nautical miles of the aircraft;

 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 stati on; or

 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.

D. Thomas A. Reeder Seeks Exemption from Requirements of Section 91.151(b)
Secti on 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 fu el to fly to
the first point of intended landing and, assuming normal cruising speed, to fly
after that for at least 20 minutes.

E. Thomas A. Reeder Seeks Exemption from Requirements of Section 91.405(a) Section 91.405, entitled Maintenance required, s ubsection (a), States the following:
Each owner or operator of an aircraft

—10

(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 prescrib ed in part 43 of this chapter.

F. Thomas A. Reeder Seeks Exemption from Requirements of Section 91.407(a)(1)
Section 91.407, entitled Operatio n after maintenance, preventive maintenance, rebuilding, or alteration, subs ection (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

.
G. Thomas A. Reeder 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 ma y operate an aircraft unless, w ithin the preceding 12 calendar months, it has
had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of this chapter; or (2) A n inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

H. Thomas A. Reeder 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 91.4 1 1 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of the section:11

(1) Records of the mainte nance, preventive maintenance, and alterations and
records of the 100

- hou r , annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propelle r , roto r , and appliance of an a ircraft. 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 approvi ng the
aircraft for return to service.

(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propelle r , and each roto r

. (ii) The current status of life

- limited parts of each airframe, engi ne, propelle r , roto r , and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since
the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by 43.9(d) of this chapter for each major alteration to the airfr ame and currently installed engines, rotors, propellers, and appliances.12

(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 wor k 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 furni shed to a registered owner or operator under 43. 1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

III. The Extent of Thomas A. Reeder seeks and the Reason Thomas A. Reede r Seeks the Reli ef.

I. Extent of Thomas A. Reeder Seeks and Reason Thomas A. Reeder Seeks Relief From Section 61. 1 13(a) & (b).

Relief from section 61. 1 13(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
hi re. This relief is requested since the limitations set forth in section 61. 1 13(a) & (b) states that a private pilot ma y , for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental
to that business or employment; and (2) the aircraft does not carry passengers or property for compensation or hire. As set forth ,ore fully belo w , Thomas A. Reeder submits that an equivalent level of safety will be maintained because no PIC will be allow ed to operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 and the DJI Phantom 313

Quadcopter 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.
Furthe r , Thomas A. Reeder s ubmits that all flights of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS, Conducted by the PIC pursuant to the grant of this petition: (1) will be incidental to Thomas A. Reeder Business, and(2) will not carry passengers or property for compe nsation or hire.

II. Extent of Relief Thomas A. Reeder Seeks and the Reasons Thomas A. Reeder Seeks Relief from Section91.7(a) Relief from Section 91.7(a), Entitled Civil aircraft airworthiness, is requested to the extent required to allow Thomas A. R eeder to determine that the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 Dro ne and the DJI Phantom 3 Quadcopter Instruction Manual).
Thomas A. Reeder seeks the requested relief because the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS does not require an airworthiness
certificate in accordance with 14 C. F .R Part 21, subp art H. Therefore, Thomas A.
Reeder will insure that the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS in airworthy condition based upon its compliance with the operating documents (i.e. Monthly Maintenance Log, and Parrot Bebop Drone
and the DJI Phantom 3 Quadcopter Instruction Manual) Prior to every flight, and
furthe r , determine that the aircraft is in condition for safe flight, as stated in the
conditions and limitations belo w

.

III. Extent of Relief Thomas A. Reeder Seeks and the Reason Thomas A. Reeder 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 and the DJI Phantom 3 Quadcopter UAS, which utilize a barometric pressure senso r , GPS eq uipment, and a radio14

communications telemetry data link to downlink altitude information from UA to PIC at the ground Control Station (GCS). Since the F AA requires that any altitude information concerning UAS operations be reported to A TC in feet AGL, Tho mas A. Reeder seeks the requested relief because the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 belo w

. As more fully set forth herein, an equivalent level of safety will be mainta ined since the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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.

IV. Extent of Relief Thomas A. Reeder Seeks and the Reason Thomas A. Reeder Seeks Relief from Section 91.151(b)

Relief from Section 91.151(b) entitled Fuel requirements for flig ht in VFR conditions, is requested to the extent required to allow flight of a battery powered Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UA during daylight hours in visual meteorological conditions (VMC), under VFR, for a total duration
of 7.7 mi nutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 3.3 minutes. Thomas A. Reeder seeks the requested relief because without exemption from Section 91.151(b), the flight time duration of the batt ery powered Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will severely constrain the practicality of any aerial video or still photo flight operations that Thomas A. Reeder proposes to conduct pursuant to this Petition. Significantl y , as set for th belo w , the technical specifications of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS, the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter operating documents and Thomas A. Reeder ’ s15

proposed operating limitations, ensure that Thomas A. Reeder will safely operate the battery powered Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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

n ormal cruising speed, to fly after that at least 3.3 minutes.

V. Extent of Relief Thomas A. Reeder Seeks and the Reason Thomas A. Reeder 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, Thomas A. Reeder requests relief from
these sections because the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS does not require Airworthiness c ertificate. As set forth more fully belo w , the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS
meets the conditions of FMRA Section 333 for operation without an airworthiness certificate, Accordingl y , Thomas A. Reeder will use trained technicians t o perform 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 and the DJI Phantom 3 Quadcopter instruct ion manual). Furthermore, Thomas A. Reeder will document
and maintain all maintenance records for the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS.

VI. The Reasons why Granting Thomas A. Reeder Request W ould be In the Public Interest; That is, H ow it W ould Benefit The Public as a Whole.
Granting the present Petition will further the public interest by allowing Thomas A.
Reeder to safel y , efficiently and economically perform 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.
Additionall y , use of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will decrease congestion of the NAS, reduce pollution and provide si gnificant16

benefits to the econom y . Notabl y , the benefits of Thomas A. Reeder ’ s Proposed operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will be realized without implicating any privacy issues.

A. Decreased Congestion of the NAS
Al lowing operation of the Parrot Be bop Drone and the DJI Phantom 3 Quadcopter UAS Provides a safer alternative to the normal manned aircraft that
can sometimes closedown areas because of the height requirements and areas they are required to fly in. This dec reases the congestion of manned aircraft in the NAS and also increase the safety of life and property in the air and on ground.

B. The Safety and Efficiency of The Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS. Conducting Aerial acquisitions w ith the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 fligh t operations. By using battery power and electric motors, the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will reduce air and noise pollution. In addition by using the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS vs. a Manned
Aircraf t, the carbon footprint can be reduces as well.
C. Performing Aerial V ideo and Photography operations with the Parrot Bebop Drone UAS will Benefit the Econom y
. In addition to being safe and efficient, the Parrot Bebop Drone and the DJI Phantom 3 Quadcopt er UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. Because of this, operations of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS as will allow United States based companies, like Thomas A. R eeder ’ s, to remain competitive and contribute to growth U.S. econom y

.17

D. There are no Privacy Issues
Similar to the manned aerial acquisition flight operations that have been conducted for decades, Thomas A. Reeder ’ s proposed operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will not implicate any privacy issues. Specificall y , the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will be operated only in compliance with operation documents which requires property owners involve ment as well as local law informant notification, and in accordance with Federal A viation Regulations, including the minimum altitude requirements of 14 C. F .R 91. 1 19.

VII. The Reasons Why Granting the Exemption W ould not Adversely Affect Safet y , or how th e Exemption W ould Provide a Level of Safety at Least Equal to that Provided by the Rule from which Thomas A. Reeder Seeks Exemption.

A. Reasons why the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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, Thomas A. Reeder ’ s Operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 securit y

. In seeking this exemption, Thomas A. Reeder submits that the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS can operate safely in the NAS pursuant to FMRA Section 333, as dem onstrated by: (a) the characteristics of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS; (b) The Pilot Certification requirement; and (c) the specific operating limitations.18

1. The specifications of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS Demonstrated in Safe Characteristics.

The Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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, sp eed, and operational capabilit y

. a) T echnical Specifications of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS. The technical specification of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS is set forth by The Parrot Bebop Drone and the DJI Phantom 3 Quadcopter User Guide and specifications from the Parrot Bebop Page of Parrots
W ebsite ( http://ww w .parrot.com/usa/products/bebop

- drone/ ) and
from the DJI Phantom 3 Quadc opter website ( http://www.dji.com/product/phantom

- 3

- pro )

. b) The Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS Autonomous Flight and Navigation Modes Enable the UAS to Remain within a Defined Operational Area.
The Parrot Bebop Drone and the DJ I Phantom 3 Quadcopter 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 and the DJI Phantom 3 Quadcopter UAS is provided in the Pilot to the map with fligh t plan section of the website and page 10 of the Parrot Behop
Drone user guide or page 11 of the DJI Phantom 3 Quadcopter user guide

. c) The Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS are designed for automatic return to home point or hover in the event of loss of the control link or navigation.

When the control link is lost, the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter U AS automatically return to their19

takeo f f position via GPS and defend to takeo f f position and
shutdown.
A comple te description of lost connection return to home (RTH)
is available on page 11 of the Parrot Behop Drone user guide or page 14 of the DJI Phantom 3 Quadcopter user guide

.

2. Flight Operations of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS is limited to line of sight of a PIC with a safety observe r

.
Thomas A. Reeder is and will only use pilots who possess a current and
valid medical certificate to act as a PIC of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS. Additionall y , a safety observer will assist the pilot during flight time.

3. Flight of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will be conducted pursuant to specific operating limitations.
In seeking this exemption, Thomas A. Reeder proposes to comme rcially operate Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS for the special purpose of conducting aerial video and photography over
certain areas of The United States, Pursuant to the following operating
limitations: a) Operations authorized by th is 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 and the DJI Phantom 3 Quadcopter UAS. Proposed operations of any othe r aircraft will require a new petition or a petition to amend this grant. b) UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y

. c) The U A

’ s may not be flown at a n indicated airspeed excee ding 3 2
knots.20

d) 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 AC T

. All altitudes reported to ACT must be in feet AGL. e) Th e UA must be operated within VLOS of the PIC at all times. This requires the PIC to be able to use human vision unaided by any
device other than corrective lenses. f) The use of first person view by the PIC or Safety Observer is not permitted. g) All Operations must utilize a safety observe r . the SO may be used to satisfy the VLOS requirements as long as the PIC always maintains VLOS capabilit y

. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted duri ng 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. h) The SO must not p erform 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. i) The operating documents and the grant of exemption mu st 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 cond itions 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 operato r ’ s21

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 exemptio n. If the operator determines that any update or revision would a f fect the basis upon
which the F

AA granted the exemption, then the operator must petition for amendment to its grant of exemption. The F A A ’ s UAS Integration Office (AFS

- 80) may be contacted i f questions arise regarding updates or revisions to the operating documents. j) 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 a f fects 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 alter ations must be properly
documented in the aircraft records. k) Any UAS that has undergone maintenance or alterations that a f fect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test fligh t. The PIC who conducts the functional test flight must make an entry in
the aircraft records. l) The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sect ions of the operating
documents. m) The operator must follow the UAS manufacture r ’ s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. n) The operator must carry out its maintenance, inspections, and record keeping r equirements, in accordance with the operating22

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. o) Each UAS operated under this exemption must comply with all
manufacturer Safety Bulletins. p) The authorized person must make an entry in the aircraft record of
the corrective action taken a gainst discrepancies discovered between inspections. q) The PIC must possess at least a current medical certificate. r) The operator may not permit any PIC to operate unless the PIC meets the operato r ’ s qualification criteria and demonstrates the ability to safe ly operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C. F .R. § 61.51(b). Flights for the purposes of training the operato r ’ s PICs are permitted under the terms of the exemption. Howeve r , training operations may only be conducted during dedicated training
sessions. During training, proficienc y , 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

. 1 19. s) 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
cond itions (VMC). If flight at night is required, a special request will23

be made at the F

AA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. t) The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current F AA

- published aeronautical chart unless a letter of agreement with that airport ’ s management is obtained, and the operation is conducted in
accordance with a NO T AM as required by the operato r ’ s COA. The
lett er of agreement with the airport management must be made
available to the Administrator upon request. u) 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. v) 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 accordan ce with the operating
documents w) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. x) 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 w ith 25% battery power remaining. y) The operator must obtain an Air T raffic Organization ( A T O) issued
Certificate of W aiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will al so require the operator to request a Notice to Airman (NO T AM) 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 A T O issued COA including c lass of airspace, altitude level and potential transponder requirements.24

z) All aircraft operated in accordance with the exemption must be identified by serial numbe r , registered in accordance with 14 C. F .R. part 47, and have identification (N

- Number) markin gs in
accordance with 14 C. F .R. part 45, Subpart C. Markings must be as large as practicable. aa) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) o r other appropriate government oversight agency requirements. bb) 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 avai lable to the Administrator or any law enforcement official upon request. cc) The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. dd) The UAS may not be operated by the PIC from any moving device
or veh icle. ee) 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: 1) Barriers or structures are present that suffic iently 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 a nd are within 500 feet of the UA, flight operations must cease immediately and/or; 2) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or25

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; 3) Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per §
91. 1 19(a). ff) 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 e ach flight to be
conducted. gg) 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 F AA's UAS Integration Office (AFS

- 80) within 24 ho urs. Accidents must be reported to the
National T ransportation Safety Board (NTSB) per instructions
contained on the NTSB W eb site: ww w .ntsb.go v

.

B. Reasons Why An Exemption From The Requirements Of Section 61. 1 13(a) And (b) W ould Not Adversely Affect Safet y
. Thomas A. Reeder submits that the equivalent level of safety established by
Section 61. 1 13(a) and (b) will be maintained because no PIC will be allowed to operate the Parrot Bebop Drone and the DJI Phantom 3 Qua dcopter 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 and the DJI Phantom 3 Quadcopter UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Thomas A. Reeder 's proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of private p ilot aeronautical26

knowledge requirements to those of commercial pilot requirements (See Exemption No. 1 1062); and the airmanship skills necessary to safely operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS, Thomas A.
Reeder submits that t he additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Thomas A. Reeder ’ s proposed flight operations.
The F AA has previously granted relief from Section 61. 1 13(a) and (b) s pecific to 26 UAS, in circumstances simila r , in all material respects, to those presented
herein (e.g. Exemption Nos. 1 1062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080,
11 109, 111 10, 111 12, 11 136, 11 138, 11 150, 11 153, 11 156, 11 158, 11 159, 11 160,
11 161). T homas A. Reeder will not allow any PIC to operate the Parrot Bebop
Drone or the DJI Phantom 3 Quadcopter UAS unless that PIC has demonstrated, by meeting min imum flight

- hour requirements of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS train ing and currency requirements, that the PIC is able to safely operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate
distances fr om people, vessels, vehicles and structures. Specificall y , the PIC must have accumulated and logged, in a manner consistent
with 14 C. F .R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the
hour requirements, the PIC must accomplish 3 takeo f fs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 1 1062, 11 138, and 11 153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Thomas A. Reeder ’ 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:27

In Exemption No. 1 1062, the F AA required that prior to conducting operations for the purpose of motion picture filming (or similar ope rations), 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. 1 1062, 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 F AA 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 accomplis h 3 takeo f fs and landings in the preceding 90 days (for currency purposes). The F AA finds that at a minimum, the flight

- hour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitione r ’ s proposed operations. The F

AA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement.
T raining, proficienc y , and experience

- building flights can also be con ducted under the grant of exemption to accomplish the required flight time. During training, proficienc y , and experience

- building flights the PIC is required to operate
the UA with appropriate distances in accordance with 14 C. F .R 91. 1 19. Exemption No. 1 1 138 at page 15. Accordingl y , Thom a s A. Reeder will ensure safe operations by not allowing any PIC to operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency require ments, that the PIC is able to safely operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehic les and structures.28

C. Reasons Why An Exemption From The Requirements Of Section 91.7(a) W ould Not Adversely Affect Safet y
. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Thomas A. Reeder w ill ensure that the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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. Additionall y , the F AA has previous ly granted relief from Section 91.7(a) specific to UAS, in circumstances
simila r , in all material respects, to those presented herein (e.g. 28 Exemption
Nos. 1 1062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 111 10, 111 12,
11 136, 11 138, 11 150, 11 153, 11 156, 11 157, 11 158, 11 159, 11 160, 11 161).

D. Reasons Why An Exemption From The Requirements Of Section 91.121 W ould Not Adversely A f fect Safet y
. The equivalent level of safety established by Section 91.121 will be maintained
because the altitude infor mation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 Thomas A. Reeder ’ s operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The al titude 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 F AA has previously granted relief from Section 91.121 specific to UAS, in
circumstances simila r , in all material respects, to those presented herein (e.g. Exemption Nos. 1 1062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109,
111 12, 11 136, 11 138, 11 150, 11 153, 11 156, 11 157, 11 158, 11 159, 11 160, 11 161).29

E. Reasons Why An Exemption From The Requirements Of Section 91.151(b) W ould Not Adversely Affect Safet y
.
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 speci fications of
the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y , Thomas A. Reeder will ensure that it will safely operate t he battery powered Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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 sp eed, to fly after that for at least 3.3 minutes. Here, as in Exemption No. 11 109, the technical specifications of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS; the limitations on the proposed flight operations; and the location of the propos ed 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 and the DJI Phantom 3 Quadcopter UAS provide audible and visual warnings to the PIC at
the GC S when the U A

’ s experiences low battery voltage, the first warning occurring at approximately 33% remaining battery powe r , and again at approximately 10% remaining battery powe r

. At the critically low battery level, the Parrot Bebop Drone and the DJI Phant om 3 Quadcopter UAS will descend and
land automaticall y . Significantl y , previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversely a f fected 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.
Moreove r , the F

AA has previously granted relief from Section 91.151 specific to UAS, in circumstances simila r , in all material respects, to those presented herein (e.g. Exemption Nos. 88 1 1, 10808, 10673, 1 1042, 1 1062, 1 1063, 1 1064, 1 1065,
1 1066, 1 1067, 1 1080, 11 109, 111 10, 11 136, 11 138, 11 150, 11 153, 11 156, 11 157,
11 158, 11 159, 11 160, 11 161).30

F. 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) W ould Not Adversely Affect Safet y

. In seeking this exemption, Thomas A. Reeder submits that the equivalent lev el 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 Thomas A. Reeder will use trained technicians to perform main tenance, 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 and the DJI Phantom 3 Quadcopter Instruction Manual). Furth ermore, Thomas A.
Reeder will document and maintain all maintenance records for the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS.
Since the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will be inspected as prescribed by the operating documents, Thomas A. Reeder 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 a f fect safety because Thomas
A. Reeder will use trained technician s 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 Sec tions 91.407, 91.417(a) and 91.417(b), because all
maintenance of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Sig nificantl y , previous exemptions granted by the F AA 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 a f fected when the technical characteristics and operating
limitations of the UAS are considered.31

In consideration of Thomas A. Reeder ’ s proposed operating limitations, the operating documents, and the technical aspects of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS, Thomas A. Reeder submits that safety will
not be a dversely a f fected by granting exemption from 14 C. F .R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).
The F AA has previously granted relief specific to UAS in circumstances simila r , in
all material respects, to those pres ented herein (e.g. Exemption Nos. 1 1062,
1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 111 10, 111 12, 11 136, 11 138,
11 150, 11 153, 11 156, 11 157, 11 158, 11 159, 11 160, 11 161).

G. The F AA May Prescribe Any Other Conditions For Safe Operation.

In accorda nce with Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA) and 14 C. F .R. § 21.16 entitled Special Conditions, Thomas A.
Reeder requests that the F AA prescribe special conditions for the intended operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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. 1 13(a) & (b), 91.7 (a), 91.121, 91.15 1(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 U A ’ s for the limited purpose of conducting aerial video and photography over certain areas of the United States for compens ation 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 furthe r , provides the authority for such UAS to operate

w ithout 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 and the DJI Phantom 3 Quadcopter 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 unusual32

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:
If the F AA 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 fea ture of the aircraft, aircraft engine or propelle r , he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 1 1 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the F

AA 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 F AA may prescribe sp ecial conditions for Leading Edge ’ s intended operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 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. 1 13(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 Registe r , stating: The
Rules From W hich Thomas A. Reeder Seeks Exemption:
Thomas A. Reeder seeks exemption from the requirements of 14 C. F .R Sections
61. 1 13(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 Thomas A. Reeder Seeks: This exemption will permit Thomas A. Reeder to commercially operate an
Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.33

VIII. A ny Additional Information, V iews, Or Arguments A vailable T

o Support Thomas A. Reeder ’ s Request. This Petition is made pursuant to the F AA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of T ransportation to determine if certain UAS may operate safely in the NAS. As such, Thomas A. Reeder ’ s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14
C. F .R. Part 1 1, as set forth above.
FMRA Section 333 sets forth the requirements for consid ering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to
national security; and furthe r , provides the authority for such UAS to operate without
airworthiness certification. As discussed in detail above, T homas A. Reeder will operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national
securit y

.

CONCLUSION As set forth herein, Th omas A. Reeder seeks an exemption pursuant to 14 C. F .R. §
1 1.61 and Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS commerciall y , without a n airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the F AA Administrator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Thomas A. Reeder to safel y , efficientl y , and economically operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS commercially within the NAS.34

WHEREFORE, in accordance with the Federal A viation Regulations and the F AA
Modernization and Reform Act of 2012, Section 333, Thomas A. Reeder respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C. F .R Sections 6 1. 1 13(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
Thomas A. Reeder to operate the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS commercially for the purpose of conducting a erial video and photography over certain areas of the United States.

Date: February 23, 2016

Respectfully submitted, Thomas A. Reeder 5 Partridge Run Hampton, NJ 08827 201

- 852

- 2047 treeder651@gmail.com