1

United States of America 

Department of Transportation

Federal Aviation Administration 

Washington DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

THOMAS A. REEDER

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 

AND 

DJI PHANTOM 3 PROFESSIONAL QUADCOPTER

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

112-95)

submitted on February 23, 2016

Thomas A. Reeder

5 Partridge Run

Hampton, NJ 08827

201-852-2047

treeder651@gmail.com
2

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 THOMAS A. REEDER

SEEKS EXEMPTION..............................................7

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

THOMAS A. REEDER SEEKS THE RELIEF..........................11

REASONS WHY GRANTING THOMAS A. REEDER’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 THOMAS A. REEDER’S REQUEST................29

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

APPENDICES.........................................................................31
3

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
4

SUMMARY

Thomas A. Reeder 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 Thomas A. Reeder to operate an UAS for the commercial purpose of 

conducting aerial video and photography for real estate, golf courses, construction 

companies, special events, film sets, landscaping and weddings over certain areas of 

the United States.

INTERESTS OF THE PETITIONER

Thomas A. Reeder 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 experience working for Golf Course Construction Companies, owning 

Architectural Sheet Metal and Alucobond Panel Companies and working in the 

Restaurant/Banquet Service Industry. Thomas A. Reeder has over 35 years of 

recreational/hobby experience in RC Aircraft 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 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 operation
5

Background

UAS: Parrot Bebop Drone

Thomas A. Reeder 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 1 pound, while having a length of 12.6 inches, a width if 11 

inches and a height 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 

takeoff and landing (VTOL) 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 pounds, while having a length of 18 inches, a 

width if 13 inches and a height of 8 inches and a maximum speed of approximately 32 

knots. The DJI Phantom 3 Quadcopter is equipped with four main rotors driven by 

lithium polymer battery powered electric motors.

The DJI Phantom 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 and registration marking.
6

BASIS FOR PETITION

Petitioner, Thomas A. Reeder, 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 and the DJI Phantom 3 Quadcopter 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, Thomas A. Reeder’s operation of the Parrot Bebop Drone UAS and the 

DJI Phantom 3 Quadcopter 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, 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 these 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 experienced personnel or 

technicians to perform 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 Manuals). 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 61.113(a) & (b), entitled Private Pilot 

privileges and limitations: Pilot in Command, is required by Thomas A. Reeder to the 

extent 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 and the DJI Phantom 3 Quadcopter UAS in a manner consistent with the
7

exemption, including evasive and emergency maneuvers and maintaining 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 

accordance 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 the 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 of 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. The 

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.

Additionally, Thomas A. Reeder seeks exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Thomas A. Reeder

submits that safety will not be affected by operation of the Parrot Bebop

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, Thomas A. Reeder provides the following 

information in support of its petition for exemption:
8

I. Name and Address of Petitioner.

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.com

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

61.113(a) & (b)

Section 61.113, entitled Private Pilot Privileges and Limitation: Pilot in command, 

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

aircraft.

2. A private pilot may, 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 airworthiness, subsection (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 operationa) Below 18,000 feet MSL, to—

 The current reported altitude 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 station; 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)

Section 91.151, Entitled Fuel requirements for flight in VFR conditions, 

subsection (b) states the following:

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

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

the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 20 minutes.

E. Thomas A. Reeder 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—
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 prescribed in part 43 of this chapter.

F. Thomas A. Reeder 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.

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 may 

operate an aircraft unless, within the preceding 12 calendar months, it has 

had —

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

been approved for return to service by a person authorized by 43.7 of this 

chapter; or

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

accordance with part 21 of this chapter

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 91.411 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 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.

(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.
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 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.

III. The Extent of Thomas A. Reeder seeks and the Reason Thomas A. Reeder 

Seeks the Relief.

I. Extent of Thomas A. Reeder Seeks and Reason Thomas A. Reeder 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 business or employment; and (2) the aircraft does not carry passengers or 

property for compensation or hire.

As set forth ,ore fully below, Thomas A. Reeder submits that an equivalent level 

of safety will be maintained because no PIC will be allowed 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 3 
13

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.

Further, Thomas A. Reeder submits 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 compensation 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. Reeder 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 Drone 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, subpart 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 

further, determine that the aircraft is in condition for safe flight, as stated in the 

conditions and limitations below.

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 sensor, GPS equipment, and a radio 
14

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, Thomas 

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 below. As more fully set forth herein, an 

equivalent level of safety will be maintained 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 flight 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 minutes 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 battery 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.

Significantly, as set forth below, 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’s 
15

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 

normal 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 certificate. As set forth more 

fully below, the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS 

meets the conditions of FMRA Section 333 for operation without an airworthiness 

certificate, Accordingly, Thomas A. Reeder will use trained technicians to 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 instruction 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 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 Thomas A. 

Reeder to safely, 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.

Additionally, use of the Parrot Bebop Drone and the DJI Phantom 3 Quadcopter 

UAS will decrease congestion of the NAS, reduce pollution and provide significant 
16

benefits to the economy. Notably, 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

Allowing operation of the Parrot Bebop 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 decreases 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 with 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 flight 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

Aircraft, the carbon footprint can be reduces as well.

C. 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 and the DJI 

Phantom 3 Quadcopter 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. Reeder’s, to remain competitive and 

contribute to growth U.S. economy.
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. Specifically, the Parrot Bebop Drone and the DJI Phantom 3 

Quadcopter 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.

VII. 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 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 security.

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 demonstrated 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, speed, and 

operational capability.

a) Technical 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 

Website (http://www.parrot.com/usa/products/bebop-drone/) and 

from the DJI Phantom 3 Quadcopter 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 DJI 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 flight 

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 UAS automatically return to their
19

takeoff position via GPS and defend to takeoff position and 

shutdown.

A complete 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 

observer.

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. Additionally, 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 commercially 

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 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 and the DJI Phantom 3 Quadcopter 

UAS. Proposed operations of any other 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 photography.

c) The UA’s may not be flown at an indicated airspeed exceeding 32

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 ACT.

All altitudes reported to ACT must be in feet AGL.

e) The 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 observer. the SO may be used 

to satisfy the VLOS requirements as long as the PIC always 

maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting 

is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that 

the SO can perform the functions prescribed in the operating 

documents.

h) 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.

i) 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 
21

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.

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 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.

k) 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.

l) 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.

m) The operator must follow the UAS manufacturer’s 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

n) The operator must carry out its maintenance, inspections, and 

record keeping requirements, in accordance with the operating 
22

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 against 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 operator’s qualification criteria and demonstrates the 

ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training 

sessions. During training, proficiency, and 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.

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 

conditions (VMC). If flight at night is required, a special request will 
23

be made at the FAA 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 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.

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 accordance 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 with 25% battery power remaining.

y) 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.
24

z) 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.

aa)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.

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 available 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 vehicle.

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 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;

2) The aircraft is operated near vessels, vehicles or structures 

where the owner/controller of such vessels, vehicles or 
25

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 § 

91.119(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 each 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 FAA's UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the 

National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

B. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Thomas A. Reeder submits that the equivalent level of safety established by

Section61.113(a) and (b) will be maintained because no PIC will be allowed 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 

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 pilot aeronautical 
26

knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the 

Parrot Bebop Drone and the DJI Phantom 3 Quadcopter UAS, Thomas A. 

Reeder submits that the 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 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). Thomas 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 minimum flight-hour requirements of the Parrot Bebop 

Drone and the DJI Phantom 3 Quadcopter UAS training 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 from people, vessels, vehicles and structures.

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

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

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

model of UAS to be used for operations under the exemption). In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes).

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

experience that was obtained in compliance with applicable regulations will 

ensure an equivalent level of safety during 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. 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.

Exemption No. 11138 at page 15.

Accordingly, Thomas 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 

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.
28

C. 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, Thomas A. Reeder will 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. 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).

D. 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 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 altitude 

information will be generated by GPS equipment installed onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically established by 

the UAS at ground level.

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

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

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

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
29

E. 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 and the DJI Phantom 3 Quadcopter UAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, Thomas A. Reeder will ensure that it will safely 

operate the 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 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 and the DJI Phantom 3 Quadcopter 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 and the DJI 

Phantom 3 Quadcopter 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 and the DJI Phantom 3 Quadcopter 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).
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) Would Not Adversely

Affect Safety.

In seeking this exemption, Thomas A. Reeder 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 Thomas A. Reeder 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 

and the DJI Phantom 3 Quadcopter Instruction Manual). Furthermore, 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 affect safety because Thomas 

A. Reeder 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 and the DJI Phantom 3 Quadcopter 

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.
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 adversely affected by granting exemption from 14 C.F.R. Sections 

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

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

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

11063, 11064,11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

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

G. 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, Thomas A. 

Reeder requests that the FAA 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 §§ 61.113(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 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 unusual 
32

design features of the aircraft. Section 21.16, entitled Special Conditions, states 

the following:

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

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

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

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations.

See 14 C.F.R. § 21.16.

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

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

Parrot 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 61.113(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 Thomas A. Reeder Seeks Exemption:

Thomas A. Reeder 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 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. Any Additional Information, Views, Or Arguments Available To Support

Thomas A. Reeder’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, Thomas A. Reeder’s request 

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

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

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

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

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

airworthiness certification.

As discussed in detail above, Thomas 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 

security.

CONCLUSION

As set forth herein, Thomas A. Reeder 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 and the DJI Phantom 3 

Quadcopter 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 Thomas A. Reeder to safely, 

efficiently, 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 Aviation Regulations and the FAA 

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 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 

Thomas A. Reeder to operate the Parrot Bebop Drone and the DJI Phantom 3 

Quadcopter UAS commercially for the purpose of conducting aerial 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