Swift Radioplanes, LLC

726 Prescott Heights Dr.

Prescott, AZ 86301

June 26, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave. SE 

Washington, DC 20590 

Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

To Whom It May Concern, 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, 

Swift Radioplanes, LLC (the Petitioner), a licensed business in the State of Arizona, hereby applies for 

exemption from a specific list of Federal Aviation Regulations (FARs) in order to operate an Unmanned 

Aircraft System (UAS) for commercial applications within the national airspace governed by the Federal 

Aviation Administration (FAA). All flight operations will be conducted under the conditions and 

boundaries outlined herein or as established by the FAA in accordance with Section 333. 

The exemption would permit Swift Radioplanes to pursue its commercial interests by providing services 

to customers whose requirements can be satisfied with the use of UAS to capture aerial data. Swift 

Radioplanes requests these exemptions in order to perform commercial flights in the following areas:

 Surveying 

 Mapping

 Agriculture 

 Product Demonstrations

All flights will be conducted over private or controlled access property with the consent and knowledge 

of the property owner or controlling party. 

The Pilot in Command (PIC) for all flight operations conducted by Swift Radioplanes will hold at least a 

Private Pilot Certificate and current 2

nd class medical certificate. All visual observers (VO) will be trained 

to perform the duty of assisting the PIC per the observer requirements of National Policy N8900.227 

(14)(a) and (16)(e).

The Federal Aviation Regulations from which an exemption is requested: 
 14 CFR § 61.113(a)

 14 CFR § 91.7(a)

 14 CFR § 91.119(c)

 14 CFR § 91.121

 14 CFR § 91.151(a)(1)

 14 CFR § 91.405(a)

 14 CFR § 91.407(a)(1)

 14 CFR § 91.409(a)(1) & (2)

 14 CFR § 91.417(a) & (b)

THE UNMANNED AIRCRAFT SYSTEMS

Swift Radioplanes believes that UAS are an efficient, safe, and cost effective solution to the 

aforementioned areas of use. Swift Radioplanes believes that the unique nature of small UAS will offer 

an indispensable service to the public, now and in the future, and will be met will economic and 

technological growth. 

Swift Radioplanes is seeking this exemption in order to operate a Swift Radioplanes Lynx M UAS and a 

DJI S900 UAS. The Lynx M is an electric, fixed-wing system with a maximum takeoff weight (MTOW) of 

8.8 lbs. The DJI S900 is an electric, rotary-wing “hexacopter” system with a MTOW of 18 lbs. Both 

systems are controlled by the Pixhawk flight controller, manufactured by 3D Robotics, utilizing 

APM:Plane and APM:Copter firmware respectively.

The general information and system description of the Lynx M UAS, to include safety devices and failsafes, as well as the performance and system limitations, initial setup, normal procedures, emergency 

procedures, and field repair instructions are found within the Lynx M Aircraft Flight Manual and the 

Operator and Crewmember Checklist. Both documents are incorporated herewith as part of the Swift 

Radioplanes exemption application as Exhibit 1 and Exhibit 2 respectively. The attached documents are 

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

The Lynx M has been developed by Swift Radioplanes to safely and effectively perform the 

aforementioned areas of use. The system has undergone rigorous testing procedures by Swift 

Radioplanes and has been previously been approved to operate under two COAs: 2013-WSA-62 and 

2013-WSA-136. Additionally, Swift Radioplanes has already received the N-Number 501SR for a Lynx 

model with serial number 0022.

The safety features of the Lynx M and the intimate knowledge of the system that Swift Radioplanes 

holds will significantly mitigate any operational risk. 

FLIGHT OPERATIONS 

Swift Radioplanes will ensure that all operations adhere to strict standards as set below: 

 In addition to requiring a Private Pilot certificate, each PIC will have UAS specific training that 

highlights the unique aspects of operating a UAS in the National Airspace (NAS). 

 Each PIC will have Remote Control (RC) experience that will enable a wider envelope of risk 

mitigation if the Unmanned Aircraft (UA) needs to be flown manually.
 The UA will be operated at airspeeds in accordance with the Aircraft Flight Manual.

 The UA will be operated at 400 feet above ground level (AGL) and below at all times. 

 The UA will be operated within visual line-of-sight (VLOS) at all times. 

 All operations will utilize a visual observer (VO). The UA will be operated within VLOS of the PIC 

and VO at all times. 

 The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding 

traffic and other ground based obstacles. 

 Proper preflight inspections will take place before each flight in accordance with the Aircraft 

Flight Manual and the Operator and Crewmember Checklist.

 The UA may not operate within 5 nautical miles (NM) from any airport or heliport.

 The UA may not be operated below Visual Flight Rules (VFR) minimums.

 The PIC must maintain a battery reserve that allows the UA to return to a point of landing at 

normal cruise speed and land at a specific battery voltage that complies with the Aircraft Flight 

Manual.

 The UA must remain clear of and yield to all other air traffic. 

 All operations will be conducted over private or controlled-access property with prior 

permission from the property owner or controlling party.

Swift Radioplanes is confident that the knowledge of the PIC, along with the strict safety standards set 

by Swift Radioplanes, the FAA, and the physical safety properties of the UAS, will allow for safe and 

efficient operations. Swift Radioplanes hereby requests exemption under Section 333 in order to pursue 

commercial UAS applications with the intent to provide customers with safe and consistent commercial 

flight operations.

Respectfully, 

Matthew Lyon

President

Swift Radioplanes, LLC

726 Prescott Heights Dr.

Prescott, AZ 86301
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Swift Radioplanes requests exemption from the following regulations as well as any additional 

regulations found by the FAA to be necessary for UAS flight operations. 

14 CFR § 61.113(a), Private pilot privileges and limitations: Pilot in command 

This regulation limits private pilots to non-commercial operations. Unlike a conventional aircraft that 

carries a pilot, passengers, and cargo, UAS are remotely controlled and thus carry no pilot, passengers or 

freight on board. Swift Radioplanes respectfully proposes that operator requirements should take into 

account the characteristics of UAS. Swift Radioplanes also believes that a PIC with a private pilot 

certificate has sufficient skill, knowledge, and aeronautical decision making to successfully conduct 

operations. Furthermore, Swift Radioplanes does not think that a commercial pilot certificate will 

significantly improve a PIC’s performance while flying a UAS. Therefore, Swift Radioplanes asks for an 

exemption from 14 CFR 61.113(a) in order to operate commercially with the minimum of a private pilot 

certificate.

14 CFR § 91.7(a) Civil aircraft airworthiness 

As no such certificate will be applicable in the form contemplated by the FARs, this regulation is 

inapplicable.

14 CFR § 91.119(c) Minimum safe altitudes

This regulation states that over other than congested areas, an aircraft must not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Swift Radioplanes believes that, because of the 

nature of most UAS operations, an exemption is required in order to allow operation closer than 500 

feet to any person, vessel, vehicle, or structure. The UAS will be flown at an altitude allowing, if a power 

unit fails, an emergency landing without undue hazard to persons or property on the surface. Due to the 

small size of the UAS, the hazard to persons, vehicles, and structures is minimal compared to manned 

aircraft. Additionally, Swift Radioplanes believes that permitting UAS flights to 400 feet (AGL) and below

is an effective means of maintaining separation from manned aircraft. 

14 CFR § 91.121 Altimeter settings 

This regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

of a station along its route and within 100 NM of the aircraft. The UAS will always fly 400 feet AGL and 

below and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft.

Both UAS that Swift Radioplanes has petitioned to use are equipped with barometric pressure sensors 

used for maintaining and displaying flight altitudes. The sensor is calibrated as a preflight check to 

establish a ground reference altitude. Swift Radioplanes believes that this method for measuring 

altitude is sufficient for UAS operations due to their relatively small and localized areas of operation.

14 CFR § 91.151(a)(1) Fuel requirements for flight in VFR conditions 

This regulation provides that no person may begin a flight in an airplane under VFR conditions, during 

the day, unless there is enough fuel to fly to the first point of intended landing and to fly after that for at 

least 30 minutes. The intent of this paragraph is to provide a fuel reserve as a safety buffer for delays to 

landing. A literal interpretation of this regulation would drastically reduce the useful flight time of a 

fixed-wing UAS, and render most rotary-wing systems unusable. Again, Swift Radioplanes maintains that 

the local nature of UAS operations should be taken into account, and that the fuel/battery reserve 
requirements should reflect proportionally to the size of the area of operations. As both UAS are electric 

powered, the maximum flight duration of each system is limited to battery capacity. Each UAS will land 

at a specific battery voltage, per the Aircraft Flight Manual, to ensure approximately 20% of capacity 

remains. 

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(1) & (2); 417(a) & (b): Maintenance Inspections

Swift Radioplanes requests exemption from the stringent maintenance standards that are required of 

manned aircraft. Swift Radioplanes believes that, due to the mechanical simplicity, electric propulsion, 

and ease of repair of these systems, that general and preventive maintenance and field repairs can be 

performed by the PIC. Maintenance of the Lynx M UAS will be accomplished pursuant to the Aircraft 

Flight Manual, included as Exhibit 1, and provided as an attachment to the petition. Maintenance of the 

DJI S900 will be done according to the user manual. The PIC will be required to make a thorough 

preflight inspection according to the Operator and Crewmember Checklist, included as Exhibit 2. 

Additionally, the landing methods of UAS and frequent operations from field environments means that

these airframes will endure a certain level of acceptable and intentional handling that is unique to small 

UAS operations.