Swift Radioplanes, L LC 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 accordanc e 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 Regulation s (FARs) in order to operate a n Unmanned Aircraft System ( UAS) for commercial applications within the national airspace governed by the Federa l Aviation Administration (FAA). All flight operations will be conducted under the conditions and
boundaries o utlined 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 whos e requirements can be satisfied with the use of UAS to cap ture 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 w ith the consent and knowledge of the property owner or controlling party.

The Pilot in Command (PIC) for a ll fli ght 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 SYSTEM S

Swift Radioplanes believes that UAS are an efficient, safe, and cost effective solution to t he
aforementioned areas of use. Swift Radioplanes believes that the unique na ture of small UAS will offer

an indispensable service to the public, now and i n 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 s ystem with a maximum takeoff w eight (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 fail

safes, as well as the performance and system limitations, initial setup, normal procedures, emergency procedures, and field repair instructions are foun d 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 he ld in a separate file pursuant to 14 C.F.R. § 11.35(b).

The Lynx M has been developed b y 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 Radiopla nes 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 spe cific 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 envel ope of risk mitigation if the Unmanned Aircraft (UA) needs to be flown man ually. 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 operatio ns 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 prefli ght 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 Ru les (VFR) minimum s

.

 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 cle ar 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 controlli ng 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 phy sical 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 86301EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Swift Radiopl anes 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 limit s 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 op erator requirements should take into
account the characteristics of UAS. Swift Radioplanes also believe s that a PIC with a private pilot certificate has sufficient skill, knowledge, and aeronautical decision making to successfully conduct operations. Furth ermore, Swift Radioplanes does not think that a commercial pilot certificate will significantly improve a PIC’s p erformance while flying a UAS . Therefore, Swift Radioplanes ask s 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 altitu des
This regulation states t hat 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 all ow 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 mann ed 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 4 00 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 altitud es. 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 an d 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 reserverequirements 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 mechani cal simplici ty, 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

, incl uded as Exhibit 1 , and provided as an attachment to the petition. Maintenance of the
DJI S900 will be don e according to the user manual. The PIC will be required to make a thorough preflight inspection according to the Op erator and Crewmember Checklist , included as Exhibit 2

. A dditionally, the landing methods of UAS and frequent operations from field environments m eans that
these airframes will endure a certain level of acceptable and intentional handling that is unique to small UAS operations.