Paul Sweigert

6205 Providence Drive

Carpentersville, IL 60110

847-844-8491

Paulsweigert@comcast.net

7/6/2015

Hon. Michael Huerta 

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from certain parts of the FARs. 

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, 

Paul H Sweigert (or the “Petitioner”), hereby applies for a summary exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow him to operate small Unmanned Aircraft Systems (“UAS”) for aerial video and data 

collection, under the conditions and limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively inexpensive UAS under 

controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would provide safety enhancements 

to the already safe news gathering operations presently using manned helicopters and airplanes. Approval of this 

exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish 

requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act.

The name and address of the applicant:

Paul H Sweigert

6205 Providence Dr.

Carpentersville, IL 60110

847-844-8491

paulsweigert@comcast.net

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 
14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 3 

The Appendix describes the FARs from which an exemption is requested and summarizes the justification for each 

requested exemption.

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act, which directs 

the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the 

national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Administrator must determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles “may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 

333(c) (emphasis added). The Secretary has delegated his aviation authority to the Administrator of the FAA. The 

Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements 

for civil aircraft, a term defined under §40101 of the Act, which includes UASs. The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 

44702-44716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 

44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1). 

Summary of Request:

As a long time radio control pilot, I am requesting an exemption, and permission to use my UAS, DJI Flame Wheel 

450 (further in this report are the detailed specifications of the UAS), for the purpose of taking aerial photos and 

videos for the home inspection / insurance business, professional videography and for the home sales business in 

the suburbs of the greater Chicago area. This is a technology that is perfect for realtors, home inspectors and 

property owners who wish to get a better perspective of the home and or neighborhood they are interested in. 

Roof inspections for example can be done much safer than ever before. Homeowners would now have the ability 

to see video of their property from a perspective never seen before. These videos would be extremely affordable 

compared to years before.

Why the exemption would not adversely affect safety:

This can be done very safely in a controlled environment, on private property, with limited airtime required, 

extremely low noise, in uncongested areas. I fly with very short time limits (6 minutes max,) in a very small area

usually under 100 feet and always fly under the AMA guidelines.
Prior to flight,

 Verify weather conditions are favorable for safe operation, clear visibility, low or no wind. 

 Map out flying area, create flight plan

 Select a takeoff area free of obstacles mindfully of the possibility of using the “Return to Home” function, 

place UAS in a safe position on the ground for takeoff 

 Verify propellers are properly secured and not damaged.

 ensure all batteries are fully charged, UAS battery, Transmitter, FPV receiver battery

 verify there are 6 or more satellites acquired

 verbally warn of takeoff

 hover at 10 – 15 feet and verify all controls are operating properly

While in flight,

 Fly well under 400 feet.

 Always fly “line of sight”

 Never fly over people

 I am always aware of my location and have a backup plan available in case of emergency

 Use a spotter

 Monitor my battery use

While landing, 

 Make sure landing spot is clear 

 Verbally warn of upcoming landing

 Disconnect battery after landing

 Record battery usage and remaining voltage 

Description of UAS:

DJI F450 

DJI Flame Wheel 450 (F450)

 Frame Weight 282g

 Diagonal Wheelbase 450mm

 Takeoff Weight 1600g

 NAZA–M Lite flight control system, which includes Gyro, Compass, GPS.* 

 Spectrum DX6i 2.4GHz transmitter

 Orange Rx R620 DSM2 Compatible Full Range 6Ch 2.4Ghz Receiver w/Failsafe

 Action Camera 1080i mounted on a two axis gimbal. 

 FPV transmitter (5.8GHz), receiver and monitor mounted on DX6i transmitter, all of which comply with FCC 

requirements. 

* Naza M Lite safety features include the following.

 “Failsafe” function, where if signal is lost, or interference occurs with the controller, or it flies out of range, 

the UAS will automatically return to its “home” position. 

 “GPS hold- auto hover” if radio control sticks are released. 

 “Return to Home” function, if at any time you lose orientation or you are unable to finish the flight, the 

RTH system can be triggered and the UAS will fly and safely land in its original takeoff spot.

Pilot in Command (PIC) Background and experience:

I have 6 years’ experience in flying radio control airplanes, helicopters and quad copters and have about 20 hours 

of flight time using the DJI Flame Wheel F-450. I have always been an extremely responsible UAS pilot and am in 
great health. I fly UAVs every weekend and regularly train on a simulator during bad weather. Although motion 

sickness prevents me from piloting a real aircraft, I am able to experience the excitement of flight through flying 

model RC aircraft. Videography has been a long time hobby of mine and I have always had a fascination with 

aerial video. I enjoy taking aerial videos, editing them down, packaging them in a media format such as a DVD. I 

have done such videos for family members, friends and neighbors, all have been very happy with the end product. 

In the future I would like to apply for employment as a UAV pilot and I believe that getting this exemption would 

be an asset. I hold a valid driver’s license from the State of Illinois and have a clean driving record. 

Why the public would be served by granting this exemption:

I believe this new technology can help businesses perform inherently dangerous tasks in a much safer way. The 

home inspection industry for one is anxious to have this technology to enhance their ability to safely inspect 

properties; no longer would a person be required to physically walk on a roof to inspect it. In addition “Drones” are 

very popular now, especially with the younger generation; aerial wedding video for example has seen quite an 

increase in demand. I would like to play a part in these new trends. Also I believe it could potentially increase home 

sales, benefiting realtors, buyers and sellers alike. There are so many uses, to many to list.

The Petition to use a UAS for aerial data collection and its proposed limitations are similar in all material respects 

to those approved by the FAA in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket 

No. FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642) and 11310 to Colin Hinkle (see 

Docket No. FAA-2014-0608). In those grants the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the Petitioner and carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, and 11310 also apply to 

the situation presented by this Petition. 

Thank you for your consideration.

Respectfully Submitted,

Paul Sweigert
APPENDIX

FAR section Subject Justification 

14 CFR § 45.23(b) Requirement to display registration 

number on vehicle 

Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification requirements 

and procedures 

Designed for manned aircraft; not 

suitable for off-the-shelf UAS 

14 CFR § 61.3 Requirement for pilot certificate Part 61 requirements designed for 

manned aircraft, not UAS; petition 

describes training for UAS operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not 

suitable for off-the-shelf UAS 

14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew members to be 

onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls during 

flight instruction 

No one aboard to operate controls 

14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below these 

altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration and 

airworthiness certificates to be 

onboard 

No one aboard to read certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 

14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; 

will be operated below ATC radar 

coverage 

14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; not 

suitable for off-the-shelf UAS 

14 CFR § 91.407(a) (1) Inspection approval requirements Designed for manned aircraft; not 

suitable for off-the-shelf UAS 

14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not 

suitable for off-the-shelf UAS 

14 CFR § 91.417 (a) & (b) Maintenance records requirements Designed for 

manned aircraft; not suitable for offthe-shelf UAS