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SUPlER~AP 

November 9, 2015 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue, SE 

West Building Ground Floor, Room Wl2-140 

Washington, DC 20590 

Re: Petition for Exemption of Switch, Ltd. 

Dear Sir or Madam, 

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Enclosed for filing is the original of Switch's Petition for an Exemption Seeking Relief 

from the Requirements of Title 14 ofthe Code of Federal Regulations Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

Concerning Commercial Operation of a DJI Inspire 1 Unmanned Aircraft Systems Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (Public Law 112-95), which 

was filed online today, November 9, 2015. 

Should you have any questions regarding this filing, please feel free to contact me at 

(702) 522-5397. 

Enclosure 

7135 SOUTH DECATUR BLVD • LAS VEGAS, NEVADA 89118 • 702.444.4000 • supernap.com 
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UNITED STATES OF AMERICA DEPARTMENT 

OFTRANSPORTATION FEDERALAVIATION 

ADMINISTRATION WASHINGTON, DC 

Regulatory Docket No. ______ _ 

IN THE MATIER OF THE PETITION FOR EXEMPTION OF: 

Switch, Ltd. 

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 DJIINSPIRE 1 UNMANNED 

AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

1 

Submitted on October~ 2015 

Switch, Ltd. 

Rob Roy, Chairman and CEO 

7135 South Decatur Blvd. 

Las Vegas, Nevada 

(702) 444-4000 

TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS .................................................................................................................... 3 

SUMMARY .................................................................................................................................................... 4 

INTRODUCTION AND INTERESTS OF THE PETITIONER ................................................................................ 4 

BACKGROUND .............................................................................................................................................. 4 

BASIS FOR PETITION ..................................................................................................................................... 4 

A. Name And Address Of The Petitioner ............................................................................................. 6 

B. The Specific Sections of 14 C.F.R. From Which Switch Seeks Exemption ....................................... 6 

C. The Extent Of Relief Switch Seeks And The Reason Switch Seeks The Relief ................................. 9 

D. The Reasons Why Granting Switch Request Would Be In The Public Interest ............................. 11 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety ........................ 12 

F. The Rules From Which Switch Seeks Exemption ........................................................................... 22 

G. Any Additional Information, Views, Or Arguments Available To Support Request ..................... 22 

CONCLUSION ............................................................................................................................................... 22 

APPENDICES •.............................................................................................................................................. 23 

APPENDIX- A: DJIInspire 1 Technical Specifications ........................................................................... 24 

APPENDIX- B: DJIInspire 1 Manufacturer's User Manual ................................................................... 25 

APPENDIX- C: DJIInspire 1 Manufacturer's Maintenance Manual ..................................................... 26 

APPENDIX- D: DJIInspire 1 Manufacturer's Safety Guidelines ····················:······································27 

2 
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AGL 

AOI 

ATC 

ATO 

AV 

_) CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot in Command 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

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SUMMARY 

Switch, Ltd. ("Switch") 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 an 

unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Switch to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video surveillance and videography of its data center campuses 

and the immediately surrounding areas to give its campuses an additional layer of physical security both 

during construction and normal operations. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Switch designs, builds, and operates ultra-secure, ultra-resilient in which its clients store their mission 

critical data and computing systems. Switch's SUPERNAP facilities are the first and only carrier neutral 

colocation data centers to be certified Tier IV Gold in Operations by the Uptime Institute, and are also 

certified Tier IV Gold in the Design and Facility categories. As part of its commitment to essentially 

eliminating risk for its clients, Switch's facilities have 24/7 on-site fire safety and security staff, all of whom 

are employed by Switch. The objective of Switch's proposed aerial surveillance and video operations is to 

augment Switch's security presence by enhancing its ability to monitor its datacenters and perimeter 

areas. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 UAS 

Switch seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 

1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizes electronic tablet or smart phone systems (the Proposed UA is referred to herein as the "Proposed 

118," and together with the other system components, the "Proposed UAS"). The Proposed UA has a 

maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 

11.8 inches, and a maximum speed of approximately 42 knots. The proposed UA is equipped with four 

main rotors, which are driven by Lithium Polymer battery powered electric motors. 

The Proposed UA 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. 

BASIS FOR PETITION 

Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FMRA, Section 

333, Special Rules for Certain Unmanned Aircraft Systems, Switch hereby petitions the Administrator to 

commercially operate the Proposed UA in the National Airspace System (NAS), and for an 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). 

(1) In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Switch's proposed operation of the Proposed UA meets the 

conditions of FMRA Section 333 and will not require an airworthiness certificate in accordance with 

4 

14 C.F.R. Part 21, Subpart H. Accordingly, Switch requests relief from Sections 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. 

Switch submits that the requested relief is proper because Switch will ensure an equivalent level of 

safety. Switch will use experienced personnel or 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 applicable Instruction Manual(s)), 

and will document and maintain all maintenance records for the Proposed UA. 

(2) Switch also requests relief from certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges and limitations: Pilot in command, to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the Proposed UA in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

(3) Switch further seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

Proposed UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Switch submits that it will ensure that the Proposed UA is in an airworthy 

condition prior to every flight by confirming that the Proposed UA is in compliance with the 

operating documents (i.e., Monthly Maintenance Log and applicable Instruction Manual(s)), and 

that the aircraft are in a safe condition for flight. 

(4) Switch also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the Proposed UA will not have a typical barometric altimeter onboard. However, 

altitude information of the Proposed UA will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the UA to 

the GCS for active monitoring of the flight path. This altitude information, combined with Switch's 

operation of the Proposed UA within visual line of sight, at or below 500 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. 

(5) Finally, Switch seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Switch submits that safety will not be affected by 

operation of the Proposed UA during daylight hours under VFR in VMC conditions with enough 

battery power to fly for a total duration of approximately 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly for at least an additional4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Switch provides the following information in support of its petition for 

exemption: 

5 

A. Name and Address of the Petitioner. 

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

Switch, ltd. 

Adam Kramer, VP Strategy 

7135 South Decatur Boulevard 

las Vegas, Nevada 89118 

Phone: (702) 267-6695 

Email: adam@supernap.com 

With a copy to: 

Switch, ltd. 

Attn: legal Department 

7135 South Decatur Boulevard 

las Vegas, Nevada 89118 

Phone: (702) 444-4000 

Email: switchlegal@supernap.com 

B. The Specific Sections of 14 C.F.R. from Which Switch Seeks Exemption. 

1. Switch seeks an exemption from the requirements of sections 61.113(a) & (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

prescribe the following, in relevant part: 

(a) 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. 

(b) 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. 

2. Switch seeks an exemption from the requirements of section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Switch seeks an exemption from the requirements of section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

6 

... 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating-

(1) Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of 

an appropriate available station; or 

(iii) 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. 

4. Switch seeks an exemption from the 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 o flight in o rotorcraft under VFR conditions unless 

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

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

speed, to fly after that for at least 20 minutes. 

5. Switch seeks an exemption from the requirements of section 91.40S(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or 

operator of an aircraft-

(a) Shall have that aircraft inspected 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[.] 

6. Switch seeks an exemption from the 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 a person authorized under 

§ 43. 7 of this chapter[.] 

7. Switch seeks an exemption from the requirements of sections 91.409(a)(1) & (2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

7 

(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. 

8. Switch seeks an exemption from the requirements of sections 91.417(a) & (b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state 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 this section: 

(1) Records of the maintenance, preventive maintenance, and alteration 

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 date of completion 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. 

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(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. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(l) 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 the 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. 

C. The Extent of Relief Switch Seeks and the Reason Switch Seeks that Relief. 

1. Switch seeks relief from sections 61.113(a) & (b) relating to pilot qualification to 

the extent necessary to conduct the proposed UAS operations. 

Switch seeks relief from Section 61.113{a) and {b) entitled Private pilot privileges and limitations: Pilot in 

command, to the extent necessary to allow a PIC holding a private pilot or higher level certificate and a 

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 because the limitations set forth in section 61.113(a) and (b) state 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 more fully throughout this Petition, Switch will maintain an equivalent level of safety because 

no PIC will be allowed to operate the Proposed UAS unless that PIC has met certain flight-hour and 

currency requirements and demonstrated that the PIC is able to safely operate the Proposed UAS in a 

manner consistent with the operational specifications described in this application for exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures. Further, Switch submits that all operations of the Proposed UAS 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Switch business; and 

{2) will not carry passengers or property for compensation or hire. 

9 

2. Switch Seeks Relieffrom Section 91.7(a) to allow Switch to determine the UAS's 

airworthiness based on compliance with the UAS operating documents. 

Switch seeks relief from Section 91.7(a) to allow it to determine that the Proposed UAS is in airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating documents 

(i.e., the Switch UAS Operations Manual, Monthly Maintenance Log, and DJIInspire 1 Instruction Manual). 

Switch also seeks the requested relief because the Proposed UA does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Under the requested exemption, Switch will be able to ensure that the Proposed UA is in airworthy 

condition based upon its compliance with the operating documents prior to every flight, and further, 

determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below. 

3. Switch seeks relief from section 91.121 to allow flight operations utilizing a barometric pressure 

sensor, GPS, and radio communications telemetry data for altitude information. 

Switch seeks relief from Section 91.121, entitled Altimeter settings, to the extent required to allow flight 

operations of the Proposed UAS, which utilizes a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station. Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control in feet above ground level, Switch seeks the requested relief because the 

Proposed UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the Proposed UA 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 on the headsup display of the GCS. 

4. Switch seeks relief from Section 91.151(b) to accommodate flight time limitations 

associated with the UAS battery power systems. 

Switch seeks relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered Proposed UA during daylight 

hours in visual meteorological conditions, under VFR, for a total duration of 13.5 minutes to the first point 

of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Switch 

seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered Proposed UA will severely constrain the practicality of Switch's proposed use in 

monitoring its facilities pursuant to this Petition. 

The technical specifications of the Proposed UAS, the DJI Inspire 1 operating documents, and Switch's 

proposed operating limitations, demonstrate that Switch can safely operate the battery powered Proposed 

UA during daylight hours in visual meteorological conditions (VMC), under VFR, and with enough battery 

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. 

10 

5. Switch seeks relief from sections 91.40S(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b) because the proposed UAS does not require an airworthiness 

certificate 

Switch seeks relief from sections 91.405{a), 91.407{a){1), 91.409{a){1) & (a){2), and 91.417{a) & (b) because 

those sections only apply to aircraft with an airworthiness certificate and the Proposed UA meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. Notwithstanding this 

request for exemption, Switch will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS 

operating documents {i.e., the Switch Aerial Operations Manual, Monthly Maintenance Log, and DJIInspire 

1 Instruction Manual). Furthermore, Switch will document and maintain all maintenance records for the 

Proposed UAS. 

D. The Reasons Why Granting Switch's Request is in the Public Interest. 

Granting the present Petition will further the public interest by allowing Switch to safely, efficiently, and 

economically perform aerial surveillance and videography of its data center campuses, thereby further 

enhancing the security of those data centers and the customer and end-user data housed within them. 

Notably, because Switch's proposed flight operations focus on monitoring of Switch's own property and 

the boundaries of that property, the proposed operations do not implicate any privacy issues. 

1. The public will benefit from decreased congestion of the NAS. 

The Proposed UA are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to aerial surveillance and obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of the 

Proposed UAS would reduce the amount of manned aircraft in the NAS, minimize noise and air pollution, 

and increase the safety of life and property both in the air and on the ground. Additionally, by reducing the 

number of manned aircraft operating in the NAS, the exemption will reduce congestion on and around 

airports associated with arriving and departing aircraft. The Proposed UA does not require an airport to 

takeoff or land. Likewise, reducing the number of manned aircraft conducting aerial surveillance and 

videography operations will ease the strain on air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The public will benefit from the safety and efficiency of the Proposed UAS. 

Conducting aerial surveillance and videography with the Proposed UAS instead of manned aircraft will also 

benefit the public by drastically reducing the levels of air and noise pollution in comparison to those 

generated during traditional aerial surveillance and videography flight operations. The Proposed UAS uses 

batteries to power its electric motors and as a result does not produce any air pollution. It is the most 

viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

aircraft that are typically utilized for such flight operations, which burn approximately 20-30 gallons per 

hour of leaded aviation fuel. While reducing the carbon footprint of aerial acquisitions, the battery powered 

electric motors Proposed UA also virtually eliminate noise pollution. 

Using the Proposed UAS to perform flight operations, will also substantially reduce or completely eliminate 

the risk to life and property in the air and on the ground associated with traditional manned aircraft flight 

operations. Aside from absence of flight crew members onboard the aircraft, the Proposed UA (weighing 

approximately 6 pounds 7.5 ounces, at maximum gross weights with length of 17.3 inches, width of 17.7 

inches, and with no fuel on board), presents far less potential for collateral damage to life and property on 

11 
.. 
the ground, and in the air, compared to the type of manned aircraft that typically conduct similar 

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 

34 feet, and a fuel capacity of 180 gallons). 

3. Performing aerial surveillance and videography operations with the Proposed UAS will 

benefit the. economy. 

In addition to being safe and efficient, the Proposed UAS is an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the Proposed UAS will allow United 

States based companies, like Switch, to remain competitive and contribute to growth of the U.S., state, and 

local economies. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must 

adopt new and alternative technology in order to remain competitive. The battery powered Proposed UA 

is one such technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides that flexibility without the high operating costs of a traditional manned aircraft. 

Technology like the Proposed UAS, allows companies like Switch to further leverage their competitive 

advantages and remain profitable leading to greater job stability for employees and contractors, and 

ultimately to the growth of the U.S. and local economies. Improved financial performance of U.S. 

companies, through commercial use of technology like the Proposed UAS also contributes to a stable 

workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies like Switch to invest in research and development in order to protect and expand on their 

competitive advantages both in the United States and abroad. 

4. The proposed operations do not present any privacy issues. 

Switch's operation of the Proposed UAS will not implicate any privacy issues. Specifically, the Proposed 

UAS will be operated only in compliance with operating documents (i.e., the Switch Aerial Operations 

Manual, Monthly Maintenance Log, and OJI Inspire 1 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. Moreover, Switch's 

proposed operations will take primarily on Switch's own property and the immediately surrounding areas. 

E. 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 Switch Seeks Exemption. 

1. The Proposed UAS meets the conditions of the FAA Modernization and Reform Act of 

2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, Switch's operation of the Proposed UAS meets the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 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. Specifically, FMRA Section 333 states the following, in part: 

(a) In Generai.--Notwithstanding any other requirement of this subtitle, and 

not later than 180 days after the date of enactment of this Act, the 

12 

Secretary af Transportation shall determine if certain unmanned 

aircraft systems may operate safely in the national airspace system 

before completion af the plan and rulemaking required by section 332 

af this Act ar the guidance required by section 334 of this Act. 

(b) Assessment af Unmanned Aircraft Systems.--ln making the determination 

under subsection (a), the Secretary shall determine, at a minimum-

(1} which types of unmanned aircraft systems, if any, as a result af their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight da not 

create a hazard ta users af the national airspace system or the public 

or pose a threat to national security; and 

(2} whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph {1}. 

(c) Requirements for Safe Operation.--lf the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Switch submits that the Proposed UAS can operate safely in the NAS pursuant 

to FMRA Section 333, as demonstrated by: (a) the characteristics of the Proposed UAS; (b) the pilot 

certification requirement; and (c) the specific operating limitations identified in this Petition and by the FAA 

in granting the Petition. 

a. The specifications of the Proposed UAS demonstrate its safe characteristics. 

The Proposed 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. 

i. Technical specifications of the Proposed UAS. 

The technical specifications of the Proposed UAS are set forth by the DJI Inspire 1 Technical Specifications, 

attached hereto as Appendix A. 

ii. The Proposed UAS's autonomous flight and navigation modes enable the UAS 

to remain within a defined operational area. 

The Proposed UAS may be operated in both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the Proposed UAS is provided at pages 45-50 of the DJI 

Inspire 1 User Manuals, attached hereto as Appendix B. 

iii. The Proposed UA is designed for automatic return to the home point in the 

event of a loss of the control link or navigation. 

13 

When the Control Link is lost, the Proposed UA will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the Proposed UA does not reacquire control link data from the GCS, it will assume that the 

Control Link is lost and return to the home position (i.e., failsafe mode) via GPS, descend to the takeoff 

position, and shut down. A complete description of the DJI Inspire 1 's Failsafe Functions are set forth at 

pages 13 through 15 in the attached DJI Inspire 1 User Manual. 

iv. The Proposed UAS's GCS and its operation. 

A complete description of the operation and specifications of the Proposed UAS's GCS and flight control 

software is provided at pages 40 through 47 of the attached DJI Inspire 1 User Manual. 

b. Flight operations with the Proposed UAS will be limited to those within line of 

sight of a certificated pilot in command with a safety observer. 

Switch will only utilize certificated operators to act as a pilot in command {PIC) of the Proposed UAS, and 

will utilize a safety observer to assist pilots during all flight operations. 

c. Flights of the Proposed UA will be conducted pursuant to specific operating 

limitations. 

In seeking this exemption, Switch proposes to commercially operate the Proposed UAS for the special 

purpose of conducting aerial surveillance and videography over certain areas of United States, primarily 

its own property, pursuant to the following specific operating limitations: 

·1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, which is a rotorcraft UAS weighing less 

than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial surveillance and videography of Switch's private property and, to the 

extent Switch has permission of the property owner to conduct such operations, of 

other private property. 

3. The UA may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be 

in feet AGL. 

5. The UA must be operated within visual line of sight {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, as specified on the PIC's FAA-issued airman medical certificate. 

6. The use of first person view by the PIC or safety observer is not permitted. 

14 

7. All operations must utilize a safety observer. The SO may be used to satisfy the VLOS 

requirement 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. 

8. 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. 

9. 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 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. 

10. 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. 

11. 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. 

12. 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. 

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must 

15 

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. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass airman medical certificate. The PIC must also meet 

18. The operator may not permit any PIC to operate the UAS 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. 

19. 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. Jf flight at night 

is required, a special request will be made at the FAA office closest to proposed area 

of operations. Flights under special visual flight rules are not authorized. 

20. 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. 

21. 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. 

22. 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. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

16 
•, 
24. 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. 

25. The operator must obtain an Air Traffic Organization issued Certificate of Waiver or 

Authorization prior to conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOT AM) not more 

than 72 hours in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements in the COA 

including class of airspace, altitude level and potential transponder requirements. 

26. 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the requirements of the Federal Communications 

Commission and other applicable government agencies. 

28. The documents required under 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. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. 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 except in the following circumstances: 

a. 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; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or 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; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per§ 91.119(a). 

17 

32. 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. 

33. 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. 

~. Reasons why an exemption from the requirements of section 61.113(a) & (b) would not 

adversely affect safety. 

Switch submits that the equivalent level of safety established by sections 61.113(a) & (b) will be 

maintained because no PIC will be allowed to operate the Proposed UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

Proposed UAS in a manner consistent with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Switch's proposed area of operations, and the operating limitations set forth above, the 

parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot 

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

Proposed UAS, Switch submits that the additional manned airmanship experience of a commercially 

certificated pilot does not correlate to the airmanship skills necessary for Switch's specific proposed flight 

operations. 

The FAA has previously granted relief from sections 61.113(a) & (b) 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, 11158, 11159, 

11160, 11161, 11812). 

Switch will not allow any PIC to operate the Proposed UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the Proposed UAS training and currency requirements, that the PIC 

is able to safely operate the Proposed UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. More 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 have accomplished 3 takeoffs and landings 

in the preceding 90 days (for currency purposes). 

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

with applicable regulations will ensure an equivalent level of safety during Switch's proposed operations. 

The Administrator has held that prior documented flight experience obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows: 

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 

18 

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 ond 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 ond 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. 

In sum, Switch's proposed UAS flight operations will ensure a level of safety equivalent to sections 

61.113(a) & (b) by not allowing any PIC to operate the Proposed UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

Proposed UAS in a manner consistent with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons why an exemption from the requirements of section 91.7{a) will not adversely 

affect safety. 

Switch's proposed flight operations will maintain the equivalent level of safety established by Section 

91.7(a) because prior to every flight Switch will ensure that the Proposed 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. 

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. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161, 11812). 

4. Reasons why an exemption from the requirements of section 91.121 would not 

adversely affect safety. 

Switch's proposed flight operations will maintain a level of safety equivalent to that established by Section 

91.121 because the altitude information from the Proposed UA 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 Switch's 

operation of the Proposed UA within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed 

19 

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, 

11812). 

5. Reasons why an exemption from the requirements of section 91.151(b) would not 

adversely affect safety. 

An equivalent level of safety to that established by 14 C.F.R. Section 91.151 (b) would exist under a grant 

of this exemption due to (1) the technical specifications of the Proposed UAS; {2) the limitations on the 

proposed flight operations; and {3) the location of the proposed flight operations. Accordingly, Switch will 

ensure that it will safely operate the battery powered Proposed UA during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

As in Exemption Nos. 11109 and 11812, the technical specifications of the Proposed 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). Safety will also be ensured as the Proposed UAS 

provide audible and visual warnings to the PIC at the GCS when the UA 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 Proposed UAS will descend and land 

automatically. 

Previous exemptions granted by the FAA concerning Section 91.151 demonstrate that safety is not 

adversely affected when the technical characteristics and operating limitations of the Proposed 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 in this Petition (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, 11812). 

6. 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. 

Switch 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 also be met because Switch 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., the Monthly Maintenance Log and the OJI Inspire 1 

Instruction Manual). Furthermore, Switch will document and maintain all maintenance records for the 

Proposed UAS. A copy of the OJI Inspire 1 User Manuals is attached hereto as Appendix B; a copy of the 

Proposed UAS Maintenance Manual and Maintenance Log is attached hereto as Appendix C and E, 

respectively. 

20 

Switch will also ensure that it maintains a level of safety equivalent to that established by Sections 91.407, 

91.417(a) and 91.417(b), because all maintenance of the Proposed UAS will be performed by trained 

technicians. Such maintenance will be documented using the monthly maintenance log. 

The FAA has previously granted exemptions concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), which shows that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. In consideration of Switch's proposed 

operating limitations, the operating documents, and the technical aspects of the Proposed UAS, Switch 

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). Consequently, 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, 

11150,11153,11156,11157,11158,11159,11160,11161,11812). 

7. The FAA may prescribe any other conditions to ensure safe operation. 

In accordance with Section 333 of the FMRA and 14 C.F.R. § 21.16 entitled Special Conditions, Switch 

requests that the FAA prescribe special conditions for the intended operation of the Proposed UAS, which 

contain such safety standards as 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 UAs for the limited purpose of conducting aerial video and photography over 

certain areas of the United States in association with Switch's business. 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, as well as 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 Proposed 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 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 navel ar unusual design feature af 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 Switch's intended operation of the Proposed 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). 

21 
'· 
F. A Summary that can be Published in the Federal Register, stating the Rules from which 

Switch seeks exemption: 

Switch 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 Switch seeks: 

This exemption will permit Switch to commercially operate an Unmanned Aircraft System (UAS) for the 

purpose of conducting aerial surveillance and videography over privately-owned property on which it 

operates data centers. 

G. Any Additional Information, Views, or Arguments Available to Support Switch's Request. 

This Petition is made pursuant to FMRA Section 333, which directs the Secretary of Transportation to 

determine if certain UAS may operate safely in the NAS. 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 poses a 

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

airworthiness certification. As discussed in detail above, Switch will operate the Proposed 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. As such, Switch's request for exemption should be granted pursuant to FMRA Section 333 and 14 

C.F.R. Part 11. 

CONCLUSION 

As set forth herein, Switch seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FMRA, 

which will permit safe operation of the Proposed UAS commercially, without an airworthiness certificate, 

for the limited purpose of conducting aerial surveillance and videography over certain areas of the United 

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the 

FMRA, while also advancing the interests ofthe public. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of 2012, Section 333, Switch 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 Switch to operate the 

Proposed UAS commercially for the purpose of conducting aerial surveillance and videography over 

certain areas of the United States in connection with Switch's data center business. 

Dated: October .:30 2015 

Respectfully submitted, 

t:iov _, 

Chairman and CEO 

Switch, Ltd. 

APPENDICES 

APPENDIX- A: DJIInspire 1 Technical Specifications 

APPENDIX- B: DJIInspire 1 Manufacturer's User Manual 

APPENDIX- C: DJIInspire 1 Manufacturer's Maintenance Manual 

APPENDIX- D: DJIInspire 1 Manufacturer's Safety Guidelines 

23 

. APPENDIX- A: DJIInspire 1 Technical Specifications 

24 

APPENDIX- A: OJIInspire 1 Technical Specifications 

Envision will only utilizes safe and reliable UAS. DJI is an industry leader in small UAS production. DJI 

UASs are loaded with ground breaking software enabling the user to set parameters which will not allow 

flight into controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, 

DJI software provides real-time altitude and location information to the P!C via the linked monitor 

(smart phone/tablet devices) 

DJ/ Inspire 1 -Aircraft 

Model 

Weight (Battery Included) 

Hovering Accuracy (GPS Mode) 

Max Angular Velocity 

Max Tilt Angle 

Max Ascent Speed 

Max Descent Speed 

Max Speed 

Max Flight Altitude 

Max Wind Resistance 

Max Flight Time 

Motor Model 

Propeller Model 

Operating Temperature Range 

Dimensions 

DJI Inspire 1 -Gimbal 

Model 

Output Power (with camera) 

Operating Current 

Angular Vibration Range 

Mounting 

Controllable Range 

Mechanical Range 

Max Controllable Speed · 

DJI Inspire 1 -Camera 

Name 

Model 

Total Pixels 

Effective Pixels 

Image Max Size 

ISO Range 

Field of View 

CMOS 

HD Video Recording 

TGOO 

Glbs 7.5291oz (2935g) 

Vertical: O.Sm; Horizontal: 2.Sm 

Pitch: 300°/s; Yaw: 150°/s 

35° 

Sm/s 

4m/s 

22m/s (A Til mode, no wind- NOT RECOMMENDED) 

4500m 

10m/s 

Approximately 18 minutes 

DJI3510 

DJI1345 

14°F to 104°F (-10°C to 40°C) 

17 W' X 17 %" X 12" 

ZENMUSE X3 

Static: 9W; In Motion: llW 

Static: 750mA; In Motion: 900mA 

±0.03° 

Detachable 

Pitch: -90° to +30°; Pan: ±320° 

Pitch: -125° to 45°; Pan: ±330° 

Pitch: 120°/s; Pan: 180°/s 

X3 

FC350 

12.76M 

12.4M 

4000x3000 

100-3200 

94° 

Sony EXMOR 1/2.3" 

UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30 

FHD:1920x1080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/S0/60 

Operating Temperature Range 

OJ I Inspire 1 -Transmitter 

Name 

Operating Frequency 

Communicating Distance (unobstructed) 

Output Power 

Operating Temperature Range 

Battery 

Cl 

5. 728-5.850GHz; 2.400-2.483GHz 

2000m 

9W 

14°F to 104°F (-10°C to 40°C) 

600mAh liPo 25 

APPENDIX- 8: OJ I Inspire 1 Manufacturer's User Manual 

' 

25