# DRAFT Petition for Exemption (PURSUANT to 14 CFR SECTION 11.81)

Identification of Petitioner This petition for exemption is submitted on behalf of SwingPointMedia, Inc., including its principals, Jeff Harrison and Amy Anderson (collectively referred to as “SPM”), 54102 Avenida Bermudez, La Quinta, California 92254, (760) 413-3508 (via email at sps.jdh@gmail.com ).
Company Profile SPM is the owner and operator of Small Unmanned Aircraft Systems (“SUASs”) equipped to conduct aerial photography for the motion picture and television industry for scripted closed set filming. SPM is an innovative media producer focused on providing value to small businesses seeking affordable advertising via online and television commercials utilizing aerial photography.
SPM believes that Unmanned Aircraft is truly the future direction of cutting edge media production. Unmanned Aircraft provides for an efficient, affordable, and safe way to enhance the commercials of our clients when compared to the use of helicopters or fixed wing aircraft. This efficiency and cost savings can be passed on to SPM clients, who in turn can more readily promote their business, attract new clientele and provide greater employment opportunities for local residents.

Petition Based Upon Precedence—Prior Exemption This petition is based, in part, upon prior exemption granted pursuant to, and in the matter of, Astreaus Aerial (Regulatory Docket No. FAA-2014-0352, on September 25, 2014).

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# DRAFT Description of Relief Sought SPM is seeking an exemption to operate commercially a small unmanned vehicle (55 pounds or less) in motion picture and television operations.
Petitioner Seeks the Following Exemptions SPM applies for an exemption from specific Federal Aviation Regulations (“FARs”) to allow commercial operation of its SUASs, within and under the conditions outlined in this petition, and under such other limitations as may be established by the FAA as required by Section 333 of the FAA Modernization and Reform Act of 2012, Pub. Law 112-95, 126 Stat. 11 (2012) (the “2012 Act”).
SPM requests exemptions from section of 14 CFR: part 21 (Certification), 45.23(b) (N number identification), 61.113(a) and (b) (flying for hire), 91.7(a), 91.9(b) and (2) (Airworthiness), 91.103 (preflight, airport), 91.109 (dual controls), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1) (Airframe mechanic), 91.409(a)(2) (Annual Inspections), 91.417(a), and 91.417(b) (Maintenance records), which sections are delineated as follows:

Part 21 prescribing the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals. (SPM believes relief from this section is not necessary under the statutory criteria provided in Section 333 of Public Law 112-95 [P.L. 112-95] in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS.)
Section 45.23(b)prescribing that when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters
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# DRAFT not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. (SPM believes relief from this section is not necessary as the proposed UAS is not certificated under Section 21.191 and this petition is submitted in connection with proposed operations as a Civil UAS.)
Section 61.31(a)prescribing that a person who acts as a pilot in command of any of the following aircraft must hold a type rating for that aircraft for other aircraft specified by the Administrator through aircraft type certificate procedures: (1) Large aircraft (except lighter-than-air). (2) Turbojet-powered airplanes. (3) Other aircraft specified by the Administrator through aircraft type certificate procedures. SPM believes relief from this section is not necessary under the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS. SPM, however, respectfully requests exemption of 14 CFR 61.113(a) and (b), and if granted the UAS will fully comply with the qualifications of PIC’s noted herein. Furthermore, in light of recent developments, Petitioner Amy Anderson, a skilled UA Pilot with 500 plus airtime hours dedicated exclusively to UA flying, requests leave to amend this petition should new Federal Aviation Administration rules preclude the requirements noted in 14CFR 6.113(a) and (b), for PIC’s flying UA’s.
Section 91.7(a)prescribing that no person may operate a civil aircraft unless it is in an airworthy condition. (SPM requests relief from this section by Pilot in Command (PlC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.)
Section 91.9(b)(2)prohibits operation of U.S.-registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual,

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# DRAFT approved manual material, markings, and placards, or any combination thereof. (SPM believes relief from this section is not necessary as the FAA has previously determined relief is not required provided the relevant materials published by the manufacturer are kept in a location accessible to the PIC in compliance with the regulations.)
Section 91.103(b)prescribing that a pilot shall for any flight, become familiar with runway lengths at airports of intended use, and takeoff and landing distance information. (SPM believes relief from this section is not necessary provided the PIC complies with the Proposed Conditions and Limitations set forth in this petition.)
Section 91.109(a) prescribing, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. (SPM believes relief from this section is not necessary provided the P1C complies with the Proposed Conditions and Limitations set forth in this petition or utilizes the Dll Inspire 1 UAS dual control feature.)

Section 91.119prescribing that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (SPM believes relief from this section is not necessary provided the Pilot in Command (PIC) complies with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.) (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (SPM believes relief from this section is not necessary provided the Pilot in Command (PIC) complies with the applicable

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# DRAFT operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (SPM requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.)

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure." (SPM believes relief from this section is not necessary provided the PIC complies with the Proposed Conditions and Limitations set forth in this petition.)
Section 91.151(a)prescribing that no person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after that for at least 30 minutes [emphasis added]. (SPM requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.)
Section 91.203(a)prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31(c). (SPM believes relief from this section is not necessary as the FAA has previously determined relief is not required provided the relevant materials published by

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# DRAFT the manufacturer and the Proposed Conditions and Limitations are kept in a location accessible to the PIC in compliance with the regulations.) Section 91.203(b)prescribing, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. (SPM believes relief from this section is not necessary as the FAA has previously determined relief is not required provided the relevant materials published by the manufacturer and the Proposed Conditions and Limitations are kept in a location accessible to the PIC in compliance with the regulations.)
Section 91.405(a)requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. (SPM requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.)
Section 91.407(a)(1)prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under § 43.7 of the same chapter. (SPM requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.)
Section 91.409(a) prescribing that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had .... (2) that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. (SPM requests relief from this section by Pilot in Command (PIC) compliance with the

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# DRAFT applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) Section 91.417(a) and (b)prescribing, in pertinent part, that— (a) 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. (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.

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# DRAFT (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)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 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. (SPM requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition.)
Unmanned Aircraft System (UAS) SPM intends to operate The INSPIRE1, T600 (UAS), which is specifically designed for aerial media production. The specifications of the Inspire1, T600 are as follows: Aircraft Model T600 Weight 2935gm (Battery Included) Hovering Accuracy (GPS Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35°

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# DRAFT Max Ascent Speed 5 m/s

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# DRAFT Inspire1 T600 Specifications-Continued Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude 4500 m Max Wind Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range -10° to 40° C Diagonal Distance 559 to 581 mm Dimensions 438x451x301 mm Mounting Detachable Remote Controller Name C1
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# DRAFT

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# DRAFT Inspire1 T600 Specifications-Continued Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed) 2 km EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini-HDMI Power Supply Built-in battery Charging DJI charger Dual User Capability Host-and-Slave connection Mobile Device Holder Tablet or Phone Max Mobile Device Width 170mm Output Power 9 W Operating Temperature Range -10° to 40° C Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C
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# DRAFT

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# DRAFT Inspire1 T600 Specifications-Continued Charging Temperature Range 0-40° C Battery 6000 mAh LiPo 2S Charger Model A14-100P1A Voltage 26.3 V Rated Power 100 W Battery(Standard) Name Intelligent Flight Battery Model TB47 Capacity 4500 mAh Voltage 22.2 V Battery Type LiPo 6S High voltage battery Energy 99.9 Wh Net Weight 570 g Operating Temperature Range
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# DRAFT -10° to 40° C

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# DRAFT Inspire1 T600 Specifications-Continued Storage Temperature Range Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W Battery (Optional) Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery Type LiPo 6S Energy 129.96 Wh Net Weight 670 g Operating Temperature Range -10° to 40° C Storage Temperature Range Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C
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# DRAFT

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# DRAFT Inspire1 T600 Specifications-Continued Charging Temperature Range 0° to 40° C Max Charging Power 180 W DJI Pilot App Mobile Device System Requirements iOS 8.0 or later Android 4.1.2 or later Supported Mobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. * Samsung S5, Note 3, Sony Z3 EXPERIA, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini.
The UA is specifically designed with the safety of the NAS and persons/property on the ground. The design features of the UA include an advanced Inertial Measurement Unit (IMU) incorporates both a 6-axis gyroscope and an accelerometer to monitor miniscule changes in tilt and movement. This allows the aircraft to compensate and adjust immediately, holding its position at all times.
As UA flies, its position is constantly updated and recorded using a high-strength, intelligent GLONASS + GPS system. This dual positioning system enables higher precision and quicker satellite acquisition, allowing PIC to see where the aircraft is on a live map and giving it a point to hover at when the controls are released. In additional to traditional GPS, GLONASS offers an even greater level of precision by providing even

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# DRAFT more satellites. The UAS remembers its takeoff point and dynamically tracks current position, so the PIC can bring the UA back to his/her location at the press of a button. This UA Main Controller receives thousands of bits of data every second and translates that data into action as the PIC flies the UA. The Main Controller tells every part of the UA what to do, calculates environmental conditions in real-time, and ensures that the aircraft responds the PIC’s control commands instantly.
The UA’s Electronic Speed Controllers (ESCs) handle communication between the Main Controller and the motors. The ESC’s tell each motor exactly how fast to spin and how much power to use at all times. As the PIC flies and maneuvers around, each motor moves at its own speed as calculated by advanced algorithms, providing the PIC complete control.
If the battery runs low or connection with the UA remote controller is lost, the UAS uses its positioning system and smart flight technology to return back to the PIC.

Pre-Flight Inspection, Maintenance and Repair All pre-flight inspection by the PIC, as well as maintenance and repair, shall be conducted by the UAS operator in accordance with the UA manufacturer’s user manual, safety guidelines and maintenance manual. (See attached.)
Us Radio Frequency Spectrum and Associated Equipment The UA utilizes a Radio Frequency (RF) of 5.725-927.7 GHz/2.400-2.483 GHz.
Qualifications of PIC’s Operating the UA A. PIC must possess a private pilot’s certificate and a valid third-class medical certificate. B. PIC must have accumulated and logged a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor).

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# DRAFT C. PIC must have accumulated and logged a minimum of five hours as UAS pilot with the make and model of UAS to be utilized for operations under the exemption and three take-offs and landings in the preceding 90 days.
D. The PIC must have successfully completed the qualification process as verified by manufacturer’s representative. Visual observers possessing similar skill levels will be utilized during operations to provide line- of-sight guidance (VLOS) to the PIC as an adjunct to the built in systems aboard the UA.

Medical Standards and Certification of Pic’s PIC’s directly responsible for the operation of the UAS pursuant to CFR parts 61, 67, shall maintain a Class 3 medical certificate subsequent to a flight physical obtained from a qualified Aviation Medical Examiner (AME.)

Operation of the UAS The intended operation of the UAS involves aerial photography for use in internet and television commercials in primarily remote areas, or within clearly defined boundaries relevant to a specific intended subject of the aerial photography.
Historically this type of photography has been accomplished via the use of helicopter’s holding a standard airworthiness certificate issued under 14 CFR, part 21, Subpart H. When equipped for aerial photography this type of helicopter could weigh between 5,500-6,500 pounds. Operations of this sort include an onboard pilot and crew members as needed.
The UAS weighs approximately 7 pounds fully loaded and has no onboard pilot or crew. The PIC and crew (if any) will be located remotely from the aircraft. The limited weight ofthe UAS substantially reduces any potential for harm to participating and nonparticipating persons or property in the event of any incident, fuel spillage, or fire, as the

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# DRAFT UAS carries no fuel. Additionally, the risk of injury to an onboard pilot and crew is eliminated.
When applicable to the operation, the danger of filming in close proximity to participating persons is substantially mitigated by the limited weight and size of the UAS. Traditional filming risks utilizing a helicopter in close proximity to participating persons using an FAA issued Certificate of Waiver has been historically mitigated via standard airworthiness certification under 14 CFR, part 21, Subpart H.

Operation of the UA The level of safety provided by the UA meets, or more realistically exceeds the provided by 14 CFR, part 21, Subpart H. The UA will be operational within defined boundaries specific to the subject of the aerial photography. This encompasses an area where the specific subject is located. As part of the filming process spotters will be utilized at the target location on the ground to ensure the safety of participating and non-participating persons within the defined area. Spotters will be in communication with a designated Communications Person (CP) (part of the UA crew) via two-way radio or cell phone, utilizing frequencies of non-interference to UA controls. The CP will then relate any pertinent information to the PIC. All non-participating personnel will be kept 500-feet from flight operations.
Maximum Operating Speed and Altitude The proposed maximum altitude for the UA is 400 feet, and proposed maximum speed is 22 m/s (ATTI mode, no wind.) For flight visibility, distance from hazards, etc., please see attached specifications and safety manuals.

Characteristics of the Area of Operation In accordance with statutory mandate under Section 333, the intended area of operation consists of a sparsely populated region with little or no human traffic, minimum structures, little to no electrical structures, and light business/residential.

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# DRAFT Operation Near an Airport In accordance with statutory mandate under Section 333, the intended operation in not located anywhere near a commercial or private airport.
Visual Line-of-Sight (VLOS) In accordance with Statutory mandate under Section 333(b)(1), the PIC will utilize VLOS in addition to any built-in controls on board the UA. This will be accomplished by a qualified member of the flight crew (Non-PIC) and augmented by spotters in communication with the qualified flight crew member (CP).
Pre-Flight Safety Risk Assessment In accordance with 14 CFR 91.7(b), pre-flight safety risk assessments shall be completed pursuant to guidelines contained in the manufacturer’s safety and operation manuals (Attached.)
Operations Involving Flight Standards District Office (FSDO) The UAS intends to coordinate its operations with the local FSDO with respect to any proposed aerial photography, and accordingly be guided by FSDO’s instructions.

Certificate of Waiver or Authorization (COA) The UAS intends to complete the COA application should a waiver be granted.

Public Interest and Benefit The above "aerial work" services, normally provided in manned aircraft, may be provided with increased safety and at significantly lower cost in situations where the use of unmanned UAS aircraft would supplement or replace the use of manned aircraft as a result of safety or economic considerations in certain applications where extended operational range and limited time aloft are not a factor. The proposed UAS operations will pose no threat to the public given its small size and lack of combustible fuel when

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# DRAFT compared to larger manned aircraft, minimize potential ecological affects or damage, and promote economic growth by providing data information to individuals or companies requiring aerial survey or imaging data. Additionally, the growth of the UAS industry has precipitated a large influx of "recreational" UAS pilots without formal knowledge or training regarding the effects or potential danger of UAS flight with the National Airspace System (NAS). While it is unclear what, if any, pilot certification requirements will ultimately apply to UAS pilots operating for commercial purposes under the final rulemaking process, there is a present need for training and dissemination of the applicable federal aviation regulations and flight characteristics of UAS to the general public; specifically current and potential UAS operators. UAS flight and ground demonstration and instruction for compensation utilizing the current system of certificated flight instructors provides economic incentive to accomplish the public goal of integration of both recreational and commercial UAS into the NAS while promoting safety and maintenance public awareness of current regulations affecting UAS operation. Exemptions Provide a Level of Safety Equal to or Greater than the Existing Level Under Current Regulations The use of UAS operated under the requested exemptions as set forth above have the capacity to operate with less risk of accident or injury and the associated loss of property or life while performing the same aerial work services offered in manned aircraft in certain situations where extended operational range and limited time aloft are not a factor. Likewise, UAS flight and ground demonstration and instruction for compensation promote and encourage the existing system of certificated flight instructors to participate in the public educational process utilizing UAS rather than manned aircraft. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The Inspire 1 carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated.

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# DRAFT This petition for exemption does not propose an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology. Rather the risk is mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting daytime operations only, and requiring that the UAS be operated within VLOS and yield right of way to all manned operations. Additionally, the Proposed Conditions and Limitations provide that the SPM will request a notice to airmen (NOTAM) prior to operations to alert other users of the NAS. SPM’s UAS has the capability -to operate safely after experiencing certain in-flight contingencies or failures and uses an auto-pilot system to maintain UAS stabilityaugmentation and control. The UAS is also able to respond to a loss of GPS or a lostlink event with pre-coordinated automated flight maneuvers. These safety features provide an equivalent or higher level of safety compared to a manned aircraft holding an airworthiness certificate (restricted or otherwise) performing a similar operation.

Federal Register Summary SwingPointMedia, including its pilot Amy Anderson, seeks exemption from the following regulations for the purpose of conducting flight instruction and commercial "aerial work" flight operations utilizing Unmanned Aerial Systems ("UAS") as set forth under the provisions of 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol and the following additional relief:

14 CFR Summary of Regulation FAA Consideration or Action Requested Part 21: Certification procedures for products and parts, Airworthiness Certificates Relief not necessary pursuant to prior exemption PART 61: Certification: Pilots, Light Instructors, and Ground Instructors Relief not necessary pursuant to prior exemption 1 61.31(a) Type ratings required. Relief not necessary (Section 333 of P.L. 112-95) 61.31(c) Aircraft category, class, and type ratings: Limitations on the carriage of persons, or operating for compensation or hire. Relief not necessary (Section 333 of P.L. 112-95) 2

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# DRAFT 61.31(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. Relief not necessary (Section 333 of P.L. 112-95) 2
Part 91: Standard Instrument Procedures Relief not necessary pursuant to prior exemption 1 91.7(a) Civil aircraft worthiness Relief granted in prior exemption with conditions and limitations 1 91.7(b) Civil aircraft worthiness Relief not necessary pursuant to prior exemption 1 91.9(b)(2) Civil aircraft flight manual, marking, and placard requirements Relief not necessary pursuant to prior exemption 1 91.103(b) Preflight action Relief not necessary pursuant to prior exemption 1 91.109(a) Flight instruction; simulated instrument flight and certain flight tests Relief not necessary pursuant to prior exemption 1
91.119 Minimum safe altitudes; general Relief [paragraph (c)] granted in prior exemption with conditions and limitations 1 91.121 Altimeter settings Relief granted in prior exemption with conditions and limitations 1 91.151(a) Fuel requirements for flight in VFR conditions Relief [paragraph 91.151(a)(1), day] granted in prior exemption with conditions and limitations 1 91.203(a) and (b) Civil aircraft: Certifications required Relief not necessary pursuant to prior exemption 1 91.405(a) Maintenance required Relief granted in prior exemption with conditions and limitations 1 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration Relief granted in prior exemption with conditions and limitations 1 91.409(a)(1) and (2) Inspections Relief granted in prior exemption with conditions and limitations 1 91.417(a) and (b) Maintenance records Relief granted in prior exemption with conditions and limitations 1

CONCLUSION Approval of the Petition for Exemption for SwingPointMedia should be granted for aerial photography and movie production limited to two years for movie production subject to the following provisions and restrictions:
1. Specific liability insurance coverage for remote aircraft operation shall be maintained.
2. Formal mandatory safety procedures shall be adopted and maintained to include marking and maintaining a restricted area excluding those not directly involved in

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# DRAFT operation of the remotely piloted aircraft and cameras. Those safety operations should exclude operating less than 50 feet over an open-air assembly of persons or over active railroads, roadways or highways.
3. Visual Line of Sight with the aircraft must be maintained by the Pilot in Control at all times. If VLOS cannot be maintained the aircraft must be immediately brought in and landed.
4. The Pilot in Control shall have passed an FAA “ground school” exam but shall not be required to hold a current pilot’s license or medical certificate.
5. No operation shall be above 400 feet or in any restricted airspace without specific prior clearance/approval from ATC for the location. A UAV flight plan filing may be required by the ATC so that a NOTAM may be issued.
6. An observer/spotter shall be required who is in direct communication with the Pilot in Command at all times. Communication may be by radio or by verbal communication within proximity to the Pilot in Command.
7. The remotely piloted aircraft must have automatic provision for Return to Base upon loss of remote control signal. Nothing in this restriction shall prohibit autonomous operation of the aircraft providing the Pilot in Command or UAV operator can regain direct control at any time during the automated flight.
8. The Pilot in Command must have available a (portable) transceiver capable of monitoring and communicating on aircraft frequencies (118.000 to 136.975 MHz.) if it becomes necessary.
9. At any time that the Pilot in Command must communicate with an aircraft in the area or Air Traffic Control, the transmission shall be identified by the letters “U A V” or “Unmanned Aircraft” followed by the name of the company conducting the video production.

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# DRAFT 10. The Pilot in Control be in possession of a current sector map of the area of operation (paper or electronic) in at the time of flight and must be aware of restrictions and communication frequencies applicable for that location.
11. If the designated Pilot in Command lacks sufficient specific skills to operate the UAV being used the PIC may be in direct supervision of and be fully responsible for an operator who has sufficient skills for operating (flying) the specific UAV being used.
12. Such limited operating approval may be rescinded or suspended by the FAA or NTSB in the event of an accident or if there is cause to believe any of the stated provisions have not been met or maintained. Unless otherwise specified in this grant of exemption, the UAS, the USA PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. Respectfully submitted,
SWINGPOINTMEDIA

_____________________________ Amy Anderson

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