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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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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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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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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 91.119 prescribing 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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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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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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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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(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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Max Ascent Speed

5 m/s

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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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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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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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-10° to 40° C

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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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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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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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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 of 

the 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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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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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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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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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 stability 

augmentation 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 

exemption1

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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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 

exemption1

91.7(a) Civil aircraft worthiness Relief granted in prior exemption with 

conditions and limitations1

91.7(b) Civil aircraft worthiness Relief not necessary pursuant to prior 

exemption1

91.9(b)(2) Civil aircraft flight manual, marking, 

and placard requirements

Relief not necessary pursuant to prior 

exemption1

91.103(b) Preflight action Relief not necessary pursuant to prior 

exemption1

91.109(a) Flight instruction; simulated 

instrument flight and certain flight 

tests

Relief not necessary pursuant to prior 

exemption1

91.119 Minimum safe altitudes; general Relief [paragraph (c)] granted in prior 

exemption with conditions and limitations1

91.121 Altimeter settings Relief granted in prior exemption with 

conditions and limitations1

91.151(a) Fuel requirements for flight in VFR 

conditions

Relief [paragraph 91.151(a)(1), day] 

granted in prior exemption with conditions 

and limitations1

91.203(a) and (b) Civil aircraft: Certifications required Relief not necessary pursuant to prior 

exemption1

91.405(a) Maintenance required Relief granted in prior exemption with 

conditions and limitations1

91.407(a)(1) Operation after maintenance, 

preventive maintenance, rebuilding, 

or alteration

Relief granted in prior exemption with 

conditions and limitations1

91.409(a)(1) and (2) Inspections Relief granted in prior exemption with 

conditions and limitations1

91.417(a) and (b) Maintenance records Relief granted in prior exemption with 

conditions and limitations1

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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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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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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