To whom it may concern, 

In regards to section 333 of the FAA Modernization and reform care act of 2012 and 14 C.F.R. I Ryan 

Switala apply for exemption from the Federal Aviation Regulations to allow me to take pictures of 

short videos for commercial purposes using a Small Unmanned Aircraft System . The “sUAS” would be 

operated under the conditions outlined established by the FAA under section 333.

I intend to use my sUAS JJRC H16 YiZhan Tarantula X6 in conjunction with a Gopro hero 3 to take photos 

and short videos to enhance the cinematography of requested photos and video’s. The complete set up 

of camera a sUAS would under the weight of 4 lbs. Use a sUAS would be a more practical and cost effect 

way to achieve elevated photos and video. In addition the benefit of safety in the national airspace 

would be increased using a sUAS. 

For the reasons stated below I, Ryan Switala, respectfully request the grant of an exemption allowing me 

to operate ultra light weight, remote controlled UAS’s for commercial aerial 

photography/videography/cinematography.

I. Contact Information 

Ryan Switala 

1614 Copperfield Ct Howell, MI 48843 

ffrswitala@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Ryan Switala

Requests Exemption are:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14

C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. §

91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1);

14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417

(a) & (b)

III. The Extent of relief Ryan Switala seeks and the Reason He Seeks Such Relief:

I Ryan Switala will be the pilot in charge of the sUAS. I will not operate my sUAS near airports, hospitals, 

restricted airspace or no fly zones. At all times my sUAS will maintain a distance of 50-100 yards away 

from any public. My sUAS will be powered by a battery opposed to an engine that will require 

combustible fuels to be on board. Flight time will be spanning from five (5) To fifteen (15) Minutes and 

at no time will be over an altitude of 200 AGL. Always using a fully charged battery would ensure a safe 

flight. All fights would be based on weather, any adverse weather including winds up to and including 10 
kph the flight would be canceled. Following all the stated guidelines above I plan to keep the safety of 

any flight as the highest priority. 

I have been operating other sUAS for the past few years, using a standard pre-flight inspection process, 

checking the weather on a FAA approved website and being an active hobbyist of sUAS I have the 

experience, knowledge and skills to reduce the chance of possible accidents. By granting of an exception 

I understand that I will be under significantly more restriction than a hobby operator. 

IV. How will Ryan Switala request benefit the Public As a whole:

Aerial photography and videography will help enhance the pictures of real-estate and other memorable 

events such as weddings, birthday parties and family events. Using a sUAS would eliminate the expense 

to the customer of hiring a pilot and a plane to take pictures in the traditional matter as well as the risk 

to civilians with using a small manned aircraft. 

V. Reasons Why Ryan Switala’s Exemption Will Not Adversely Affect Safety Or How The Exemption 

Will Provide a Level of Safety At Least Equal To Existing Rule:

By granting I, Ryan Swtiala this exemption I will create a safer community. With following all the laws 

and regulation and well as adhering to personal rigorous preflight inspections, line of sight flight paths 

and keeping the sUAS at distances that are less than the required minimum I intend to keep safety as my 

number one priority. 

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my,

Ryan Switala’s, UAS permits exemption from Part 21 because my UAS meets

(and exceeds) an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's

from the airworthiness certificate requirement in consideration of the weight, size,
speed, maneuverability and proximity to areas such as airports and dense

populations. I Ryan Switala current and projected UAS's meet or exceed

each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there

are no on board pilots or passengers, and given the size of the UAS's, this

Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a

B.

safety/flight manual delineating areas of where safety can be defined.10 The

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and

32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable with my sUAS

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft

certifications and registrations. They are inapplicable for the same reasons

described above. The equivalent level of safety will be achieved by maintaining

any such required certifications and registrations by me, Ryan Switala.

14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according

to certain specifications. My UAS are, by definition, unmanned. They therefore do

not have a cabin, cockpit or pilot station on which to mark certain words or 
phrases. Further, two-inch lettering is difficult to place on such small aircraft with

dimensions smaller that minimal lettering requirement. Regardless, I will mark its

UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on

its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone

assisting me as a spotter with the UAV will see the markings. The FAA has

previously issued exemptions to this regulation through Exemptions Nos. 8738,

10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial

operations. I, Ryan Switala, can achieve an equivalent level of safety

as achieved by current regulations because my UAS does not carry any pilots or

passengers. The risks attended to the operation of my UAS is far less than the

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq.

Thus, allowing me, Ryan Switala, to operate my UAS meet and exceed current

safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It

allows helicopters to be operated at lower altitudes in certain conditions. My UAS

will never operate at an altitude greater than 200 AGL; safely below the standard

of 400 AGL. I, Ryan Switala will however operate my UAS in safe areas away

from public and traffic, providing a level of safety at least equivalent to or below

those in relation to minimum safe altitudes. Given the size, weight,

maneuverability and speed of my UAS, an equivalent or higher level of safety will

be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance
Inspections.

C.

D.

E.

The above-cited Regulations require, amongst other things, aircraft owners and

operators to “have [the] 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.

. . .”

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my, Ryan Switala’s , UAS.

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my

UAS permits exemption from Part 21 because my Ryan Switala’s, UAS meets

an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA

is authorized to exempt aircraft from the airworthiness certificate requirement

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act.

Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness

certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations.

My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the

operation of an aircraft without an airworthiness certificate. As no such certificate
will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the

aircraft. As there are no pilots or passengers, and given the size of the UAS's,

this Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a manual. The FAA has previously issued exemptions to this

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B,

10167, maintenance program that involves regular software updates and curative

measures for any damaged hardware. Therefore, an equivalent level of safety

will be achieved.

In summary, Ryan Switala seeks an exemption from the following

Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14

C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. §

91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1);

14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417

(a) & (b) to commercially operate my, Ryan Switala, small unmanned

vehicle/lightweight unmanned aircraft vehicle in thereby enhance safety. 

Thank you for your time in this matter, 

Ryan Switala