28 June 2015

Thomas F Mann President

SwormIM LLC

75-5919 Alii Drive

Suite S2

Kailua Kona, HI 96740

Thomas.Mann@swormim.com

808-238-5613

Subject: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.F.R. Part 11

Dear FAA:

 SwormIM, LLC, is located at 75-5919 Alii Dr Suite S2 Kailua Kona, HI 96740. On behalf of 

SwormIM, LLC; Pursuant to Section 333 of the FAA Modernization Reform Act of 2013 (“FAA 

Reform Act”) and 14 C.F.R, Part 11 SwormIM LLC, requests an exemption to provisions of the 

Federal Aviation Regulations (FAR) specifically Section 333.

 This request for relief of includes the provisions of 14 CFR part 21, Certification procedures for 

products and Parts, Subpart H-Airworthiness Certificates; 14 CFR 45.23 Display of marks; 

general and 45.29 Size of Marks; 14 CFR 61.113 Private Pilot privileges and limitations: Pilot in 

Command; 14 CFR 91.9 Civil aircraft flight manual, markings and place card requirements; 14 

CFR 91.103 (b) Preflight Action; 14 CFR 91.109 Flight Instructions; 14 CFR 91-119 Minimum 

safe altitude ; 14 CFR 91.121 Altimeter; 14 CFR 91-151 Fuel Requirements, 14 CFR Subpart E. 

91.4001-91-417) Maintenance and Alterations. 

 We request this exemption to operate unmanned aircraft systems (UAS) to conduct remote 

sensed imaging (RSI) with data acquisition and integration, mapping, geographic information 

systems (GIS), and real estate, sports development and public photography.

 SwormIM Unmanned Aircraft Systems (UAS) include the DJI Phantom II, 3DR Iris+, 3DR XM8, 

3DR Solo, 3DR XM. 

 DJI and 3DR are the two largest international and United States based UAS developers. DJI 

and 3DR have establish strong training programs, not limited just texts, but on line learning.
These companies have established preflight checklist, operational inspections for each unique 

UAS, and has an established history with construction, safety, and utility in the UAS community. 

 We will operate our UAS with these programs as a basis for our company. We will further 

refine them to enhance the safety and effectiveness of our UAS projects. We especially note 

that each of these companies allow us to access lesson learned from their UAS programs.

 These safety and aviation requirements will be combined with the regulator guidance we 

receive from the FAA from our approved exemption. We will utilize all our AUS equipment 

within the stated parameters as established by their manufactures. We will provide 

documentation to each of our clients which will highlight the safety and effectiveness of our 

UAS. We will continue to consult with subject matter experts, to enhance our operational 

safety. Our company will ensure compliance with local law and respect of our land and land 

owners. SwormIM will operate our UAS in a transparent and open way to ensure the continued 

growth in AUS. 

 We seek this Exception to Section 333 so that we can provide remote imagining and data 

exploitation to individual and small business. We are a focused on providing creative solutions 

to geographic as well as photographic issues effecting individuals and small business. We will 

provide safe remote sensing to our clients so that they may make informed choices as to the 

expansion, location, and growth of their business. We expect that with this exemption we will 

be able to develop a viable market for an AUS business.

 Without the aid of our company, each of them is put a competitive disadvantage. We are a 

Hawaiian Island based company, and know our home islands well. Mainland companies who 

could provide limited services are expensive and not responsive to our local communities. We 

also can provide assistance to address issues concerning land and water use to business and 

communities throughout the Hawaii Islands.

 Further, we seek to expand the employment opportunities to military veterans through our 

training with industry development program. Fort Shafter Hawaii is home to the Army 

Geospatial Battalion. We look to partner with them on community based projects. Our 

president served a full career in the Army Geospatial development initiatives. 

With Respect,

Thomas F. Mann

President 

SwormIM