October 14, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

RE: Petition for Exemption from Certain Federal Aviation Regulations, Pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012. 

Dear Sir/Madam: 

In 2012, Congress passed the FAA Modernization and Reform Act (“FMRA”). In Section 333 of that Act, 

Congress directed the Secretary of Transportation to consider whether certain unmanned aircraft 

(“unmanned aircraft system”) may be operated safely in the national airspace system (“NAS”) prior to the 

Federal Aviation Administration’s (“FAA”) completion of the rulemaking Congress had ordered under 

the Act’s Section 332. (FMRA §333(a)). 

In making that determination, the Secretary is required to consider whether a unmanned aircraft system, 

“as a result of [its] size, weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do[es] not create a hazard to users of the national airspace system 

or the public or pose a threat to national security,” and “whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under section 44704 of title 49.” (FMRA §333(b)). 

If the Secretary determines “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.” (FMRA §333(c)).

To that end, and pursuant to the FMRA’s Section 333, and in accordance with the procedures set forth in 

14 C.F.R. Sections 11.15, 11.61 and the relevant portions of 14 C.F.R. Sections 11.63 through 11.103, I 

hereby submit this petition for an exemption from certain of the Federal Aviation Regulations (“FARs”) 

addressed more specifically below, so that I may operate a small unmanned aircraft system commercially 

in the NAS.1

 

1 Petitioner takes no position with respect to what FAA regulations, if any, apply to the proposed operations. 

Petitioner assumes solely for purposes of this petition that the FAA’s position is an exemption from the 

indicated aviation regulations may be required.
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GRANTING THIS EXEMPTION REQUEST WOULD BE IN THE PUBLIC’S INTEREST:

If this application for the allowance of commercial operations using an unmanned aircraft is approved, the 

operation of this aircraft will be completed in a manner that serves the public interest in the following 

ways:

• The allowance of this operation to use a UAS would fulfill Congress’s goal under § 333 of the FMRA 

by allowing UAS operation with significant safety precautions in a low risk environment before the 

publication of the rulemaking required under FMRA § 332.11

• The allowance of this operation will provide safe work conditions for those that are handling the aircraft 

on the ground, and for those that are supporting the operation in the air, as well as other manned and 

unmanned operators at all times.

• This paper based airframe is a time tested and proven design and has been considered by many to be a 

safe and nonhazardous to manned aviation or the general public. As such, this UAS is significantly safer 

than other aviation platforms because it is lighter and less prone to fire risks associated with other liquid 

fueled aircraft (Clayco Petition / Regulatory Docket No. FAA–2014–0507).

• This UAS is more environmentally friendly to operate than a manned helicopter or small plane because 

it reduces noise and air pollution (Cooley Petitions / Regulatory Docket No. FAA–2015–1992).

• UAS use contributes to reduced airport congestion by reducing the commercial use of small planes and 

helicopters (Woolpert Petition / Regulatory Docket No. FAA-2014-0506).

• Since this unmanned aircraft is very lightweight and slow flying, there is a minimal to no risk to life and 

property on the ground due to the limited potential and kinetic energy involved (Woolpert Petition / 

Regulatory Docket No. FAA-2014-0506).
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THE PETITIONER: 

My name and contact information is: 

Eric Charles Swanson

11626 South Walnut Ridge Drive

Palos Park, IL 60464-1053

support@cardinaluav.com

As of the writing of this exemption letter, I am an FAA-certified airman. I currently hold an FAAissued Private Pilot certificate with a tailwheel endorsement and an Aircraft Dispatcher certificate 

(Federal Aviation Administration Certificate #3772345). 

I started and completed my 14 CFR Part 141 Private Pilot and 14 CFR Part 65 Aircraft Dispatcher 

certification training at Lewis University, which is located on the Lewis University Airport (KLOT). 

Although I am in the process of continuing my flight training, I have had the privilege learn to operate 

a variety of aircraft over my relatively short aviation career. To date, I have had the opportunity to log 

flight time as pilot in command in aircraft such as the Cessna 140, 152, 172 (Non-Glass / G1000) and 

the Piper J-3 Cub.

In addition to this certification, I completed my Bachelors of Science in Air Traffic Control 

Management at Lewis University - an approved and federally recognized CTI program. As part of the 

senior capstone project for this degree, I was able to shadow air traffic controllers working live air 

traffic at C90 – Chicago TRACON during the summer of 2014 for more than 120 hours. This 

experience provided me valuable insight into the daily lives of approach/departure control in one of 

the nation’s busiest airspaces. As such, I was able to gain a much deeper insight into the methodology 

and construction of airspace, IFR and VFR traffic procedures, airport operations, traffic management,

insight into FAA Order JO 7110.65, emergencies, and more from the perspective of one of the most 

visible portions of the Federal Aviation Administration.

Since 2007, I have had the opportunity to operate many small unmanned aircraft systems for hobby 

and recreation purposes. Throughout the years, I have had the opportunity to fly in an assortment of 

locations at many different times during the day. As a result, I have collected over the years many 

hours of experience operating a wide range of unmanned aircraft systems from nitro menthol and 

electric fixed wing aircraft, to electric based quadrotor helicopters. In addition to this, I am an active 

Academy of Aeronautics (AMA) member and actively participate in online discussions with other 

aero modelers and provide reliable and timely responses to building/flying techniques.

Since I have a wide range of aeronautical knowledge in one of the world’s most complex and busy 

airspaces, I am declaring to the necessary parties that the submittal of this application is a public 
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declaration that I possess sufficient aeronautical knowledge, medical requirements (unrestricted 1st

class medical), and experience to operate this unmanned aerial system safely at all times in the 

national airspace system.

I am also employed as a Research Assistant for the Global Security Sciences division at Argonne 

National Laboratory in Lemont, Illinois. I am not currently employed as a federal employee at this 

time as I am employed by University of Chicago / Argonne LLC. Throughout my employment, I have 

had the opportunity to formally study the regulatory environments of national civil aviation 

authorities around the world, industry trends, manufacturing statistics, peer reviewed research, 

privacy concerns, and more in relation to the operation of unmanned aircraft systems.
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THE UNMANNED AIRCRAFT: The unmanned aircraft system that I am requesting to operate 

commercially is a “powered” paper airplane known as the “PowerUp 3.02,” manufactured by Tailor Toys 

L.L.C. The specifications of the unmanned aircraft system are:

 

2 Manufacturer’s website: http://www.poweruptoys.com

Airframe components Description of components

Structure: 

Carbon fiber hull; glass reinforced nylon impact resistant cockpit and 

motor mount; and a rubber tip for dampening impacts on crashes and 

avoiding injury. 

Control Software: iOS & Android mobile applications. 

Connectivity: Bluetooth 4.0 

Battery: Internal lithium polymer 75mAh, with built-in protection circuit. 

Dimensions: 20cm (7.9in) length. Width varies depending upon paper size and paper 

folding method. Theoretical maximum with unfolded paper is 29.3 cm 

(11.5 in)

Weight of motor: 9gr (0.32oz). 

Weight of camera: 5gr (0.18oz). 

Weight of paper: 5gr (0.18oz). 

Total takeoff weight: 19gr (0.67oz). 

Speed: Airplane speed is dependent on the airplane design, wing span and 

battery level. For most conservative designs, the aircraft will operate at a 

speed of 5 m/s / 16.4 f/s (18 km/h / 11.2 mp/h). With a well folded 

Nakamura design, it is possible to reach airspeed in excess of 8 m/s / 

26.25 f/s 18 mph.

Expected control range: 40-50m / (120-180f) radius from operator. The operation of this aircraft 

will always be performed within line of sight of the operator and visual 

observer. As such, a range check will be performed prior to operation as 

to confirm safe operation in preexisting environmental conditions.

Safety system: If communication with unmanned aircraft system is lost due to it flying 

beyond the control range, the smart phone app will automatically shut the 

airplane's motor off, allowing the unmanned aircraft system to glide 

down to the surface. 

Flight time: 5-10 minutes. 
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REASON FOR REQUESTING AN EXEMPTION: 

I intend to operate my unmanned aerial system by utilizing the unique capabilities of this aircraft to 

collect and support the generation of commercial aerial photography videography at restricted 

admittance airshows, journalism requests, and educational events. I also intend on utilizing the 

products generated from this unmanned aerial system as means to complement lectures and 

presentations on topics of aviation to decrease public ignorance of aviation laws and regulations 

through the demonstration of safe operations.

OPERATIONS / MISSIONS

In order to expedite the processing of this application, I am hereby declaring the commercial

operations and missions that this aircraft, operator, and visual observer will be capable of achieving. 

These missions include:

Aerial surveying, mapping, data collection, remote sensing, education and research, monitoring,

filmmaking, videography, and photography
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THE EQUIVALENT LEVEL OF SAFETY: 

Due to the size, weight, speed and limited operational capabilities of the unmanned aircraft system, I 

intend to operate pursuant to an FAA-granted exemption, an equivalent or higher level of safety will 

exist than performing the same operations with a manned aircraft under existing regulations. I agree 

to be bound by the following limitations and conditions when conducting commercial operations with 

the unmanned aircraft system under an FAA-granted exemption include:

 The majority of the unmanned aircraft system structure (fuselage and wings) will be composed of 

paper, a frangible and readily available material.

 The unmanned aircraft system will have a weight of 19-grams, which is considerably less than 

0.1% of the maximum allowable weight of 55 lbs, and approximately 0.9% of the 4.4 lbs weight 

limit proposed under the NPRM’s “Micro UAS” proposal.

 The unmanned aircraft system will have a maximum operating speed of no more than 18 mph, 

which is no more than 18% the speed of the maximum allowable operating speed of 100 mph and 

less than 60% the speed of the 30 knots proposed under the NPRM’s Micro UAS proposal.

 All flights will be operated within line of sight of the Pilot in Command (“PIC”) and the visual 

observer.

 The average maximum flight time for each operational flight will be approximately 5-10 minutes.

 All flights will be operated at an altitude no greater than 180 feet Above Ground Level (“AGL”), 

which is slightly more than one-half the length of a football field.

 The unmanned aircraft operator will be a designated PIC

 The PIC will plan the operations prior to each flight.

 The PIC will inspect the unmanned aircraft system prior to each flight to ensure the unmanned 

aircraft system may be flown safely and not present any actual hazard to any persons or property.

 The PIC will be trained in the operation of the unmanned aircraft system, and will have the 

requisite experience flying the type of unmanned aircraft system to be flown.

 Prior to a commercial operation, the unmanned aircraft’s systems will be reviewed to ensure 

proper functionality.
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REGULATIONS FROM WHICH EXEMPTION IS REQUESTED:

• 14 C.F.R. Part 21, Subpart H; 

• 14 C.F.R. 45.11(a)(d)

• 14 C.F.R. 45.21

• 14 C.F.R. 45.23(b); 

• 14 C.F.R. 45.25.

• 14 C.F.R. 45.29

• 14 C.F.R. 61.3; 

• 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. 91.126; 

• 14 C.F.R. 91.127; 

• 14 C.F.R. 91.129; 

• 14 C.F.R. 91.130; 

• 14 C.F.R. 91.131; 

• 14 C.F.R. 91.133; 

• 14 C.F.R. 91.137; 

• 14 C.F.R. 91.138; 

• 14 C.F.R. 91.139; 

• 14 C.F.R. 91.141; 

• 14 C.F.R. 91.143; 

• 14 C.F.R. 91.144; 

• 14 C.F.R. 91.145; 

• 14 C.F.R. 91.151(a); 

• 14 C.F.R. 91.203(a)&(b); 

• 14 C.F.R. 91.405(a); 

• 14 C.F.R. 91.407(a)(1); 

• 14 C.F.R. 91.409(a)(1)(2); and 

• 14 C.F.R. 91.417(a)&(b). 
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REASONS EXEMPTIONS FROM CERTAIN REGULATIONS ARE REQUESTED:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates. 14 C.F.R. §91.203(a)(1) establishes the 

procedural requirements for the issuance of airworthiness certificates required under FAR 

§91.203(a)(1). If the FAA believes this regulation applies to my unmanned aircraft system, I request 

an exemption. 

Both 49 U.S.C. §44701(f)) and Section 333 of the FMRA authorize the FAA to exempt certain 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed and operational capabilities. Due to the size, weight, speed and limited operational capabilities 

of the unmanned aircraft system I intend to operate, an exemption from Part 21 Subpart H would 

satisfy the requirements of an equivalent level of safety under Part 11 and Section 333 of the FMRA, 

as the FAA might believe is required for me to fly my unmanned aircraft system commercially. 

The unmanned aircraft platform I intend to operate carries neither a pilot nor a passenger. It carries no 

flammable liquid fuels. As such, the unmanned aircraft platform I wish to operate without an 

airworthiness certificate will be at least as safe, and indeed far safer than any manned aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart 

H. Moreover, the size, weight, speed and limited operational capabilities of the unmanned aircraft 

system I intend to operate presents no credible threat whatsoever to national security. As such, I 

request an exemption from this regulation.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §45.11(a)(3) General. This regulation requires that the aircraft identification plate must be 

secured to the aircraft fuselage exterior so that it is legible to a person on the ground, and must be 

either adjacent to and aft of the rear-most entrance door or on the fuselage surface near the tail 

surfaces. Since there is no door on this aircraft, nor is the aircraft large enough to support the required 

materials for the typography of 14 C.F.R §45.23(b), relief from this regulation is necessary due to the 

inability to comply with this regulation. As such, I request an exemption from this regulation.

14 C.F.R. §45.21 General. This regulation requires that all aircraft except as provided in § 45.22, 

may not operate a U.S.-registered aircraft unless that aircraft displays nationality and registration 

marks in accordance with the requirements of this section and §§ 45.23 through 45.33. However since 

the construction and the size of the aircraft make it impossible to place traditional markings on the 

airframe, I am requesting relief from this regulation. If relief is granted under 14 C.F.R. §45.25 
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Location of Marks on Fixed Wing Aircraft as well, the largest and easiest to read typography will be 

applied to the sides of the battery/electrical components located near the front of the airframe to assist 

with the spirit of the law as it is written in 14 C.F.R. §45.21 and §45.23(b). As such, I request an 

exemption from this regulation.

14 C.F.R. §45.23(b). Marking of the Aircraft. This regulation requires, “when marks include only 

the Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport 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 not less than 

2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," 

or "provisional," as applicable. 

Even though the unmanned aircraft system will have no airworthiness certificate, the FAA might 

believe an exemption would be required, as the unmanned aircraft system has no entrance to any 

cabin, and no cockpit or pilot station on which the word “Experimental” could be placed. Given the 

size of the unmanned aircraft system, two-inch lettering will be impossible. If it is determined to be 

required, the word “Experimental” will be displayed on the fuselage in compliance with §45.29(f), 

and the equivalent level of safety will be provided.

As such, I request an exemption from this regulation.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §45.25 Location of Marks on Fixed Wing Aircraft. This regulation requires that 

operators of aircraft place the required marks on either vertical tail surfaces or the sides of the 

fuselage behind the trailing edge of the wing. As the structure of this aircraft supports the construction 

of a delta shaped wing and features no horizontal stabilizer in the construction plans, it is impossible 

to place the registration markings in the traditional sense. The purpose of the relief for this regulation 

is to allow for the placement of the registration on both sides the battery/electrical components 

located near the front of the airframe to assist with the spirit of the law as it is written in 14 C.F.R. 

§45.23(b). This would also support the spirit of the law as it is written in 14 C.F.R. §45.11 (d). If the 

placement of the registration markings is allowed in this area, then this would be on the most 

structurally rigid, visible, and unchanging portion of the airframe. As such, I request an exemption 

from this regulation.
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14 C.F.R. §45.29 Size of Marks, Fixed Wing Aircraft. This regulation requires that markings must 

be 12 inches high of uniform height, width, thickness, and spacing on both sides of the aircraft. 

However, due to the limited size of the aircraft and the issues involved in the application of those 

letters, I request an exemption from this regulation. If relief is granted under 14 C.F.R. §45.25 

Location of Marks on Fixed Wing Aircraft as well, the largest and easiest to read typography will be 

applied to the sides of the battery/electrical components located near the front of the airframe to assist 

with the spirit of the law as it is written in 14 C.F.R. §45.23(b). As such, I request an exemption from 

this regulation.

14 C.F.R. §61.3 Requirement for certificates, ratings, and authorizations. This regulation 

requires, in relevant part, that no person may serve as a “required pilot flight crewmember” of a civil 

aircraft of the United States, unless that person has a pilot certificate issued under Part 61. 14 C.F.R. 

1.1 defines “crewmember” as “a person assigned to perform duty in an aircraft during flight time.” I 

request an exemption from this regulation.

As an operator of this unmanned aircraft system, I would never be performing any duties in an aircraft 

since it would be impossible for me to do so. I would, at all times, be outside of the unmanned 

aircraft. Thus, I would not be a crewmember at all under 14 C.F.R. 1.1, much less a “required pilot 

flight crewmember” under 14 C.F.R. §61.3. As such, the latter regulation would not even apply to me, 

as it contains no requirement for airman certification for non-crewmembers. 

“Air commerce,” in turn, is defined under 49 U.S. Code §40102(a)(3). It reads, “‘air commerce’ 

means foreign air commerce, interstate air commerce, the transportation of mail by aircraft, the 

operation of aircraft within the limits of a Federal airway, or the operation of aircraft that directly 

affects, or may endanger safety in, foreign or interstate air commerce. 

If the requested exemption is granted, I have neither the intent nor the ability to engage in “air 

commerce” as defined by statute. I would not be able to fly my unmanned aircraft system in “foreign 

air commerce,” “interstate air commerce” or operate my unmanned aircraft system “within the limits 

of a Federal airway.” Nor would my 19-gram paper airplane remotely “endanger safety in foreign or 

interstate air commerce.” Therefore, and for the aforementioned reasons, I request an exemption from 

14 C.F.R. §61.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §61.113(a) and (b): Private Pilot Privileges and Limitations. Pursuant to 14 C.F.R. 

61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an 
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aircraft that is carrying passengers or property for compensation or hire. I request an exemption from 

this regulation. 

Given the size, weight, speed and limited operational capabilities of the unmanned aircraft system to 

be flown, my unmanned aircraft system may achieve an equivalent level of safety as achieved by 

current regulations because it does not carry any pilots, nor any passengers or property for 

compensation or hire. The risks attendant to the operation of my unmanned aircraft system are far less 

than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 61.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. This regulation requires that no person may 

operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate 

issued for the aircraft if this exemption is granted, no FAA regulatory standard will exist for 

determining airworthiness. I request an exemption from this regulation. 

Given the size, weight, speed and limited operational capabilities of the unmanned aircraft system to 

be flown, regular maintenance and use of a safety checklist prior to each flight will provide an 

equivalent level of safety. Recommendations and requirements from the aircraft manufacturer will be 

included in the process of self-certifying airworthiness of the airframe. Prior to operations for a 

commercial purpose, the airframe will be test flown with the presence of a qualified visual observer to 

verify airworthiness and flight characteristics prior to commencing a commercial flight.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. This regulation provides that 

“no person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft 

Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof.” I request an exemption from this regulation.

Given the size, weight, speed and limited operational capabilities of the unmanned aircraft system to 

be flown, it is not possible to carry such a flight manual onboard the aircraft, and there would be no 

pilot on board to read it. The equivalent level of safety will be maintained either by writing the 

operating instructions on the unmanned aircraft system itself, or by keeping the operating instructions 

at the ground control point where I will be flying my unmanned aircraft system, where I will have

immediate access to the content. 
- 13 -

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.103: Preflight Action. This regulation requires, in relevant part, that each pilot in 

command take certain actions before each flight to ensure the safety of flight, including familiarizing 

oneself with “runway lengths at airports of intended use, takeoff and landing distance information,” 

and “other reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind and 

temperature.” I request an exemption from this regulation. 

Since I will not be taking off from or landing upon any airport runways, takeoff and landing distance 

information, airport elevation and runway slope will not be relevant to my unmanned aircraft system

operations. Given the size, weight, speed and limited operational capabilities of my unmanned aircraft 

system, aircraft gross weight, and wind and temperature will also not be relevant to my unmanned 

aircraft system operations. Lastly, FAA-approved flight manuals do not exist for my unmanned 

aircraft system. 

Nonetheless, I will still take all actions necessary pre-flight actions to ensure the airworthiness of the 

unmanned aircraft system and the safety of each flight. Given the size, weight, speed and limited 

operational capabilities of the unmanned aircraft system to be flown the equivalent level of safety will 

be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.109: Flight Instruction. This regulation provides 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. I request an exemption from this regulation. 

I have no intention to, nor will I, use my unmanned aircraft system to conduct flight instruction, nor 

are dual controls technically possible with my unmanned aircraft system. Instruction to other 

individuals will not be given as the operation of this aircraft will be a simple demonstration of the 

aerial capabilities of this aircraft. As of the writing of this exemption request, I am not in possession 

of any flight/ground instructor certificate. I will be utilizing this aircraft as a means for launching

discussion about unmanned aircraft systems after the aircraft has safely landed and the flight is 

complete. Therefore, an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.
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14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation 

of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums 

prescribed, provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. I request an exemption from this regulation.

As set forth above, the unmanned aircraft system I intend to operate will never operate above 180 feet

above ground level. The equivalent level of safety will be provided due to the size, weight, speed and 

limited operational capabilities of the unmanned aircraft system. Compared to flight operations with 

manned aircraft weighing far more than the 19gram unmanned aircraft I intend to fly, coupled with 

the lack of flammable fuel, any risk associated with my intended operations is essentially nonexistent 

when compared to those presented by manned aircraft operating at or below 500 AGL. In addition, 

the extremely low-altitude operations of the unmanned aircraft system I intend to fly will ensure 

significant separation between the unmanned aircraft system operations and the operations of manned 

aircraft that must comply with Section 91.119.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810. 

14 C.F.R. §91.121 Altimeter Settings. This regulation requires 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.” I request an exemption from 

this regulation. 

Since the unmanned aircraft system I intend to fly does not have and cannot have a barometric 

altimeter or a GPS altitude read out, an exemption is necessary. An equivalent level of safety will be 

achieved by the size, weight, speed and limited operational capabilities of the unmanned aircraft 

system.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.126 Operating on or in the vicinity of an airport in Class G airspace. This 

regulation requires, in relevant part, that each person operating an aircraft on or in the vicinity of an 

airport in a Class G airspace area must maintain two-way radio communications with the control 

tower prior to 4 nautical miles from the airport. I request an exemption from this regulation. 

Since the paper based unmanned aircraft system to be flown does not and cannot have a two-way

aviation band transceiver, and given the size, weight, speed and limited operational capabilities of the 

unmanned aircraft system, an equivalent level of safety will be provided.
- 15 -

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.127 Operating on or in the vicinity of an airport in Class E airspace. This 

regulation requires, in relevant part, that each person operating an aircraft on or in the vicinity of an 

airport in a Class E airspace area must maintain two-way radio communications with the control 

tower prior to 4 nautical miles from the airport. I request an exemption from this regulation. 

Since the paper based unmanned aircraft system to be flown does not and cannot have a two-way

aviation band transceiver, and given the size, weight, speed and limited operational capabilities of the 

unmanned aircraft system, an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.129 Operations in Class D airspace. This regulation requires, in relevant part, that 

each person operating an aircraft in Class D airspace must comply with §§91.126 and 91.127 and the 

two-way radio communications with the control tower prior to entering that airspace and thereafter 

maintain those communications while within that airspace. I request an exemption from this 

regulation. 

Since the paper based unmanned aircraft system to be flown does not and cannot have two-way

aviation band transceiver, and given the size, weight, speed and limited operational capabilities of the 

unmanned aircraft system, an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.130 Operations in Class C airspace. This regulation requires, in relevant part, that 

each person operating an aircraft in Class C airspace must comply with §91.129 and that the aircraft 

must be equipped with the applicable equipment specified in §91.215 (a transponder and automatic 

altitude reporting equipment). I request an exemption from this regulation. 

Since the paper based unmanned aircraft system to be flown does not and cannot have a two-way

aviation band transceiver or a transponder, and given the size, weight, speed and limited operational 

capabilities of the unmanned aircraft system, an equivalent level of safety will be provided.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.
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14 C.F.R. §91.131 Operations in Class B airspace. This regulation requires, in relevant part, 

that each person operating an aircraft in Class B airspace, must comply with §91.129; must receive 

prior ATC clearance from the ATC facility having jurisdiction for that area; must hold a certain level 

of pilot certification; and the aircraft must be equipped with the applicable equipment specified in 

§91.215 (a transponder and automatic altitude reporting equipment). I request an exemption from this 

regulation. 

Since the paper based unmanned aircraft system to be flown does not and cannot have a two-way

aviation band transceiver or a transponder, an equivalent level of safety will be achieved by virtue of 

the size, weight, speed and limited operational capabilities of the unmanned aircraft system.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.133 Restricted and prohibited areas. This regulation requires, in relevant part, that 

no person may operate an aircraft within a restricted area (as designated in Part 73), contrary to the 

restrictions imposed, or within a prohibited area, unless that person has the permission of the using or 

controlling agency, as appropriate. I request an exemption from this regulation. 

Since the paper based unmanned aircraft system to be flown does not would not present any credible 

threat to anything or anyone restricted and prohibited areas are intended to protect, and given the size, 

weight, speed and limited operational capabilities of the unmanned aircraft system, an equivalent 

level of safety will be provided.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.137 Temporary flight restrictions in the vicinity of disaster/hazard areas. This 

regulation requires, in relevant part, that no person may operate an aircraft within an area designated 

by the Administrator though a Notice to Airmen (NOTAM), as one in which temporary flight 

restrictions apply due to certain hazards or conditions unless certain conditions are met. I request an 

exemption from this regulation. 

Since the paper based unmanned aircraft system to be flown would not present any credible hazards 

to persons or property on the surface, and given the size, weight, speed and limited operational 

capabilities of the unmanned aircraft system, an equivalent level of safety will be provided.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.
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14 C.F.R. §91.138 Temporary flight restrictions in national disaster areas in the State of Hawaii.

This regulation requires, in relevant part that no person may operate an aircraft within an area in 

Hawaii, designated by the Administrator though a Notice to Airmen (NOTAM), as one in which 

temporary flight restrictions apply due to certain hazards or conditions unless certain conditions are 

met. I request an exemption from this regulation. 

Since the paper based unmanned aircraft system to be flown would not present any hazards to persons 

and property on the surface, an equivalent level of safety will be achieved by virtue of the size, weight, 

speed and limited operational capabilities of the unmanned aircraft system. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.139 Emergency air traffic rules. This regulation requires, in relevant part, that no 

person may operate an aircraft, or other device governed by the regulation concerned, within airspace 

designated by the Administrator though a Notice to Airmen (NOTAM), whenever the Administrator 

determines that an emergency condition exists, or will exist, relating to the FAA's ability to operate 

the air traffic control system and during which normal flight operations under this chapter cannot be 

conducted consistent with the required levels of safety and efficiency. I request an exemption from 

this regulation.

Since the unmanned aircraft system to be flown, given its size, weight, speed and limited operational 

capabilities, would not be conducted inconsistent with the required levels of safety and efficiency, an 

equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.141 Flight restrictions in the proximity of the Presidential and other parties. This 

regulation requires, in relevant part, that no person may operate an aircraft over or in the vicinity of 

any area to be visited or traveled by the President, the Vice President, or other public figures contrary 

to the restrictions established by the Administrator and published in a Notice to Airmen (NOTAM). I 

request an exemption from this regulation. 

Since the unmanned aircraft system to be flown would present no credible danger whatsoever to those 

intended to be protected by the regulation, an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.
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14 C.F.R. §91.143 Flight limitations in the proximity of space flight operations. This regulation 

requires, in relevant part, that when a Notice to Airmen (NOTAM) is issued in accordance with this 

section, no person may operate any aircraft of U.S. registry, or pilot any aircraft under the authority of 

an airman certificate issued by the Federal Aviation Administration, within areas designated in a 

NOTAM for space flight operation except when authorized by ATC. I request an exemption from this 

regulation. 

Since the unmanned aircraft system to be flown would present no credible danger whatsoever to any 

space flight operation intended to be protected by the regulation, and given the size, weight, speed 

and limited operational capabilities of the unmanned aircraft system, an equivalent level of safety will 

be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.144 Temporary restriction on flight operations during abnormally high

barometric pressure conditions. This regulation requires, in relevant part, that absent a waiver, no 

person may operate an aircraft or initiate a flight when any information indicates that barometric 

pressure on the route of flight currently exceeds or will exceed 31 inches of mercury. 

I request an exemption from this regulation. 

Given the size, weight, speed and limited operational capabilities of the unmanned aircraft system to 

be flown, operation can be conducted with a more than acceptable level of safety, and an equivalent 

level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.145 Management of aircraft operations in the vicinity of aerial demonstrations 

and major sporting events. This regulation provides that the FAA will issue a Notice to Airmen 

(NOTAM) designating an area of airspace in which a temporary flight restriction applies when it 

determines that a temporary flight restriction is necessary to protect persons or property on the surface 

or in the air, to maintain air safety and efficiency, or to prevent the unsafe congestion of aircraft in the 

vicinity of an aerial demonstration or major sporting event. I request an exemption from this 

regulation. 

Given the size, weight, speed and limited operational capabilities of the unmanned aircraft system to 

be flown, the unmanned aircraft system would not present any credible hazard to persons or property 

on the surface or in the air; will not have any effect on air safety and efficiency of the national 
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airspace system; and will not cause any unsafe congestion of aircraft in the vicinity of an aerial 

demonstration or major sporting event, and an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions. Section 91.151(a) 

prohibits an individual from beginning “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; or (2) At night, to fly after that for at least 45 minutes.” I request an exemption from 

this regulation. 

The unmanned aircraft system I intend to fly provides approximately 5-10 minutes of sustained flight 

and uses no liquid fuel. Given the size, weight, speed and limited operational capabilities of the 

unmanned aircraft system to be flown, none of the risks that Section 91.151(a) was intended to 

alleviate even apply, and an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration. The 

regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil 

aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate . . 

. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section ... is displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. I request an exemption from this regulation. 

The unmanned aircraft system I intend to fly when fully loaded weighs .03 lbs, or 54.97 lbs less than 

55 lbs. and is operated without a pilot or any passengers onboard. If an exemption from obtaining an 

airworthiness certificate is granted, as I would expect, there would be no airworthiness certificate to 

display. Nor would there be any pilot or passengers to view any such certificate. Lastly, there is no 

ability or place to carry an airworthiness certificate on or within the unmanned aircraft system. 

Given the size, weight, speed and limited operational capabilities of the unmanned aircraft system to 

be flown an equivalent level of safety will be provided. 

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.
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14 C.F.R. §91.215 ATC transponder and altitude reporting equipment and use. This regulation 

requires that all aircraft that have been certified with an engine driven electrical system are required to 

have a transponder installed and operational in the airframe at the time of operation. Since this is an 

electric based propulsion aircraft, the potential exists for regenerative charging at low power settings 

or on decent. Although this is not the same as a continuously producing alternator/generator in a 

manned fixed wing aircraft such as the Cessna 172, this process can be considered as an engine 

driven electrical system to recharge the batteries located within the airframe. In addition to this, any 

operation of an aircraft within the 30 nautical mile veil around areas defined in appendix D, section 1

of Part 91 requires a transponder that can reply to Mode 3/A interrogations with the code specified by 

ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC 

and intermode and Mode S interrogations in accordance with the applicable provisions specified in 

TSO C-112, and that aircraft is equipped with automatic pressure altitude reporting equipment having 

a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure 

altitude information in 100-foot increments. I request exemption from this regulation.

Since the unmanned aircraft system to be flown does not and cannot have a two-way aviation band 

transceiver or a transponder, and is constructed without an altimeter, an equivalent level of safety will 

be achieved by virtue of the size, weight, speed and limited operational capabilities of the unmanned 

aircraft system.

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

regulations require that an aircraft operator or owner “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...” and others shall 

inspect or maintain the aircraft in compliance with Part 43. I request an exemption from this 

regulation. 

Given that these sections and Part 43 applies only to aircraft with an airworthiness certificate, these 

sections will not apply to me if my unmanned aircraft system is exempted from having an 

airworthiness certificate, which I expect would be the case. Ongoing regular and preventative 

maintenance will be accomplished by me and in accordance with my personal knowledge and 

experience, and given the size, weight, speed and limited operational capabilities of the unmanned 

aircraft system to be flown, an equivalent level of safety will be provided.

An exemption request for relief from this particular regulation was approved for an identical airframe 

and similar operation under Docket No. FAA–2015–1810.
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SUMMARY OF REQUEST FOR FEDERAL REGISTER: 

In accordance with 14 C.F.R. §11.81(f), a summary of my Petition for Exemption request is provided 

for publication in the Federal Register. Eric Charles Swanson (“the Petitioner”), is requesting 

exemptions from the following Federal Aviation Regulations to the extent the FAA believes they 

would apply to my unmanned aircraft system: 

• 14 C.F.R. Part 21, Subpart H; 

• 14 C.F.R. 45.11(a)(d)

• 14 C.F.R. 45.21

• 14 C.F.R. 45.23(b); 

• 14 C.F.R. 45.25.

• 14 C.F.R. 45.29

• 14 C.F.R. 61.3; 

• 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. 91.126; 

• 14 C.F.R. 91.127; 

• 14 C.F.R. 91.129; 

• 14 C.F.R. 91.130; 

• 14 C.F.R. 91.131; 

• 14 C.F.R. 91.133; 

• 14 C.F.R. 91.137; 

• 14 C.F.R. 91.138; 

• 14 C.F.R. 91.139; 

• 14 C.F.R. 91.141; 

• 14 C.F.R. 91.143; 

• 14 C.F.R. 91.144; 

• 14 C.F.R. 91.145; 

• 14 C.F.R. 91.151(a); 

• 14 C.F.R. 91.203(a)&(b); 

• 14 C.F.R. 91.405(a); 

• 14 C.F.R. 91.407(a)(1); 

• 14 C.F.R. 91.409(a)(1)(2); and 

• 14 C.F.R. 91.417(a)&(b).

The exemption is requested since the FAA considers any aircraft flown for commercial purposes –

even a small paper airplane – to be regulated based on current federal aviation laws. As defined in the 

Administrator v. Pirker case and the ruling by the Department of Transportation, an unmanned 

aircraft system is considered to be an “aircraft” under the federal definitions of the word. As such, in 
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order to operate within the confines of established law it is required of me – the operator – to receive 

a commercial exemption from certain FARs as to operate a small, 19-gram, camera-equipped 

unmanned powered paper airplane to create and support the creation of video, photography, 

educational events and research, journalism, aerial surveying, mapping, data collection, remote 

sensing, and monitoring.

If this exemption is granted as requested, it would permit me, the Petitioner, to use the unmanned 

aircraft system to operate in any class of airspace. If granted, the Petitioner intends to operate the 

unmanned aircraft system at all times below an altitude of 200ft AGL and in accordance to applicable 

FAA regulations. Finally, the operator will exercise common sense and good judgement throughout 

the operation of the UAS. If there is any doubt in the safety of those on the ground and in the air, the 

operation will be discontinued and the aircraft will safely land. Nonetheless, the Petitioner will 

conduct all operations with the full regard for the safety of manned aircraft in flight and persons and 

property on the ground. 

CONCLUSION: 

I am entitled to submit a petition for exemption from regulations that would burden me if (1) I can 

provide a level of safety at least equal to that provided by the rules from which I seek the exemption, 

and (2) my request is in the public interest.3 

With this petition I believe I have met and will exceeded the standards that have been requested from 

an operator requesting to operate an unmanned aircraft for a commercial purpose. I believe that my 

request for exemption from certain federal aviation regulations is reasonable, rational and is in line 

with congressional intent as outlined in FMRA Section 333 to contemplate, and that it fulfills 

procedurally what a Petition for Exemption requires. 

I have explained how my intended unmanned aircraft system operations would provide an equivalent 

level of safety to each of the relevant FARs, mostly based upon the extremely small size, diminutive 

weight, low speed and limited operational capabilities of the unmanned aircraft system to be flown. 

I have also explained how my intended unmanned aircraft system operations would be in the public 

interest. It would further the goals of Congress, it would reduce the risk of hazard to persons and 

property and it would be in harmony with the First Amendment. 

 

3 See FAA’s “Guidelines for Submitting a Petition for Exemption” at http://aes.faa.gov/Petition/
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For your reference and convenience, additional documentation such as the operations manual 

provided by the manufacturer have been attached after my signature below to this document. The 

documentation provided in the digital .PDF document is identical to the print version and is the most

recent version provided by the original manufacturer of this unmanned aerial platform that I wish to 

utilize for commercial operations. Within the document, it details operation of the aircraft, general 

repair, and the operation of the control station on the Apple/Android app.

I request that the FAA grant the requested exemption with minimal delay. If there are any 

outlaying issues due to an oversight on my behalf, please feel free to contact through electronic 

mail at: support@cardinaluav.com, or call me at: (708) 653-6564 for the fastest response.

Thank you, I’m excited about the opportunity to work with you on this approval process.

Eric Charles Swanson

10/14/2015
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