Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14

CFR Part 11, SWIFT Aero, operators of Unmanned Aircraft Systems (UAS), hereby apply for an

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of

designated UAS, provided such operations are conducted within and under the conditions outlined

herein or as may be established by the FAA as required by Section 333.

Established in 2014 and based in downtown Las Vegas, NV, SWIFT Aero is poised to be Las Vegas’

leader in aerial photography and cinematography. SWIFT will operate the safest platforms with the

best cameras available. Our fleet was handpicked to assure that we have the best possible aircraft for

any situation. The SWIFT team has backgrounds in military UAS operations and training, Air Traffic

Control and the oil and gas sector. From inspection and surveying to professional cinematography,

SWIFT Aero is prepared to handle any project.

Thank you in advance for your time and consideration.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and

sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, architecture,

land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events,

cinematography, closed set cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the owners

or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines, onshore and offshore oil and natural gas installations,

oil and natural gas pipelines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in

cases of an emergency or natural disaster only when the local authorities or government has

requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to increase

awareness and improve safety for current and future UAS operations within the NAS.

As described fully below, the requested exemption would permit the operation of designated UAS as

set forth in this document under controlled conditions in the NAS that would be a) limited b)

controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness

of UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation’s (the FAA
Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft

systems in the national airspace system.”

The name and address of the applicant is:

SWIFT Aero, submitted by Sean Brown

Ph: 702.983.9860

Email: sean@swift.aero

Address: 320 E Carson Blvd, Floor 2

Las Vegas, NV 89101

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

SWIFT Aero will operate one or more of the following UAS models:
1. ZeroTech E1100: Primary cinematography aircraft, specifications to follow below.

2. Ascending Technologies Falcon 8: Primary inspection and surveying aircraft, specifications to follow

below.

3. DJI Inspire 1: Secondary cinematography and primary real estate aircraft, specifications to follow

below.

Product Specifications:

Aircraft: ZeroTech E1100

Flight Time: 10-18 Minutes

Diagonal Wheelbase: 1320mm

Empty Weight: 12kg

Max Takeoff Weight: 18kg

Number of rotors: 8

Propulsion: 6 cell, 22000 mAh LiPo Battery
Payload/Camera: RED Epic

Communication: Two independent control/data links (2.4 GHz) and one analogue video

receiver (5.8 GHz)

Navigation Sensors: High-Performance GPS, Gemini Dual Redundancy Auto Pilot.

Safety Features:

1. Gemini Dual Redundancy Autopilot: automatically switches between IMUs in case

of failure or sensor loss.

2. Parachute System: Manual or automatically deploys in case of sudden motor

loss.

3. Return Home: Aircraft will return to pre-determined location autonomously if

communication is lost.

4. Real Time Flight Telemetry: PIC receives current aircraft data.

Product Specifications:

Aircraft: ASCTEC Falcon 8

Flight Time: 12-22 Minutes

Height: 125mm

Width: 770mm
Length: 820mm

Empty Weight: 1086 g

Max. Takeoff Weight: 2.3 kg

Max Payload: 800 g

Number of rotors: 8

Rotor Diameter: 8in

Propulsion: 3 Cell, 6250mAh LiPo Battery

Payload/Camera: Variable and dictated by requirements of application, not to exceed 800 g.

Communication: Two independent control/data links (2.4 GHz) and one analogue video

receiver (5.8 GHz)

Navigation Sensors: AscTec Trinity (IMU, barometer and compass) x3 and AscTec HighPerformance GPS

Safety Features:

1. AscTec Trinity IMU: Aircraft status and flight components, navigation and related

electronics are simultaneously and consistently monitored with triple

redundancy.

2. Redundant Propulsion System: Trinity IMU monitors performance of each motor

and will alert PIC of any abnormal occurrence while simultaneously

adjusting power output of other motors to compensate.

3. Redundant Control Link: Two completely independent digital data links are

responsible for the transmission of all commands and telemetry data. The

failure of one of these links has no influence on the control of the flight

system.

4. Three Safety Modes: In event of data link interruption, the Falcon 8 has three

options to choose from:

A: Direct Landing: Aircraft will land autonomously

B: Return at Current Altitude: Aircraft will proceed to a

pre-determined location at its current altitude and land

autonomously.
C: Return High: Aircraft will ascend to a pre-determined altitude and

then proceed to a pre-determined location and land

autonomously.

5. Automated Pre-Flight Check: AscTec Trinity IMU automatically checks itself and

every flight component on power up to prevent take offs in the case of

critical malfunctions.

6. Real-Time Flight Telemetry: PIC receives all of the following telemetry from the

mobile ground station: GPS Position, GPS Quality and Strength, Data Link

Quality and Strength, Battery Voltage, Altitude, Vertical Airspeed, Horizontal Airspeed,

Operating Temperatures as well as external factor warnings such as

strong wind.

Aircraft: DJI Inspire 1

Flight Time: 12-20 Minutes
Height: 301mm

Width: 438mm

Length: 451mm

Weight (Battery Included): 2935 g

Max. Takeoff Weight: 3400g

Max Payload: 400g

Number of rotors: 4

Rotor Diameter: 13in

Propulsion: 6 Cell, 5700mAh LiPo Battery

Payload/Camera: DJI FC350

Communication: 2.4 GHz control/data link and 5.8 GHz video receiver.

Aircraft and Equivalent Level of Safety

1. The UAS will weigh significantly less than 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no more

than 55mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer

(VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in operation,

but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes

of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not

more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer

(VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have logged a minimum of

20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’ production

activities.
9. A pre-flight inspection and safety check will be performed on the aircraft, remote and all related

components.

10. All flight activities will be logged.

11. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

12. Flights will not be closer than a 5 mile radius of any airport.

13. The operator will obtain verbal/written consent of all persons involved with the planned operation

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and

the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S.

Department of Transportation required under the FOM. With the advanced permission of the FSDO,

operations at closer range may be approved.

14. The PIC and VO will have been trained in operation of UAS and receive up to date information for

the particular UAS to be operated.

15. The PIC and VO will be able to communicate by voice and/or radio at all times.

16. Written and/or verbal permission and permits will be obtained from territorial, state, county or

city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as

appropriate to flight operations.

17. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have

the capability to return to a predetermined location within a designated location and land

autonomously.

18. The UAS will have the capability to abort a flight in case of emergencies with an automated

“Return Home and Land” function.

19. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or

emergencies such as low battery.

SWIFT Aero Staff

Owner: Craig McKay

Craig is the founder of SWIFT AERO Ae. Craig has over 15 years of experience in the Oil and Gas

industry and holds current Offshore Survival and UKOOA Medical certifications. Craig has logged over

30 hours in small (under 55 lbs) multi-rotor aircraft.

Lead UAS Operations and Training Consultant: Kyle Williams

With over 1700 hours of UAV flight time, Kyle Williams is an experienced operator in the UAS field.

Recently retired from the Royal Air Force, he finished his military career as a UAV Flight Examiner and

Instructor Pilot, responsible for the design and implementation of UAV Force training programs. His
involvement in the training world included syllabus development, implementation and simulator

development. Moreover, he led the planning team responsible for emergency management and

contingency planning for UK RPAS operation. He holds an FAA CPL/IR along with being an FAA CFI.

With over 2900 hrs of worldwide manned flight time, he brings a wealth of experience and knowledge

to Swift Aero Operations.

Lead Pilot: Sean Brown

Sean holds academic qualifications specific to aviation (Associates Degree in Air Traffic control). In

addition, he has also undertaken FAA approved ground school courses for both Private and

Commercial Pilot licences, with credit received by the training institution for successful completion in

2014. He subsequently passed the written exam for an FAA Private Pilot licence. Since his training, he

has attended a UAS training establishment and received a Commercial UAS Pilot Certificate. He has

logged over 200 hours in small (under 55 lbs) multi-rotor aircraft and 50 hours in small (under 55 lbs)

fixed wing aircraft.

Federal Aviation Regulations to which exemption is requested:

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

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated

with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA

to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the

size, weight, speed, operational capability, and proximity to airports and populated areas of the

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without

an airworthiness certificate in the restricted environment and under the conditions proposed will be

at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive

materials or flammable liquid fuels, and operates exclusively within a secured and designated area.

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by

both the operator and under the requirements and in compliance with local public safety

requirements. These safety enhancements provide a greater degree of safety to the public and

property owners than conventional operations conducted with airworthiness certificates issued under

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no

credible threat to national security posed by the UAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial

external load. 14 C.F.R. § 45.23 (b). Marking of the Aircraft The 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,"

"lightsport," "experimental," or "provisional," as applicable.

14 C.F.R. § 45.23 (b). Marking of the Aircraft The 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," "lightsport," "experimental," or

"provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption

may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the

word “Experimental” can be placed. Given the size of the UAS, two inch lettering will be impossible.

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). US Department

of Transportation February 20, 2015 The equivalent level of safety will be provided by having the UAS

marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with

the UAS will see the identification of the UAS as “Experimental.” 14 C.F.R. § 61.113 (a) and (b): Private

Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who

holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers

or property for compensation or hire. The proposed UAS operations may achieve an equivalent level

of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots or

passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels

inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will be, or be under the

direct supervision of, a FAA Certificated Private Pilot with current Third Class or higher medical

certificate. It is believed that the operation and limitations set forth in the FOM will equate to the safe

operation of the UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The 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, should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each

flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: 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. The UAS, given its size and configuration has no ability or place to carry such

a flight manual on the aircraft, not only because there is no pilot on board, but because there is no

room or capacity to carry such an item on the aircraft. The equivalent level of safety will be

maintained by keeping the flight manual at the ground control point where the pilot flying the UAS

will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain

actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not

be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the
FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight

battery requirements, landing and takeoff distances and aircraft performance data before initiation of

flight.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 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. UAS and remotely piloted aircraft, by their design do not have fully

functional dual controls. Flight control is accomplished through the use of a control box that

communicates with the aircraft via radio communications. The FAA has approved exemptions for

flight training without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor

passengers will be carried in the aircraft and by the size and speed of the aircraft.

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. As this exemption is for a UAS that is a helicopter and the

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an

elevated platform from which filming is planned, an exemption may be needed to allow such

operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception

that in circumstances where the UAS is used to survey or photograph a structure whose height

exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on

the structure. It will however be operated in a restricted area with security perimeter, where buildings

and people will not be exposed to operations without their pre obtained consent. The equivalent level

of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it

is operated. No flight will be taken without the permission of the property owner or local officials.

Because of the advance notice to the property owner and participants in the filming activity, all

affected individuals will be aware of the planned flight operations. Compared to flight operations with

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of

flammable fuel, any risk associated with these operations is far less than those presently presented

with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations of

the UAS will ensure separation between these UAS operations and the operations of conventional

aircraft that must comply with Section 91.119. 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.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read

out, an U.S. exemption may be needed. An equivalent level of safety will be achieved by the operator,

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch

site shown on the GPS altitude indicator before flight.

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.” The applicant believes that an exemption from 14 CFR

§91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area

where only people and property owners or official representatives who have signed waivers will be

allowed does not engender the type of risks that Section 91.151(a) was intended to alleviate given the

size and speed of the small UAS. The applicant believes that an equivalent level of safety can be

achieved by limiting flights to 30 minutes or 25% of battery power — whichever happens first. This

restriction would be more than adequate to return the UAS to its planned landing zone from

anywhere in its limited operating area.

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 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. The UAS fully loaded weighs well under the

proposed 55lb limit and is operated without an onboard pilot. As such, there is no ability or place to

carry certification and registration documents or to display them on the UAS. An equivalent level of

safety will be achieved by keeping these documents at the ground control point where the pilot flying

the UAS will have immediate access to them, to the extent they are applicable to the UAS.

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. Given that these sections and Part 43

apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant.

Maintenance will be accomplished by the operator pursuant to the flight manual and operating

handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and

will carry a small payload and operate only in restricted areas for a limited period of time. If

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400

feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety. An equivalent level of safety will be achieved

because maintenance and inspections will be performed in accordance with the UAS Manufacturer's

User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior

to initiating flight and perform required maintenance needed.

Additional Information:

Given the small size of the UAS in scope and the controlled environment provided, the proposed

operations will adhere to the Reform Act’s safety requirements. The approval of this application

presents no national security issues. Regarding the level of safety surrounding the proposed

operations and the public benefit, reduction in environmental impacts, including but not limited to
reduced emissions and noise, the grant of the requested exemption is in the public interest.

Accordingly, the applicant graciously requests that the FAA grant the requested exemption.

Publishable Summary:

SWIFT Aero seeks an exemption from the following Federal Aviation Regulations: 14 CFR Part 21

subpart H, 14 CFR 42.23 (b), 14 CFR 61.113 (a) & (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR

91.103, 14 CFR 91.109, 14 CFR 91.119 (c), 14 CFR 91.121, 14 CFR 91.151 (a), 14 CFR 91.203 (a) & (b),

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) & (b) to commercially

operate its fleet of small UAS in photography, cinematography, inspection and surveying operations.

The applicant, SWIFT Aero, believes this exemption request and associated safety considerations

adequately satisfy criteria provided in Section 333 of the Reform Act of 2012, providing sufficient

justification for the granting of commercial operations of the applicant’s UAS.

Sincerely,

Sean Brown, Lead Pilot

SWIFT Aero

sean@swift.aero

Office: 702.983.9860

Cell: 702.250.1363

320 E Carson Blvd, Floor 2

Las Vegas, NV 89101