Kevin A. Culbertson 

Swordfish Productions, LLC (d.b.a. Sandpiper Drones) .... 

1691 East Jefferson Way, 312 

May 1, 2015 

U.S. Department ofTransportation 

Docket Operations 

Simi Valley, California 93065 

(818) 244-4722 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Refonn Act") and 14 

C.P.R. Pali 11, Swordfish Productions, LLC (d.b.a. Sandpiper Drones), is petitioning for an exemption 

from the Federal Aviatim; ~eg)Jlations ("PARs") described belo_v/to ·enab!e Sandpiper Drones to 

commerciailyoperatethe follO\ying U.rimarined Aircraft Systerns: DJI Phmit6in 1; DJI fnspire · 1 ;· DJI 

Spreading Wings S-900; DJ(Spreadihg Wings·s~·IOoo. · · ' ,. · •· · ·. · · · 

Furthermore,-~e r~quest a ~~mmary grant as we believe you will find the administration has already 

granted previous e;x.etnptions similay to our request ooth iri operation' arid with' regard to the UAS. • . . • . . . . .• ' J ·~ ~ ~ • ,~, ' ; . . . ' . . - i • • • • ' 

proposed. These are inqluded as Ap:perigi~ G: :. ' · • ' • • ·' ' • ~ • > ' • • • j ' 

This exemption request will permit Sandpiper Drones to operate UAS commercially for the purpose of 

capturirig still _l;liJd motion. digital irpages of prop.erty, people, and events. 

Sandpipe~ Drones will provide a·s'e~icb'that is·b~neftcial to ah in'dustry that is already using- and 

apparently seeks to continue to use- UAS for these purposes. Through the grant of this exemption we will 

provide a legal option to users of these services while providing relevant operational experience and 

information to the FAA as well as the current and future community ofUAS operators and end product 

users. 

Sandpiper Drones believes this will benefit the public by demonstrating that an image capture service is 

viable to be operated lawfully. This includes the operation OfUAS by certificated pilots trained in the 

National Airspace System and tho~gh i:l demonstration of the ability for increased integration ofUAS in 

the NAS. , . l • ·' 

All operations by_Sangp~pfr .Qrpne~_wil,l~trictly adhere to safety, applicable PARs, Operators Handbook, 

Airwmihiness, Pirectiv¢sr ~rid ~Jl'.ofh~~ £iHidyliJ;l~S lr9ll)-. tpe EAA as applicable. Sandpiper Drones will 

conduct its operations in ,a mmjnel· as tQinairitain the level of safety expected of current manned aircraft 

operations. · · · '···-·".·• · ',_. .. · '··· ''·c·, .. :· · ,, . . / · : .. '···=~c.·:~· · ·:•' ::· ·, . 

SandpiperDroneswill operat~ e:x;6Jusi~;l)r'i~ ·conttolled COJ.?.ditions, withinvisualline of sight, at low 

altitudes not to exceed 400 _feet above 'ground level, or no higher than ~00 feet above the highest obstacle 

with prior Flight Safety District Office approval. An)! UAS ·in operation by Sandpiper Droi1es will not 

exceed 55 poundstot;;t-1 weight. · · · · . . - . . 
At all times Sandpiper Drones will have a Chief Pilot responsible to properly train, maintain safe 

operations, ensure currency requirements are met, and consistently assure an open line of communication 

with the FAA. The Chief Pilot will, at a minimum, be a certificated commercial pilot and maintain a 

medical certificate appropriate for UAS operation as defined by the FAA. 

As a business operated by a co-founder with the unique combination of professional experience as a pilot 

instructor at a major airline; a camera operator and director with major television networks; and founder 

of several successful start-up business, Sandpiper Drones will demonstrate and maintain a high standard 

ofUAS operations with a thorough understanding of the impotiance of safety guidelines in the NAS, the 

desire to promote these standards in the user community, and the ability to demonstrate a commercially 

viable legal operation in the use and integration ofUAS in the NAS. 

The name and address of the applicant is: 

Kevin A. Culbertson 

Swordfish Productions, LLC (d.b.a. Sandpiper Drones) 

1691 East Jefferson Way, 312 

Simi Valley, California 93065 

kculbertson@icloud.com 

(818) 244-4722 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 

C.F.R. 91.105; 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)(2); 14 C.F.R. 91.417(a). 

Appendix C lists select previous exemptions granted by the administration where discussion of each rule 

listed above is provided. 

TheApplicable Legal Standard Under Section 333 

Sandpiper Drones submits that grant of this exemption application advances the Congressional mandate 

in Section 333 of the Reform Act to accelerate the introduction ofUAS into the NAS if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether certain UAS 

may operate safely in the NAS before completion of the rule making required under Section 332 of the 

Reform Act. In making this determination, the Secretary is required to detennine which types ofUAS do 

not create a hazard to users of the NAS, the public, or pose a threat to national security in light of the 

following: the UAS's size, weight, speed, and operational capability; operation of the UAS in close 

proximity to airports and populated areas; and operation of the UAS within visual line of sight of the 

operator. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined in the act, from the 

requirement that all civil aircraft must have current airworthiness certificate and those regulations 

requiring commercial pilots to operate aircraft in commercial service. The Administrator may grant an 

exemption from a requirement of a regulation prescribed if the Administrator finds the exemption is in the 

public interest. 

The grant of the requested exemption is in the public interest based on Section 333 of the Reform Act; the 

additional authority in the Federal Aviation Act; the strong equivalent level of safety surrounding the 

proposed operations; and the significant public benefit, including enhanced safety and cost savings 
pennission from land owner/controller required before commencing any flight; operations to occur under 

Visual Flight Rules during Visual Meteorological Conditions (VMC); aircraft to remain within Visual 

Line of Sight (VLOS); operations to be conducted in a controlled environment with only the necessary 

persons present, any person present, not employed by Sandpiper Drones, will sign a waiver 

acknowledging UAS operations, proper safety procedures, and a statement acknowledging risks; 

operations will be conducted with a visual observer (VO), in addition to the UAS pilot, who will remain 

in VLOS with the UAS pilot, the UAS, and the area of operations at all times. VO will assist in 

maintaining a controlled environment, spotting hazards to persons or property, monitoring and 

communicating on appropriate ATC, CTAF, or other appropriate radio frequencies; operations will cease 

when battery capacity falls below 25% or a battery power reserve of less than 10% flight time is 

indicated. 

Operator Requirements 

Sandpiper Drones understands and upholds the stance that necessary precautions are required to protect 

aircraft already operating in the NAS, and the safety and security of the flight crew members, passengers 

as well as the public and property. For this reason Sandpiper Drones will require all pilots of the UAS to 

minimally be appropriately certificated pilots with appropriate medical certification as determined by the 

FAA for UAS operation. 

Privacy 

All flights will occur over private or controlled access property with the prior consent and knowledge of 

the property owner(s) or duly authorized representative. 

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to allow 

commercial operations ofUAS conducting aerial flights as described above. 

Respectfully, 

1- d. !.vt(C 

Kevin A. Culbertson 

Swordfish Productions, LLC (d.b.a. Sandpiper Drones) 
APPENDIX A SUMMARY OF SANDPIPER DRONES SECTION 333 EXEMPTION REQUEST 

Sandpiper Drones hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of its UAS in aerial photography/videography. An exemption is requested from the 

following regulations: 

14 C.F.R. Part 21; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 

C.F.R. 91.105; 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)(2); 14 C.F.R. 91.417(a). 

APPENDIXB 

Operating manuals 

http:/ /www.dj i.com/product/phantom/download 

http:/ /www.dj i.com/product/inspire-1 /download 

APPENDIXC 

http://vlww.dji.com/product/spreacling-wingss900/download 

http://www.dji.com/product/spreading-wingss 1 000/download 

For purposes of expediting the exemption process, we are including reference to granted exemption and 

docket numbers for similar organizations utilizing the type ofUAS requested for our exemption and 

organizations which we believe propose a similar justification (NOTE: this list is not meant to be allinclusive): 

DJIPhantom Exemption No. 11418 

Regulatory Docket No. FAA-2015-0184 

Exemption No. 11442 

Regulatory Docket No. FAA-2015-0218 Exemption No. 11416 

Regulatory Docket No. FAA-2015-0182 

Exemption No. 11434 

Regulatory Docket No. FAA-2015-0201 DJI Spreading Wings S-900 

Exemption No. 11437 Exemption No. 11423 

Regulatory Docket No. FAA-2015-0221 Regulatory Docket No. FAA-2015-0152 

Exemption No. 11420 Exemption No. 11400 

Regulatory Docket No. FAA-2015-0178 Regulatory Docket No. FAA-2015-0155 

Exemption No. 11378 DJI Spreading Wings S-1000 

Regulatory Docket No. FAA-2015-0065 

Exemption No. 11439 

DJI Inspire 1 Regulatory Docket No. FAA-20 15-0225 

Exemption No. 11423 Exemption No. 11442 

Regulatory Docket No. FAA-2015-0152 Regulatory Docket No. FAA-20 15-0218 

Exemption No. 11428 Exemption No. 11416 

Regulatory Docket No. FAA-2015-0172 Regulatory Docket No. F AA-20 15-0182 

Exemption No. 11426 

Regulatory Docket No. FAA-20 15-0173