January 29, 2015 

Precision Unmanned Aerial, LLC 

1056 Snidow Dr 

West Linn, Oregon 97068 

305-218-5954 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 

91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b). 

Dear Sir or Madam: 

I am the Precision Unmanned Aerial {PUA), LLC, managing member, and currently the Director 

of Operations on a Part 135 certificate. I hold three airline transport pilot ratings (ASEL, MSEL, 

Rotorcraft) and have been conducting the types of operations of interest to PUA, LLC in 

conventional aircraft for several years. We operate Precision Unmanned Aerial, LLC at the 

highest level of safety possible while lowering the operational risks to the public. One of our 

main goals is to bring awareness to the general public and noncommercial operators about safe 

UAS operation. We are currently working on computer based software to help operators who 

are not pilots understand the National Airspace System (NAS) so they will not violate airspace 

when flying recreationally. We believe all UAS noncommercial operators should be required to 

complete some kind of educational course upon purchase of a UAS. We look forward to helping 

the FAA with any research needed for establishing UAS rules and regulations. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and 14 C.F.R. Part 11, Precision Unmanned Aerial, LLC, an operator of Unmanned Aircraft 

Systems ("UAS") specializing in aerial photography for: yacht photography, land surveying, real 

estate photography, motion picture and television industry and search operations is applying 

for an exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation 

of its UASs, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. As described below, the 
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requested exemption would permit the operation of small UAS under controlled conditions. 

Approval of this exemption would thereby enhance safety and fulfill 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." Section 333(c) of the 

Reform Act. 

The name and address of the applicant is: 

Name: Precision Unmanned Aerial, LLC 

Attn: 

Email: 

Address: 

Ryan Swakon 

rswakon@precisionunmannedaerial.com 

1056 Snidow Dr 

West Linn, OR. 97068 

Phone: 305-218-5954 

Regulations from which the exemption is requested: 

• 61.113(a) & (b) 

• 91.7 (a) 

• 91.103 

• 91.119(c) 

• 91.121 

• 91.151(a) 

• 91.203(a) & (b) 

• 91.405(a) 

• 91.407(a)(1) 

• 91.409 (a)(1) & (2) 

• 91.417(a)&(b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national 

airspace system (NAS) before completion of the rulemaking required under Section 332 of the 

Reform Act. In making this determination, the Secretary is required to determine which types of 

UAS do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 
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• The UAS's size, weight, speed, and operational capability 

• Operation of the UAS in close proximity to airports and populated areas 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system." I d. §333(c). 

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 under 

§40101 of the Act, and UASs from the requirement that all civil aircraft must have a current 

airworthiness certificate. The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S. C. §44701(f) See 

also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Such operations will insure that the UAS will not create a hazard to users of the national 

airspace system or the public. Given the small size of Precision Unmanned Aerial, llC UASs and 

the environment within which they will operate, Precision Unmanned Aerial, llC UAS 

operations adhere to the Reform Act's safety requirements. Additionally, approval ofthis 

application presents no national security issues. Based on the substantial level of safety 

surrounding the proposed operations, and the significant public benefit (enhanced safety), 

reduction in environmental impacts (reduced emissions and noise), the grant of the requested 

exemption is in the public interest. Accordingly, Precision Unmanned Aerial, LLC respectfully 

requests that the FAA grant the requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

Precision Unmanned Aerial, LLC currently operates two different types of UASs and has 

plans to add an additional model to our fleet the second quarter 2015. 

• DJI Phantom 2 (Currently) 

• DJI Inspire 1 

• DJI SlOOO 

(Currently) 

(SQ- 2015) 

Both the Phantom 2 and the Inspire 1 are highly successful consumer grade UAS 

Quadcopters designed to carry a high definition (HD) camera powered by four electric motors. 

It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor 
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augmented with global positioning system (GPS) to maintain its geospatial orientation and 

position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time 

video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from 

PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either 

loss of RC or GPS signal. Altitude can be limited by the on board flight controller system and 

maximum altitude can be preprogrammed by the PIC. The flight controller/ipad will warn the 

pilot via telemetry and external lighting cues before reaching a low battery state. An automatic 

termination of flight and landing will be initiated when the battery reaches a predetermined 

low state. 

All UAS operations conducted by Precision Unmanned Aerial, LLC will: 

• Weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). 

• Operate at speeds of no more than 50 knots, can hover, and can simultaneously move 

vertically and horizontally. 

• Only operate its UAS in line of sight of the operator (PIC). 

• Limit each operational flight to 30 minutes or less. Flights will be terminated at 25% 

battery power reserve should that occur prior to the 30 minute limit. 

• Operated at an altitude of no more than 400 feet AGL. 

• Be operated by a FAA licensed airman with at least a private pilot's certificate and third 

class medical. 

• Be operated at a lateral distance of at least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have not 

signed a waiver in advance of the operation. 

• Require operators (PIC) to check for any Temporary Flight Restrictions (TFR) by calling 

1800 WX Brief and a current sectional chart for the area of operation to make sure they 

will not violate National Airspace System (NAS). 
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• Have the capability to return to a pre-determined location if the UAS loses 

communications or loses its GPS signal 

• Have the ability to communicate if needed by Radio or Phone. Operators (PIC) during all 

UAS operation have the local Flight Standards District Offices (FSDO) and the closest 

airport control towers phone number and frequency. 

• Be entered and tracked in our aircraft management software. The software tracks all of 

the components of the UAS as well as flight time for the UAS and pilot. It will not allow 

maintenance to be overflown, thereby enhancing the safety of the program. 

DISCUSSION OF EXCEPTIONS REQUESTED 

14 C.F.R. § 61.113{a) and (b): Private Pilot Privileges and limitations: Pilot in Command 

Sections 61.113 (a) and {b) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have a private pilot's license rather than a commercial pilot's license to operate a 

small UAS. 

Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground-based 

Operator. The operational area is controlled and restricted, and all flights are planned and 

coordinated in advance. The level of safety exceeds that provided by a single individual holding 

a commercial pilot's certificate operating a conventional aircraft. The risks associated with the 

use of a UAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 allowing UAS use by a private pilot as the PIC exceeds the present 

level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.7 (a) Civil aircraft airworthiness 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

Since no FAA regulatory standard exists for determining airworthiness of the UAS, the 

regulation will need an exemption. Precision Unmanned Aerial, LLC compliance with our 

operating documents will be sufficient means for determining an airworthy condition. 
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14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the 

safety of flight. 

As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety will be provided. The PIC will take all actions, including 

reviewing weather, flight battery requirements, Notices to Airmen (NOT AM), landing and 

takeoff distances, and aircraft performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, 

in pertinent part, that: 

" ... except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: ..... 

(b) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure." 

Because Precision Unmanned Aerial, LLC requests authority to operate at altitudes only up to 

400 AGL, an exemption is needed to allow such operations. 

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 

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: 
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"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 far at least 30 

minutes; or (2} At night, to fly after that for at least 45 minutes." 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUASflights would be limiting factor. 

Given the limitations on the UAS on exemption may be needed. 

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 o civil aircraft unless it has 

within it the following: {1} on appropriate and current airworthiness certificate. 

{b) No person may operate o 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 weigh is no more than 55 lbs and is operated without an on board pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the UASs. An equivalent level of safety will be achieved by keeping these documents at 

the ground control point where the controller (PIC) of 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 section 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 these UAS are very limited in size and will carry a small payload. 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 
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flight, perform required maintenance, and keep a log book of any maintenance performed as 

well as track all flight hours. 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 Manual, as referenced in the Aircraft 

Operations Manual. As provided in the Operations Manual, the operator will ensure that the 

UAS is in working order prior to initiating flight and perform required maintenance needed. 

SUMMARY FOR PUBLICATION 

Precision Unmanned Aerial, LLC seeks an exemption from the following rules: 

14 CFR 61.113(a) & (b); 91.7 (a); 91.103;91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) &(b). 

To operate commercially small unmanned vehicle (SSibs or less) in yacht photography, land 

surveying, real estate photography, motion picture and television industry and search 

operations. Approval of exemptions allowing UASs commercial operations in the areas list 

above will enhance safety by reducing risk. A UAS weighing fewer than 55 lbs. and powered by 

batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 

carried on board traditional aircraft performing the same function. The UAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights. The operation of small UAS conducted in the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These UASs operate at very slow speeds, close to the ground, as a 

result, are far safer than conventional operations conducted with turbine helicopters operating 

in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled areas with the property owner's prior consent 

and knowledge. Filming will be only of people who have given their consent or otherwise have 

agreed to be in the area where filming will take place. Satisfaction of the criteria provided in 

Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proximity to 

airports and populated areas and operation within visual line of sight and national security) 

provide more than adequate justification to grant Precision Unmanned Aerial, LLC requested 

exemption. 
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February 2, 2015 

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If you have any questions or need any additional information, please contact me at 305-218-

5954 or rswakon@precisionunmannedaerial.com 

Sincerely, 

Precision Unmanned Aerial, LLC 

/ ~f 

on/ 

~· -

Managing Member