March 18, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), Schultz ATM (the operator), Jordan Schultz (the applicant), planned operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography and survey for various industries hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operations of their sUASs, 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 more fully below, the requested exemption would permit the operation of sUAS by the applicant for commercial use that would provide the following benefits:

1. Operations would be performed in an area of operation limited in size suitable to the specific use, in advance of flight. 2. The flight would be planned in advance to minimize hazards to persons and property in the air and on the ground. 3. The operator would reasonably limit or control access to provide safety to those not involved in the operation. 4. Operation of a sUAS would provide significant safety, environmental and other enhancements not possible by larger sized aircraft. 5. An FAA licensed airman with a Private grade or higher pilot certificate would operate the sUAS or directly supervise the operation. 6. Provide a beneficial and currently unavailable service to government organizations and the general public that would serve the public interest.

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 applicant has logged over 4000 hours of flight time while holding FAA commercial certificates in fixed wing, helicopter and glider categories. The applicant is also an active Certified Flight Instructor (CFI) in rotorcraft and fixed wing aircraft. Utmost safety and professionalism will continue to be utilized at all times in full-size and unmanned aircraft.It is possible to operate the sUASs so to not create a hazard to users of the National Airspace System (NAS), the public or pose a threat to national security if done so safely and responsibly.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics of sUAS and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure as the proposed operations represent a safety enhancement to the already safe aerial commercial photography and survey operations conducted with conventional aircraft.

The sUAS planned to be operated is a rotorcraft aircraft weighing 55 lbs or fewer pounds including payload. The sUAS would operate, under normal conditions, at a speed of no more than 30 knots. Operations will be performed by a qualified sUAS PlC, as outlined below, to insure that the sUAS will "not create a hazard to users of the national airspace system or the public." Given the small size of the sUAS involved and the pre-planned environment within which it will operate, the applicant believes that these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence immediately. Also, operation in a researched (to include applicable NOTAMs), pre-defined area will prevent the possibility of a national security issue. The operation of sUASs by knowledgeable professionals with experience in the NAS will serve to enhance safety, add to the public benefit and reduce environmental impacts related to current methods of aerial photography and survey.

These limitations and conditions to which the operator, or it's employees, acting as sUAS PIC agrees to be bound when conducting commercial operations under an FAA issued exemption:

1. Safety will be the first and foremost consideration in any sUAS operation. 2. sUAS pilot will be an FAA licensed airman with at least a Private Pilot certificate or the sUAS pilot will be directly supervised by an FAA licensed airman with at least a Private Pilot certificate. 3. The sUAS FAA licensed airman will be considered Pilot in Command (PIC), whether flying or supervising, and will be responsible for safe operation of the flight. 4. Flights will be operated within line of sight of the PIC and/or an observer. 5. The sUAS will weigh less that 55 lbs total. 6. Flights will be operated in Class G airspace whenever possible. If operation in other airspace is required, the relevant controlling agency will be notified at least 24 hours prior to the operation and, if required, any necessary permission obtained. 7. Flights will be operated under visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR). 8. The sUAS will at all times give way to any aircraft carrying persons.9. The sUAS will not operate above an altitude of 400 AGL (above ground level). 10. All operations will be required to utilize a Visual Observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO and PIC must be able to communicate verbally at all times. 11. All operations will initially establish and area of operation that will include a defined lateral and vertical area where the sUAS will operate. Safety procedures will be established for persons, property and applicable airspace within the area of operation. 12. Flight planning will include flight completion with at least 25% battery power remaining as measured by the sUAS or applicable timing methods. 13. The sUAS will utilize GPS navigation, failsafe, return-to-home (RTH) and/or flight abort safety features. 14. All operations will include a safety briefing with all participants being present. 15. All required permission and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 16. Written, to include electronic, and/or oral permission from the relevant property owners will be obtained prior to an operation. 17. The sUAS pilot will be trained in advance for the safe operation of the sUAS to be operated. This will include operation of the sUAS both in normal and emergency modes of operation, and will include familiarization with the operation manual (or similar) if published by the sUAS manufacturer. Training will also include types of maneuvers to be performed and the safe operation in relation to persons, property and applicable airspace.

It is the applicant's belief that the size, speed, operating environment, limitations and level of applicant's experience in the NAS outlined provides an "equivalent level of safety" or better when operating a sUAS for the public interest as outlined in Section 333 in the FAA Modernization and Reform Act of 2012. lt is requested that the FAA issue an exemption to permit safe, legal, commercial sUAS operation by the applicant as soon as possible.

Sincerely,

Jordan Schultz Schultz ATM 10418 Shire Country San Antonio, TX 78254Appendix A

Exemption Requests and Equivalent Level of Safety

Schultz ATM requests an exemption from the following regulations as well as any additional regulations that may technically to apply to the operation of sUAS’s:

14 CFR Part21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for UAS, we request an experimental certificate be issued for the sUAS's operated by the applicant under either or both of the following provisions: 21 .191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property and will only fly under strict operational requirements. Combined with the fact that any aircraft operated would be light weight and is constructed primarily out of foam or plastic, we propose that a sUAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same function. lf an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.119 Minimum safe altitudes: General. The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained, and careful pre-planning has been performed. Further, sUAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and careful pre-planning would provide an equivalent level of safety.14 CFR 91.121 Altimeter settings. The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The sUAS will normally be flying close to the ground, and in line of sight of the PIC and VO. This line of sight operation will provide separation from other aircraft, obstructions and terrain, and would override the use of an altimeter for such a purpose. We feel that this will provide an equivalent level of safety.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide a reasonable reserve of energy to plan for a safe landing should there be a delay in landing. The close proximity to the ground station, the ability for rotorcraft to land in a very small space and the built in energy level monitoring of the sUAS we feel provide an equivalent level of safety if the flight is planned to be completed with 25% battery energy remaining. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. lt is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." Prior to every flight, the PIC will inspect the aircraft to ensure that it is in an airworthy condition. Any general maintenance procedures or replacement of consumable items outlined by the sUAS manufacturer, if applicable, will be complied with by the PlC. ln no circumstance will a sUAS be operated in a condition that is deemed, or suspected to be, unsafe. lf such a determination is reached, and the problem cannot be remedied to the satisfaction of the PlC, the sUAS will not be operated until consulting with the manufacturer or one of it's authorized dealers to complete necessary repairs. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.