May 5, 2015

 Exemption No. 11468

 Regulatory Docket No. FAA–2015–0259

Mr. Brandon Schulz

Manager

United Dynamics AT Technologies Corp.

2681 Coral Ridge Road

Brooks, KY 40109

Dear Mr. Schulz:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated January 30, 2015, you petitioned the Federal Aviation Administration for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct aerial videography/cinematography to enhance safety and reliability of 

power generation utilities.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI S800 Hex-rotor.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Brandon Schulz is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.
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Conditions and Limitations

In this grant of exemption, Mr. Brandon Schulz is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S800 Hexrotor when weighing less than 55 pounds including payload. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
4

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
5

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
7

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
Brandon Schulz, Private Pilot/UAS Pilot/Inspector - Section 333 E

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Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

January 30, 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 of the Federal Aviation Regulations from 14

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Brandon Schulz, am writing pursuant to the FAA Modernization and Reform Act of

2012 and the procedures contained within 14 C.F.R. 11, to request that I,

Brandon Schulz , an owner and operator of small unmanned aircraft, be exempted

from the Federal Aviation Regulations (“FARs”) listed below so that I, Brandon Schulz,

may operate my small ultra light weight unmanned aircraft system (“UAS”)

commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Brandon Schulz, am a Private Pilot, UAS Pilot, and inspector for 

Fossil and Renewable Power Generation Facilities (read: no Nuclear Power Plants). I 

have built, maintained, and flown remote control helicopters for 15 years and served as 

a flight instructor in multiple recreational flying clubs. I have added a hobby grade hexrotor helicopter1 UAS to my inventory equipped with a Sony camera with intent for

aerial videography/cinematography to enhance safety and reliability of Power 

Generation Utilities; following exemption and approval by the FAA. Thereby

enhancing their safety and reducing costs and environmental impacts caused by 

lack of inspection and maintenance. 

I have flown RC helicopters for over fifteen (15) years without incident. I have logged 

over 3 years of experience with this specific model1. Committed to safety with each

flight. My, Brandon Schulz's, exemption request would permit operation of ultra light

weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) 

in limited airspace.

2

The inherent regulated safety culture within Fossil and Renewable Power Generation 

Utilities provides an ideal ground for preplanned, safe, and controlled UAS inspections.

Currently, similar lightweight, remote controlled UAS's are legally operated by amateur

hobbyists under FAA and AMA guidelines with a high level of safety. I, Brandon Schulz, 

have personally instilled safety

1 Appendix A - DJI S800 Operator Manual 2 Appendix B - Airspace Example

Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition
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protocols and controls3 to avoid and prevent public hazard, as well as manned aircraft 

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight 

UAS's specific to Fossil and Renewable Power Generation Utility inspection usage as

I, Brandon Schulz, record flight data and other information gained through permitted

flight operations to share with the FAA through any required FAA reports to assist with

future protocol and safety regulation.

Granting my, Brandon Schulz's, request comports with the Secretary of Transportation’s

(FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the

national airspace system, but to “...establish requirements for the safe operation of 

such aircraft systems [UAS's] in the national airspace system” under Section

333(c) of the Reform Act specific to the use of UAS's for safety and inspection 

purposes. Further I, Brandon Schulz, will conduct my operations in compliance with 

the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Brandon Schulz, respectfully request the grant of an 

exemption allowing me to operate ultra light weight, remote controlled UAS’s for the 

inspection of Fossil and Renewable Power Generation Utilities to enhance public safety 

and the safety of Fossil and Renewable Power Generation Utility employees. This 

exemption, if granted, will benefit the public through increased safety, lower 

Environmental impacts, and lower energy costs.

I. Contact Information:

Brandon Schulz, Manager

United Dynamics AT Technologies Corp.

2681 Coral Ridge Rd. 

Brooks, KY 40109

Cell: 414-587-4547

Office: 502-957-7525

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which Brandon Schulz Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

3 Appendix C - Personal Protocols and Controls
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Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

III. The Extent of relief Brandon Schulz seeks and the Reason He Seeks Such

Relief:

I, Brandon Schulz, submit this application in accordance with the Reform Act, 112 P.L.

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

me, Brandon Schulz, contemplated commercial inspection, safety and other flight

operations within the NAS. The Reform Act in Section 332 provides for such integration

of civil unmanned aircraft systems into our national airspace system as it is in the

public’s interest to do so. My, Brandon Schulz's, ultra light weight UAS meets the 

definition of “small unmanned aircraft” as defined in Section 331 and

therefore the integration of my ultra light weight UAS is expressly contemplated by the 

Reform Act. I would like to operate my ultra light weight UAS prior to the time period by 

which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that 

can be administered uniformly to all inspections related to UAS aerial video and 

photography. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system. Considerations include: The 

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be 

operated near airports or heavily populated areas; and, Whether the UAS will be 

operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an 

exemption for me, Brandon Schulz. My UAS utilizes six (6) counter-rotating propellers 

for balance, control and stability. My UAS is equipped with GPS and auto return safety 

technology. Weighing less than fifteen (15) pounds (far below the maximum 55 pound

limit); including camera with gimbal.

I, Brandon Schulz, considers safety as foremost with each flight. Every flight is 

carefully planned for the specific task before any operations take place. This 

planning identifis any risks and take in account the airspace to be operated in, flight 

path, public safety, personal safety, maintenance records, and a preflight check of 

the UAS. My small unmanned aircraft is designed to hover in place via GPS and

operate in less than a 24 knot wind. For safety, stability and fear of financial loss I will

not fly in winds exceeding my personal safety maximums and aircraft design). Built in

safety systems include a GPS mode that allows my UAS to hover in place when radio

controls are released. With three modes to choose from. This provides the safest, most 

reliable and stable platform to prevent accident and hazard. When pilot communication 

is lost the UAS has an integrated failsafe that allows it to slowly descend to point of take 

off. I do not operate my UAS near airports, Hospitals, nor Police heliports, and do not

operate near areas where general

public is within fifty to one hundred (50-100) yards depending on location, conditions

and weather. Every flight is preplanned and run through a safety check to ensure the 

general public and other aircraft would not be a risk factor. I am constantly on alert 

for any manned aircraft (Police/Medical helicopters, GA, AG, Commercial etc.) and

prepared to land/abort immediately to the nearest and safest ground point should a

manned aircraft approach my location or I suspect manned aircraft may approach

near my location. In addition, I always fly with a "spotter" for an addition level of safety. 

The spotter supplements my (the PIC) situational awareness by constantly scanning for 

other aircraft as well as people. My UAS is capable of vertical and horizontal operations,
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and are flown only within my line of sight of me, as the remote control pilot. Utilizing 

battery power rather than combustible fuels, flights generally last between five (5) to

fifteen (15) minutes, with an altitude under one hundred fifty (150) feet AGL, or nor 

more than 50ft above the structure of inspection. I, Brandon

Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

Schulz, utilize a fresh fully charged battery with each flight. As a safety precaution;

every battery is charged and tested utilizing a Battery Management System that tracks 

battery condition such as capacity, internal resistance, and voltage. Any battery that 

does not meet its specification after a charge cycle is complete is marked as "not 

airworthy" and discarded. Full flight time limit for each battery is fifteen (15) to twenty

(20) minutes as tested. I do not operate my UAS at or below manufacture

recommend minimum charge levels for operation; preferring to remain well within a

safe operating range to insure adequate communication between radio control and UAS

to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand 

with each exercise to insure replacement for sufficient safe level of operation. I do not

believe in taking risk that may cause a crash, that could create hazard to the

public/property/manned aircraft, and have no desire to lose an investment. I have

clocked numerous practice flights in remote areas as a hobbyist simulating flights for

future commercial use to gain familiarization with the characteristics of this specific

UAS's performance under different temperature and weather conditions. I also practice

computerized simulated flights to maintain adequate skills and response reflex time. All

for the sake of safety.

I, Brandon Schulz, am extremely cautious when operating of my UAS/ultra light weight

unmanned aircraft and will not “create a hazard to users of the national airspace system

or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls

well within Congress’s contemplated safety zone when it promulgated the Reform Act 

and the corresponding directive to integrate UAS's into the national airspace 

system. Douglas Trudeau’s UAS, used in hobby flight, has a demonstrable safety 

record and does not pose any threat to the general public or national security.

IV. How Brandon Schulz's Request Will Benefit the Public As A Whole:

Fossil and Renewable Power Generation Utilities own and operate thousands of 

components that require periodic inspections to meet industry standards. These 

components are often hazardous in nature due to their location or the materials and 

compounds that they contain. Historically the only way to visually inspect these 

components was by means of putting a human, with a camera, in harm's way. 

Dangerous man lifts, buggies, suspended scaffolding, and commercial manned

helicopters are often used. In many cases the inspections are limited or delayed due to 

safety and cost. My ultra light UAS provides the utilities with an inspection that does not 

put humans in harm's way. It allows the components to be inspected without 
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combustible fuels or putting human life at risk. In addition, the public benefits from my 

UAS inspecting Power Generation Utilities due to the inherit safety that is required on all 

plant sites. These locations utilize safety measure from OSHA, NFP, and the NSC by 

training all personal on site before work is conducted. All plant sites are security 

controlled locations with limited access. Safety training is required for every individual on 

site as well as Personal Protective Equipment such as hard hats, safety glasses, proper 

clothing, and steel toed boots. Inspections of components are isolated from the 

personnel on site by means of a "sterile area". Barricades with appropriate signage 

restricts any person from entering the inspection area. This provides a safety blanketed 

environment to integrate UAS operations. As an added measure of safety, Fossil and 

Renewable Power Generation Facilities are also marked on Sectional Charts to provide 

a blanketed level of awareness to all aircraft operating in that airspace in addition to the 

COA and NOTAM that would be required before UAS operations.

Congress has already proclaimed that it is in the public’s interest to integrate 

commercially flown UAS's into the national airspace system, hence the passing of the 

Reform Act. Granting my, Brandon Schulz's, exemption request furthers the public 

interest through safety inspections, environmental inspections, and preventive 

maintenance inspections of Fossil and Renewable Power Generation Utilities. My

ultra light weight UAS is battery powered and creates no emissions that can harm the

environment. The consequence of my ultra light weight UAS crashing is far less

than a full size helicopter or fixed wing aircraft; which are heavy, contain

combustible fuel and can cause catastrophic devastation to the public.
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Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

The public’s interest is furthered by minimizing ecological and crash threat by permitting 

aerial video/photo capture through my battery operated ultra light weight UAS's. 

Permitting me, Brandon Schulz, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially furthers the economic 

impact for the entire United States of America.

V. Reasons Why Brandon Schulz's Exemption Will Not Adversely Affect Safety 

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing 

Rule:

My, Brandon Schulz's, exemption will not adversely affect safety. Quite the contrary, 

for the reasons stated permitting me, Brandon Schulz, to log more flight time in the 

NAS, in communication with the FAA, will allow me to contribute to the innovation and 

implementation of new and novel, as of yet undiscovered safety protocols for 

UAS that can embraced by the FAA for development cooperation. In addition I,

Brandon Schulz, submit the following representations of enhancements to current 

Fossil and Renewable Power Generation Utilities inspections.

My UAS operations would only be performed in secured and sterile locations for 

safety.

My UAS operations would prevent any person (except for myself and the spotter) 

from entering the sterile flight area. 

Anyone inside or outside the sterile flight area would be wearing full Personal 

Protective Equipment

My UAS weighs less than 15 pounds complete with a small ultra light weight

high quality Sony camera;

I only operate my UAS below 200ft AGL or less than 50ft above the highest 

structure;

my UAS only operate for 5-15 minutes per flight;

I land my UAS prior to manufacturer recommended minimum level of battery 

power;

I pilot my UAS through remote control only by line of sight with additional help from 

a spotter;

My UAS has GPS a flight safety feature whereby it hovers and then slowly lands 

if communication with the remote control pilot is lost;

I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols;

I only operate in reasonably safe environment that are strictly controlled and 

are not near airports (unless permission is given) and actively populated areas;

I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance;

I always obtains all necessary permissions prior to operation; and,

I have procedures in place to abort flights in the event of safety breaches or 

potential danger.

Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition
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My, Brandon Schulz's, safety protocols provide a level of safety equal to or exceeding 

existing rules. It is important to note that absent to the integration of commercial UAS 

into our national airspace system, helicopters and aerial man lifts are the primary means

of inspection. While the safety record of these procedures remarkably strong, there has

been injuries and loss of life due to humans being subjected to these calculated risks;

it is far safer to operate a battery powered ultra light weight UAS.

First, the potential loss of life is diminished because UAS's carry no people on 

board and I only operates my UAS in specific areas away from mass populations. 

Second, there is no liquid fuel on board a UAS and thus the potential for

fire or explosions is greatly diminished.

Third, the small size and extreme maneuverability of my UAS allow me to 

remotely pilot away from and avoid hazards quickly and safely.

Forth, the safety blanketed environment of Fossil and Renewable Power 

Generation Utilities (Required safety training, barricades, hard hats, proper 

clothing, secure sites, limited access) is a perfect environment to integrate UAS 

safety into the NAS. 

Lastly, given its small size and weight, even when close enough to capture 

amazing images, my UAS need not be so close to the objects they are focused 

on through the technology and use of post editing software allowing pan and 

zoom.

Accordingly, my UAS has been experimentally operated for familiarization/competency 

and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements 

for procurement of necessary airworthiness certificates in relation to FAR §

91.203(a)(1). The size, weight and enclosed operational area of my, Brandon 

Schulz's, UAS permits exemption from Part 21 because my UAS meets (and 

exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. 

The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My, 

Brandon Schulz's, current and projected UAS's meet or exceed each of the 

elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are 

no on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a
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Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

safety/flight manual delineating areas of where safety can be defined.

4 The FAA

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required certifications and 

registrations by me, Brandon Schulz.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to 

certain specifications. My UAS are, by definition, unmanned. They therefore do not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is difficult to place on such small aircraft with dimensions smaller that 

minimal lettering requirement. Regardless, I will mark its UASs in the largest possible 

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R.

§45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see 

the markings. The FAA has previously issued exemptions to this regulation through 

Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Brandon Schulz, can achieve an equivalent level of safety as achieved by 

current Regulations because my UAS does not carry any pilots or passengers. 

Furthermore, my Private Pilot License and associated NAS knowledge have given me 

the means to understand the NAS and FAR's associated with all operations in the NAS 

and hold my operations to an equal, or higher, safety standard. The risks attended to

the operation of my UAS is far less than the risk levels inherent in the commercial

activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Brandon Schulz, to

operate my UAS meet and exceed current safety levels in relation to 14

C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. My UAS will never 

operate at an altitude greater than 200ft AGL or 50ft above the tallest structure. I, 

Brandon Schulz, will operate my UAS in safe areas away from congested areas, the 

public, and traffic; providing a level of safety at least equivalent to or below those in

relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of

my UAS, an equivalent or higher level of safety will be achieved.

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

4 Appendix E - Safety/Flight Manual
Brandon Schulz, Private Pilot/UAS Pilot/Inspector - Section 333 E

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Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] 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. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my, Brandon Schulz's, UAS. However, as a safety precaution I inspect my 

UAS before and after each flight. Maintenance logs and flights logs will be kept on record and 

with the aircraft.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14

C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, 

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and

enclosed operational area of my UAS permits exemption from Part 21 because my, 

Brandon Schulz's, UAS meets an equivalent level of safety pursuant to Section 333 of

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My 

UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation

of an aircraft without an airworthiness certificate. As no such certificate will be 

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738,

9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software 

updates and curative measures for any damaged hardware. Therefore, an equivalent 

level of safety will be achieved.

In summary, Brandon Schulz seeks an exemption from the following

Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 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. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (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. §

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Brandon 

Schulz's, small unmanned vehicle/lightweight unmanned aircraft vehicle in Power 

Generation Utility inspection operations at an equal or higher level of safety congruent 

to these regulations.

Currently, Fossil and Renewable Power Generation Utility inspections require use of

larger aircraft running on combustible fuel or aerial man lifts. Granting my, Brandon 

Schulz's, request for exemption will reduce current risk levels and thereby enhance 

safety. My UAS craft do not contain potentially
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Brandon Schulz, Private Pilot/UAS Pilot/Inspector- Section 333 Exemption Petition

explosive fuel, is smaller, lighter and more maneuverable than conventional manned 

helicopters. Further, I operate at lower altitudes and in limited airspace eliminating

potential public risk flying to and from established air fields. I, Brandon Schulz, have

been informally analyzing flight information and will compile safety protocols and 

the implementation of a flight operations manual for Fossil and Renewable Power 

Generation Utility inspection usage that exceeds currently accepted means and methods 

for safe flight. Formal collection of information shared with the FAA will enhance

the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my, Brandon 

Schulz's, UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. My, Brandon Schulz's, operation of my UAS, weighing less 

than 15 pounds and travelling at lower speeds within limited areas will provide

an equivalent level of safety as that achieved under current FARs. Accordingly I,

Brandon Schulz, respectfully request that the FAA grant my exemption request and am

willing to cooperate in sharing information to benefit the FAA, safety of manned

aircraft, and the general public at large.

Respectfully submitted,

Brandon Schulz, Manager

United Dynamics and AT Corp.

2681 Coral Ridge Rd.

Brooks, KY 40109
Appendix A

DJI S800 Hex-rotor

Operator Manual

URL Below

http://download.dji-innovations.com/downloads/s800/S800_User_Manual_en.pdf

Hyper Link Below

S800 Manual
Brandon Schulz, Private Pilot/UAS Pilot/Inspector, UDC Brooks, KY

Appendix B

Airspace 

Example
Brandon Schulz, Private Pilot/UAS Pilot/Inspector, UDC Brooks, KY

Fossil Power Generation Utility

Airspace Example*

*This example is intended as a theoretical sample only and does not identify all hazards and risks but 

rather points out a select few that may be considered before a UAS flight is considered. Educational 

purposes only. Do not use for navigation.

Identifier Consideration

Fossil Power Generation Facility-- Use to Identify exact location for NOTAM

 Victor Airway 234----------- Be aware of aircraft on Victory Airway 234

 Transition Area---------- Be aware of aircraft on long final for RWY18

 Public Airport KSAR----- Notify Airport/Distance >5sm

DO NOT USE FOR NAVIGATION
Appendix C

Brandon Schulz

Personal Protocols and Controls
Brandon Schulz, Private Pilot/UAS Pilot/Inspector, United Dynamics and AT Page 1

Corporation Brooks, KY

Protocols and Controls

Fossil and Renewable Power Generation Facilities

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight.

Pre-Flight Protocol:

Obtain any NOTAMs, TFR's, etc before flight. 

Check batteries with Battery Management System to insure fully charge.

Inspect batteries for damage or leakage that may affect proper operation.

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight.

Consult Sectional Charts to identify airspace and location. 

Obtain a weather briefing for the flight area. 

o Contact any local airports to advise of estimated flight time, estimated flight duration,

estimated elevation of flight in addition to filing for a NOTAM. 

Inspect flight area for

o vicinity of public safety helipads/heliports

o vicinity of medical helipads/heliports

o vicinity of light poles

o vicinity or utility wires

o vicinity of trees

o flocks of birds that may cause interference and potential flight impact

o vicinity of any elevated obstructions that may pose potential flight hazard 

o vicinity of roadways with moderate to heavy traffic that can be distracted 

o public gatherings that may attract viewers

o optional point of control for best visual site of UAS while in flight

Takeoff and landing

o inspect area for best and safest point of takeoff and landing

o Erect a barricade that is consistent with plant site restricted space and post signage.

Flight Protocol:

takeoff and land from same location

remain alert to birds, sound or aircraft, curious public, and approaching vehicles

do not allow anyone to engage in conversation or distract the remote control pilot 

restrict flight to minimal elevation sufficient to acquire desired results

remained prepared for emergency landing at all times

pay attention to flight time

o Programmed alarm on the pilot's remote and UAS will signal battery levels

land UAS and shut down propulsion immediately following landing
Brandon Schulz, Private Pilot/UAS Pilot/Inspector, United Dynamics and AT Page 2

Corporation Brooks, KY

Protocols and Controls

Fossil and Renewable Power Generation Facilities

Post flight:

a. disconnect battery to prevent accidental activation of propulsion system 

b. secure UAS in a safe location

c. remove all barricades and signage in accordance with plant site procedures

Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

o manned aircraft is heard or seen in vicinity of flight

o there is a public gathering within established safety boundary wanting to observe flight

o pilot is being distracted from focusing on flight and safety

o sudden change in weather

o sudden increase in vehicular traffic in vicinity of flight

o birds enter into proximity of flight

o any sudden unsafe event that can cause collision, distraction or interruption of control
Appendix E

Brandon Schulz

Safety/Flight Manual
Brandon Schulz, Private Pilot/UAS Pilot/Inspector, United Dynamics and Page 1

AT Corp. Brooks, KY

Safety Flight Manual

Fossil and Renewable Power Generation Facilities

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography

inspections. Maintaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative.

Date: Location:

Pre-flight Inspection: Yes No Comment:

Elements (circle) (circle) Comment

Ceilings Go No Go

Visibility Go No Go

Wind Speed Go No Go

Proximity to airport: (see attached map pinpointing approximate location of flight) 

Airport notified Yes No Date: Time:

Phone Number: Contact Name: 

Nearest major structure:

Proximity to medium traffic road:

Proximity to heavily traveled roadway road:

Proximity to congested population:

Approx. Takeoff Time

Approx. Landing Time

Estimated Elevation

Safety Concerns:

Additional Comments:

Unedited flight video/photos available for FAA upon written request within 180 days of flight: Yes No