Drew Schulte SDHS Inc. DBA: San Diego Home Sales 2683 Via De La Valle G-227 Del Mar, CA 92014 April 20, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave. SE Washington, DC 20590 Subject: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14C.F.R. Part 21, 45.27(a), 45.29(3)(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151 Followingthe format ofthe FAA Exemption No. 11138- Regulatory Docket No. FAA- 2014 -04811 have included: 1. Supplemental Response for Petition 2. TBS Discovery PRO User Manual 3. Personal flight operations safety controls Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14C.F.R. Part 11, I, Drew, a licensed Real Estate Broker in the state ofCalifornia, preparingthis exemption request myself would like to apply from an exemption from the following Code ofthe Federal Regulations (C.F.R.) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (UAS) for aerial imaging and video ofSan Diego Landmarks, and Real Estate our company is engaged in selling. I have over 20 years ofexperience in the fixed wing model aircraftworld, and recently have been flying single and multirotor rc's for over 2years nowwithout any incidents. Ijust added a professional grade TBS Discovery Pro to my lineup and have equipped itwith a GoPro Hero 4 Black camera. The maximum gross weight is 1200 grams (2.64 lbs) full takeoffweight. This aircraft is equipped with four rotors that are driven by four 900kv electric motors with a maximum speed of25 mph. Myintent is for aerial videography/cinematographyto enhance academic community awareness and augment real estate listingvideos; following an exemption and approval by the FAA. My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote control} in a predetermined area away from general public, airports, heliports and vehicular traffic, under 300 feet and after carefully reviewing, inspecting and examiningthe area ofaerial observation. This would allowfor communityvideos and within property boundaries for individual homeowners real estate listings videos/photos. I will abide by all FAA requirements to ensure this exemption will provide a level ofsafety at least equal to existing rules and will only operate in a safe environmentthat is strictlycontrolled, are away from power lines, elevated lights, airports and actively populated areas; and 1will conduct extensive preflight inspections and protocols, during which safety carries primary importance.

14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 Given the size, weight, speed, and limited operatingarea associated with the aircraftto be utilized, 1am asking exemption from 12CRFpart21, Subpart H (Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required), subjectto certain conditions and limitations, is warranted and meetsthe requirements for an equivalent level ofsafety under 14CFRpart11 and Section 333 of P.L. 112-95 (Section 333)

14C.F.R. 45.27 (a): location of marks; non fixed-wing aircraft. 14C.F.R. 45.29 (3)(c)(d)(e)(f)(h): Size of Marks Furthermore I request and exemption from §45.23 Marking ofthe aircraft because my UAS does notand will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two inch letter is difficultto place on such a small aircraftwith dimensions smallerthan the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible letter by placingthe word "Experimental" or assigned numberor name (based on a request or ruling by the FAA) on itsfuselage as required by §45.29(f) so that anyone assisting him as a spotterwill see the markings. Ialso ask for an exemption from §91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be required and should be granted since theyonly applyto aircraftwith an airworthiness certificate. But, as a safety precaution Iwill reform a preflight inspection ofmy UAS before each flight as outlined in this operating document.

14C.F.R. 61.113 (a) 

### & (b) : Private pilot privi,leges and limitations: Pilot in command. Under §61.113 (a) 

### & (b) private pilots are limited to non-commercial operations, however Ican achieve an equivalent level ofsafety as achieved by current regulations because my UAS does notcarry any pilots or passengers. While helpful, a pilot's license will not ensure remote control piloting skills. The risks ofoperating a UAS are far less than the risk levels inherent in the commerc.ial activities outlined in 14CFR part 61, et seq., I also will be operating my UAS below 300 feet, in visual line ofsight, and not within 5 miles ofan airport. I request an exemption from §61.113 Private Pilot Privileges and Limitations.

14C.F.R. 91.103 (b) (1), (b)(2): Preflight Action Ifgranted an exemption Iagree to additional safety procedures including, but not limited to: 1. Keeping my UAS within a radius of 1000feet the controller and PIC2. Operate the UAS forflights less than 10 minutes, land my UAS accordingtothe manufacture's recommend minimum level of battery power. 3. Operate my UAS onlywithin visual line ofsight (VLOS}. 4. Use the UAS's global positioning system GPS flight safetyfeature; it hovers ata pre-determined altitudethen returns to the location ittook offfrom and lands safely ifcommunication is lostfrom the remote control. 5. Conduct all flight operations duringthe day 6. Wearflight operations neon orange vests, with a sign stating 11Attention Aerial Photography in Process- Please Remain back 150feet". Iwill also identifythe landing 50'x50' landing zone with 4 orange triangular markers. Images have been included with mysubmission. 7. Contact respective airports ifoperation will be within 5 milesto advise them ofestimated flighttime, duration, elevation and any other pertinent information. 8. Always obtain all necessary permission priorto flight operations 9. Log all flights in my UAS Pilot Log, along with any aircraft maintenance 10. Always operatethe UAS with a second person acting as spotter

Aerial videographyforgeographical awareness of Real Estate has been around for decades through manned fixed winged aircraft and helicopters, butfor a small business owner like myselfthe cost is too prohibitive to applyto my business. Granting me this exemption would allow me to achieve the same professional quality images as a helicopter, butwith much less risk and environmental impact. Mysmall UAS will pose no public threatgiven its small size and lack ofcombustible fuel when compared to a manned aircraft. The operation ofthis UAS will minimize ecological damage to sensitive areas and promote economic growth by providing information to companies and individuals considering relocating 

# . inthe San Diego area.