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 of Transportation 

Docket Management System 

1200 New Jersey Ave. 

SE Washington, DC 20590 

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.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 

Following the format of the 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 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, 

Drew, a licensed Real Estate Broker in the state of California, preparing this exemption request myself 

would like to apply from an exemption from the following Code of the Federal Regulations (C.F.R.) to be 

allowed commercial operation of lightweight Unmanned Aircraft Systems (UAS) for aerial imaging and 

video of San Diego Landmarks, and Real Estate our company is engaged in selling. 

I have over 20 years of experience in the fixed wing model aircraft world, and recently have been flying 

single and multirotor rc's for over 2 years now without any incidents. I just added a professional grade 

TBS Discovery Pro to my lineup and have equipped it with a GoPro Hero 4 Black camera. The maximum 

gross weight is 1200 grams (2.64 lbs) full takeoff weight. This aircraft is equipped with four rotors that 

are driven by four 900kv electric motors with a maximum speed of 25 mph. My intent is for aerial 

videography/cinematography to enhance academic community awareness and augment real estate 

listing videos; 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 examining the area of aerial observation. 

This would allow for community videos 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 of safety at least equal to existing rules and will only operate in a safe environment that is strictly 
controlled, are away from power lines, elevated lights, airports and actively populated areas; and 1 will 

conduct extensive preflight inspections and protocols, during which safety carries primary importance. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, 1 am 

asking exemption from 12CRFpart21, Subpart H (Airworthiness Certificates) and §91.203 (a) and (b) 

(Certifications required), subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14CFRpart11 and Section 333 of P.L. 112-95 

(Section 333) 

14 C.F.R. 45.27 (a): location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3)(c)(d)(e)(f)(h): Size of 

Marks 

Furthermore I request and exemption from §45.23 Marking of the aircraft because my UAS does not and 

will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally 

two inch letter is difficult to place on such a small aircraft with dimensions smaller than the minimal 

lettering requirement. I understand the need for markings and will mark my UAS in the largest possible 

letter by placing the word "Experimental" or assigned number or name (based on a request or ruling by 

the FAA) on its fuselage as required by §45.29(f) so that anyone assisting him as a spotter will see the 

markings. 

I also 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 they only apply to aircraft with 

an airworthiness certificate. But, as a safety precaution I will reform a preflight inspection of my UAS 

before each flight as outlined in this operating document. 

14 C.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 I can achieve 

an equivalent level of safety as achieved by current regulations because my UAS does not carry any 

pilots or passengers. While helpful, a pilot's license will not ensure remote control piloting skills. The 

risks of operating a UAS are far less than the risk levels inherent in the commerc.ial activities outlined in 

14 CFR part 61, et seq., I also will be operating my UAS below 300 feet, in visual line of sight, and not 

within 5 miles of an airport. I request an exemption from §61.113 Private Pilot Privileges and 

Limitations. 

14 C.F.R. 91.103 (b) (1), (b)(2): Preflight Action 

If granted an exemption I agree to additional safety procedures including, but not limited to: 

1. Keeping my UAS within a radius of 1000 feet the controller and PIC 
2. Operate the UAS for flights less than 10 minutes, land my UAS according to the manufacture's 

recommend minimum level of battery power. 

3. Operate my UAS only within visual line of sight (VLOS}. 

4. Use the UAS's global positioning system GPS flight safety feature; it hovers at a pre-determined 

altitude then returns to the location it took off from and lands safely if communication is lost from the 

remote control. 

5. Conduct all flight operations during the day 

6. Wear flight operations neon orange vests, with a sign stating 11Attention Aerial Photography in 

Process- Please Remain back 150 feet". I will also identify the landing 50'x50' landing zone with 4 

orange triangular markers. Images have been included with my submission. 

7. Contact respective airports if operation will be within 5 miles to advise them of estimated flight time, 

duration, elevation and any other pertinent information. 

8. Always obtain all necessary permission prior to flight operations 

9. Log all flights in my UAS Pilot Log, along with any aircraft maintenance 

10. Always operate the UAS with a second person acting as spotter 

Aerial videography for geographical awareness of Real Estate has been around for decades through 

manned fixed winged aircraft and helicopters, but for a small business owner like myself the cost is too 

prohibitive to apply to my business. Granting me this exemption would allow me to achieve the same 

professional quality images as a helicopter, but with much less risk and environmental impact. My small 

UAS will pose no public threat given its small size and lack of combustible fuel when compared to a 

manned aircraft. The operation of this UAS will minimize ecological damage to sensitive areas and 

promote economic growth by providing information to companies and individuals considering relocating . in the San Diego area.