Exemption Request under Section 333 of the FAA 

Reform Act and Part 11 of the Federal

Aviation Regulations

Matthew Schumann/Schumann Granite

10046 Hwy 290 East Suite A. 

Fredericksburg Texas 78624

210-200-9929

mpschumann@yahoo.com

Aerial imaging for agriculture, construction/architecture, and real estate

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

THE UNMANNED AIRCRAFT (UA):

• DJI Phantom Professional, is lightweight (under 15 lb. gross weight), battery operated

Multi-Rotors that takes off and land vertically.

THE UA INCLUDES:

• An on-board flight computer with GPS navigation and location ability that receives signals for

flight controls from a ground-based transmitter/controller;

• A Gimbal with a camera capable of capturing imagery in the form of full color, high
definition still photos and video

• An on-board telemetry system that delivers flight data from the on-board flight computer to the

on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass

direction of flight and direction back to its launch site

• A 5.8GHz on-board radio transmitter that transmits live video from the on-board camera plus all

the flight data from the telemetry system described above

THE GROUND STATION PART OF THE SYSTEM:

• A Pilot in Command (PIC) who will be in operational control of the mission from beginning to

end, and who controls the UA while in the air

• A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA

while in flight.

• The DJI includes a 2.4GHz radio transmitter/controller operated by the PIC to control the UA

while in flight

• The DJI Phantom 2 Ground Station DJI Vision App which receives and displays video and system

telemetry real time from the UA

UAS OPERATING GUIDELINES:

UA's will be operated in the field with both a PIC and aVO in accordance with the following Restrictions:

• All operations must occur in FAA Class G airspace at no more than 400ft AGL, at airspeed of no

more than 25 knots and always within Visual Line of Sight.

• All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate

by voice at all times during a flight operation

• The PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51 (b), 10 hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot

with a similar UA type

• The UA will not be operated over densely populated areas; without prior approval

• The UA will not be operated over any open-air assembly of people; without prior approval
• The UA will not be operated within 5 NM of an airport or heliport; without prior approval

• The UA will not be operated at air shows

• Operations will be restricted to day only and weather conditions equivalent to VFR

• The PIC will brief the VO and property owner about the operation and risk before operation

• No flight will be made without a Pre-Flight Inspection by the PIC before each operation to

ascertain that the UA is in a condition safe for flight

PILOT IN COMMAND (PIC) AND VISUAL OBSERVER:

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel

Qualifications. Additionally, the PIC will hold at a minimum, a current Sport Pilot certificate. The PIC will

perform maintenance on the system in accordance with manufacturer guidelines and/or instructions.

In the event the PIC cannot perform maintenance, the UA will be returned to the manufacturer or a

manufacturer certified technician to perform any necessary repairs.

I submit that the combination of the UA's light weight, flight performance and ability, fully qualified

flight crew and strict operation under the guidelines established in 8900.227, and under all of the

Restrictions listed above, the FAA can have full confidence that the operation will have an equivalent or

greater level of safety than manned aircraft performing the same mission.

INTENDED USE:

The requested exemption would allow us to use the UA for aerial image acquisition to support various

mapping and surveying applications as well as video documentation for the public good. Typical

applications would include, but are not limited to:

• Aerial Photography

• Aerial Surveys

• Volumetric Surveys

• Architectural Surveys

• Bridge Inspections

• Utility Corridor Vegetation Management

• Building Inspection Surveys
• Disaster Response

PUBLIC SAFETY:

UA's, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel; they operate at lower altitudes (under 400') and weigh less than 31bs with

no people on board thereby reducing current risk levels and enhancing public safety. With a small

payload and maximum flight time of approximately 22 minutes, UA's offer little or no risk to national

security.

SUMMARY GRANT REQUEST:

This request follows many others using similar systems and process that have been granted previously. I

am requesting the FAA issue a summary grant of exemption as this request would not set a precedent.

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213

also apply to this request

• A grant of exemption would be in the public interest

• Denial of this exemption request would unfairly limit our ability to provide these services to our

clients

THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED

Beside each regulation number is the page of the attached Addendum upon which each may be found

together with a proposed equivalent level of safety for each regulation:

- 14 CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a) (1) Addendum Page 1

- 14 CFR 45.23 (b) Addendum Page 1

- 14 CFR 91.7 (a) Addendum Page 2

-14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 Addendum Page 3
- 14 CFR 91.151 Addendum Page 3

- 14 CFR Subpart E (91.401- 91.417) Addendum Page 4

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level

of safety. Please contact us at any time if you require additional information or clarification.

I am the primary point of contact for this request and look forward to working with your office.

Matthew Schumann

10046 Hwy 290 East Ste A.

Fredericksburg Texas 78624