May 28, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC20590 

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

Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Jason 

Schott, the operator of small Unmanned Aircraft Systems ("sUAS"), seeks an exemption from the Federal Aviation Regulations 

("FARs") listed below and discussed in Appendix A. Attached as Attachment 8 and Attachment C is a summary of this request. 

The requested exemption would permit commercial operation of lason Schott sUAS's, which weigh approximately 5 Ibs. and 

performs aerial surveys and videography that consists of still photographs and videography tnken by on board cameras. The 

sUAS's takes a series of high quality, still digital images and video that are used to promote real estate sales and survey in 

Colorado. Additional aerial inspections/survey applications may include construction jobsite monitoring, pipeline inspection and 

precision topological surveys. Use of the sUAS for aerial inspections and surveys reduce the need to utilize conventional manned 

aircraft, manned lifting devices or manned climbing for the same purpose and provides very high quality imagery at a fraction of 

the cost. These savings result in enhanced safety, efficiency and productivity for the affected activities, as well as environmental 

benefits. 

Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent 

level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as 

required by Section 333. 

As described more fully below, the requested exemption would authorize commercial operations of aerial photos, video and 

inspections or surveys using the sUAS's, which weigh less than 5 Ibs. and are small in size. (See attoched O&M manuals for the 

DJI Phantom 2 Vision+). The sUAS's will be op rated under controlled conditions at low altitude in airspace that is limited in 

scope, as described more fully herein; it will have automated control features as described below and in the O&M manuals. The 

sUAS also will be operated by an individual who is a member of the AMA (Academy of Model Aeronautics) and has loggesd 50' 

hours flying the named sUAS. Finally, the airspoce in which the sUAS will operate will be Class G airspace or airspace approved 

by the FAA in advance 
lason Schott respectfully submits that because these small, unmanned aerial vehicles will be used in lieu of comparatively 

hazardous operations now conducted with fixed wing and rotary conventional aircraft or other manned means of inspections, 

the FAA can have confidence that the operations will achieve at least the equivalent level or greater level of safety. Approval of 

the exemptions would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems 

in the national airspace system." 

The name and address of the applicant are: 

lason Schott 

Ph: 303-513-7795 

Emoil:josonschott65@gmail.com 

Address: 1212 South Kimbark Street 

Longmont Colorado 80501 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21; 

14 C.F.R. 45.13(b) 

14 C. F. R 45(c) 

14 C. F. R 47 

14 C. F. R 61.23(a); 

14 C.F.R. 61.113(a) & (b); 

14 C. F. R. 61.133 (a); 

14 C. F. R. 91.7(b); 

14 C.F.R. 91.9(b)(2); 

14C. F. R. 91.109(a); 

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) &(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. 91.417(a) &(b). 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are 

appropriate, provide an equivalent level of safety, and are in the public interest. 

The Applicable Lega/ Standard under Section 333 

Jason Schott submits that grant of this exemption application for use of the proposed UAS's in precision aerial inspections will 

advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs into the national 

airspace system ("NAS") if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether 

certain UASs may operate safely in the NAS before completion of the rulemaking required under the Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of 

the NAS or the public or pose a threat to national security in the light of the following: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the sUAS in closed proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act §333(a)(1). If the Secretary determines that such vehicles "may operate safely in the national airspace system, the 

Secretary shall establish requirement for the safe operation of such aircraft in the national airspace system. " Id. §333(c) 

(emphasis added).1 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, 

includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must 

have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service: 

The Admfnistrator may grant an exemption from a requirement of a regulation prescribed undersubsection (a) or (b) of this 

section or any of the sections 44 702-44 71 6 of this title if the Administrator finds the exemption is in the public interest. 

lApplicant submits that this provision places a duty on the Administrator to not only process applications for exemptions under 

Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow 
approval, to supply conditions for the safe operation of UAS. lason Schott welcomes the opportunity to consult with FAA staff in 

order to address any issues or concerns that this proposal may raise that they believe may require modification. 

49 U.S.C. §44701(f). See also 49 U.S.C. §44721 (a); 49 U.S.C. §44704; 14 C.F.R. §91.203(a)(1). 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of 

safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings 

associated with transitioning to UASs for aerial inspections and survey photography and real estate photography. Accordingly, 

the applicant respectfully requests that the FAA grant the requested exemption without delay. 

Airworthiness of the sUAS 

A critical element of the exemption application involves evidence of the airworthiness oft he 

sUAS. The Federal Aviation Act (49 U.S. C. §44701 (f) and Section 333 of the Reform Act both autharize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular sUAS. Our small UAS's will operate at low speed in a 

controlled environment, at least five miles from an airport or dense/y populated area. An analysis of these criteria demonstrates 

that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will 

be a least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

Mandatory Operating Conditions (see O&M and Safety lists) 

Grant of the exemption to lason Schott will be subject to the following mandatory conditions, which are based upon operating 

conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions: 

• All operations to occur in Class G airspace. 

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. 

• Operations to be conducted over private or controlled-access property. 

• Permission from land owner/controller required before commencing flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Aircraft to remoin within Visual Line of Sight (VLOS). 

VLOS guaranteed with a cylinder of operation around operator of 112 nautica/ miles 

(NM). Cylinder walls may be expanded by observer with ability to control aircraft. 
• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runwoy centerline 

measured from runway thresholds 

• All required permissions and permits will be obtained from territorial, stat e, county or 

City jurisdictions, including local law enforcement, fire, or other oppropriate governmental agencies. 

Operator Requirements 

lason Schott respectfully purposes that operator requirements should take into 

Account the characteristics of the particular UAS. Certain UASs, such as the Dll Phantom 2 

Vision+, are characterized by a high degree of control and various built-in technical capabilities that limit the potential for 

operation outside of the operating conditions set forth above. 

Please see details in the attached O&M manuals. 

Additional automated safety functions and safety enhancing features of the sUAS's include the 

following: 

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate return 

to aircraft take-off location ("home"). 

• Low power on the aircraft triggers escalating alarms at GCS. 

• If the auto-pilot detects a lost-link to the GCS, landing procedure begins. 

Given these safety features, lason Schott proposes that operators of the sUAS should not be required to hold a commercial pilot 

certification. Instead, operators should be required to: 

• Hold a private pilot license and have a current medical certification. 

• Have completed the manufacturer's training or a minimum of 10 hours training program for operation of the sUAS's. 

lason Schott notes that the FAA has found that safety factors permitted operation of sUASs by operators with these 

qualifications in the cose of operations pursuant to public COAs when the mandatory operating conditions specified above were 

present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 

20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the requirements for and privileges associated 

with the gront of airmen's certificates. 49 USC §44701 (f). 
In summary, applicant seeks an exemption from the FARs set forth above in Appendix A to allow commercial operations of a 

sUAS's conducting precision aerial inspections or surveys and real estate photos. 

Approval of the exemption allowing commercial operations of the sUAS for precision inspection, survey work, and real estate 

photos will enhance safety by reducing risk. 

Conventional aerial inspection, survey operations, and real estate photos, using jet or piston powered aircraft present risks 

associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 Ibs., or more, carry large quantities of fuel, 

passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. Other conventional manned 

climbing or manned lifts risk safety hazards associated with falls, electrical hazards, fuel related hazards, and inhalation 

associated with the structures being inspected. In contrast, a sUAS weighing less than 15 Ibs. and powered by batteries 

eliminates a portion of that risk given the reduced mass and lack of combustible fuel carried on board a manned aircraft and the 

lack of risks associated with manned lifts or manned climbing apparatus. The sUAS will carry no passengers or crew and, 

therefore; will not expose any individuals to the risks associated with manned aircraft flights, manned lifts or climbing hazards. 

Additionally, no national security issue is raised by the grant of the requested exemptions. 

Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other dangerous 

materials, the sUAS poses no threat to national security. 

The operation of the sUAS, weighing less than 15 Ibs. for inspections, surveys, and real estate photos in accordance with the 

strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting Jason Schott from the requirements of Part 21. 

The sUAS's satisfaction of the criteria set forth in Section 333 ofthe Reform Act-size, weight speed, operating capabilities, lack of 

proximity to airports and populated areas, operation within visual line of sight, and national security-and its showing of an 

equivalent level of safety as it may relate to the requirement for FAA training, provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of the sUAS in the commercial aerial inspection, survey, and 

real estate photo business. 

Thank you in advance for y r ti e 

~ 

lason Schott 

Enclosures 

Appendix A: Exemption Request and Equivalent Level of Safety Showings under 

Applicable Rules Subject to Exemption 
Attachment 8: DJI Phantom 2 Vision+ O&M Manual 

Attachment C: Safety Checklists