U.S. Department of Transportation 

Federal Aviation Administration 

Washington, DC 

September 9, 2015 

Petitioner 

Stephen M. Shroyer 

1609 E. 6th Street 

Deer Park, WA 99006 

509-276-5538 

shroyersm12@gmail.com 

Stephen Shroyer will be providing clients with high quality imaging for a variety of 

commercial, public and residential uses. He is a retired U.S. Army Master Aviator and a 

current Airline Transport Pilot certificate holder with over 7,000 hours of flying 

experienc~ in both rotary and fixed wing aircraft and is seeking an exemption from these 

specific requirements of Title 14 C.F.R.: 

I. 61.113 (a) and (b) 

II. 91 . 119 (b) and (c) 

Ill. 91.121 

IV. 91.151 (a) 

V. 91.405 (a) 

VI. 91.407 (a)(1) 

VII. 91.409 (a)(1) and (2) 

VIII. 91.417 (a) and (b) 
Definitions 

I. AGL Above Ground Level 

II. ATC Air Traffic Control 

Ill. COA Certificate of Authorization 

IV. FAA Federal Aviation Administration 

V. FAR Federal Aviation Regulation 

VI. GPS Global Positioning System 

VII. NAS National Airspace System 

VIII. PIC Pilot in Command 

IX. UA Unmanned Aircraft 

X. sUAS Small Unmanned Aerial System 

XI. VFR Visual Flight Rules 

XII. VLOS Visual Line of Sight 

Summary 

In the instance of granting exemption, Stephen Shroyer will be operating the sUAS in 

order to fulfill contract obligations, such as: aerial photography and videography for real 

estate agents, appraisers, property managers, general contractors; solar panel 

installation technicians; agriculturists, utility inspections (only where safe flight is 

attainable); chambers of commerce and associated businesses; wildlife conservation 

organizations; public departments; and all other institutions requiring filmography (safe 

flight permitting) 
I 

Aircraft 

DJI Phantom 3 

A. Weight (Including Battery and Propellers) 

B. Diagonal Size (Including Propellers) 

C. Max Ascent Speed 

D. Max Descent Speed 

E. Max Flight Time 

F. Remote Controller Operating Frequency 

G. Auto -Takeoff 

H. Auto-Return Home 

I. Low Battery Failsafe 

2.821bs 

23.23 in 

11.2 mph 

6.7 mph 

-23 minutes 

2.400 GHz- 2.483 Ghz 

Rises to a preset height and will 

hover in place until directed 

where to go 

Remembers the exact spot it took 

off from to enable a tap of a 

button to return back home 

If the flight battery is running low 

or the Phantom 3 loses 

connection with the remote it will 

automatically return back home 

Specific Sections of C.F.R. From Which Stephen Shroyer Seeks Exemption 

I. Section 61.113(a) and (b)- Private Pilot Privileges and Limitations 

Section 61.113 states that no person who holds a private pilot certificate may act as a 

pilot in command of an aircraft that is carrying passengers or property for compensation 

or hire; nor may that person, for compensation or hire, act as a pilot in command of an 

aircraft. The sUAS will not carry a pilot or passengers. Then the stated operations can 

achieve the equivalent level of safety by requiring the PIC operating the aircraft to have 

completed FAA Private Pilot Ground school instruction and passed the FAA Private 

Pilot written exam to operate these sUAS. These sUAS are not capable of carrying a 

pilot or passengers, therefore distinguishing them as remotely controlled vehicles. The 

area of operation is controlled and restricted providing a sound level of safety 

referenced from the operations manual. The risk associated with the operation if a UAS 

is greatly reduced with a certificated Airline Transport Pilot acting as PIC this exceeding 

the present level achieved by section 61.113. 
II. Section 91.119 - Minimum Safe Altitudes 

Section 91.119 states persons may operate a helicopter at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with routes or altitudes specifically prescribed for helicopters by the 

FAA. The sUAS meets this criterion as a helicopter and requests the ability to operate at 

altitudes up to 400' AGL. Only in accordance with pre-obtained consent will the sUAS 

operate while also maintaining an altitude less than 400' AGL. For comparison with 

traditional aircraft and rotorcraft the sUAS weighs less than 10 lbs. while also preventing 

potential risks associated with flammable fuel. Lastly the 400' AGL ceiling limits any 

ability for the sUAS to interfere with conventional aircraft operating at or above 500' 

AGL. 

Ill. Section 91.121 -Altimeter Settings 

Section 91.121 states each person operation and aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be by reference to an altimeter 

this is set, when operating below 18,000 feet MSL, to the current reported altimeter 

setting of a station along the route and within 100 nautical miles of the aircraft. In the 

case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure. The sUAS will reference its 

altitude base on GPS and will be restricted to a 400' AGL ceiling. The PIC will also 

verify GPS elevation from multiple ground based sources prior to takeoff. 

IV. Section 91.151- Fuel Requirements for Flight in VFR Conditions 

Section 91.151 states no person may begin a flight in a rotorcraft under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 20 minutes. The sUAS battery powered operation flight time is not able to 

incorporate a 20 minute reserve window following successful first point of intended 

landing due to the current battery capacity limitations. In order tq provide adequate 

reserve power for return landing the sUAS will abide by the 12 minute flight time or 25% 

of remaining battery power, whichever happens first. 
V. Section 91.405(a), 91.407 (a)(1), 91.409 (a)(1) and (2), and 91.417(a) and (b) 

These sections only apply t aircraft with an airworthiness certificate; Stephen Shroyer 

requests exemption from these sections because the DJI Phantom 3 does not require 

airworthiness certificates. The sUAS is in accordance with the FMRA Section 333 for 

operation, absent and airworthiness certificate. In order to insure proper maintenance 

the operation manual will be cited for necessary corrective measures. In addition, the 

PIC is the person most familiar with the aircraft and best suit~d to maintain the aircraft in 

an airworthy condition, and any sUAS conducted maintenance will be documented for 

the life of the aircraft. 

Public Interest 

~ Real estate agents will be able to set their listing apart with a unique perspective 

only available from sUAS photographic equipment, therefore increasing the 

prospect of meeting or exceeding the asking price. 

~ Property managers and contractors will have the ability to survey their property 

for anomalies with preventing human endangerment due to hazardous conditions 

~ Solar panel and ce11 phone tower technicians can safely inspect potential 

installation locations as well as detecting probable maintenance issues 

associated with their equipment without putting themselves in high elevation, 

sloping or hazardous weather conditions. 

~ Agriculturists will have the ability to survey their land in a timelier manner and 

better document the condition of their property. 

~ Marketing firms and other businesses would use unique aerial photography and 

video to promote marketing campaigns and increase revenue. 

~ Search and rescue entities could utilize the sUAS to help quickly aid in finding 

the location of person(s) while providing a better vantage point in closer quarters. 

~ Governmental Natural Resource agencies could use sUAS as a tool to better 

manage the conservation and use of public lands. 

Public Safety 

~ The sUAS will reduce air and noise pollution do to the aircraft being powered by 

a battery and brushless electric motors. 

~ This small aircraft creates less potential for harm, should and emergency 

situation occur, thanks to its size and weight. 

~ Furthermore the lack of combustible fuel also significantly decreases the chance 

of producing harm. 
Conclusion 

Based on the criteria provided under the FMRA Section 333, Stephen Shroyer requests 

that the FAA grant him exemption form 14 C.F.R Sections 61.113(a)&(b), 91.119(b) and 

(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91409(a)(1) & (a)(2), and 91.417(a) &(b) 

in order to conduct contracted commercial sUAS operations using the OJI Phantom 3 

for a wide range of industries and applications. 

Sincerely,