Petition for Exemption 14 CFR § 11.81 

Name: Barbara Puszkiewicz- Cimino (Design Sp3ctre LLC)

Address: 20 Manhattan Pl, Huntington, NY 11743

Cell Phone: 516-270-4879

Fax: 631-420-0083

Email: barbarapuszkiewicz@gmail.com

The specific section or sections of 14 CFR from which you seek an exemption;

Petition for Exemption under Sec 333

The extent of relief you seek and the reason you seek the relief;

Sec 333 prohibits the use of a UAS for commercial purposes on private property. Design Sp3ctre LLC is 

an IT company that provides services such as website design and database creation and would like to 

extend its services to supporting commercial real estate groups throughout Long Island, NY with aerial 

photography. I am simply petitioning for an exemption to use a UAS for a commercial purpose on 

properties owned by real estate companies and/or specific individuals for the sole purpose of doing 

aerial photography and videos to further use them on clients’ websites and their promotional materials

as well as utilizing it in their maintenance/ inspection in-house programs. I am in touch with a certified 

pilot, James Kelly, and former FAA Runway Safety Program Officer Vincent Cimino who will be in charge 

of operating the UAS. 

How your request would benefit the public as a whole;

My request benefits the public by providing better images and understandings of the property that they 

may be interested in renting/ leasing. It gives brokers more accurate information to share with potential 

tenants, whether small business in commercial use or private individuals looking for homes. It would 

also allow me to simplify their inspection and maintenance procedures regarding roofing and elevated 

elements of the building. With this exemption I will be able to document the land and properties and

take advantage of technology that now exists in the form of UAS’s and allows me to do so using a 

certified pilot in command that understands how to safely operate such technology.
Reasons why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule;

Having an FAA licensed Private Pilot in charge of the UAS, who is also a certified pilot as well as former 

FAA Runway Safety Program Officer Vincent Cimino, therefore understanding the importance of 

different uses and safety concerns regarding FAA regulated airspace would make me a good candidate 

for exemption of Sec 333 while not adversely affecting Air Safety. The specific UAS that I am looking at 

(Yuneec Typhoon Q500 4K), and for which I am seeking exemption, is one with many safety programs, 

including SAFE technology and GPS navigating. When flying for this commercial purpose I would be 

flying at a maximum altitude of 60 meters and flying mostly horizontally for the purposes of taking 

photos, decreasing the risk of any interference. My pilot’s general knowledge of the aviation safety 

systems implemented by the FAA would be used to ensure that safety would not be affected by my

operations. We would not be flying near disaster areas, sporting events, or high traffic areas including 

airports, and we would pay attention to NOTAMS.

I intend to fly in one of these two safe modes:

(1) Smart mode*: In Smart Mode the TYPHOON will always move in the direction the right-hand 

control stick is pushed relative to the pilot and no matter which way the front/nose is pointed. 

So if you push the stick to the left the TYPHOON will always move to the left, regardless of the 

direction the nose is pointing and even if it’s spinning. This mode can also be helpful for pilots 

that lose orientation while flying in Angle (Pilot) Mode.

*Which also includes: SMART CIRCLE In most cases the Smart Circle will keep the TYPHOON from coming 

within approximately 26 feet (8 meters) of you (as long as you position yourself at least 26 feet/8 meters 

behind the TYPHOON. 

GEO-FENCE The geo-fence is a virtual ‘barrier’ that will keep the TYPHOON from 

traveling further than 300 feet (91 meters). 

(2) Home mode: In Home Mode the GPS connectivity will fly back the TYPHOON, and automatically 

land within 13-26 ft (4-8m) of the pilot. It can be helpful if one loses orientation during flight; 

with simple activation of the Home Mode, TYPHOON automatically moves toward the home 

position. And if the TYPHOON ever loses the link with the ST10+ it will automatically enter Home 

Mode.

A summary we can publish in the Federal Register—

I, Barbara Puszkiewicz-Cimino, on behalf of Design Sp3ctre LLC, am seeking an exemption of the FAA’s 

Sec 333 rule that does not allow the use of an Unmanned Aircraft to be used for commercial purposes 

with respect to National Airspace Safety. I am simply petitioning for an exemption to provide a 

commercial service to my clients’ companies who wish to obtain and capture aerial photography and 

videos of said properties for purposes including them in real estate listings, and for use as a marketing 

tool for their business, as well as inspection and maintenance programs. Having an FAA licensed Private 

Pilot as well as former FAA Runway Safety Program Officer Vincent Cimino in charge of this project and 

therefore understanding the importance of different uses and safety concerns regarding FAA regulated 

airspace, I would be a good candidate for an exemption of Sec 333, while not putting Air Safety at risk. 

The specific UAS (Typhoon Q500 4K) I am seeking exemption with is one with many safety programs, 

including SAFE technology and GPS navigating. When flying for this commercial purpose we would be 
flying at a maximum altitude of 60 meters and flying mostly horizontally for the purposes of taking 

photos, decreasing the risk of any interference. Our pilot’s general knowledge of the aviation safety 

systems implemented by the FAA would be used to ensure that safety would not be affected by our

operations. We would not be flying near disaster areas, sporting events, or high traffic areas including 

airports, and I would pay attention to NOTAMS. We appreciate the FAA’s consideration of this petition 

for exemption.

Any additional information, views, or arguments available to support your request;

We are fully aware of the pre flight safety checks and procedures implicated in the operation manual for 

the Typhoon Q500 4K and intend to implement pre flight safety checks and utilize the safety technology 

provided with this unit. We intend to only fly in non-populated, commercial areas and stay clear of all 

utility lines, etc. We intend to be fully aware of our surroundings at all times and to only fly the 

unmanned aircraft within a visual line of sight and only in Visual Flight Conditions.

We understand and will comply with all the health and safety regulations for PIC’s and will have certified 

pilot in charge of the UAS under this exemption.

Operations of the Typhoon Q500 4K include the following information and operations manual:

Dimensions: 565 mm x 330 mm x 420mm (length) x 210 mm (height)

Flight Time: up to 25m

Weight with Battery and Payload: 1700g

Transmitter 10-channel 2.4 GHz 

3 Flight Modes: Smart, Angle, Home

Maximum Rotation Rate: 65 degrees/s

Maximum Roll Angle: 35 degrees

Operating Temperature: -5 degrees Celsius to 80 degrees Celsius

Radio Control Frequency Band: 2.4 GHz

Max Descent Speed: 2m/s

Max Flight Speed: 8m/s

Control Transmission Range: FCC Compliance (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) 

Video Transmission Range: FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m 

(984.252 ft)
General Safety Precautions and Warnings I intend to Follow:

• Always keep a safe distance in all directions around your model to avoid collisions or injury. This model 

is controlled by a radio signal subject to interference from many sources outside your control. 

Interference can cause momentary loss of control.

• Always operate your model in open spaces away from full-size vehicles, traffic and people.

• Always carefully follow the directions and warnings for this and any optional support equipment 

(chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach of children.

• Always avoid water exposure to all equipment not specifically designed and protected for this 

purpose. Moisture causes damage to electronics.

• Never place any portion of the model in your mouth as it could cause serious injury or even death.

• Never operate your model with low transmitter batteries.

• Always keep aircraft in sight and under control.

• Always move the throttle fully down at rotor strike.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

If you want to exercise the privileges of your exemption outside the United States, you must state the 

reason.

I have no intention of using this exemption outside the United States

Sincerely,

Barbara Puszkiewicz-Cimino

Design Sp3ctre LLC