Stephen Grigoriou D.B.A. – Stephen Grigoriou Photography

28 Meadow Drive hello@stephengrigoriouphotography.com

Lowell, MA 01854 www.stephengrigoriou.com

Petition for Exemption/Rulemaking

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H;

14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2) 14 CFR 91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 CFR Part 11, Stephen Grigoriou, operator of Unmanned Aircraft Systems (UAS), hereby

applies for an exemption from the listed Federal Aviation Regulations to allow commercial 

operation of designated UAS, provided such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit the operation of designated UAS as set forth in this 

document under controlled conditions in the NAS that would be a) safe, b) controlled, c) 

predetermined, and d) limited. Approval of this exemption would increase public awareness of 

UAS operations and enhance safety. 

Furthermore, given the small size of the UAS’s involved and the restricted controlled 

environment within which they will operate, the applicant fits within an equivalent level of 

safety in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately. Likewise, due to the size of the UASs and the 

controlled areas in which the relevant UASs will operate, approval of the application presents no 

adverse impact to public safety. Given the following, the grant of the requested exemptions is 

clearly in the public interest: Stephen Grigoriou proposes that the exemption requested herein 

apply to civil aircraft that have the characteristics and that operate with the limitations listed 

herein. These limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which Stephen Grigoriou agrees to be bound when conducting 

commercial operations under an FAA issued exemption including:

1. The UAS will weigh less than 55 lbs.
2. Flights will be operated within a line of sight of the operator.

3. Maximum total flight time for each operational flight will be 20 minutes.

4. Flights will be terminated at 20% battery power reserve.

5. Flights will be operated at an altitude of no more than 400 feet.

6. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

7. The UAS will only operate within a controlled area as defined in the Procedures.

8. The operator will post advisor notice around the controlled area.

9. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required.

10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land.

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

Commercial operation of the UAS, as described herein, which are equipped with camera(s) and 

sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, and other related professional activities.

2. Aerial photography and/or video for public and/or private use including public events, 

cinematography and newsgathering.

3. Aerial inspection/photography/video of residential/commercial structures under contract with 

the owners or local government authority.

4. Aerial inspection/photography/video of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the

NAS.

I, Stephen Grigoriou, plan to operate a UAS, the DJI PHANTOM 3 Professional that is 

comprised of an unmanned aircraft (UA or Phantom 3) and a transportable ground station. The 

Phantom 3 is referred to as a quad-copter with a maximum gross weight of about 3 pounds. It is 

equipped with four rotors that are driven by electric motors powered by batteries. The UA has a 

maximum airspeed of 16 m/s.

In addition, I, Stephen Grigoriou, plan to operate a UAS, the DJI Inspire 1 that is comprised of 

an unmanned aircraft (UA or Inspire 1) and a transportable ground station. The Inspire 1 is 

referred to as a quad-copter with a maximum gross weight of about 6.5 pounds. It is equipped 

with four rotors that are driven by electric motors powered by batteries. The UA has a maximum 

airspeed of 22 m/s.
Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and 

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

level of safety. Please contact me at any time if additional information or clarifications are 

needed to satisfy my petition.

Thank you for your consideration,

Stephen Grigoriou