Petition	for	Exemption	14	CFR	§ 11.81

IN	THE	MATTER	OF	Exemption for	petition	under	SEC	333,	SYRACUSE	BUSINESS	

SERVICES	SEEKS	RELIEF	AND	EXEMPTION	FROM	 REQUIREMENTS	UNDER	TITLE	

14	OF	THE	CODE	OF	FEDERAL	REGULATIONS	SECTIONS	61.113	 (b);	91.405	(a);	

91.407(a)	(1);	91.409	(a)	(1)	and	(2);	91.417	(a)	and	(b)

Submitted	on	6/02/2015	by

Steve	Roberts

Syracuse	Business	Services,	d.b.a.	Zoey	Advertising

936	N.	Clinton	Street

Syracuse,	NY	13204
																															

June	2,	2015

Federal	Aviation	Administration

800	Independence	Avenue,	SW

Washington,	DC	20591

Please	accept	this	Petition	for	Exemption	under	Section	333	as	a	request	for	

authorization	from	the	Federal	Aviation	Administration	to	operate	a	UAS	for	civil	

purposes other	than	for	recreation	or	hobby.		The	UAS	will	be	used	to	take	

professional	commercial	photography.		

UAS	Specs	and	Details: DJI	Inspire1	Quadcopter

Model:	T600

Weight	(Battery	Included):	2935	g

Hovering	Accuracy	(GPS	Mode)

Vertical:	0.5	m

Horizontal:	2.5	m

Max	Angular	Velocity

Pitch:	300°/s

Yaw:	150°/s

Max	Tilt	Angle:	35°

Max	Ascent	Speed:	5	m/s

Max	Descent	Speed:	4	m/s

Max	Speed:	22	m/s	(ATTI	mode,	no	wind)

Max	Flight	Altitude:	4500	m

Max	Wind	Speed	Resistance:10	m/s

Max	Flight	Time:	Approximately	18	minutes

Motor	Model:	DJI	3510

Propeller	Model:	DJI	1345

Indoor	Hovering:	Enabled	by	default

Operating	Temperature	Range:	-10°	to	40°	C

Diagonal	Distance:	559	to	581	mm

Dimensions:	438x451x301	mm

Video: 4K	@	24-30	fps,	or	1080p	@	24-60fps,

Photos:	12	Megapixels

Lens:	9	elements	in	9	groups	including	an	aspherical	element

1/2.3	inch	CMOS	sensor

940	wide-angle	FOV

3-axis,	3600	rotating	gimbal

Remote	Controller Specs Name:
																															

C1

Operating	Frequency:

5.725~5.825	GHz

2.400~2.483	GHz

Transmitting	Distance	(Outdoor	And	Unobstructed):

2	km

EIRP:

10dBm@900m,	13dBm@5.8G,	20dBm@2.4G

Video	Output	Port:

USB,	mini-HDMI

Power	Supply:

Built-in	battery

Charging:

DJI	charger

Dual	User	Capability:

Host-and-Slave	connection

Mobile	Device	Holder:

Tablet	or	Phone

Max	Mobile	Device	Width:

170mm

Output	Power:

9	W

Operating	Temperature	Range:

-10°	to	40°	C

Storage	Temperature	Range:

Less	than	3	months:	-20°	to	45°	C

More	than	3	months:	22°	to	28°	C

Charging	Temperature	Range:

0-40°	C

Battery:

6000	mAh	LiPo	2S
																															

Petition	for	Exemption	under	Section	333:	Request	for	FAA	authorization	to	

“operate	a	UAS	for	civil	(non-governmental_	purposes	other	than	for	creation	or	

hobby.”

BASIS	FOR	PETITION

Our	sole	intention	is	to	produce	high	quality,	professional	commercial	photography	

and	video,	at	a	lower	altitude	(400	feet	maximum)	that	cannot	be	achieved	in	a	

helicopter.		For	higher	altitude	photography	needs,	we	will	use	the	commercial	

helicopter	and	commercial	pilot	that	our	company	has	used	for	the	past	28	years.	

Our	clients	have	hired	us	to	photograph	and	take	video	of	commercial	property	and	

real	estate.		We	create	images	for	use	in	marketing	and	publishing.			Our	intended	

area	of	operations	will	always	be	a	clear	and	open	space,	in	order	to	ensure	a	quality	

photograph	and	total	safety.		We	are	a	mature,	professional	company	and	therefore	

we	take	the	permission	that	the	FAA	may	grant	us	seriously.				

SYRACUSE	BUSINESS	SERVICES	Requests	exemption	and	relief	from	the	

following	sections	of	14	CFR:

§ Section	61.113,	“Private	pilot	privileges	and	limitations:	Pilot	in	Command,”

Subsection(b)

§ Section	91.405	“Maintenance	Required”

§ Section	91.407	(a)	(1),	“Operation	after	maintenance,	preventative		

maintenance,	rebuilding,	or	alteration.”

§ Section	91.409	“Inspections”

§ Section	91.417	(a)	and	(b)	“Maintenance	Records.”

Extent of relief that Syracuse Business Services seeks regarding section 61.113 (b) 

Private pilot privileges and limitations: Pilot in Command, Subsection (b) prescribed the 

following, in part:

“(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if – (1) The flight is only incidental to that 

business or employment and (2) The aircraft does not carry passengers or property for 

compensation or hire.”

Extent to which Syracuse Business Services seeks relief from this section is to fly 

commercially for hire, for professional photography.

Extent of relief that Syracuse Business Services seeks in regards to sections 91.405(a), 

91.407(a)(1), 91 .409 point(a)(1) and (a)(2), 91.4179 1.417 (a) and (b). These 

requirements are all associated with an airworthiness certificate. There are currently no 

airworthiness certificates for small UAVs.
																															

BACKGROUND	and	CREDENTIALS

Our	company,	Syracuse	Business	Services	(d.b.a. Zoey	Advertising),	has	28	years	of	

experience and	over	1,000	hours	of	airtime	logged	in commercial	aerial	

photography.	 Our	organization	has	consistently	followed	and	exceeded	regulatory	

laws,	rules,	and	regulations	put	in	place	by	the	FAA.		We	are	bonded	and	insured,	as	

this	is	not	a	new	business	for	us.		In	our	previous	ventures,	we	have	used	a	

commercial	helicopter	for	professional	photography.		The	UAS	will	simply	be	a	new	

mechanism	we will	use	for	the	same	concept:	commercial	photography.		

We	are	not	new	to	aerial	photography	and	aviation.		This	is	simply	an	additional	

tool, which	will	allow	us	to	create	visually	appealing	and	effective	art	for	our	clients.		

Although	we	will	always	operate at	400	feet	or	less,	the	vast	majority	of	our	visual	

documentation	will	occur	at	200	ft	and	below.		Our	maximum	speed	will	be	

approximately	25	knots,	though	generally	operating	much slower	than	that,	to	

ensure	quality	imagery	and	maximum	safety.		

SAFETY

Safety	always	has	been	and	always	will	be	the number	one	priority.		We	are	acutely	

aware	of	airport	locations,	aircraft	patterns,	and	safety	regulations	in	conventional	

aircraft	navigation.			Adequate	notice	will	be	given	to	all	individuals	and	property	

owners	in	the	area	where	photography	and/or	video	will	occur	to	ensure	the	

complete	safety	of	operation.		We	will	always	respect	property	owners	and	fly	with	

the	best	of	intentions.		

We	are	fair-weather	flyers,	just	as	we	are	in	the	commercial	helicopter.		Clear	skies	

with	extended	visibilities	are	a must	for	excellent	imaging,	and	therefore	we	only	fly	

on	clear	days.		We	will	never	fly	into	clouds,	or	lose	direct	line	of	sight	from	the	

quadcopter.	We	will	never	fly	directly	over	people,	as	the	safety	of	others	is always	a	

direct	priority	of	ours.

We have	always	flown	VFR	in	the	commercial	helicopter	with	multiple	sets	of	eyes	

on	the	look-out	for	other	aircraft,	obstacles,	towers,	power	wires,	air	fowl,	and	any	

other	potential	dangers	or	obstructions.		We	are	acclimated	to	and	focused	on	

keeping	our	eyes	on	the	sky	during	fly-time.		There	would	be	and	will	be	no	reason	

for	us	to	take	our	eyes	off	of	our	quadcopter.

Pursuant	to	the	statutory	mandate	under	Section	333	(b)	(1),	our	UAS	will	be	

operated	within	visual	line-of-sight.		Because	we	intend	on	television	filming,	we	

will	actively	communicate	with	the	Flight	Standards	District	Offices	(FSDOs)	prior	to	

operations.		We	will	coordinate	with	the	FSDO’s	prior	to	the	flight	to	ensure	all	

compliance	measures	are	met	to	the	highest	standard.

The	quadcopter	will	undergo	a	full	and	complex	safety	inspection	of	all	parts	to	

ensure	everything	is	working	properly.				Our	pre-flight	checklist	includes	battery	

tests,	prop	safety	checks,	electronic	tests,	GPS	test,	and	other	factors	to	assure	the	
																															

quadcopter’s flight-readiness.		We	will	check	the	weather,	wind	speed,	and	wind	

direction	to	confirm	ideal	flight	conditions	prior	to	take-off.		If	flight	conditions	are	

not	conducive,	we	simply	do	not	fly.	We	will	follow	all	checklists	and	adhere	to	all	

guidelines,	both	internally	and	put	in place	by	the	FAA,	to	ensure	comprehensive	

and	exhaustive	safety	when	the	UAS	is	in-flight,	just	as	we	do	in	the	commercial	

helicopter.

PUBLIC	INTEREST	&	BENEFIT

This	exemption	would	benefit	the	public	as	a	whole	by	providing	an	opportunity	for	

small	businesses	to	leverage	UAS	technology	to	grow	their	business.		This	allows	

them	to	do	so	in	a	safe,	professional	manner.		These	businesses	will	be	using	an	

experienced	PIC	that	understands	how	to	safely	navigate	the	UAS	and	operate	the

technology.		This	exemption	promotes	the	safety	of	the	public,	as	folks	will	be	far	

less	inclined	to	use	an	Operator	that	may	not	abide	by	the	safety	regulations	that	we	

are	educated	on	and that	may	not	have the level	of	understanding	of	the	technology,	

which	we	have	mastered.		

Thank	you	for	considering	our	Petition	for	Exemption	regarding	the	FAA	operations	

regulation	regarding	“the	use	of	a	UAS	for	purposes other	than	hobby	or	recreation.”

Our	Petition	requests	an	exemption	from	regulation	stating	that the	UAS	must	be

used	for	recreation	or	hobby,	as	we	intend	on	using	it	for	professional	commercial	

photography.		It	is	our	sincerest	desire	and	hope	that	we	are	able	to	move	our	

business	forward	upon	the	granted	exemption.		Please	contact	Steve	Roberts	by

phone	at	315-471-7700	with	any	questions	or	concerns.