EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT L - 

~ -~ ~,.. 

Nicholas Zouroudis 

Zouroudis Photography, LLC 

5460 NW 55th BLVD 

Coconut Creek, FL 33073 

February 18th, 2015 

U.S Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) &(b);91.7 (a); 91.9 

(b) (2);91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) &(b) to operate commercially for buyer education purposes 

in Real Estate. 

To Whom It May Concern: 

My name is Nicholas Zouroudis and I am submitting this request for an exemption of section 333 of the 

FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R 45.23(b);14 C.F.R. §§ 

61.113( a) &(b);91.7 (a); 91.9 (b) (2);91.103(b); 91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) and 

(b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) 

Background 

I work in the real estate and real estate photography industry and specialize in high end coastal land and 

estate homes. When listing a property, especially the size of the properties near coastal areas, it is of 

significant benefit to use an UAS for aerial photography and videography to help the buyer make an 

informed decision about the piece of property being purchased. This also includes the purchase of 

homes. Many out-of-state buyers see the benefit of being able to see aerial photographs and video of 

high eves, roofs, etc. to note their condition before making an offer on a home. 

Regarding the Unmanned Aircraft System 

The UAS I will be using is a small rotorcraft weighing less than 55 pounds with any and all payload. These 

UAS's operate at a speed no greater than 30 knots and can climb to an altitude no higher than 400ft 

AGL. It operates only in the line of my sight as the sole operator and within a radius of 300ft. It does, 

however, have the capability of a 1200ft radius of operation, but I have found, in my recreational use, 

that the line of sight is typically within 300ft of the operator. These flight restrictions ensure that it is not 

a hazard to the airspace in which it will be operated. This UAS falls within the safety zone that the FAA 

will, with an exemption in place, allow commercial operation of a UAS. 

The particular UAS that will be operated is a DJI Phantom 3 Professional. The specific specifications are 

found on the following pages: 

Zouroudis Photography, LLC 15460 NW 55` h BLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT LL~ -_~~ 

Ai rcraft 

• Supported Battery 

DJI 5200mAh LiPo Battery 

• Weight (Battery & Propellers Included) 

1242g 

• Hover Accuracy (Ready To Fly) 

Vertical: 0.8m; Horizontal: 2.5m 

• Max Yaw Angular Velocity 

200°/s 

• Max Tiltable Angle 

35° 

• Max Ascent I Descent Speed 

Ascent: 6m/s; Descent: 2m/s 

• Max Flight Speed 

15m/s (Not Recommended) 

• Diagonal Motor-Motor Distance 

350mm 

Gimbal 

• Working Current 

Static: 750mA; Dynamic: 900mA 

• Control Accuracy 

±0.03° 

• Controllable Range 

Pitch: -90° - oo 

• Maximum Angular Speed 

Pitch: 90°/s 

Camera 

• Operating Environment Temperature 

0°C-40°C 

• Sensor Size 

1/2.3" 

• Effective Pixels 

12 Megapixels 

• Resolution 

43843288 

• 4K Recording 

3840x2160 60fps 

• Recording FOV 

11 oo 1 85° 

Zouroudis Photography, LLC 15460 NW 55" BLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT L~: 

Remote Control 

• Operating Frequency 

5.728 GHz- 5.85 GHz 

• Communication Distance (Open Area) 

CE Compliance: 400m; FCC Compliance: 800m 

• Receiver Sensitivity 

(1 %PER) -93dBm 

• Transmitter Power 

CE Compliance: 25mW; FCC Compliance: 100mW 

• Working Voltage 

120 mA@3.7V 

• Built-In LiPo Battery Working Current/Capacity 

3.7V, 2000mAh 

Range Extender 

• Operating Frequency 

2412-2462M Hz 

• Communication Distance (Open Area) 

500-700m 

• Transmitter Power 

20dBm 

• Power Consumption 

2W 

Zouroudis Photography, LLC 15460 NW 55` h BLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

Procedures for Flight 

As an avid aviation enthusiast, I understand the necessity for safety when flying an airplane or an UAS. 

The procedures for flight are as follows (in no particular order): 

1. With an observer, make a walk around the area that is going to be filmed or photographed by 

the UAS. We will observe the location of trees, power lines, or any other obstacle that may 

interfere with the safe flight of an UAS. 

2. Ensure that nothing will prevent a line-of-sight operation during the flight. 

3. Test batteries in UAS, remote controls, and range extenders. The only acceptable battery level 

will be above 75% before takeoff. The UAS will be grounded before the battery level (which is 

monitored remotely) reaches 25%. 

4. Conduct a pre-flight checklist. 

5. Review the plan for the flight with the observer. Review altitudes, distances, and movements 

of the UAS. 

6. Ensure the PIC has license and medical on hand. 

7. Establish a security perimeter for observers. Care will also be taken to obtain the consent of 

all persons involved in the area and ensure a perimeter of 100ft is kept of the flight operation to 

maintain a sterile area. 

8. The operator will file FAA Form 7711-1 or equivalent, with the appropriate Flight Standards 

District Office. 

9. 3 days prior to the operation of an UAS, the PIC will submit a written plan of activities to the 

FSDO if required. 

10. PIC and observer will maintain communication throughout the entire flight. 

11. Permission from homeowner, landowner, or other property owner will be obtained prior to 

flight. 12. Permission from the local authorities will be obtains prior to flight. 

13. In the event the UAS loses signal, the built in programming will force the UAS to return to is 

location of takeoff, and will safely land and power down. 

14. Flights have the capability of being aborted due to unpredicted obstacles or emergencies. 

Radio Frequency 

This particular UAS operates at a frequency of 5.728GHz- 5.85 GHz. It is compliant with the FCC to 800m. 

The power of the radio falls within the FCC compliance of 100mW. 

Qualifications of UAS PIC 

At all times, the PIC of the UAS will be an FAA certified Private Pilot with a current 3rd class medical. 

Because the UAS will not carry passengers and will fly within a restricted area, it will exceed the safety 

standards set forth in 14 C.F.R 61.113 a& b. The PIC will also undergo training that the FAA will require 

to operate such UAS. The PIC will have over 100 hours of flight time. The PIC will also carry at all times a 

portable 2-way radio for air traffic monitoring and announcement of the location of the UAS if required 

by the FAA. At all times there will be an observer who will also monitor the UAS, surrounding buildings 

or obstacles, observers, and will be the second set of eyes to warn of any dangers that may affect the 

safe flight of the UAS. 

Zouroudis Photography, LLC 15460 NW 55` h BLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT 

Operations of the Unmanned Aircraft 

As stated earlier, the UAS will be a tool mostly for out of state real estate clients to be able to view 

properties, view entire structures, and educate them more fully before entering into a real estate 

transaction. 

The flights of the UAS will not pose a safety threat with the proper procedures in place as mentioned in 

the section "Procedures for Flight." As described earlier, there will, at all times, be an observer, a safety 

perimeter of 100 feet, battery levels above 75% before flight, a full pre-flight checklist and run-up, 

review of the flight plan, permission of property owners, written plan submitted to the FSDO if required, 

proper communication between PIC and observer, and permission from local authorities. Flights will 

only be conducted during daylight hours. 

The UAS does not have the capability to fly over 29.1577 knots and speeds will generally be around 3-10 

knots. The UAS will not be operated if clouds are at a level below 700ft AGL. This will ensure a safe 

distance from clouds and any low-flying aircraft. 

The indented area of operation will be in rural settings, as well as neighborhoods where homes are on 

lots over one-half acre and have a distance of 75-100 feet between homes. It will not be used in highdensity residential settings as that could pose too many safety concerns. Potential hazards in the 

intended area of operation are trees, power lines, structures, street lights, and fences. Because of the 

slow flight of the UAS when in operation for videography and photography for the intended purpose, 

the PIC and observer will be able to safely maneuver the UAS around the obstacles. The UAS also has 

capabilities of hovering in place which allows it to be flown at very low speeds. 

The intended cities and counties of use have small non-towered municipal airports. The UAS will never 

be flown near the airports so as to pose any sort of safety concern to pilots in the area. The altitude of 

the UAS will barely be above structures which should not pose any concern to piloted aircraft in the 

area. But for added safety, a 2-way radio to communicate to air traffic will always be on hand. This UAS 

will NEVER be flown within a 5-mile radius of any large international airport. The UAS has built in 

restrictions that prevent flight within those distances from an airport. The built in flight restrictions 

prevent takeoff in a 5-mile radius of a large International airport such as FLL, MIA, etc. The UAS will also 

be prevented from taking off within .6 miles of a smaller regional airport such as IDA If the UAS is in 

flight and tries to fly into a no-fly zone, the UAS will stop and return back. 

If required be the FAA, I will notify the FSDO of my flight operations prior to flight. 

14 C.F.R. Part 21, Subpart H, 91.203(a) &(b) Airworthiness Certificate 

Because the UAS is under 551bs, fully loaded, and does not carry a pilot, passenger, any explosive 

materials or flammable fuel, operates in a fully restricted and controlled environment, I request 

exemption from 91.203 part A& B. 

14 C.F.R. 45.23 B Marking the Aircraft 

The UAS will not have an airworthiness certificate and because there is no entrance to the cabin, 

cockpit, or pilot station, there is no place inside the aircraft to place the word "Experimental." If required 

Zouroudis Photography, LLC 15460 NW 55` h BLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT -- - 

by the FAA, I will place the word "Experimental" on the exterior of the UAS. However, due to the size, 2 

inch lettering will not be possible. 

14 C.F.R. 61.113 A& B Private Pilot Privileges and Limitations: Pilot in Command 

Unlike civil aircraft, the UAS does not carry living things on board; rather, it is controlled remotely via a 

safe and restricted location. The risks during operation are so minuscule that the PIC will exceed the 

present level of safety required for a commercial pilot to operate a rotorcraft with a commercial license. 

14 C.F.R. 91.9 B(2): Civil Aircraft Flight Manual in the Aircraft 

Because of the size and configuration of the UAS, no such manual can be carried. The flight manual will 

be carried at the ground station where the PIC and observer are operating the UAS. 

14 C.F.R. 91.103 B(2): Preflight Action 

A thorough pre-flight inspection and run-up of the aircraft will be performed prior to any flight of the 

UAS. Please see the appendix for the pre-flight checklist. 

14 C.F.R. 91.105: Flight Crewmembers at Station 

Because there are no souls on board a UAS, regulation 91.10S should be exempt from my purposes of 

using a UAS. However, crewmembers will be on the ground and in direct communication, namely the 

PIC and Observer. 

14 C.F.R. 91.109: Flight Instruction 

The UAS does not have dual controls. The PIC communicates to the UAS via a radio control box. The FAA 

has approved exemptions for flight training without fully functional dual controls for a number of 

aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

The UAS will never operate at an altitude greater than 400ft AGL. It will be operated within a restricted 

area and with the consent of any and all persons or property involved. 

14 C.F.R. 91.121 Altimeter Settings 

The UAS that will be used does not have an altimeter. Rather, it uses GPS to determine the altitude. 

Since the normal protocol is to set your altimeter to the barometric pressure reading at the time of 

flight, an exemption will be needed. A safety check will be performed before each flight ensuring that 

the GPS altitude is reading correctly. 

14 C.F.R. 91.151: Fuel Requirements for Flight in VFR Conditions 

The battery in the D11 Phantom 2 Vision+ is capable of 25 minutes of powered flight. Given that the UAS 

will never be further than 300ft away and 400ft AGL, the longest possible time it could take the UAS to 

return to the ground safely is approximately 1.5 minutes. I categorize battery life under 10 minutes as 

Zouroudis Photography, LLC 15460 NW 55 ` hBLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com 
EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT L.:A:=-.=':~& , 

the danger zone. The UAS will automatically return to its point of origin and safely land when the battery 

life reaches 2 minutes. Battery life as well as flight-time remaining is displayed on the screen visible to 

the PIC and observer. For safe flight, I will never fly the UAS with under 10 minutes of battery life. 

14 C.F.R. 91.203 A& B: Carrying Civil Aircraft Certification and Registration 

The UAS weighs under 55 pounds and does not have an on-board pilot operating it. The UAS is not 

capable of carrying such documents should they be required. These documents, if required by the FAA, 

will be carried by the PIC and will be accessible upon request immediately. 

14 C.F.R. 91.405 A; 407 A(1); 409 A(2); 417 A& B: Maintenance Inspections 

This regulation applies to aircraft that have an airworthiness certificate and should not apply to the 

operation of my intended use for the UAS. However, regular maintenance, checks, and cleaning of the 

UAS will be performed before each flight and if required by the FAA, can be logged into a log book and 

surrendered upon request. Regular maintenance will include cleaning of the 4 motors on the UAS 

Rotorcraft, motor testing, flight control testing, checking lights, and a cleaning of the entire UAS. Should 

a mechanical issue arise during a flight, the UAS will land immediately and should not pose a safety 

concern because of its lightweight, restricted flying area, and low and slow maneuvering. 

General Summary 

I feel that my operation of the UAS will meet and exceed all current safety standards set forth by the 

FAA. I am seeking exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) &(b);91.7 (a); 91.9 (b) (2);91.103(b); 

91.105; 91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 

91.409 (a) (2) and 91.417 (a) &(b) to operate commercially for buyer education purposes in Real Estate. 

Approval of this exemption will ensure safe flight operations for my UAS following the strict guidelines 

set forth in the request. 

Should you have any questions or need to contact me, my information is: 

Nicholas A Zouroudis 

5460 NW 55' h BLVD Unit 102 

Coconut Creek, FL 33073 

nzouroudis@gmail.com 

954-228-5339 

I feel that the criteria for exemption in Section 333 of the Reform Act of 2012 (namely size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual line 

of sight and national security) have been satisfied and adequate justification has been provided for this 

exemption. I appreciate your time and consideration in this matter. 

Respectively Yours, 

//

io as o dis 

Zourouli hotography 

Zouroudis Photography, LLC 15460 NW 55` h BLVD Unit 102 1 Coconut Creek, FL 33073 1 nzouroudis@gmail.com