Singer’s Creations

4075 Linglestown Road
PMB #333 Harrisburg, PA 17112
717-576-2707 mike@singerscreations.com

November 2, 2014

U.S. Department of Transportation, Docket Operation s West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 1 4 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91. 409 (a)(2); 14 CFR 91.417 (a) and (b)

Dear Sir or Madam:

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Singer’s Creations hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to a llow commercial use of its Small Unmanned Aircraft Systems (SUASs), so long as such operations are conducted within and under the conditions outlined herein or as may be e stablished by the FAA as required by
Section 333.

An exemption is being requested because (1) existin g regulations will burden Singer’s Creations (2) Singer’s Creations can provide a leve l of safety that is equal (or greater than in many cases) to those provided by existing rules, an d (3) the request is in the public interest. The FAA’s authority to issue exemptions from operat ing rules, and the Secretary’s authority granted by Section 333 of P.L. 112-95, Special Rule s for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain SUAS op erations in the National Airspace System (NAS) prior to implementation of the SUAS ru le. This incremental step will allow Singer’s Creations to safely and legally enter into the NAS.November 2, 2014

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As described in detail below, the requested exempti on would permit Singer’s Creations to operate SUASs under controlled conditions in airspa ce that is (1) limited (2) predetermined (3) controlled as to access, and (4) would provide safety enhancements to the already safe operations of those aircraft of similar size, weigh t, speed, and operating capability that have been granted entry into the NAS via the rules in Ac ademy of Model Aeronautics (AMA) National Aircraft Safety Code. 1 Approval of this exemption would thereby greatly enhance safety and fulfill the Secretary of Transportation’ s (the Secretary) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system” per Section 333 (c) of the Reform Act.

Singer’s Creations is requesting exemption from the following regulations:

14 CFR Part 21, Subpart H 14 CFR 61.23 (a) 14 CFR 61.113 (a) and (b)
14 CFR 91.109
14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(1) 14 CFR 91.409 (a)(2) 14 CFR 91.417 (a) and (b)

This exemption application is expressly submitted t o fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Act. This law dir ects the Secretary to consider whether certain unmanned aircraft systems may operate safel y in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of U ASs do not create a hazard to users of the NAS, to the public, or pose a threat to nationa l security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an unmanned aircraft system, as a result of its size, weight, speed, operational capability, proximity to airports and populated areas, and oper ation within visual line of sight (VLOS)
does not create a hazard to users of the NAS or the public or pose a threat to national

1 See the attached “AmaSafetyCode.pdf” document.November 2, 2014

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security, and (2) whether a certificate of waiver, certificate of authorization, or
airworthiness certification under 49 USC 44704 is r equired for the operation of civil (nongovernmental) UASs. Therefore, if the Secretary det ermines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the nati onal airspace system”. 2

**Operation Overview**

Singer’s Creations’ SUASs are quadcopters, weighing 3 or fewer lbs. (including payload). The SUASs have the capability to hover and move in the vertical and horizontal planes simultaneously. They will operate only in visual li ne of slight (VLOS) and will operate only in tightly controlled and limited airspace. They are c apable of operating at speeds of up to 29 knots, but will be routinely operated at much lower speeds. They will routinely be operated below 200 feet above ground level (AGL), and never about 400 feet AGL.

Singer’s Creations’ exemption request would permit its commercial operation of SUAS for aerial photography and videography in tightly contr olled and limited airspace. Aerial photography and videography services will be offere d to homeowners, realtors, home builders, home contractors, and/or home inspectors for use in, but not limited to, real estate marketing and safer inspections of home exte riors. All operations will be conducted on private property and with the written and/or ora l permission of the property owner(s). Operations will always be conducted in areas that a re clear of all people, except the pilot in command (PIC) and the PIC’s helper(s). Such operati ons will ensure that the SUAS will “not create a hazard to users of the national airspace s ystem or the public”. 3

**Aircraft**

Singer’s Creations operates Phantom 2 Vision+ 4 (Phantom) SUASs manufactured by DJI, a well-known leader in quadcopter technology. DJI str ives to bring new perspectives to aerial work and help companies accomplish feats safer, fas ter, and with greater efficiency. They

2 Singer’s Creations interprets this provision to pl ace the duty on the Secretary to not only process applications for exemptions under section 3 33 of the Reform Act, but for the Secretary to craft conditions for safe operations o f SUAS, if it should be determined that the conditions set forth herein do not fulfill the stat utory requirements for approval.

3 Reform Act Section 333 (b)

4 http://www.dji.com/product/phantom-2-vision-plusNovember 2, 2014

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have an unparalleled commitment to R&D, a culture o f constant innovation, and a focus on transforming complex technology into easy-to-use de vices.

The standard Phantom quadcopter package includes th e Phantom itself, camera, gimbal, propulsion system, flight control system, 5.8 GHz r emote controller, and 2.4 GHz Wi-Fi communication system. The remote uses a 5.8 GHz fre quency to prevent interference with the video/telemetry channel. This second channel al lows for a constant connection with the Phantom to monitor it via a smartphone that is atta ched to the remote controller.

The Phantom is about 1 foot square in size. It has a maximum ascent speed of 11 knots, a maximum descent speed of 3 knots, and a maximum fli ght speed of 29 knots. While operating within VLOS, the remote control has a ran ge of 2,624 feet. The total weight (including the payload) is 2.55 lbs. 5

The Phantom is equipped with a DJI Naza-M V2 flight control system. This provides for incredible ease of use and stability. Pilots can co ntrol the Phantom’s movements in many directions – including pitch (forward and backward) , roll (left and right), elevator (up and down), and yaw (turn left or right). The flight con trol system can also provide Intelligent Orientation Control (IOC), failsafe, battery level warnings, and show the aircraft’s current heading, direction, and approximate distance from h ome on the on-screen radar. The builtin GPS system aids in stabilizing the aircraft and automatically and safely returns it back to its home point in any case where communication betw een the remote control and quadcopter are lost.

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter that measures both attitude (ATTI) and al titude. The inertial measurement tells the Phantom how it’s tilted. And the gyros tell it if it’s rotating in any particular direction.

The Phantom’s compass read geomagnetic information and assist the Global Positioning System (GPS) to accurately calculate the position a nd height of the aircraft. The vertical hover accuracy is +/- 2.6 ft. The horizontal hover accuracy is +/- 8.2 ft.

The Phantom has LED flight indicators beneath each of its four rotor arms. The LEDs illuminate to indicate the status of the flight con trol system and alert the PIC of any possible
issues.

5 http://www.dji.com/product/phantom-2-vision/specNovember 2, 2014

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Such highly advanced capabilities will ensure that the SUASs can be safely operated and “not create a hazard to users of the national airsp ace system or the public.” 6

**Equivalent Level of Safety**

In an effort to join the FAA in its mission to prov ide the safest, most efficient aerospace system in the world and to minimize the risk to the NAS or to persons and property on the ground, Singer’s Creations agrees to be bound by th e following limitations and conditions when conducting commercial operations under an FAA issued exemption:

A. For the purposes of ensuring SUASs will be operated within the standards that the
FAA has allowed in the AMA National Model Aircraft Safety Code:

1. SUASs will not be flown:

a. In a careless or reckless manner.

b. At a location where SUAS activities are prohibited.

2. SUAS pilots will:

a. Yield the right of way to all human-carrying aircra ft.

b. See and avoid all aircraft and a spotter must be us ed when appropriate 7

.

c. Not fly higher than 400 feet above ground level or within three (3) miles of an airport without notifying the airport operato r.

d. Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement.

e. Not exceed a takeoff weight of 55 pounds (including payload).

6 Reform Act Section 333 (b)

7 AMA Document #540-DNovember 2, 2014

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f. Ensure the aircraft is identified by affixing the o wner’s contact

information to the outside of the SUAS.

g. Not operate SUASs while under the influence of alco hol or while using any drug that could adversely affect the PIC’s ability to safely control the
model.

h. Not operate SUASs carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons or property.

3. SUASs will not be flown unless:

a. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific

event.

b. An inexperienced pilot is assisted by an experience d pilot.

4. All pilots shall avoid flying directly over unprote cted people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.

5. A successful radio equipment ground-range check in accordance with manufacturer’s recommendations will be completed be fore the first flight of a new or repaired model aircraft.

6. SUASs must use the radio-control frequencies curren tly allowed by the Federal Communications Commission (FCC).

7. SUASs will not knowingly operate within three (3) m iles of any pre-existing flying site without a frequency-management agreement. 8

8. Excluding takeoff and landing, no SUASs may be flow n outdoors closer than 25 feet to any individual, except for the PIC and the PIC's helper(s) located at the

8 AMA Documents #922 and #923November 2, 2014

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takeoff site.

9. Under no circumstances may a pilot or other person touch a SUAS in flight while it is still under power, except to divert it from s triking an individual.

10. The PIC of the SUAS shall:

a. Maintain control during the entire flight, maintain ing visual contact without enhancement other than by corrective lenses prescribed for the pilot.

b. Fly using the assistance of a camera or First-Perso n View (FPV) only in accordance with the procedures outlined in AMA Docu ment #550.

c. Fly using the assistance of autopilot or stabilizat ion system only in accordance with the procedures outlined in AMA Docu ment #560.

11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown closer than 50 feet to any above-ground elect ric utility lines.

12. The flying area must be clear before the engine is started, except for PIC and the PIC's helper(s).

B. In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in an effort to enhance the safety offered by the already safe operations mentioned above, Singer’s Creations also agrees to be bound by the following
limitations and conditions:

1. Flights will be operated within VLOS of the PIC.

2. Maximum total flight time for each operational flig ht will be 25 minutes. Flights will be terminated at 25% battery power reserve sho uld that occur prior to the
25 minute limit.

3. The SUAS will only operate in tightly controlled an d limited airspace.November 2, 2014

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4. A briefing will be conducted in regard to the plann ed SUAS operations prior to

each flight. It will be mandatory that all personne l who will be performing duties within the boundaries of the safety perimeter be pr esent for this briefing.

5. The PIC and the PIC’s helper(s) will have been trai ned in operation of SUAS and received up-to-date information on the particular S UAS to be operated.

6. The pilot and the PIC's helper(s) will at all times be able to communicate by
voice.

7. If the SUAS loses communications or loses its GPS s ignal, the SUAS will have capability to return to a pre-determined location w ithin the security perimeter and safely land.

8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

9. All flights will be conducted on private property a nd with the written and/or oral permission of the property owner(s).

10. Flights will always be conducted in areas that are clear of all people, except for the PIC and the PIC's helper(s).

11. All flights will be conducted outdoors in visual me teorological conditions (VMC) and never during severe weather conditions.

12. Flights will not occur in weather conditions that p revent the PIC from operating within visual line-of-sight (VLOS) at all times or in weather conditions that dramatically affect the UAS’s flight (e.g. high win ds).

13. If an operation occurs in an area where people coul d inadvertently enter the area, an operational border will be established wit h traffic cones. If it’s not
feasible to use traffic cones due to interference w ith the photography/videography, the PIC's helper(s) will b e responsible for keeping a safe perimeter around the operation. The operation will cease immediately and be rescheduled if it’s impossible to establish a sa fe perimeter around theNovember 2, 2014

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operation.

14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative maintenance plan can be followed, as d escribed in the
“Preventative Maintenance” section below.

15. The SUAS will not be routinely operated in the prox imity of any airports. In any cases where the SUAS must be operated within three (3) miles of an airport, the airport operator will be notified before the operat ion commences.

The operation of SUASs, weighing less than 3 lbs., conducted in the strict conditions as outlined above, will provide an equivalent level of safety supporting the grant of exemptions requested herein, including exempting th e applicant from the requirements of Part 21 and allowing commercial operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled environment. As a result, they offer a m uch safer way to capture aerial photography and videography. Furthermore, the propo sed operations represent a safety enhancement to the already safe operations that hav e been granted by the FAA for the
establishment of the AMA National Model Aircraft Sa fety Code.

**Preflight Action Plan**

The PIC will follow a comprehensive pre-flight chec klist to ensure that the SUAS is in a condition for safe flight. This plan will be improv ed as needed in order to ensure all known safety precautions and/or safety precautions sugges ted by the manufacturer are being
accounted for.

A. Pre-flight Inspection

1. Check that the remote control, Phantom battery, ran ge extender, and smartphone are all fully charged.

2. Verify that the Phantom battery is not swollen or d amaged in any way. Clean the contact needles and pads if necessary.November 2, 2014

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3. Turn the motor shafts with your fingers and verify they are smooth without

excessive play or binding.

4. Verify that the propellers are mounted correctly. P ropellers with a black top
should be mounted on the mount shafts that have a b lack dot. Propellers with a silver top should be mounted on the mount sh afts that have a silver dot. Each propeller should spin all the way down on to the motor shaft.

5. Run finger along the edge of edge blade to check fo r any rough edges.

6. Flex both side of the propellers’ blades to check f or hairline cracks where the blades connect in the center of the propeller.

7. Verify that the landing gear is secure (not cracked /broken/loose).

8. Verify that the compass and compass cable is firmly attached to the landing

gear.

9. Verify that the Micro-SD card has been inserted and formatted.

10. Verify that the damping absorbers are not broken an d/or worn.

11. Verify that the anti-drop pins are in place and loc ked.

12. Remove the Gimbal guard and camera lens cap.

13. Verify that the camera is secure and clean. Inspect the camera ribbon cables for tears and/or signs of wear.

14. Verify that the smartphone’s GPS is enabled.

15. Set the smartphone to do-not-disturb mode to preven t distractions while flying.November 2, 2014

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16. Set the smartphone to forget any Wi-Fi networks in range in order to prevent

the Wi-Fi connection from changing mid-flight.

17. Verify that the smartphone’s audio is on to ensure the low battery warning
and other alarms can be heard.

B. Power Up

1. Verify that S1 and S2 are in the top position on th e remote control.

2. Power on the equipment in the following sequential order:

a. Range Extender (“System” is blinking green; “Power” is solid green)

b. Remote Control (2 beeps to indicate it’s in FCC mod e)

c. Insert and start the Phantom battery.

3. Watch the Phantom LED startup sequence for abnormal indications. The rear LEDs should blink green for at least 10-15 seconds to indicate that it locked onto 6+ satellites and has marked the home point (f or use by the failsafe feature).

4. Calibrate the Phantom’s compass.

5. Place the Phantom on an open, flat ground with the battery indicators facing towards the PIC at least 10 feet away.

C. DJI Vision Application

1. Connect the smartphone Wi-Fi to the range extender.

2. Launch the “DJI Vision” application on the smartpho ne.November 2, 2014

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a. Verify that the Wi-Fi connection is “Phantom-#####” and is marked

with a green dot.

b. Verify the number of satellites is 6+.

c. Verify the Wi-Fi signal strength.

d. Verify that the Phantom and range extender batterie s are reporting a full charge.

e. Verify that both the PIC’s and Phantom’s location i s the same before taking off to ensure the home point has been accura tely marked.

f. Verify the location of the Phantom in the “Flight R adar”. If it’s not in the correct position/direction and/or shows a dista nce of “N/A”, it did not mark the home point.

g. Use the “Find my Phantom” feature to ensure the blu e (home point location) and red (Phantom location) dots are in th e same location on
the screen.

D. Ready to Fly

1. Verify that the remote control antenna is perpendic ular to the ground (pointing skyward).

2. Verify that the front, flat face of the range exten der is pointed toward the
Phantom.

3. Verify that the rear LEDs are still slowly blinking green and still connected to
6+ satellites.

4. Start the Phantom motors using the CSC command on t he remote control.November 2, 2014

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5. Verify that the motors are functioning normally, ar e not making any unusual

noises, and are all spinning at the same speed.

6. Verify that the area is still clear of obstructions , people, power lines, etc.

7. Take off and hover at about 6-8 feet above the take off point to verify that the Phantom has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc.), land immediately and repeat the “Pre-flight Inspection” and “Power Up” sequences.

8. Verify that the Phantom holds a steady position whi le yawing 360 degrees.

9. Verify that the Phantom response appropriately to a ll controls – yaw left/right, pitch forward/backward, roll left/right , and throttle up/down.

**Preventative Maintenance**

A comprehensive preventative maintenance plan will be followed in order to ensure the SUAS’s software is up-to-date, the batteries are in good health, and the aircraft itself is always ready for safe flight 9

.
**Pilot in Command (PIC) Qualifications**

The PIC does not hold an airman certificate or medi cal certification. Since the SUAS is similar in size, weight, speed, and operating capab ility as those currently allowed to be flown for hobby/recreation, holding the PIC to thos e same set of standards will allow for an equivalent level of safety.

The PIC holds a Bachelor of Science degree in Compu ter & Information Systems. Since the SUAS is controlled by a highly advanced computer sy stem and runs on software that must be configured, updated, and maintained, computer pr oficiency is a must to ensure the SUAS is ready to be safely operated in the NAS.

9 See the “Preventative Maintenance Checklist” on pa ge 41 of the attached “PhantomGuide.pdf” document.November 2, 2014

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It cannot be assumed that a commercial pilot, appro ved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely o perate an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlle d pre-approved airspace. Since there are no standards for either private or commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operat ion of the SUAS acquired from actual operation of the aircraft will be the most importan t factors in establishing an equivalent level of safety. With that in mind, Singer’s Creati ons proposes that its PIC be required to do the following prior to the first commercial operati on:

1. Perform 20 flights or log 20 hours of flight time ( the greater of the two) with the
Phantom.

2. Successfully learn and demonstrate all flight maneu vers in the “Phantom Pilot Training Guide”. 10

3. Study and be familiar with all sections of the “Pha ntom 2 Vision+ User Manual”. 11

4. Study and be familiar with all sections of the “Gui de to the Phantom 2 Vision &
Vision+”. 12

5. Study, be familiar with, and demonstrate (where pos sible) the “Always be Prepared for the Worst” scenarios. 13

**Public Interest**

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent level of safety, a reduction in environm ental impacts, and are free from the
harmful emissions associated with the manned aircra ft that are currently used for aerial photography and videography. Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, ap proval of this application presents no risk to the public. Furthermore, the public will be able to legally acquire aerial photography and

10 See the attached “PhantomTrainingGuide.pdf” docume nt.

11 See the attached “PhantomUserManual.pdf” document.

12 See the attached “PhantomGuide.pdf” document.

13 See “Always be prepared for the Worst” on page 13 o f the attached “Guide to the Phantom 2 Vision & Vision+”.November 2, 2014

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videography to help in, but not limited to, adverti sing homes for sale, advertising uninhabited home lots, use of photos and video as a n aid when researching homes for sale on the market, or safely accessing high and/or awkw ard areas of a home’s exterior to assess damage that needs to be repaired.

**Privacy**

Since the areas being photographed or filmed will b e on private property, accessed only after given written and/or oral consent by the prop erty owner(s), and clear of all people, except for the PIC and the PIC's helper(s), approva l of this application presents no risk to the public privacy.

**National Security**

Due to the size of the SUAS and the tightly control led and limited airspace in which the SUAS will operate, approval of this application pre sents no risk to national security.

**Requested Exemptions**

Singer’s Creations requests exemption from the foll owing regulations since it’s not possible to fully comply with them, and since attempting to follow them for the purposes of operating a SUAS would be a burden:

**Airworthiness Certificates** 14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements f or the issuance of airworthiness certificates as required by FAR 91.203 (a) (1). Giv en the size and limited operating area associated with the aircraft to be utilized by Singer’s Creations, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety
under Part 11 and Section 333 of the Reform Act. Th e Federal Aviation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both a uthorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, an d proximity to airports and populated areas of the particular SUAS. In all case s, an analysis of these criteria demonstrates that the SUAS operated without an airw orthiness certificate, in the restricted environment and under the conditions pro posed, will be at least as safe,November 2, 2014

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or safer, than a conventional aircraft operating wi th an airworthiness certificate without the restrictions and conditions proposed.

**Medical certificates** 14 CFR 61.23 (a)

This regulation requires pilots of manned aircraft to hold a medical certificate. Since risks associated with the operation of the proposed SUAS are so diminished from the level of risk associated with any manned aircraft; the SUAS is of a size, weight, speed, and operational capabilities which makes it much safer than any manned aircraft; since operations will occur in tightly co ntrolled and limited airspace; and considering that all operations will be on private property that is clear of all people, obtaining and maintaining a medical certificate wou ld not improve the safety of the operation. In the very rare case of a mishap, the S UAS being flown will pose significantly less of a threat than manned helicopt ers and fixed wing aircraft because the SUASs are a fraction of the size, a fraction of the weight, will be flown at a fraction of the speed, carry no flammable fuel, and carry no crew or passengers.

**Private pilot privileges and limitations: Pilot in command**  14 CFR 61.113 (a) and (b)

These regulations limit private pilots to non-comme rcial operations. Because the SUAS will not carry a pilot or passengers; due to t he SUAS’s size, weight, speed, and operational capabilities; and since operations will occur in tightly controlled and limited airspace, the proposed operations can achie ve the equivalent level of safety of current operations that currently require a comm ercial pilot’s license. Furthermore, since there are no standards for eithe r private or commercial SUAS pilot certificates, knowledge of airspace regulatio ns and dexterity in the control and operation of the SUAS acquired from actual operatio n of the aircraft will be the most important factors in establishing an equivalent lev el of safety. It cannot be assumed that a commercial pilot, approved to operate a mann ed helicopter or fixed wing aircraft, has the skill or ability to safely operat e an unmanned aerial vehicle, operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace.

**Flight instruction**
14 CFR 91.109November 2, 2014

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This regulation provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruc tion unless that aircraft has fully functioning dual controls.

SUASs and remotely piloted aircraft, by their desig n do not have fully functional dual controls. Flight control is accomplished through th e use of a control box that
communicates with the aircraft via radio communicat ions. The FAA has approved exemptions for flight training without fully functi onal dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot no r passengers will be carried in the aircraft and by the size and speed of the aircraft.

**Altimeter settings**
14 CFR 91.121

This regulation requires each person operating an a ircraft to maintain cruising altitude by reference to an altimeter that is set “ ...to the elevation of the departure airport or an appropriate altimeter setting availab le before departure.” As the SUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of saf ety will be achieved by the operator by confirming the altitude of the launch s ite shown on the GPS altitude indicator before flight.

**Fuel Requirements for Flight in VFR Conditions** 14 CFR 91.151 (a)

This regulation prohibits an individual from beginn ing “a flight in an airplane under VFR conditions unless (considering wind and forecas t weather conditions) there is enough fuel to fly to the first point of intended l anding, and, assuming normal cruising speed – (1) During the day, to fly after t hat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the SUAS provides approximatel y 25 minutes of powered flight. That would make it impossible to meet the 3 0 minute reserve requirement. Given the limitations on the SUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.November 2, 2014

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An equivalent level of safety can be achieved by li miting flights to 25 minutes or 25% of battery power (whichever occurs first). This res triction would be more than adequate to return the SUAS to its planned landing zone from anywhere in its limited operating area.

**Maintenance Inspections** 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91. 409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b)

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.. .,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply. Mainten ance will be accomplished by the operator pursuant to the aforementioned Phantom use r manual and guide. An equivalent level of safety will be achieved because these small SUASs are very limited in size, will carry a small payload, and op erate only in restricted areas for limited periods of time. If mechanical issues arise , the SUAS can land immediately and will be operating from no higher than 400 feet AGL. As outlined in the aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is in working order prior to initiating flight and perfor m maintenance as required. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

In accordance with 14 CFR Part 11, the following su mmary is provided for publication in the Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially operate smal l unmanned aircraft systems (55 lbs. or less) in order to safely and legally captur e aerial photography andNovember 2, 2014

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videography for use by homeowners, realtors, home b uilders, home contractors, and/or home inspectors.

The operation of SUASs conducted in the strict cond itions outlined above, will provide an equivalent and/or greater level of safety supportin g the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft o perate at slow speeds, close to the ground, and in a sterile environment, and as a resu lt, are far safer than existing operations conducted with helicopters operating in close proxi mity to the ground, people, or other buildings in the vicinity.

Given the small size of the SUASs involved, the slo w speed at which they must be operated in order to capture photos and videos, and the rest ricted environment within which they will operate, the Phantom demonstrates that it can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by exemption, allow commercial operations of SUASs to commence immediately. Also, due to the size of the SUASs and the
restricted areas in which the relevant SUASs will o perate, approval of this application presents no threat to national security. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations, the significant public benefit – including enhanced safety, reduction in environmental impacts , no emissions, ability to legally obtain aerial photography and videography services – the g rant of the requested exemptions is in the public interest. Accordingly, Singer’s Creation s respectfully requests that the FAA grant the requested exemption without delay.

Satisfaction of the criteria provided in Section 33 3 of the Reform Act – size, weight, speed, operating capability, proximity to airports and pop ulated areas, operation within the visual line of sight, public safety, and national security – provide more than adequate justificationNovember 2, 2014

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to grant Singer’s Creations the requested exemption , allowing for commercial operations as
described herewith.

Sincerely,

Michael Singer Founder, Singer’s Creations

Enclosures (4)