Lawrence L. Singer Sr.

1412 Shields Road

Saint Thomas

United States 

Pennsylvania

17252

Company Name: L.L. Singer Security Professionals

Professional Security and Private Detective Business and Aerial Photography Business

I'm applying for an exemption to fly my 550 Tri-copter and 1100 Octocopter drone with attached SJ4000 

cameras for commercial purposes. I currently run a production company that focuses on real estate 

videos and photos in Franklin County Pennsylvania. All of my flights for commercial purposes are at or 

below 200 feet, the drone weighs less than 55 pounds (approximately 5-10 pounds), I only operate 

during daytime Visual Flight Rules (VFR) conditions, I operate within visual line of sight (VLOS), and I 

maintain these distances away from airports or heliports: 5 nautical miles (NM) from an airport having 

an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but 

not an operational tower; or 2 NM from an airport without a published instrument flight procedure or 

an operational tower; or 2 NM from a heliport with a published instrument flight procedure. In addition 

to this, I also have a spotter with me while I fly to point out any possible obstructions to my flight path

I plan to operate a 550 Tricopter and 1100 Octocopter, which is comprised of an unmanned aircraft and 

a transportable ground station. The UA is referred to as a quadcopter and Octocopter with a maximum 

gross weight of about 3 and 10 pounds. It is equipped with four rotors one the quadcopter and 8 rotors 

on the octocopter that are driven by electric motors powered by batteries. The UA has a maximum 

airspeed of 35-45 knots. The UAS will have a small SJ4000 camera to the UAS and operate the UA over 

various areas near Franklin County Pennsylvania, to enhance community awareness and augment 

photographic areas. The UAS will provide the community with new and picturesque representations of 

their city and its surroundings. Aerial videography for geographical awareness, real estate marketing, 

and personal photography has been around for a long time through manned fixed wing aircraft and 

helicopters, but for small business owners, its expense has been costprohibitive. Granting this 

exemption would allow me to provide this service at a much lower cost. Furthermore, my small UAS will 

pose no threat to the public given its small size and lack of combustible fuel when compared to larger 

manned aircraft. The operation of this UAS will minimize ecological damage and promote economic 

growth by providing new opportunities to individuals and businesses in the San Diego metro and 

surrounding areas.

The Pilot, Lawrence L. Singer Sr, will provide the following levels of safety: I will only operate in 

reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, 

airports and actively populated areas; I will conduct extensive preflight inspections and protocols, during 
which safety carries primary importance. Comment Period Closed ID: FAA201512860003 Document 

Information Date Posted: Jun 30, 2015 Show More Details Submitter Information Submitter Name: 

Lawrence Singer Sr Comments 0 Docket Information This document is contained in FAA20151286 

Related Dockets: None Related RINs: None Related Documents: This count refers to the total 

comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all 

submissions, however some Comments Received* U.S. DOT/FAA Request for Additional Information 

Lawrence Singer Sr Exemption/Rulemaking * 7/2/2015 Regulations.gov Other Document 

http://www.regulations.gov/#!documentDetail;D=FAA201512860003 2/2 I will operate the UAS below 

200 feet and within a radius distance of 1000 feet from the controller to aid in direct line of sight visual 

observation; I will operate the UAS for 45 minutes per flight; I will land this UAS prior to the 

manufacturer's recommended minimum level of battery power; I will operate this UAS only within visual 

line of sight (VLOS); I will use the UAS global positioning system (GPS) flight safety feature whereby it 

hovers and then slowly lands if communication with the remote control pilot is lost; I will contact 

respective airports if operations will be within 5 miles to advise them of my estimated flight time, flight

duration, elevation of flight and other pertinent information; I will always obtain all necessary 

permissions prior to operation; I will have procedures in place to abort flights in the event of safety 

breaches or potential danger.

I also will provide additional training to any other pilots who I intend to hire as employees or 

independent contractors and insure all laws and or rules will be followed and take full responsibility for 

their flying. I have 2 pilots within my company which have 30 years of commercial Aviation and private 

pilot experience. My intention is to make this a full time business for Real Estate, Roofing, Construction, 

Farming and Insurance or any industry with the need for aerial video. 

I also have been in contact with local police departments and fire companies to insure any help with 

emergency situations in which my company may be of assistance. Currently my company can custom 

build and repair most UA’s and will continue with current technology to ensure safety and regulations 

set forth by the FAA.

I have 20 years of Private investigative experience and 10 years of professional Security Experience.

Currently I have over 300 Hours of Pilot Flight Time 
I plan to comply with any of the conditions and limitations of this grant of exemption will be grounds for 

the immediate suspension or rescission of this exemption. I have read and understand all of the rules 

and will continue to comply.

1. Operations authorized by this grant of exemption are limited to the 550 Tri-copter and 100 

Octocopter when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption 

holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 

knot speed restriction. In no case will the UA be operated at airspeeds greater than the 

maximum UA operating airspeed recommended by the aircraft manufacturer.

3. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.

5. All operations must utilize a visual observer (VO). The UA must be operated within the visual line 

of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO.

6. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during 

UAS operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The 4 operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if quesons 

arise regarding updates or revisions to the operating documents.

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g., replacement of a flight critical component, must undergo a functional test 

flight prior to conducting further operations under this exemption. Functional test flights may 

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The 
functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight.

10. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

11. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

12. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

13. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized.

14. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless 

a letter of agreement with that airport’s management is obtained or otherwise permitted by a 

COA issued to the exemption holder. The letter of agreement with the airport management 

must be made available to the Administrator or any law enforcement official upon request.

15. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC.

16. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property.

17. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

18. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and 

to operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.
19. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall 

be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a 

new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the attached COA.

20. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

21. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request.

22. The UA must remain clear and give way to all manned aviation operations and activities at all 

times.

23. The UAS may not be operated by the PIC from any moving device or vehicle.

24. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an undue 

hazard.

25. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

26. . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the Naonal 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

27. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must 

submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and 

times for all flights; b. Name and phone number of the operator for the UAS aerial filming 

conducted under this grant of exemption; c. Name and phone number of the person responsible 

for the on-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be 

used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement 

that the operator has obtained permission from property owners and/or local officials to 

conduct the filming production event; the list of those who gave permission must be made 

available to the inspector upon request; g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, 
and/or state over which filming will be conducted and the altitudes essential to accomplish the 

operation.

28. Flight operations may be conducted closer than 500 feet from participating persons consenting 

to be involved and necessary for the filming production, as specified in the exemption holder’s 

MPTOM.

29. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91.