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 com mercial purposes are at or below 2 00 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 aw ay 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 instru ment 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 p ath

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 quad copter 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 cost prohibitive. 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, duringwhich safety carries primary importance. Comment Period Closed ID: FAA2015 12860003 Docume nt

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 FAA 2015 1286 Related Dockets: None Related RINs: None Related Documents: This c ount 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/Rulema king * 7/2/2015 Regulations.gov Other Document http://www.regulations.gov/#!documentDetail ;D=FAA2015 12860003 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 positioni ng 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 add itional 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 comm ercial 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 dep artments 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 TimeI 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 manufa cturer. 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 li ne 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 al l 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 precede nce 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 a ny 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 upda tes 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 con ducting 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. Thefunctional 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 condi tion 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 fro m 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 ai rcraft 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 consiste nt 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 manne r 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 essentia l 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 o perations 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 perm itted 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 opera tion 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 seri al 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 fli ght 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 50 0 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 tha t 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 nonparticipat ing 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 do es 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 representa tive 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 op erator 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 respo nsible 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, in cluding 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 consenti ng 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 in cluding, but not limited to, parts 45, 47, 61, and 91.