Patrick MacAllister Date: 12 /30 /15

DBA, Aerial Optics Exemption No. 11430

P.O Box 26 Regulatory Docket No. FAA

– 2015

– 0170
Humarock MA 02047 (781)588

- 3259 Patrick@aerialoptics.net

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

To w ho it may concern,

Patrick MacAlliste r DBA, Aerial Optics would like add Search and R escue , SAR and to our existing
exemption No. 11430

.

For us t o operate emergency Search and R escue missions effectively Aerial Optics is requesting

relief from two p rovisions imposed on us under our existing COA and section 333 exemption

.

1. The requirement to issue a NOTAM

 D. Notice to Airmen (NOTAM). A distant (D) NOTAM must be issued when unmanned aircraft operations are being cond ucted. This requirement may be accomplished: a. Through the operator’s local base operations or NOTAM issuing authority, or b. By contacting the NOTAM Flight Service Station at 1

- 877

- 4

- US

- NTMS (1

- 877

- 487

- 6867) not more than 72 hours in advance, but not le ss than 24 hours prior to the operation, unless otherwise authorized as a special provision. The issuing agency will require the: (1) Name and address of the pilot filing the NOTAM request (2) Location, altitude, or operating area (3) Time and nature of th e activity.

T he u rgency of a SAR mission does not allow for a 24 hour wait time to issue a NOTAM

.

Before the start of a ll search missions Aerial Optics will notify all airports in the vicinity of our

activities and monitor air traffic via handheld radio during the flight

.

2. The 500 ’ R ule

 26. 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 mus t 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 objectsand 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

The 500 ’ Rule is extremely diffi cult to adhere to especially with all of the parties involved in a

S earch and R escue mission. We take great care of our sUAS and do everything we can to prevent
incidents. At Aerial Optic s s afety is our main concern of every flight. Also unlike most sUAS Aerial Optics sUAS all carry a minimum of 1 Million dollars in liability insurance.

CONCLUSION

By granting Patrick MacAllist er DBA, Aerial Optics these additional exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations of s UAS. Aerial Optics is committed to promoting the UAS research efforts of policymakers by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations.

As pointed out in my original 333 application, all the sUASs which our company would use, under authorization by the US DOT

- FAA, are small, light

- weight devices operated within the line of sight
of the Pilot

- in

- Command (PIC), less than 400 feet above the ground and away from any airport or location with aviation activities, unless the ai r traffic control authorities (ATC) have been notified

.

T hank you, Patrick L MacAllister, D.B.A Aerial Optics