Robert J. Randle

8798 Tomnitz #103

Las Vegas, NV 81978

rrandle@bombsawaymedia.com

Exemption Request Pursuant to Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 

subpart H

14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 

14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 

91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a) 14 

CFR 91.203 (a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2) 14 CFR 91.417(a) and (b) 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (the “Reform Act”) and 14 CFR Part 11, Robert J. Randle, 

operator of Bombs Away Media, Inc., hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of designated UAS, provided such operations 

are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

Commercial operation of an UAS, as described herein, which are 

equipped with camera(s) and sensors, would provide professional 

services in the following areas:

1. Aerial photography and/or video for public and/or private use 

including real estate, architecture, land surveying, engineering and 

other related professional activities. 

2. Aerial video and/or photography for public and/or private use 

including television, public events, cinematography and 

newsgathering. 3. Aerial inspection/photography of 
residential/commercial structures under contract with the owners or 

local government authority. 4. Aerial inspection/photography of 

residential/commercial utility infrastructure including but not limited to 

electrical power lines, wind turbines and cell towers. 5. Aerial 

video/photography or providing live video feed to assist with search 

and rescue operations in cases of an emergency or natural disaster 

only when the local authorities or government has requested it by 

contract or donation. 6. Training to persons individually or belonging 

to both private and/or public organizations to increase awareness and 

improve safety for current and future UAS operations within the NAS.

As described fully below, the requested exemption would permit the 

operation of designated UAS as set forth in this document under 

controlled conditions in the NAS that would be a) limited b) controlled 

c) predetermined and d) safe. Approval of this exemption would 

increase public awareness of UAS operations and enhance safety to 

aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to 

“....establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” 

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is 

comprised of an unmanned aircraft (UA or Phantom 3) and a 

transportable ground station. The Phantom 3 is referred to as a 

quad-copter with a maximum gross weight of about 3 pounds. It is 

equipped with four rotors that are driven by electric motors powered 

by batteries. The UA has a maximum airspeed of 16 m/s. 

I also plan to operate a UAS, the DJI Inspire 1 which is comprised of 

an unmanned aircraft (UA or Inspire 1) and a transportable ground 

station. The Inspire 1 is referred to as a quad-copter with a maximum 

gross weight of about 6.5 pounds. It is equipped with four rotors that 

are driven by electric motors powered by batteries. The UA has a 

maximum airspeed of 22 m/s. 

Also, given the small size of the UAS’s involved and the restricted 
controlled environment within which they will operate, the applicant fits 

within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the controlled areas in which the relevant 

UASs will operate, approval of the application presents no national 

security issue. Given the following, the grant of the requested 

exemptions is clearly in the public interest: Robert J. Randle proposes 

that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. 

These limitations provide for an exceptional level of safety to 

operations. These limitations and conditions to which Robert J. Randle 

agrees to be bound when conducting commercial operations under an 

FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 2. Flights will be operated 

within line of sight of operator. 3. Maximum total flight time for each 

operational flight will be 30 minutes. 4. Flights will be terminated at 

15% battery power reserve. 5. Flights will be operated at an altitude 

of no more than 400 feet AGL 6. UAS operator will be trained and 

certified in the proper safety and operations of the UAS. 6. The UAS 

will only operate within a controlled area as defined in the Procedures.

7. The operator will post advisor notice around the controlled area.

8. The operator will have been trained in operation of UAS generally 

and received up-to-date information on the particular UAS to be 

operated as required. 9. If the UAS loses communications or loses 

its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land. 10. 

The UAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies. 

Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption and are prepared to modify or amend any part of 

this request to satisfy the need for an equivalent level of safety. We 
look forward to working with your office. Please contact us at any time 

if additional information or clarifications are needed. 

Sincerely,

Robert J. Randle