January 26th, 2016

FROM: Brandon Harris

P.O. Box 152831

San Diego, CA 92195

Brandon.harris00@gmail.com

TO: Federal Aviation Administration 

US Department of Transportation

Docket Management System 

1200 New Jersey Ave. S.E 

Washington, DC 20590

Dear Sir or Madam,

I, Brandon Harris, am writing pursuant to the FAA Modernization and Reform Act of 2012 and 

the procedures contained within 14 CFR 11, to request that I, Brandon Harris, an owner and 

operator of small unmanned aircraft, to be exempted from the Federal Aviation Regulations 

(FARs) listed below so that I, Brandon Harris, may operate a small ultra-light weight unmanned 

aircraft system (UAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) in accordance with FAA UAS Regulations & Policies.

I would like to formally submit for an exemption from the following Section 333 regulations: 

 14 CFR 21

 14 CFR 45.23 (b)

 14 CFR 61.113 (a)

 14 CFR 91.7 (a)

 14 CFR 91.9 (b) (2)

 14 CFR 91.119 (c) 

 14 CFR 91.121

 14 CFR 91.151 (a)(1)

 14 CFR 91.203 (a) and (b)

 14 CFR 91.405 (a)

 14 CFR 91.40 (a) (1)

 14 CFR 91.409 (a) (1) and (2)

 14 CFR 91.417 (a) and (b)

In order to operate DJI’s following UAS: Phantom 3 Professional, Inspire 1 along the guidelines 

of the accompanying DJI Inspire 1 and DJI Phantom 3 Professional Operator’s manuals. These 

UAS will be equipped with detachable cameras and will be transported in proper storage.
This proposed exemption would allow me operation of UAS for the purpose of aerial 

videography, aerial photography and mapping as a service to the public/business interests. As 

found in exemption No. 11138 (Trudeau), the FAA recently approved similar use of a DJI UAS. 

These devices were selected because they have proven reliable flying capabilities managed by 

gyro stabilized flight, ground detection (Inspire 1 and Phantom 3 Professional), GPS aided 

navigation, compass, blinking LEDs, failsafe mode for returning base and prop guards.

This will act to further safety protocols exclusive to lightweight UAS’s specific to video and 

photography usage as I, Brandon Harris, record flight data and other information gained through 

permitted flight operations to share with the FAA through any required FAA reports to assists 

with future protocol and safety regulations. Specific section or sections of 14 CFR which I seek 

relief and the reasons:

 14 CFR Part 21: Airworthiness Certificates – given the size and limited operating area 

associated with the aircrafts to be utilized by I, Brandon Harris, an exemption from Part 

21 meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than conventional aircraft operating 

with an airworthiness certificate without restriction and conditions proposed.

 14 CFR 45.23: Display of Marks – general the UAs will not have a cabin, cockpit, pilot 

station, fuselage, boom, or tail on which to mark certain words or phrases. Furthermore, 

the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller 

than the minimal lettering requirement.

 14 CFR 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command –

The FAA has previously declared that additional manned airship experience of a 

commercially certified pilot would not correlate to the airmanship skills necessary for 

similarly proposed operations in previously issued exemptions to this regulation through 

Exemption No. 11062 and 11138.

 14 CFR 91.7: Civil Aircraft Airworthiness – Currently there is no certificate applicable to 

the UAS in question, this regulation is inapplicable.

 14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard Requirements –

Requires an aircraft flight manual in the aircraft, however there is no pilot or passenger 

on board this aircraft and given its size, this regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a safety/flight manual with the operator.

 14 CFR 91.119 (c): Minimum Safe Altitudes – I, Brandon Harris will ensure that UAS do 

not operate any higher than 400 feet at ground level. I will not fly over congested area. I 

will plan operations before hand, for proper flight safety, and proper height analysis as to 

avoid collisions.
 14 CFR 91.121: Altimeter Settings – The UAS utilize an electronic GPS with a 

barometric sensor. An equivalent level of safety will be achieved by using this 

equipment.

 14 CFR 91.151 (a)(1): Fuel Requirements for Flight in VFR conditions – The UAS that I 

will operate are powered by electricity, using lithium polymer batteries that currently 

have a flight limit of approximately no more than 20 minutes. Therefore, due to the 

limitations of the batteries, it is currently impossible to comply.

 14 CFR 91.203 (a) and (b): Civil Aircraft Certifications Required – Currently, there is no 

procedure for providing airworthiness certificates for the mentioned UAS.

I, Brandon Harris, however will always fly safely while having the manuals of the DJI Inspire 1 

and DJI Phantom 3 Professional. 14 CFR 91.405 (a) Maintenance Required, 14 CFR 91.407 

(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 14 CFR 

91.409 (a) (1) and (2): Inspection & 91.417 (a) and (b): Maintenance Records – Maintenance 

inspections may be required and should be granted since they only apply to aircraft with an 

airworthiness certificate. However, I, Brandon Harris, will perform preflight inspections of the 

UAS before each flight as outlined in the operating documents. I, Brandon Harris, will also 

follow manufacturer recommendations from said operating documents. Public interest aerial 

photography/videography and mapping as an available service to the public allows for a cheaper 

method to capturing imagery than the use of the alternatives such as aircraft and helicopters. 

They are more expensive, inconvenient, noisy, and much more threatening due to size and 

combustible fuel. I, Brandon Harris, would gladly offer my services upon request and with 

proper coordination to any land capturing, mapping, search and rescue or emergency services 

organization to benefit the public. Also as mentioned in the Trudeau exemption No 11138: 

“Manned aircraft conducting aerial filming and photography can weight 5,000 lbs. or more, are 

operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons 

or more of fuel. The petitioner’s [UAS] weighs less than 3 lbs. The pilot and crew will be 

remotely located from the aircraft. The limited weight reduces the potential for harm to persons 

or damage to property in the event of an incident or accident. The risk of an onboard pilot and 

crew during an incident or accident is eliminated with the use of a [UAS] for the proposed 

operation.”

I, Brandon Harris, am seeking exemption from the following rules: 14 CFR Part 21, 14 CFR 

45.23 (b), 14 CFR 61.113 (a), 14 CFR 91.7 (a), 14 CFR 91.9 (b)(2), 14 CFR 91.119 (c), 14 CFR 

91.121, 14 CFR 91.151 (a)(1), 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) With the exemptions of the 

mentioned rules, I will be seeking to make my UAS photography/videography and mapping

services available to the public.
Alternatively, the public had looked to use helicopters and aircrafts to achieve what I can offer in 

a safer, more cost effective manner. By not using combustible fuel, flying at safe heights and 

strictly following the usage recommendations from DJI. These include but are not limited to: 

 Flying the following UAS safely: DJI Inspire 1 and DJI Phantom 3 Professional.

 Flying below 400 feet.

 Proper visual inspection of UAS before flights.

 Keeping mentioned UAS in visual sight at all times while operation.

 Using an observer to assist if needed.

 Remain well clear of and do not interfere with manned aircraft operations, and avoid 

other aircraft and obstacles at all times.

 Not intentionally fly over unprotected persons or moving vehicles.

 Contact the airport or control tower before flying within 5 miles of an airport.

 Not flying in adverse weather conditions such as high winds or reduced visibility.

 Not flying under the influence of drugs or alcohol.

 Ensure the operating environment is safe.

 Not flying over sensitive infrastructure or property such as power stations, water 

treatment facilities, correctional facilities, etc.

 Check and follow all local laws and ordinances before flying over private property.

 Do not conduct surveillance or photograph persons in areas where there is an expectation 

of privacy without the individual’s permission.

Thank you for your time and consideration.

Brandon Harris

P.O. Box 152831

San Diego, CA 92195

Brandon.harris00@gmail.com