**II**

. **The Specific Sections of Title 14 of the Code of**

**Federal Regulations From Which Randy** **Harris Requests**  **Exemption are:**

14 CFR 21; 14 C.F.R. 45.23(b);14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1);14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

**III. The Extent of relief Randy** **Harris seeks and the**  **Reason He Seeks Such Relief:**

I, Randy Harris , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from
any currently applicable FARs operating to prevent me, Randy Harris , contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspac e system as it is in the public’s interest to do so. My, Randy

Harris , ultra light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated b y the Reform Act. I would like to operate my ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulat ion that can be administered uniformly to all real estate related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The w eight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of ane xemption for me, Randy Harris . My UAS utilizes four (4)

counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit) ; including camera with gimbal.

I, Randy Harris , considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial l oss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode 5 for aerial videography/photo graphy. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do no t operate near areas wh ere general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediatel y to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft
may approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only within
my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three (3) to seven (7) minutes, with an altitude under one hundred fifty (150) feet. I, Randy Harris , utilize a fresh fully charged battery wit h each flight as a safety precaution; full flight time limit for each battery is nine (9) to twelve (12) minutes as tested. I do not operate my UAS at or below manufacture recommend minimum charge levels foroperation; preferring to remain well within a sa fe operating

range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for fu ture commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.

I, Randy Harris , am extremely cautious when operating of
my UAS/ultra light weight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Randy Harris ’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

**IV. How Randy** **Harris ’s**  **Request Will Benefit the Public As**  **A Whole:** 
Aerial videography for geographical awareness and for r eal estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxuryhomeowners can afford to absorb such expense. Depriving

non

- luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential ca tastrophic crash that the East T exas community. Each resulting in loss of life. Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency hard landings within city limits. My, Randy Harris ’s , UAS pose no such threat since size and lack of combu stible fuel alleviates any potential threat to the public.
Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, Randy Harris ’s , exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the Washington State area. My ultra light weight UAS is battery powered and creates no emissions that can harm the environ ment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.
The public’s interest is furthered b y minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. Permitting me, Randy

Harris , to immediately fly within national air space furthers economic growth. Granting my exemptio n request substantially furthers the economic impact for the Washington State community for companies looking to relocate or build in the Washington State area as well as individuals looking to relocate for career advancement through academic and geographi cal awareness. Both of which serve as a stimulus to thecommunity.

**V. Reasons Why Randy** **Harris ’s**  **Exemption Will Not Ad**  **ve rsely** **A**

**ffect Safety or How** **the Exemption Will**  **Prov ide a Lev** **el of Safety A** **t Least Equal to**  **Existing Rule:** 
My

, Randy

Harris ’s , exemption w ill not adversely affect safety. Quite the contrary, for the reasons stated permitting
me, Randy Harris , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation o f new and novel, as of yet undiscovered safety protocols for Realtors that can be embraced by the NAR, AAR, and TAR for development in cooperation with the FAA. In addition I, Randy Harris , submit the following representations of enhancements to current aerial videography and photography for real estate:
My UAS weighs less than 5 pounds complete with a small ultra light weight high quality GoPro 4 + Black camera; I only operate my UAS below 200 feet 9 (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operate for 3

- 7 minutes per flight; I land my UAS prio r to manufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by line of sight; My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance; I always obtainsall necessary permissions prior to operation; and, I have

procedures in place to abort flights in the event of safety breaches or potential danger.
My

, Randy

Harris ’s , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkab ly

astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra light weight UAS.
First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished.
Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of p ost editing software allowing pan and zoom.
Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

**VI. A Summary** **The FAA**

**May Publish in the Federal**  **Register:**

A. 1 4 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates,Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Randy Harris ’s , UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the wei ght, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Randy Harris

, current and projected UAS's meet or exceed each of the elements.
14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworth iness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regula tion in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systemswith a barometric sen sor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required

c ertifications and registrations by me, Randy Harris

. 14 C.F.R. § 45.23: Marking of The Aircraft.
Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs i n the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.
14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.
Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, Randy Harris , can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operati on of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Randy Harris , to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.14 C.F.R. § 91.119 prescribes safe altitudes for the operation of

civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 20 0 AGL; safely below the standard of 400 AGL. I, Randy Harris , will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, w eight, maneuverability and speed of
my UAS, an equivalent or higher level of safety will be achieved.
14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapte r. . . .”
These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Randy Harris

, UAS. However, as a safety precaution I inspect my UAS before and after each flight.
A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relat ion to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Randy Harris ’s , UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exemp t aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act.Both pieces of legislation permit the FAA to exempt UAS's

from the airworthiness certificate requirement in consideratio n of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, t his Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program tha t involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

**In summar y,**  **Randy Harris**  **seeks an exemption from the follow**  **ing Regulations:**
14 C.F.R. 21, subpart H; 14 C.F.R. 45 .23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R . § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Randy Harris , small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and real estate operations, and to develop economic platforms for real estate to enhance the experience of those seeking to relocate to the Washington State area. Currently, area awareness and real estate aerialvideography/photography relies primarily on the use of larger

ai rcraft running on combustible fuel. Posing potential risk to the public. Granting my, Randy Harris , request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighte r and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. I, Randy Harris , have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Randy Harris , UAS and therefore the likelihood of de ath or serious bodily injury is significantly diminished. My, Randy Harris ’s , operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FAR s. Accordingly I, Randy Harris , respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully

Submitted,

Randy Harris Randy Harris Photography 2407 79 th Ave NE Medina, WA 98039