27 October 2015

Randall Owens

7024 Moonray Court

Eastvale, CA 92880

(951) 432-7534

rowens551@gmail.com

Dear Sir or Madam: 

This petition is being submitted on my behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 

11, Randall Owens, a freelance multimedia enthusiast, Aerial Photography Hobbyist and Recreational Unmanned 

Aircraft Systems Operator, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed 

below to allow operation of small Unmanned Aircraft Systems (sUAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Randall Owens to pursue his commercial interests in providing services to 

clients using a small Unmanned Aircraft Vehicle (sUAV) in the following areas: Aerial Photography, Real Estate, 

Marketing, and private Special Events. Randall Owens states that all sUAS flights will occur over private or 

controlled access property and will do so with the property owner's consent and knowledge and that only people 

who have consented or otherwise have agreed to be within the UAS’ radius during filming and photography 

applications.

Randall Owens has demonstrated the ability to safely operate and effectively fly the sUAS DJI Phantom 2 Vision 

Plus, DJI Phantom 3, and Walkera Tali-H500 which will be used for all commercial and private purposes. Randall 

Owens complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and 

environmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

I, Randall Owens, am seeking the exemption because I am committed to complying with all of the rules, guidelines, 

limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I have 

described, and for the purposes that I have described. Without the exemption request granted, I would be unable to 

safely and effectively run my proposed business, and it is my intention to comply with the FAA and obtain an 

exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of 

responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit and safety 

features.

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

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. 91.109 

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) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision Plus, DJI Phantom 3, 

and Walkera Tali-H500 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. Operations for the purpose of closed-set motion picture and television filming are not permitted. 

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the UA be 

operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA shall operate at an altitude of no more than 400 feet above ground level (AGL). Altitude we be reported 

in feet AGL. 

5. The UA shall be operated within visual line of sight (VLOS) of the Operator in Charge (OIC) at all times. This 

requires the OIC to be able to use human vision unaided by any device other than corrective lenses, as specified on 

the OIC’s U.S. driver’s license. 

6. Operations may utilize the services a visual observer (VO). The UA must be operated within the visual line of 

sight (VLOS) of the OIC and/or VO at all times. The VO may be used to satisfy the VLOS requirement as long as 

the OIC always maintains VLOS capability. The OIC and VO shall be able to communicate verbally at all times.

7. This exemption and all 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 upon request. 

8. 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 conducting further 

operations under this exemption. Functional test flights may only be conducted by the OIC and must remain at least 

500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue 

hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe 

operation. 

10. Prior to each flight, the OIC must conduct a pre-flight inspection and determine the UAS is in a condition 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 from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

13. The operator may not permit any OIC to operate unless the OIC demonstrates the ability to safely operate the 

UAS in a manner consistent 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. 

14. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). 

15. The UA may not operate within 5 nautical miles of an airport reference point (ARP).

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 OIC shall abort the flight in the event of unpredicted obstacles or emergencies. 

18. The OIC 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 operation and safely land the UAS without entering into 

emergency landing procedures due to low power condition.

19. The UA must remain clear and give way to all manned aviation operations and activities at all times. 

20. 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 

representative will be obtained before each flight is conducted. 

Public Benefit and Safety

Randall Owens is petitioning for an exemption to operate a DJI Phantom 2 Vision Plus, DJI Phantom 3, and 

Walkera Tali-H500 with a built-in stabilized HD camera and GPS safety features which limit its ability it flies above 

ground level (AGL) and limits the radius of the distance it flies from the operator.

The DJI Phantom 2 Vision Plus, DJI Phantom 3, and Walkera Tali-H500 all have a failsafe function that is triggered 

in the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS 

will return to its point of takeoff and land safety. If the connection is restored, the OIC can regain control of flight 

and land manually. 

The applicant and OIC respectfully requests the FAA grant the requested exemption.

Sincerely,
Randall Owens