August 4, 2015

Exemption No. 12304

Regulatory Docket No. FAA–2015–1215

Mr. Randy Harris

Randy Harris Photography

2407 79th Avenue Northeast

Medina, WA 98030

Dear Mr. Harris:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket April 27, 2015, you petitioned the Federal Aviation 

Administration (FAA) for an exemption. The petitioner requested to operate an unmanned 

aircraft system (UAS) to conduct aerial photography and videography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is the 3D Robotics Solo.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 
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meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Randy Harris is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Randy Harris is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the 3D Robotics Solo

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 may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. 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 must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

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 to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
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documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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 a PIC with a VO 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 PIC 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. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC 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. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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). Flights 

under special visual flight rules (SVFR) are not authorized.

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

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. 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.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC 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 to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

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 must 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 objects and 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.

27. 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 for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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 airspace 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 by 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 

regulation 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 weight, 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 an 
exemption 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 loss 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 Mode5 for aerial 

videography/photography. 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 not operate near areas 

where 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 immediately 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 with 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 for 
operation; preferring to remain well within a safe 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 future 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 real 

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 luxury 
homeowners 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 catastrophic crash that the East 

Texas 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 combustible 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 

environment. 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 by 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 

exemption 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 geographical 

awareness. Both of which serve as a stimulus to the 
community.

V. Reasons Why Randy Harris’s Exemption Will Not 

Adversely Affect Safety or How the Exemption Will 

Provide a Level of Safety At Least Equal to Existing 

Rule:

My, Randy Harris’s, exemption will 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 of 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 feet9 (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 prior 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 obtains 
all 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 remarkably 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 post 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. 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 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 

weight, 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 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 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 regulation 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 systems 
with a barometric sensor.

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 

certifications 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 in 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 operation 

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 200 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, weight, 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 

chapter. . . .”

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 

relation 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 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 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, 

this 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 that involves regular software updates 

and curative measures for any damaged hardware. 

Therefore, an equivalent level of safety will be achieved.

In summary, Randy Harris seeks an exemption from the 

following 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 aerial 
videography/photography relies primarily on the use of larger 

aircraft 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, lighter 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 death 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 FARs. 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 79th Ave NE

Medina, WA 98039