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. 

D. The Reasons Why Granting the Robert Randle Request Would Be 

In The Public Interest; That Is, How It Would Benefit The Public As A 
Whole.

Granting the present Petition will further the public interest by allowing 

Robert Randle to safely, efficiently, and economically perform aerial 

video and photography of construction sites, real estate, events and 

civic landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 3 and/or Inspire 1 UAS will 

decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Robert 

Randle’s proposed operation of the DJI Phantom 3 and/or Inspire 1 

UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 3 UAS are battery powered and serve as a safe, 

efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount 

of manned aircraft needed to perform aerial acquisitions, an

exemption allowing the use of a DJI Phantom 3 UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, 

as well as increase the safety of life and property in the air and on the 

ground. 

Furthermore, by reducing the number of manned aircraft operating in 

the NAS, congestion around airports caused by arriving and departing 

aircraft will be reduced. The DJI Phantom 3 UAS do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in 

fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Phantom 3 and/or Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 and/or Inspire 

1 UAS instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated 
during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, The DJI Phantom 3 and/or 

Inspire 1 UAS produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder 

internal combustion engine aircraft that are typically utilized for aerial 

video and photography, while burning approximately 20-30 gallons per 

hour of leaded aviation fuel. The DJI Phantom 3 UAS, while reducing 

the carbon footprint of aerial acquisitions, also eliminates noise 

pollution, as the UAS are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

By using the DJI Phantom 3 and/or Inspire 1 UAS to perform aerial 

acquisitions, the substantial risk to life and property in the air and on 

the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the DJI Phantom 3 and/or Inspire 1 UAS 

(weighing approximately 2.8 pounds at their maximum gross weight 

with diagonal dimension of 23.2 inches, and with no fuel on board), 

has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With the DJI 

Phantom 3 and/or Inspire 1 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 and/or 

Inspire 1 UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the 

DJI Phantom 3 UAS will allow United States based companies, like 

Robert Randle, to remain competitive and contribute to growth of the 

U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing 

out leaded aviation fuels, U.S. owned and operated companies must 

adopt new and alternative technology in order to remain competitive. 

Operating the battery powered DJI Phantom 3 and/or Inspire 1 UAS 
is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the DJI Phantom 3 and/or Inspire 1 UAS, companies 

such as Robert Randle, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, 

which will ultimately contribute to growth of the U.S. economy. 

Improved financial performance of U.S. companies, through 

commercial use of the DJI Phantom 3 and/or Inspire 1 UAS, provides 

a stable workforce that increases consumer spending; improves local, 

state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the 

United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have 

been conducted for decades, Robert Randle’s proposed operation of 

the DJI Phantom 3 and/or Inspire 1 UAS will not implicate any 

privacy issues. Specifically, the DJI Phantom 3 UAS will be operated 

only in compliance with operating documents (i.e., the ALTEK MEDIA 

GROUP Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Phantom 3 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 

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