Robert J. Randle

8798 Tomnitz #103 Las Vegas, NV 81978 rrandle@bombsawaymedia.com

Ex emption 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
fro m 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.

Comm ercial 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, architectur e, 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 ofresidenti al/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 in dividually 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 UA S 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 i s 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 powere d 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 restrictedcontrolled envi ronment 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. Ran dle 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 co nditions 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 fli ght 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 rec eived 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 U AS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

D. The Reasons W hy Granting the Robert Randle Request W ould Be In The Public Interest; That Is, How It W ould Benefit The Public As AWh ole.

Granting the prese nt 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.

Ad ditionally, 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 Inspir e 1 UAS will be realized without implicating any privacy issues.

1. The Public W ill 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 v ideo 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 W ill Benefit From The Safety And Efficiency Of The DJI Phantom 3 and/or I nspire 1 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 and/or I nspire 1 UAS instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generatedduring 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 aeria l 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 I nspire 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 aircra ft, the DJI Phantom 3 and/or I nspire 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 g round, 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 W ith the DJI Phantom 3 and/or I nspire 1 UAS W ill 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 an d 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 I nspire 1 UASis 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 Pha ntom 3 and/or I nspire 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 financ ial performance of U.S. companies, through commercial use of the DJI Phantom 3 and/or I nspire 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 th e DJI Phantom 3 and/or I nspire 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, an d 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.

Accor dingly, 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. W e look forward to working with your office. Please c ontact us at any time
if additional information or clarifications are needed.

Sincerely,Robert J. Randle