Aerial Technology Solutions, LLC July 29, 2015

John Hall, Owner/Member

Garrett Hall, Owner/Member

3511 Indian Hill Dr.

Kettering, Ohio 45429

We, John Hall and Garrett Hall, owners of Aerial Technology Solutions, LLC in Ohio are 

submitting this application in accordance with the FAA Modernization and Reform Act of 

2012 112 P.L. 95 Sec 331-334, so that Aerial Technology Solutions, LLC may operate a 

small unmanned aircraft system (UAS) commercially in airspace regulated by the Federal 

Aviation Administration (“FAA”) in accordance with FAA UAS Regulations and Policies.

The specific Sections of Title 14 of the Code of Federal Regulations which we submit an 

exemption are: 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. 91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 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)(1) and (2); 14 C.F.R. 91 417(a) and (b).

We seek relief from the currently applicable FARs so that we, Aerial Technology 

Solutions, LLC, may operate our UAS for the purpose of aerial videography and 

photography/aerial data collection as a service to businesses and the public interest. 

The UAS we utilize is the DJI Phantom 3, and it will be utilized in accordance with its 

accompanying Operator’s manual. It has been noted that this same UAS has been

approved by the FAA for similar use in other exemption requests.

The UAS weighs less than five (5) pounds, contains GPS navigation, camera, flashing 

LEDs, and a safety return home mode. Safety is of utmost importance – personal and 

public. Before each flight, we will visually inspect the UAS and rotors, making sure they 

are clean, sturdy, and properly attached. We will make sure the operating software is 

the most up-to-date software, and ensure the batteries are fully charged. The UAS will 

be tested for startup and proper responding to controls before the main flight at the 

desired location. In addition, each proposed location will be researched (by satellite 

image, mapping, and visual inspection) to ensure that there are no close airports or 

other potential hazards or concerns. The UAS will always be flown well below 400 ft. 

and within line of sight of the controls and operator. We each individually have logged 

numerous practice flights in remote areas for recreation to familiarize ourselves with 

the proper controls of the UAS, and to make sure the UAS had no defects.
This request will benefit the public as a whole by providing a necessary service while 

ensuring public safety. By utilizing this small, unmanned UAS to collect current aerial 

data and imagery, it will be much safer than using a large manned aircraft with 

passengers and flammable fuel. 

The specific sections of 14 CFR for which relief is sought and reasoning are:

14 C.F.R. Part 21 Airworthiness Certificates

The small size, weight and limited operating area of this UAS permits exemption from 

Part 21 as the UAS meets an equivalent level of safety under Part 11 and Section 333 of 

the reform Act. The legislation permits 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. Our UAS meets or exceeds 

all of the elements.

14 C.F.R. 45.23 Marking of the aircraft.

This UAS is unmanned and does not have a cabin, cockpit, pilot station, fuselage, boom, 

or tail on which to mark certain words or phrases. Further, two-inch lettering is difficult 

to place on such a small aircraft with dimensions smaller than the minimum lettering 

requirement.

14 C.F.R. 61.113(a) & (b) Private pilot privileges and limitations.

The FAA has previously declared that additional manned airship experience of a 

commercially certified pilot would not correlate to the airmanship skills necessary for 

similarly proposed operations in previously issued exemptions to this regulation.

14 C.F.R. 91.7 Civil aircraft worthiness

This regulation is inapplicable since to such certificate applicable to the UAs in question.

14 C.F.R. 91.9 (b)(2) Civil aircraft flight manual, marking, and placard

This requires an aircraft flight manual in the aircraft. Because there are no on board 

pilots or passengers and given the small size of the UAS, this regulation is inapplicable. 

The operator of the UAS will maintain a flight manual in order to achieve an equivalent 

level of safety.

14 C.F.R. 91.119 Minimum safe altitudes
We will ensure that out UAS will not operate higher than 400 feet at ground level. In 

addition, the UAS will not be flown over congested areas.

14 C.F.R. 91.121 Altimeter settings

The UAS utilizes electronic GPS with a barometric sensor. An equivalent level of safety 

will be achieved with these.

14 C.F.R. 91.151(a)(1) Fuel requirements for flight in VFR conditions

The UAS we utilize is powered by electricity and the flight time of a battery is no more 

than 25 minutes. Because of this, it is impossible to comply with part 91.151.

14 C.F.R. 91.203(a) & (b) Civil aircraft: certifications required

Currently, there are no procedures for providing airworthiness certificates for our UAS. 

We will fly safely utilizing the UAS operating manuals.

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(1) &(2); 417 (a) & (b) Maintenance and Inspections

These Regulations only apply to aircraft with an airworthiness certificate, and will not 

apply to our UAS. However, as previously mentioned, we will thoroughly inspect our 

UAS before and after each flight for safety and maintenance issues.

In summary, Aerial Technology Solutions, LLC (John Hall, Garrett Hall) seeks an 

exemption from the following regulations: 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. 91.103(b); 14 C.F.R. 

91.109; 14 C.F.R. 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)(1) and (2); 14 C.F.R. 91 

417(a) and (b).

We seek exemption so that we may commercially operate our UAS to provide aerial 

data collection, photography, and videography services to the public. The UAS we will 

be using is the DJI Phantom 3, which it has been noted has been approved by the FAA in 

similar exemption requests. This is a much more efficient and safer method of service 

as compared to manned aircraft that otherwise would have to be utilized, as ours does 

not use combustible fuel, and flies at safe heights and thus eliminates much of the 

public risk associated with manned aircraft. Any flight information that we collect 

would be willing to share with the FAA in order to benefit the FAA in these matters. As 

previously mentioned we will make sure the UAS is properly inspected and operating 

before and after each use. In addition, we will research each and every location ahead 

of time, noting location of airports, dense populations, power lines, and other potential 
hazardous situations. Because we would be providing a safer and necessary service, we, 

John Hall, and Garrett Hall, owners of Aerial Technology Solutions, LLC, respectfully 

request that the FAA grant our exemption request.

Respectfully Submitted,

John Hall

Garrett Hall

Aerial Technology Services, LLC

3511 Indian Hill Dr.

Kettering, OH 45429