September 2 , 2015 AMT, Inc.

105 North Main Street Harrodsburg, KY 40330

502.882.0217

email: usaamt@gmail.com

RE: Exemption Request pursuant to Section 333 of the FAA Modernization

& Reform Act of of 2012 (Public Law 112-95) and Part 11 of the Federal Aviation Regulations from:

14 CFR 21 14 CFR 21 Subpart H 14 CFR 45.23(b) 14 CFR 61.113(

14 CFR 61.133

14 CFR 91 14 CFR 91.7(a)

14 CFR 91.9

14 CFR 91.103 14 CFR 91.103(b)

14 CFR 91.105

14 CFR 91.109

14 CFR 91.119

14 CFR 91.119

14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b)

14 CFR 91.405 14 CFR 91.405(a) 14 CFR 91.407(a)(1)

14 CFR 91.409 14 CFR 91.409(a)(1) & (a)(2) 14 CFR 91.417(a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, AMT, Inc. d/b/a/, ReallyCoolToys hereby applies for an exemption from the listed Federal Aviation Regulations (" FARs") above, as well as any other required exemption for commercial operation of its small Unmanned Aircraft Systems ("UAS") for use in avariety of professional services, including:

Aerial imaging services, photography, videography, and cinematography

Aerial search and rescue, government and agency technical support (i.e., law enforcement support, search and rescue, fire fighting crew support, and similar law and civil services) Aerial facility monitoring, surveillance, security, and training services for government, industrial, and commercial organizations Aerial live feed reporting, broadcast, and live feed relay for community and commercially supported events Aerial systems safety and flight training and demonstration services Aerial systems development, customization, and software application design services Aerial real estate, property tour, site survey and inspection services Event showcase of UAS technologies and safety standards, UAS sales,

and demonstration Precision agriculture and wildlife research services, aerial thermal imaging, data collection, analysis, terrain mapping services Unmanned aerial system telemetry and autonomous services

I nspection of construction sites, vertical structures, pipelines, right of ways, and other civil engineering aerial support services

AMT, Inc., was established by founder and CEO, Mr. Amir Sepahban in 1995, providing UAS, UGV, ROV services and support to NASA (JSC), agencies, and commercial organizations, creating training material, documentaries, and infomercials using manned and unmanned aerial imaging systems. In 2002, d/b/a, ReallyCoolToys was formed to address the growing demand for o ff -the-shelf UAV/UAS systems by government, support agencies, commercial organizations, and enthusiasts alike. Services were expanded to areas listed above. Today, AMT specializes in providing highly advanced technical UAS products, services, and solutions, including UAS operation software and application development, as well as complete system design, development, and customization

services. An exemption granted will enable AMT to continue its commercial UAS operations and services supporting a variety of government agencies, commercial organizations, and individuals in full adherence to FAA regulations, under controlled conditions in the NAS. AMT plans to use a variety of small UAS all under 55lbs, including (but not limited to) the DJI PHANTOM 3 Professional, DJI Inspire 1, DJI S1000, and other brands of small multirotor UAS, as well as aerial Balloons/Blimps for tetheredapplications only, and Opale Paramodel OXY1 and Trike L small UAS motorized paraglider and fixed wing small unmanned aircrafts for maximum flight e ffi ciency and duration when covering agricultural acreage within permitted VLOS range. Regardless of the type of small UAS used, each system will include an unmanned aircraft and a transportable ground station or ground support stationary vehicle. The aircrafts used include small UAS quadcopters, hexacopters, octocopters, fixed wing planes, airfoils, and tethered aerial imaging systems as described. All UAS used by AMT will weigh under 55 Lbs, will be battery operated, and will operate at air speed well under 80 mph (below and in full adherence to safety requirements). Additionally, AMT d/b/a/ ReallyCoolToys is the exclusive

distributor of all Oaple Paramodel Servo Activated Rescue Parachute systems for UAS, designed specifically for the Inspire 1, DJI S800, S900, and S1000 which may be used for additional protection and safety, exceeding existing safety requirements.

Public Interest: This exemption would benefit the public as a whole by significantly reducing both the expense (primarily to public agency clients) and risk (to manned aircraft operators and people on the ground), and will eliminate pollution generated by the gas engine of fuel-operated manned or unmanned aircrafts when conducting aerial imaging services related to site surveys, inspections, public events or commercial filming operations, search and rescue, law enforcement and other agency support operations, collecting high resolution for geological and agricultural operations, and other services where AMT UAS services are needed. Additionally, given

the small size of Unmanned Aircrafts involved and the limited environment within which they will operate, their proposed operation within flying safety zones (an equivalent level of safety) assures our common objective to serve the public interest, as Congress envisioned FAA must, by exemption, allow commercial operations of UAS to commence immediately.” Granting the requested exemptions is in the public interest because of (1) the clear direction in section 333 of Public Law 112–95, (2) the strong equivalent level of safety of each operation, and (3) the significant public benefit, including enhanced safety and reduction in environmental impacts (such as reduced emissions associated with allowing small UAS for photography and inspection operations). Finally, the benefits and advantages of using small UAS, combined with twenty years of professional unmanned systems operation experience serving the government, support agencies, fortune 500 companies, and individuals alike, makes AMT an advocate for UAS flight safety and operation,ensuring the public’s best interest.

General safety considerations related to each UAS operation: - Small unmanned aircraft weighing less than 55 lbs. - Flight and operations within line of sight of PIC at all times. - Maximum flight duration will be limited at 30% of battery capacity where visual and audible ground station alerts indicate safe termination during each flight. - UAS flight operations are conducted only after successfully completing a manufacturer-specific pre-flight checklist, and at an altitude of no more

than 400 feet AGL with clear VLOS. - AMT UAS PIC will be trained and certified for proper safety and operations of each UAS in full adherence with FAA regulations. - All commercially used UAS will be registered and COA approved before operation.

- All UAS use Return To Home Fail Safe feature to safely return UAS to

take-o ff location or a preset safe landing location in the event of loss of radio signal. - All PIC-operated or preprogrammed autonomous flights may be safely terminated at once by PIC as needed. - Once FAA mobile app B4UFly is available, AMT will use the app to retrieve pertinent on-location information and flight zone related data, and to help preplan UAS operations. - Each component of UAS will be visually inspected, maintained, and repaired according to the manufacturer’s guidelines and as needed assuring UAS operational safety at all times. - Live video feed, telemetry data, project-specific scientific and sensory payload will be used on almost all UAS systems

Additional consideration: The FAA has set precedence in granting petitions to other entities that propose to engage in the same or similar types of activities under essentially the same operating parameters. Examples of exemptions granted for engaging in commercial operations similar to those we propose are found here: Exemption No. 12687, 12689, 12690, 12695, 12696, 12698, and others.

Exercising the privileges of exemption outside the United States: In support of international events and activities, as well as existing customers outside of the Unites States AMT hereby requests to exercise the privilege of exceptions outside of the United States, primarily in thefollowing countries at this time: Canada, Mexico, and EU countries. It is understood that any such exemption granted must be fully in compliance with the standards of the International Civil Aviation Organization and that further country-specific exceptions may be required and, if so, will be obtained prior to any UAS commercial use by AMT.

Conclusion: AMT, Inc., with respect for safety and FAA regulations, has conducted responsible UAS usage, and maintains a proven track record since the very first professional UAS operations conducted by Mr. Sepahban in 1995. The petitioner, AMT, Inc.,d/b/a ReallyCoolToys - CEO Amir Sepahban, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, respectfully requests that the Administrator grant this petition for an exemption from the requirements of 14 C.F.R. Sections requested above, and permit AMT, Inc., to operate the UA systems described above, commercially for the purpose of conducting those UAS services mentioned above, nationwide.

AMT is prepared to modify or amend any part of this request as needed to assure maximum UAS safety and adherence to FAA regulations as best as possible. Please do not hesitate to contact us if any additional

information is needed.

Respectfully Submitted, Amir Sepahban

Founder/CEO AMT, Inc. d/b/a ReallyCoolToys AMT, Inc.

105 North Main Street Harrodsburg, KY 40330

502.882.0217

email: usaamt@gmail.com

UAS user manual and specifications:

DJI PHANTOM 3 PROFESSIONAL UAS: The Phantom Professional UAS is comprised of a small quadcopter unmanned aircraft (UA) with a gross weight under 5 Lbs. and may be operated using the transportable ground station, by a minimum required flight crew of one, the Operator (PIC). PIC operated radio, PC or Mac, ormobile device aircraft controllers communicate with the aircraft using proven frequency spectrums 2.4Ghz, 5.8Ghz, , amongst other standardized industry frequencies. Phantom 3 Professional UAS User

Manual - http://www.dji.com/product/phantom-3/download Phantom 3 Professional UAS Specifications - http://www.dji.com/product/ phantom-3/spec

DJI INSPIRE 1 UAS: The DJI INSPIRE 1 is comprised of a small quadopter unmanned aircraft and a transportable ground control station. The UA system gross weight configuration less than 7 Lbs. The UA is capable of carrying small digital photography equipment during flight, and a maximum air speed not exceeding 43 knots and may be operated using the transportable ground station, by a minimum required flight crew of one, the Operator (PIC). PIC operated radio, PC or Mac, or mobile device aircraft controllers communicate with the aircraft using proven frequency spectrums 2.4Ghz, 5.8Ghz, , amongst other standardized industry frequencies. DJI Inspire 1 UAS User Manual - http://www.dji.com/product/inspire-1/

download DJI Inspire 1 UAS Specifications - http://www.dji.com/product/inspire-1/

spec

DJI S1000 UAS : The DJI S1000 UAS is comprised of a small octocopter unmanned aircraft (UA) and a transportable ground control station. The UA system gross weight configuration with full payload is under 28 Lbs. . The S1000 is capable of carrying digital photography and research equipment during flight, with an approximate maximum speed of 39 knots and may be operated using the transportable ground station, by a minimum required flight crew of one, the Operator (PIC). PIC operated radio, PC or Mac, or mobile device aircraft controllers communicate with the aircraft using frequency spectrums 2.4Ghz, 5.8Ghz, , amongst other standardized industry frequencies. Capable of sustained flight in the event of single

motor failure.

DJI S1000 UAS User Manual - http://www.dji.com/product/spreadingwings-s1000-plus/download DJI S1000 UAS Specifications - http://www.dji.com/product/spreadingwings-s1000-plus/spec

Opale Paramodels OXY0.5/1/1.5/3.2 UAS: The Opale Paramodels paraglider model UA comprise of small (sizes: 0.5,1/1.1, 1.5, and 3.2 square meter) wing double and single surface nonerigid airfoil/wing, a frame in the shape of a small trike or backpack made of rigid composite or aluminum structural material, and are powered by small battery operated single motor propulsion system and electronics. Opale Paramodel UA systems are used in conjunction with a variety of transportable and stationary vehicle-based ground control support equipment such as those used with the DJI UAS. The UA system gross weight configuration with full payload is under 30 Lbs for any of the Oaple model UA, each capable of carrying digital photography and research equipment during flight, with an approximate maximum speed of 30 knots and may be operated using the transportable ground station, by a minimum required flight crew of one, the Operator (PIC). PIC operated radio, PC or Mac, or mobile device aircraft controllers communicate with the aircraft using frequency spectrums 2.4Ghz, 5.8Ghz, , amongst otherstandardized industry frequencies. Capable of sustained flight under failsafe mode, where engine is shut o ff and UAS either returns to home or landing softly in a preplanned emergency safe landing zone. Opale Paramodel UAS User Manual and Specification - http://www.opaleparamodels.com/index.php/en/english/manuals