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 a 
variety 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

Inspection 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 off-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 tethered 
applications only, and Opale Paramodel OXY1 and Trike L small UAS 

motorized paraglider and fixed wing small unmanned aircrafts for 

maximum flight efficiency 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-off 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 the 
following 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, or 
mobile 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 other 

standardized industry frequencies. Capable of sustained flight under failsafe mode, where engine is shut off 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