August 10, 2015
U.S. Department ofTransportation Docket Management System 1200 New Jersey 

### Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012

Dear Ms. Newton: In response to your letter dated August 

### 3, 2015, regarding AHNTECH, I nc.'s request for an exemption from§§ 14 CFR 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) ofTitle 14, Code ofFederal Regulations (14 CFR). We respectfully submit the following:



### • The reasons whygranting the request would be in thepublic interest; thatis, how it would benefit thepublic as a whole. Aerial photography and videography for geographical surveying and for commercial marketing has previously required manned fixed wing aircraft or helicopters. For average individuals looking to accurately survey their property, or small businesses looking to create marketing programs, the expense ofsuch aerial videography is cost prohibitive. Only extremely wealthy individuals and large corporations could afford to absorb such expense. A large section ofthe public previously unable to access such photographic, video, or survey data can now do so through AHNTECH's services. In addition, AHNTECH's exemption request furthers the public interest as our flying our ultra light weight UAS is safer and better for the environment than similar missions requiring fixed wing aircraft or helicopters. Our UAS is battery powered and creates no emissions that harm the environment. Theconsequence ofour ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic damage to public and private property. Finally, permittingAHNTECH to fly within national air space furthers economic growth. We plan to increase our employment to accommodate significant requests for aerial photography, videography, and geological surveying. Also, these services will allow individuals and small businesses in the San Francisco Bay Area access to marketing footage previously available only to a small, very wealthy few.


### • The reasons why the exemption would notadversely affectsafety orhow the exemption wouldprovide a level of safety atleastequal to thatprovided 

### by the rule from whichyou seekan exemption. AHNTECH's exemption will not adversely affect safety. AHNTECH's UAS operations will be at least as safe, ifnot safer, than a conventional aircraft (fixed wing or helicopter) with an airworthiness certificate for the following reasons:
o AHNTECH's UAS weighs less than 4 pounds fully loaded; o The UAS does not carry a pilot, passengers, property ofothers, or flammable fuel; o Our UAS flights last up to 20 minutes per flight; o We will coordinate with the FAA, and file advance notice ofall operations; o We land the UAS with a significant reserve ofbattery power; o We pilot the UAS through remote control only by line ofsight; o The UAS has a GPS-based flight safety feature whereby ithovers and then slowly lands ifcommunication with the remote control pilot is lost; o We actively analyze flight data and other sources ofinformation to constantly update and enhance safety protocols; o We only operate in reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; o We conduct extensive pre-flight inspections and protocol, during which safety carries primary importance; o We have a ChiefEthics & Compliance officer, who, in addition to the pilot and operations management, oversees our safety procedures and protocols to ensure they are best-in-class; o We have procedures in place to abort flights in the event ofsafety breaches or potential danger. AHNTECH's flight safetyprotocols provide a level ofsafety equal to or exceeding existingrules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the. 

### - '



### • primary means ofaerial video and photography for marketing purposes-it is far safer to operate a batterypowered lightweight UAS

. 

### Anyadditional information, views, orarguments available to support your request AHNTECH has been providing quality contract services to the United States Government for over 30 years, granting this requestwould not only allow us to service our commercial customers, butalso submitproposals to the Government to provide aerial photography, videography, and geographic surveying services. The benefit to the Governmentwould be increased competition and better value to the taxpayer.
Respectfully submitted,

Eugene Ahn President AHNTECH, Inc.