August 10, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 

Dear Ms. Newton: 

In response to your letter dated August 3, 2015, regarding AHNTECH, Inc.'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) of Title 14, Code of Federal Regulations 

(14 CFR). 

We respectfully submit the following: 

• The reasons why granting the request would be in the public interest; that is, 

how it would benefit the public 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 of such aerial videography is cost prohibitive. Only extremely 

wealthy individuals and large corporations could afford to absorb such 

expense. A large section of the 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. The 
consequence of our 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, permitting AHNTECH 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 not adversely affect safety or how the 

exemption would provide a level of safety at least equal to that provided by the 

rule from which you seek an exemption. 

AHNTECH's exemption will not adversely affect safety. AHNTECH's UAS 

operations will be at least as safe, if not 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 of others, 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 of all 

operations; 

o We land the UAS with a significant reserve of battery power; 

o We pilot the UAS through remote control only by line of sight; 

o The UAS has a GPS-based flight safety feature whereby it hovers and 

then slowly lands if communication with the remote control pilot is 

lost; 

o We actively analyze flight data and other sources of information 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 Chief Ethics & 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 of safety 

breaches or potential danger. 

AHNTECH's flight safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into our national airspace system, helicopters are the 
. - ' 

• 

primary means of aerial video and photography for marketing purposes-it 

is far safer to operate a battery powered light weight UAS. 

Any additional information, views, or arguments available to support your 

request 

AHNTECH has been providing quality contract services to the United States 

Government for over 30 years, granting this request would not only allow us 

to service our commercial customers, but also submit proposals to the 

Government to provide aerial photography, videography, and geographic 

surveying services. The benefit to the Government would be increased 

competition and better value to the taxpayer. 

Respectfully submitted, 

Eugene Ahn 

President 

AHNTECH, Inc.