Ryan Hart – (317) 908-0581 

Garry Zukin – (317) 213-7569 

13128 Hazelwood Court 

Carmel, IN 46033 

June 7, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

Aerial Technology Services is petitioning a request for exemption pursuant to the FAA Modernization and 

Reform Act of 2012 (“FMRA”), Public Law 112-95 February 14, 2012, Section 333 and the procedures 

contained within 14 C.F.R. 11, to be exempt from the Federal Aviation Regulations as specified and seek 

exemption from the requirements of 14 C.F.R. §§ 61.113 (a) & (b), 91.7 (a), 91.121, 91.151 (b), 91.405 (a), 

91.407 (a) (1), 91.409 (a) (1) & (a) (2), 91.417 (a) & (b), to operate an Unmanned Aircraft System, 

(“UAS”), pursuant to Section 333 of the FAA FMRA. 

Introduction

Aerial Technology Services is a central Indiana based business founded by Ryan Hart and Garry Zukin. 

Work background includes knowledge and experience in real estate, large scale renewable energy projects, 

and electrical infrastructure systems. 

This exemption would allow operation of the DJI Phantom 3 and DJI S1000 UAS for the purpose of aerial 

photography/video, land surveying, agriculture industry support, and utility industry support. 

Equipment

DJI Phantom 3 

Aerial Technology Services seeks an exemption to operate the DJI Phantom 3. The DJI Phantom 3 is a 

quad-rotor unmanned aircraft and a handheld ground control station. The DJI Phantom 3 is equipped with

four electric motors powered by a lithium polymer battery. Design and operational characteristics are 

provided in the DJI Phantom 3 Operating Manual which is attached to this petition. 

DJI S1000 

Aerial Technology Services seeks an exemption to operate the DJI S1000. The DJI S1000 is a octo-rotor 

unmanned aircraft and a handheld ground control station. The DJI S1000 is equipped with eight electric

motors powered by a lithium polymer battery. Design and operational characteristics are provided in the 

DJI S1000 Operating Manual which is attached hereto this petition. 

Operations and Safety of UAS

Aerial Technology Services is committed to upholding the highest safety standards while operating a UAS. 

Our safety protocols are in line with the FAA’s mission to provide the safest and most efficient aerospace. 
All UAS operations will adhere to the following safety protocols and procedures: 

• UAS will operate within Visual Line of Sight (“VLOS”) at all times 

• Daylight only operations (sunrise to sunset) 

• Maximum airspeed of 50 mph 

• Maximum altitude of 400 feet above ground level 

• UAS will operate at all times with an operator and visual observer (“VO”) 

• Required pre-flight inspection of the UAS and ground control equipment prior to any and all 

flights 

• Any UAS deemed not fit to fly will remain grounded and will be repaired 

• If the UAS loses communication with the operator or if it loses GPS signal for longer than 8 

seconds, the UAS “Return Home” fail safe will be engaged and the UAS will automatically return 

to a pre-programmed starting location for recovery 

• UAS will not be flown in adverse weather and wind conditions 

• No UAS operations are allowed in Class A (18,000 feet & above) airspace 

• The UAS will not operate within 5 nautical miles of an airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management is 

obtained 

• UAS operate via remote control and all radio frequency communication is compliant with both CE 

and FCC regulations (See attached UAS operators manuals) 

• All operators shall adhere to all safety procedures and operating procedures as outlined in the 

attached operating manuals for each UAS 

Unmanned Aircraft Pilot in Command (“PIC”) and Visual Observors (“VO”)

Aerial Technology Services founders have been operating UAS’s as hobbyists for the past five years. They 

have accumulated over 500 flight hours with various UAS’s. They have always adhered to the highest 

safety standards in all aspects of UAS operation. Aerial Technology Services will require any PIC to have a 

minimum of 25 hours of flight time with either the DJI Phantom 3 or the DJI S1000 in order to operate the 

UAS as a PIC. 

The VO will be utilized in all UAS operations. The VO will satisfy the VSOL requirements. The VO and 

PIC will always maintain verbal communication distances at all times. Any VO that is working with a PIC 

will be made to adhere to all safety protocols and guidelines as outlined in this petition. In addition, the VO 

will be required to understand each UAS and its operating procedures specified in the attached manuals. 

Conclusion

Aerial Technology Services aims to provide solutions to businesses and individuals who are seeking aerial 

photography and video services. The current agriculture and utility markets utilize manned aircraft and 

service personnel for their aerial and ground operations. Aerial Technology Services will offer a more cost 

effective, efficient, and safer way to complete certain high risk and dangerous jobs. Aerial Technology 

Services is committed to operating legally and with the FAA's consent. Our company is looking to embrace 

this emerging technology to benefit individuals and businesses within our communities. We appreciate 

your time in the review of this petition and we look forward to your response. 

Sincerely, 

Ryan Hart & Garry Zukin 

Aerial Technology Services 

Attachments