August 12, 2015 

Ralph H Bendjebar, Sole Proprietor

Aerial Media Tech, LLC

3752 Talero Curve

Chaska, MN 55318-3700

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Petition of Aerial Media Tech, LLC, for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012. 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Aerial Media Tech, LLC, (hereinafter referred to as “Aerial Media Tech”) hereby applies for an 

exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations 

of small unmanned aerial systems (sUAS). 

The exemption is based upon information outlined in this document, Aerial Media Tech’s enclosed 

Operations Manual, the DJI Phantom 3 and Inspire 1 manufacturers manuals and guides, and any other 

requirements established by the FAA pursuant to Section 333 of the Reform Act. 

This exemption would permit commercial operations by Aerial Media Tech, which will use the DJI 

Phantom 3 and DJI Inspire 1 to conduct sUAS general photography and videography, real estate 

photography and videography, film and movie production, wildlife surveys, infrastructure and 

industrial inspections, agricultural surveys, demonstration flights, and any other related entities/

activities that can utilize the safe and efficient operation of sUAS aircraft. Aerial Media Tech’s 

operation under the exemption will be subject to strict operating requirements and conditions to ensure 

a level of safety equivalent to that of currently authorized operations using manned aircraft and under 

conditions as may be modified by the FAA as required by Section 333. 

Aerial Media Tech will operate under controlled visual flight rules (VFR) conditions at low altitude in 

airspace that is permitted in accordance with the approved Certificate of Authorization (COA). Aerial 

Media Tech will operate the sUASs with pilots who possess an FAA Pilot Certificate and have met 

Aerial Media Tech’s pilot requirements as detailed in the provided Operations Manual. Finally, the 

FAA Air Traffic Control (ATC) will approve in advance the airspace in which the sUAS will operate. 

Aerial Media Tech respectfully submits this request for an exemption due to its operation of sUASs. In 

its current form, the operations Aerial Media Tech will be conducting replace comparatively hazardous 

operations now conducted with both fixed and rotary winged aircraft. The FAA can have confidence 

that Aerial Media Tech’s operations will be conducted at an equivalent level or greater level of safety 

than that of sUASs counterparts of larger manned aircraft. Approval of this exemption would therefore 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities 

under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” 

1
For your convenience, Aerial Media Tech has organized this Exemption request as follows: 

I. Petitioner's Description ...................................................................................................................................... 2 

II. Relevant Statutory Authority ............................................................................................................................3

III. Qualifications for Approval Under Section 333 of the Reform Act.....................................................4

IV. Description of Proposed Operations................................................................................................................5 

V. Regulations From Which Exemption is Requested....................................................................................6 

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in Command

B. 14 CFR § 91.103: Preflight Action

C. 14 CFR 91.113: Right-of-Way Rules

D. 14 CFR § 91.119: Minimum Safe Altitudes

E. 14 CFR § 91.121: Altimeter Settings

F. 14 CFR §91.151(a): Fuel Requirements for Flight in VFR Conditions

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

VI. Public Interest.......................................................................................................................................................11 

VII. Privacy ..................................................................................................................................................................12 

VIII. Federal Registry Summary ...........................................................................................................................12 

IX. Conclusion............................................................................................................................................................13 

I. Petitioner's Description

Aerial Media Tech, LLC, is located in Chaska, MN. It is a sole proprietorship owned and operated by 

Ralph H Bendjebar, a retired airline pilot with FAA ATP type ratings in the Boeing 727, 737, 757/767, 

and 787, as well as the Airbus 320/330 and he is currently employed as a part-time B 787 simulator 

instructor for a Boeing training subsidiary. That time and experience has provided him the knowledge 

and tools necessary to ensure safe operations within the National Airspace System (NAS). 

He has gained extensive experience flying a number of sUAS craft over the past 3 years, including the 

currently owned DJI Phantom 3 and Inspire 1. His core competencies are to provide services of sUAS 

in general photography and videography, real estate photography and videography, film and movie 

production, wildlife surveys, pipeline patrols, infrastructure and industrial inspections, agricultural 

surveys, and demonstration flights in a compliant and safe environment. Aerial Media Tech plans on 

providing a wide range of services as the sUAS market expands. 

2
Aerial Media Tech’s goal is to operate in an accident-free environment by: 

• Ensuring all employees are trained on the latest safety procedures for the sUAS they operate as

well as Aerial Media Tech’s safety procedures outlined in the Operations Manual.

• Being proactive when performing pre-flight operations and identifying any potential safety

hazards.

• Demonstrating the ability to identify and appropriately eliminate hazards and risks to the

aircraft as well as persons involved in the flight.

II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) 

of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform 

Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may operate 

safely in the National Airspace (NAS) before completion of the formal UAS rulemaking, based on the 

following considerations: 

• The weight, speed, and operational capability of the UASs

• Operating the UAS in a relatively close proximity to airports or other populated areas

• UAS will be in direct visual line-of-sight with the observer and pilot

If the Secretary determines that such vehicles "may operate safely in the National Airspace

System, the Secretary shall establish requirements for the safe operation of such aircraft in the

National Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety

regulations and minimum standards when the Administrator decides a requested exemption is in

the public interest. A party requesting an exemption must explain the reasons why the

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety

(or how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined in

40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any of sections.

3
III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under Section 

333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The 

proposed operations would permit Aerial Media Tech the use of sUAS under controlled conditions in 

airspace that is: (1) predetermined; (2) exercises controlled access; and that (3) provides an increased 

level of safety beyond existing comparable operations when fixed or rotary winged aircraft are used. 

Aerial Media Tech uses sUASs that are multi-rotor, weighing less than 55 pounds including payload. 

They operate, under normal conditions, at speeds not to exceed 45 mph. They have the capability to 

hover in a location and move in the vertical and horizontal plane. Aerial Media Tech’s sUASs will 

operate in line-of-sight, under VFR flight conditions, and within the guidelines of a sterile environment

which is outlined in the enclosed Operations Manual. Aerial Media Tech will operate at or below 400 

feet Above Ground Level (AGL) and will file a Notice to Airmen (NOTAM) for each flight operated in

controlled airspace. All required permissions and permits will be obtained from territorial, state, county

or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies 

prior to operating a sUAS. Given the small size of the UASs involved and the restricted sterile 

environment that they will operate in, this exemption falls within the zone of safety and demonstrates 

an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS 

operations by exemption pending completion of formal rulemaking. Also, due to the aforementioned 

conditions, approval of the application presents no hazard in the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, the grant of the requested exemptions is also in the public interest. 

4
IV. Description of Proposed Operations

The enclosed Flight Operations and Procedures Manual (FOPM) describes the policies and 

procedures for Aerial Media Tech’s proposed sUAS operations. To assist the FAA in its safety 

assessment of said proposal, below is a summary of operational limitations and conditions that 

will ensure an equivalent or higher level of safety to sUAS operations.

1. The sUAS will weigh less than 55 pounds.

2. Aerial Media Tech will designate a Pilot in Command (PIC) for each mission.

3. Flights will be operated within visual line-of-sight of the PIC and observer.

4. Maximum total flight time for each operational flight will be limited to the amount of time the

sUAS can be flown and still maintain a reserve battery power of no less than 25%.

5. Flights will be operated at an altitude of no more than 400 feet AGL.

6. Flights will be operated at a lateral distance of least 500 feet from any inhabited structures,

buildings, vehicles, vessels, people not associated with the operation or who have not signed a

waiver in advance of the operation.

7. Minimum crew for each operation will consist of the sUAS PIC and a Visual Observer.

8. The sUAS PIC will be an FAA licensed airman with at least a private pilot's certificate, third

class medical, and a current check required by14 CFR Part 61.56 in an aircraft in which the PIC

is rated on his or her pilot certificate.

9. The sUAS will operate only within a confined "Sterile Area" as defined in the FOPM.

10. A site inspection will be conducted prior to the operations at a particular location. On the day

of the mission, the management person with operational control and the PIC will concur on

dispatching of the mission.

11. In accordance with FOPM, a briefing will be conducted regarding the planned sUAS 

operations prior to each mission. It is mandatory that all personnel who will be performing 

duties within the boundaries of the sterile area be present for this briefing.

12. Aerial Media Tech’s crew will use the checklist required in the FOPM.

13. All sUASs will be maintained in accordance with inspection program specified in the Aerial

Media Tech FOPM and in compliance with the manufacturer’s guidelines.

14. In the event of an accident involving Aerial Media Tech’s sUAS, that mission’s operations

will cease and the accident reported to the NTSB and AFS-80.

15. PIC and Visual Observer will at all times be able to communicate by voice.

16. PIC, Visual Observer, and any additional required operational personnel will possess the

required minimum skills and education outlined in Aerial Media Tech’s FOPM.

17. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

18. If the sUAS loses communications signal, the sUAS will have the capability to return and

land at a pre-determined location within the Sterile Area.

19. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the observer.

20. The sUAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 
21.Aerial Media Tech, by following procedures listed in the FOPM, will assure no individuals’ 

privacy is violated.

22.In accordance with Aerial Media Tech’s FOPM, the PIC will contact the Air Traffic Control 

(ATC) facility or appropriate airspace controlling authority prior to operating in airspace other 

than Class G. 

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V. Regulations From Which Exemption is Requested

1. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in Command

2. 14 CFR § 91.103: Preflight Action

3. 14 CFR § 91.109(a): Flight Instruction

4. 14 CFR § 91.113: Right-of-Way Rules

5. 14 CFR § 91.119 (c): Minimum Safe Altitudes

6. 14 CFR § 91.121: Altimeter Settings

7. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

8. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance

Inspections

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in

Command

Section 61.113 (a) & (b) limit private pilots to non-commercial operations. Conventional aircraft carry 

a pilot, passengers, and cargo during their operations. Having this rule in place ensures the skill and 

competency of the pilots. However, the DJI sUASs are controlled remotely and do not carry any 

passengers or cargo. Aerial Media Tech respectfully proposes that the FAA take into account the 

characteristics and procedures of the particular UAS in reference to requirements for PIC. Aerial Media

Tech proposes that their operations of the DJI Phantom 3 and Inspire 1 sUAS in commercial use not 

require the Pilot to hold a commercial pilot certificate but rather a private pilot certificate. Aerial Media

Tech proposes the following requirements for a PIC: 

1. The PIC must possess at least a Private Pilot’s Certificate and a valid third-class medical

certificate.

2. The PIC must have accumulated and logged a minimum of 100 flights and 25 hours of total

time as a UAS pilot and at least ten hours logged as a UAS pilot with a similar UAS type (fixed

wing or multi-rotor) and five hours in type of UAS aircraft he/she will operate (DJI Phantom 3

and Inspire 1 models).

3. The PIC must have accumulated and logged a minimum of five hours as UAS pilot with the

make and model of UAS to be utilized for operations under the exemption and three takeoffs

and landings all within the preceding 90 days.

4. The PIC must successfully display the competencies as specified in the Aerial Media Tech

Operations Manual.

5. The PIC must also meet the flight review requirements specified in 14 CFR Part 61.56 in an

aircraft in which the PIC is rated on his or her pilot certificate. 

Equivalent Level of Safety 

Aerial Media Tech utilizes both a PIC and a Visual Observer to increase safety during flight operations.

While the PIC is concentrating on flying the UAS, the Visual Observer has the ability oversee safety of

the entire operation. The Visual Observer will always remain within 10 feet of the PIC when the UAS 

is airborne to quickly communicate any observations if an emergency should happen. Procedures 

developed by Aerial Media Tech far exceed the current safety requirements established by the FAA. 

Aerial Media Tech respectfully requests the option to use a PIC and Visual Observer crew and the 

second crew member not having to possess a private pilot certificate. 

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B. 14 CFR § 91.103: Preflight Action

Aerial Media Tech requests an exemption from the preflight actions requirements of 14 CFR 91.113 

that prescribes the preflight actions under which aircraft may operate: 

Each pilot in command shall, before beginning a flight, become familiar with all available information 

concerning that flight. 

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel

requirements, alternatives available if the planned flight cannot be completed, and any known traffic

delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing

distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff

and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable

information appropriate to the aircraft, relating to aircraft performance under expected values of airport

elevation and runway slope, aircraft gross weight, and wind and temperature.

Equivalent Level of Safety 

Aerial Media Tech will only operate under VFR conditions within line of sight of its designated takeoff

and landing zones. Located in Aerial Media Tech’s Operations Manual are procedures describing steps 

the PIC and additional personnel must follow to assure that the weather will be adequate to complete 

the mission under VFR conditions. In addition, the PIC will adhere to all manufacture required 

preflight checks of the aircraft, review aircraft performance data, and become familiarized with their 

sterilized area of operations prior to conducting any flights. 

C. 14 CFR 91.113: Right-of-Way Rules

Aerial Media Tech requests an exemption from 14 CFR 91.113 Right-of-Way rules, requiring vigilance

by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section 

gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, 

under, or ahead of it unless well clear. Aerial Media Tech operates pilotless sUASs and cannot comply 

with these rules as they have been written. 

Equivalent Level of Safety 

Aerial Media Tech operates sUASs at or below an altitude of 400 feet AGL; well below the normal 

operating altitude of other, larger aircraft. Aerial Media Tech’s Operations Manual specifies that a PIC 

with experience will oversee each mission and has knowledge of the see-and-avoid rules. A Visual 

Observer will assist the PIC in looking for aircraft entering the operations area. It is the responsibility 

of the PIC to cease operations and land the sUAS immediately whenever an aircraft comes into the 

vicinity creating a potential threat. Operations cannot resume until the threat is clear. 

8
D. 14 CFR. § 91.119: Minimum Safe Altitudes

Aerial Media Tech requests an exemption from the minimum safe altitude requirements of 14 CFR 

91.119 that details the minimum safe altitudes under which aircraft may operate: 

• Over any congested area of a city, town, or settlement, or over any open air assembly of persons,

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the

aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except over open

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than

500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when

it can be operated "without hazard to persons or property on the surface," provided that "each

person operating the helicopter complies with any routes or altitudes specifically prescribed for

helicopters by the FAA." With Pinnacle’s intended operations, the sUAS is normally operated at

or below 500 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS

will maintain a lateral distance of at least 100 feet from inhabited structures, buildings, vehicles,

and vessels, and from people not associated with the operation.

Equivalent Level of Safety

Compared to the flight of normal aircraft, Aerial Media Tech’s sUAS aircraft weigh less than 55

pounds, and, given the lack of flammable fuel, pose far less risk to persons or property than

conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and

speed of the sUAS, as well as the location where it is operated. As set forth in the Operations

Manual, the sUAS will be operated in a sterile area, where buildings and people will not be

exposed to operations without their pre-obtained consent. Because of the advance notice to the

property owners and participants, all knowingly affected individuals will be well aware of the

planned flight operations as set forth in the Operations Manual. Furthermore, by operating at low

altitudes, the sUAS will not interfere with aircraft that are subject to the minimum safe altitude

regulations. Finally, the sUAS that Aerial Media Tech operates has safeguards built into its

design that warns pilots when approaching areas designated by the manufacture as “no fly

zones”. This causes the sUAS to initiate a descent to safe altitude or landing.

E. 14 C.F.R. § 91.121: Altimeter Settings

Aerial Media Tech is seeking an exemption from 14 CFR 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because the sUASs 

have GPS altitude readouts as opposed to barometric altimeters 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in Aerial Media 

Tech’s Operations Manual during the pre-flight routine. Prior to operations, Aerial Media Tech will 

confirm the altitude of the launch site shown on the GPS altitude indicator. Moreover, the PIC will use 

the GPS altitude indicator to constantly monitor the sUASs height, thus ensuring operation at safe 

altitudes. 

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F. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

Aerial Media Tech requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in 

VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and

assuming normal cruising speed –

(1) During the day, to fly after that for at least 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The batteries powering Aerial Media Tech’s sUASs provide approximately 18 minutes of powered 

flight for the DJI Phantom 3 and Inspire 1airframes. To meet the 30 minutes reserve requirement in 14 

CFR 91.151, sUAS flights could not be conducted. Given the limitations on the sUASs proposed flight 

area and the location of its proposed operations within a predetermined area, a safety margin based on a 

reserve amount of battery life is needed. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on- site without

significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% 

reserve battery power still available. This restriction would be more than adequate to safely return the 

sUAS to its planned landing zone from anywhere in the area of operation. The fuel requirement 

guidelines of Section 91.151(a) were intended to alleviate risks for larger manned aircraft that could 

operate great distances from suitable landing areas. Due to the limited distance the sUASs can fly, the 

small size of the operations area, and all operations being conducted within visual line-of-site, the 

sUASs maintain the ability to quickly return to their point-of-origin when necessary. 

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance

Inspections

Aerial Media Tech is seeking an exemption from the maintenance inspection requirements contained in

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) states that 

each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this

part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 of 

this chapter". Part 43 and these sections only apply to aircraft with an airworthiness certificate; 

therefore an exemption to these regulations is needed, as the sUASs Aerial Media Tech operates will 

not posses an airworthiness certificate. 

Equivalent Level of Safety 

Maintenance and inspections will be performed in accordance with the enclosed Aerial Media Tech 

Operations and Procedures Manual and the sUASs User Manuals, therefore ensuring an equivalent level 

of safety. As provided in the Operations and Procedures Manual, Aerial Media Tech will perform 

required maintenance, keep a log of any maintenance performed, and the operator will confirm that the 

sUAS is in working order prior to initiating flight. The operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level 

of safety. Due to the sUAS's size and carrying capacity, and the fact that flight operations will only take 

place in restricted areas for limited periods of time, if a mechanical issue arises it creates less risk than 

that associated with conventional aircraft performing the same operation. 

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VI.Public Interest

Public interest is furthered with granting Aerial Media Tech’s exemption request. Congress’s national 

policy favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those proposed in this petition. Aerial Media Tech’s goals are to help facilitate 

and promote the safe integration of sUASs into the NAS, while providing education and awareness 

of sUAS operations and capabilities. The following is a representative list of areas of interest: 

• Movies and Videography

Small-unmanned aerial systems provide unparalleled capability in their ability to quickly adapt to any 

situation. Unlike traditional filming methods that can require excessive amounts of time to change 

camera angles for different views, sUASs are light, stabilized platforms that can quickly maneuver 

through the air into position for capturing every angle in high definition video. 

• Real Estate

Real estate is an area that sUAS platforms have grown in popularity. Whether the real estate 

professional is listing commercial or residential properties, the sUAS enables them to capture dramatic 

shots for each property that would otherwise require costly and noisy helicopter operations. In 

addition to being able to capture spectacular exterior photos and video, Aerial Media Tech’s sUAS 

platforms possess internal sensors for stabilization while operating in areas where a GPS signal is not 

available. This adaptability gives real estate professionals a high quality, cost effective, safe, and 

simple solution to an otherwise costly and neighborhood-disrupting endeavor. 

• Search and Rescue/First Responders

Search and rescue/first responder personnel will also benefit from sUASs capabilities of real-time video 

and surveys that Aerial Media Tech provides. The sUASs ability to inspect dangerous or unstable areas 

without placing personnel at risk is monumental in saving lives. In addition, the sUASs can survey 

large areas of land to identify areas of interest at an expedited rate when compared to search and rescue

personnel on foot. The sUAS excels over traditional manned aircraft during these instances in both cost

and the safety of personnel on the ground. 

• Law Enforcement

Small-unmanned aerial systems are designed for rapid deployment and covering specific areas of 

interest; these are key components for law enforcement officers. Recent developments in sUAS 

platforms are allowing for easy transition between HD photos and video. Utilizing a sUAS would prove

useful by increasing officer safety when identifying areas of interests with potential threats as well as 

accident scene investigations and monitoring undercover operations from greater distances. 

• Agriculture and Conservation

Aerial Media Tech will demonstrate to farmers the advancements in agriculture analysis that a sUAS 

can provide in soil property and moisture analysis, plant counting, crop stress analysis, erosion 

analysis, 3D mapping, and other areas of agricultural land management. The sUAS can fly preprogrammed missions that allow the operator to gather precise data. While the sUAS is in flight, the 

pilot can assume full control to inspect areas of interest. Once it has been examined, the sUAS will 

resume its flight plan from the last point analyzed. Equipped with an IR camera, the sUAS can also 

provide farmers with real time video of locations of wildlife that potentially threaten their crops. 

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VII.Privacy

All flights will be conducted in accordance with any state, federal, or local laws regarding privacy. 

Aerial Media Tech has inserted a section into its Operations Manual to protect the public privacy. 

There is great concern to maintain an expected level of public privacy during the use of sUASs. 

Guidelines in the Operations Manual outline Aerial Media Tech’s policy in notification of residential 

property owners, businesses, and other organizations when sUAS operations will be conducted in their 

area. 

VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register,

should it be deemed that publication is needed: 

Aerial Media Tech, LLC, seeks an exemption from the following rules: 

14 CFR Part 61.113 (a) and (b); 14 CFR 91.103; 14 CFR 109(a); 14 CFR 91.113; 14 CFR 91.119; 14 

CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(2); 14 

CFR 91.417 (a) and (b). 

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IX. Conclusion

In meeting the criteria provided in Section 333 of the Reform Act of 2012, considering the size, speed, 

capabilities, utilization of visual line-of-sight, and operating constraints around controlled airspace and 

populated areas, Aerial Media Tech has demonstrated justification for the grant of the requested 

exemptions to operate sUASs in the defined areas. Approval of this exemption request will allow 

Aerial Media Tech, LLC, to conduct commercial operations with small-unmanned aerial systems. Due 

to each of the sUASs size, weight, lack of flammable fuel, and lack of passengers or crew on board, the

risk to the general public and property owners are virtually eliminated. 

If you have any questions or require any additional information, please do not hesitate to call. 

Regards,

c/signed

Ralph H Bendjebar 

for

Aerial Media Tech, LLC

rbendjebar@mac.com

Mobile: 612-386-4424

Attachments:

Aerial Media Tech Operations and Procedures Manual 

DJI Inspire 1 and Phantom 3 Pro User Manuals available online @ DJI.com

The above are submitted as Confidential Documents under 14 C.F.R. § 11.35(b) and exempt from 

disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements 

established by the FAA pursuant to Section 333 of the Reform Act. 

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