Augus t 12, 2015

Ralph H Be ndjebar, Sole Proprietor Aeri al M edia Tech, LLC 3752 Talero Curve Chaska, MN 55318-3700

U.S. Departm ent of Transportation Doc ket M anagem ent S yste m 1200 N ew J ersey Ave., SE Washington, DC 20590

RE: P etition of Aeri al M edia Tech, LLC, for Exemption Pursuant to Section 333 of the F AA Modernization and Ref

orm A c t of 2012.

To Whom It M ay Concern:
Purs uant to Section 333 of the FAA M odernization and Re form A c t of 2012 and 14 CFR P art 11, Aeri al M edia Tech, LLC, (hereinafter referred to as “A eria l M edi a T ech”) hereby appli es for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system s (sUAS). The exemption i s bas ed upon information outlined in thi s doc ument, Aeri al M edia Te ch’s e nclosed Operati ons M anual, the DJI Phantom 3 and Inspire 1 manufact urers m anual s and gui des, and any other requirement s es tablished by the F AA pursuant to Section 333 of the Re form A ct. Thi s exemption would permi t commercia l operat i ons by Aeri al M edia Tech, which wil l us e the D JI Phantom 3 and DJI Inspire 1 to c onduct s UA S genera l photography and videography, real es tate 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 wil l be s ubjec t to stri ct operating requirement s and condi ti ons to ensure a leve l of safety equival ent t o that of c urrently authorized operati ons us ing manned airc raft and unde r conditi ons a s m ay be modified by the FAA as requi red by Section 333.
Aeri al M edia Tech wil l ope rate under controlled visua l fl i ght rul es (VFR) conditi ons at l ow al titude in airs pace that i s perm itted in accordance with the approved Certificate of Authorization (COA). Aerial Media Tech wil l operat e the sUAS s w ith pilot s who posses s an FAA P il ot Ce rtificate and have m et Aeri al M edia Tec h’s pi l ot re quirement s as det ailed in the provided Operati ons M anual. Finally, the FAA A ir Traffi c Control (A TC) wil l approve i n advance the airspace in which the s UA S w il l operat e. Aeri al M edia Tech respectfully submit s thi s reques t for an exemption due to it s operation of sUASs. In it s current form , the operati ons A eri al M edia Tech wil l 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.”

1For 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 D escription
Aerial M edia T ech, LLC, is l ocated in Chaska, MN. It i s a s ole propri etorship 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 Boe ing training subsidiary. That time and experience ha s provi ded him the know ledge 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 provideservices 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.

2Aerial 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.

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### III. Qualifications f or Approval U nd er Section 333 of t he Reform A ct
The propos ed operations in this pe tition for exemption qualify for e xpedited approval unde r Section 333 of the Re form A ct. Each of the s tatutory criteria and other relevant fa ctors are s atisfied. The proposed operations w ould permit A erial M edia T ech the us e of sUAS unde r controlled conditions in airspace that i s: (1) predetermined; (2) exercises c ontrolled 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 5 5 pounds including payload. They operate, under normal c onditions, at s peeds not to exceed 45 mph. They have the c apability to hover in a l ocation and move in the ve rtical and horizontal pl ane. Aerial M edia T ech’s s UASs w ill 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 4 00 feet Above Ground Level (A GL) and will f ile a N otice to Airmen (NOTAM) for each flight ope rated in controlled airspace. All re quired permissions and permits w ill be obt ained from t erritorial, state, county

or c i ty jurisdictions, including local l aw e nforcement, fire, or other appropriate gove rnmental a gencies prior to operating a s UAS. Given the s mall s ize of the UASs involved and the re stricted sterile environment that they will ope rate i n, this e xemption falls w ithin the z one of safety and demonstrates an equivalent l evel of safety, in which Congress de sired the F AA to permit c ommercial UAS operations by exemption pending completion of formal rul emaking. Also, due to the a forementioned conditions, approval of the a pplication presents no hazard in the NAS. Considering the c lear direction in Section 333 of the Re form A ct, the authority contained in the F ederal Aviation Act, as amended, the e quivalent l evel of safety surrounding the propos ed operations, and the significant publ ic be nefit, the grant of the re quested exemptions i s also in the publ ic interest.

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### 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 5 5 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 4 00 feet AGL.
6. Flights will be operated at a lateral distance of least 5 00 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 1 00 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 L evel of Saf

ety Aerial M edia T ech will only operate unde r VFR conditions w ithin line of sight of its de signated takeoff and landing zones. Located in Aerial M edia T ech’s Operations M anual are proc edures de scribing steps the P IC and additional pe rsonnel must fol low t o assure that the w eather will be a dequate to complete the mission under VFR conditions. In addition, the P IC will a dhere t o all m anufacture re quired preflight c hecks of the aircraft, review aircraft pe rformance data, and become familiarized with their sterilized area of operations pri or to conducting any flights.



### C. 14 CF R 91. 113: Right-of-Way Rules
Aerial M edia T ech requests an exemption from 14 CFR 91.113 Right-of-Way rules, requiring vigilance by each person operating an aircraft s o as to see and avoid other aircraft. When a rul e of this s ection gives another aircraft the ri ght-of-way, the pi lot s hall gi ve w ay to that aircraft and may not pa ss ove r, under, or ahead of it unl ess w ell c lear. Aerial M edia T ech operates pi lotless s UASs and cannot c omply with these rul es a s they have be en written. Equivalent Level of Safety
Aerial Media Tech operates sUASs at or below an altitude of 4 00 feet AGL; well below the normal operating altitude of other, larger aircraft. Aerial M edia T ech’s O perations M anual s pecifies that a P IC with experience w ill ove rsee e ach mission and has know ledge of the s ee-and-avoid rules. A V isual Observer will a ssist the P IC in looking for aircraft e ntering the ope rations area. It i s the re sponsibility of the P IC to cease ope rations and land the s UAS immediately whenever an aircraft c omes i nto the vicinity creating a pot ential threat. Operations c annot re sume until the threat i s c lear.



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

Aerial Media Techrequests 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 5 5 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 1 airframes. 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 L evel of Saf

ety An equivalent l evel of safety will be a chieved because the ope rations w ill be c onducted on- site w ithout significant transit time by the s UAS. All fl ights w ill be pl anned to terminate w ith no less than 25%

reserve battery power still available. This re striction would be m ore than adequate to safely return the sUAS t o its pl anned landing zone from anywhere in the area of operation. The fue l re quirement guidelines of Section 91.151(a) were intended to alleviate ri sks for larger manned aircraft that c ould operate gre at di stances from suitable l anding areas. Due to the l imited distance the s UASs c an fly, the small s ize of the ope rations area, and all ope rations be ing conducted within visual l ine-of-site, the sUASs m aintain the ability to quickly return to their point-of-origin when necessary.



### G. 14 CF R § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections
Aerial M edia T ech is s eeking an exemption from the m aintenance i nspection requirements c ontained in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These re gulations s pecify 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 "s hall have the aircraft inspected as pre scribed in subpart E of this part and shall be tween required inspections ...have di screpancies repaired as pre scribed in part 43 of this c hapter". Part 43 and these s ections only apply to aircraft w ith an airworthiness c ertificate; therefore an exemption to these re gulations i s ne eded, as the s UASs A erial M edia T ech operates w ill not pos ses an airworthiness c ertificate. Equivalent L evel of Saf

ety Maintenance and inspections will be performed in accordance with the enclosed Aerial Media Tech Operations and Procedures Manual and the sUASs Use r 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 i nterest i s furthered with granting Aerial M edia T ech’s e xemption request. Congress’s national policy favors e arly integration of UAS into the national airspace in controlled, safe w orking environments such as those propos ed in this pe tition. Aerial M edia T ech’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 representativelist 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 e state i s an area that s UAS pl atforms have grown in popularity. Whether the re al e state professional i s l isting commercial or residential prope rties, the s UAS e nables them t o 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 Techprovides. 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 Techwill 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 crit eria provided in Section 333 of the Re form A ct of 2012, considering the size, speed, capabilities, utilization of vi s ual li ne-of-sight, and operating constraints around controlled airspace and populated areas, Aeria l M edia Tech ha s de monstrated justification for the grant of the reques ted exemptions to operate sUAS s in the defined areas. Approva l of thi s e xemption reques t w il l al low Aeri al M edia Tech, LLC, to conduct commercia l operat ions w ith small-unmanned aeri al s ystems. Due to each of the sUAS s s ize, weight, lack of flammable fuel, and lack of passenge rs or cre w on board, the risk to the ge neral public and property owners are vi rtually 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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