December 10th, 2015

U.S. Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE

Washington DC 20590

Dear Sir or Madam:

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

operation of an Unmanned Aircraft System (UVA), hereby applies for an exemption from the listed 

Federal Aviation Regulations to allow commercial operation of its UAV, so long as such operations are 

conducted within and under he conditions outlined herein or as may be established by the FAA as 

required by Section 333.

Commercial operation of an UAV, as described herein, which are equipped with (camera(s) and sensors, 

would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, 

architecture, agriculture land surveying, engineering and other related professional activates.

 Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and new gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the 

wonders or local government authority.

 Aerial video/photography or providing live video feed to assist with search and rescue operation 

in cases of an emergency or natural disaster only when the local authorities or government has 

request it. This would be a free service.

 The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAV for the purpose of the safe 

operation of a UAV to enhance the safety of the National Airspace System as well as for the 

protection of the persons and property.
As described fully below, the requested exemption would permit the operation of a UAV under 

controlled conditions in the NAS that would be a)limited b)controlled c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using conventional 

aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s responsibilities to establish requirements for the safe operation of such aircraft 

systems in the national airspace system.

The name and address of the applicant is:

ATO Inc.

Attn: Allen T. Owen

Ph: 919.266.2222

Email: atowen@ipass.net

Address: 5216 William and Mary Drive, Raleigh, NC 27616

ATO Inc., will operate the DJI Phantom 3 Pro, with a total weight of 1242g or 2.73lbs.

The dimensions are 350mm x 350mm or 13.77 inch x 13.77 inch. Maximum speed is no more than 

15m/s or 33.5 mph with a max cruising speed of 8m/s or 18 mph. The DJI Phantom 3 Pro has four 

motors, Motor Model DJI 2312, powered by 1 5700mAh Lithium Polymer battery.

There are four propellers, Propeller Model DJI E300 in use. The DJI 3 Pro will be controlled with the C1 

remote controller with an operating frequent of 5.728GHz – 5.850GhHz. The live video feed will have an 

operating frequency of 2.412 – 2.462MHz.

The applicate will operate the UAV in a line of sigh within a closed off and predetermined area owned 

and/operated by the property representative.

Given the small size of the UAV and the controlled environment provided the proposed operations will 

adhere to the Reform Act’s safety requirements. The approval of this applications presents no national 

security issues.

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the 

requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the 

requested exemption with minimum delay
AIRCRAFT AND SAFETY

 The UAV’s will weigh less than 55 lbs.

 The UAV’s will have a maximum operating speed of no more than 33.5 mph and flights will be 

operated within line of sigh of the Pilot in Command and/or Visual Observer.

 Maximum flight time for each operational flight will be 20-25 minutes. Flight will be terminated 

at 20% battery power reserve or 20-25 minutes of flight time, whichever comes first.

 Flights will be operated at an altitude of no more than 300 feet Above Ground Level.

 Minimum crew for each operation will consist of the UAV Pilot and a Visual Observer.

 The UAV pilot will be the designated Pilot in Command.

 A briefing and pre-flight check will be performed regarding the planned UAV operations prior to 

each flight. 

 All flights will occur under Visual Flight Rules based upon meteorological conditions at the time. 

No flight will be approved if wind conditions exceed 10 mph.

 The flights will occur no closer than a 5 mile radius of an Airport Reference Point of a tower 

controlled or uncontrolled airport. The respective airports will be contacted advising them of 

the estimated flight time, flight duration, elevation of flight and other pertinent information. 

 The operator will obtain verbal/written consent of all persons involved with the planned 

operation.

 The Pilot in Command and the Visual Observer will have been trained in operation of UAV and 

receive up-to-date information for the particular UAV to be operated. 

 The Pilot in Command and the Visual Observer will be able to communicate by voice, radio, 

and/or text at all times.

 Written and or/verbal permission and permits will be obtained from territorial, state, county or 

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

when applicable. 

 If the UAV loses communications with the remote controller or loses GPS signal, the UAV will 

have the capability to return to a pre-determined location within a designated location and land 

autonomously.

 The UAV will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 

Additional Information

I, Allen T. Owen, have been in operation of non-commercial UAV’s for 6 years. I have complete 

understanding of the capabilities of UVA’s and the safety concerns involved with the operation of a UAV. 

I have consulted and received liability insurance through Transport Risk Management and I am a current 
member of AMA, Academy of Model Aeronautics. I have researched and studied the following FAA 

regulations and fee that ATO Inc. meets or exceeds the requirements and therefore request exemptions 

from the following rules:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Thank you for your consideration and we look forward to hearing from you soon,

Allen T. Owen

ATO Inc.

5216 William and Mary Drive

Raleigh, NC 27616

919.266.2222

atowen@ipass.net