December 10 th, 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 he rein 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 an d/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 ne w 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 e mergency 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 t he 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 nation al 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 t he 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 v ideo 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 con trolled 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 delayAIRCRAFT 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 Gro und 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 flig ht.  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 pers ons 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 ca pability to return to a pre
- deter mined 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 currentmember of AMA, Academy of Model Aeronautics. I have researched and studied the following FAA

regul ations 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 C FR 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