1

May 19 , 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Request for exemption from multiple regulatory provisions to allow the use of small unmanned aerial systems over land controlled by employees of 

### Atlas Im ages to assist in the safe capture of video, images, and surveying of persons and property for commercial use.
Dear Sir or Madam 

### Atlas Im ages pursuant to the FAA Modernization and Reform Act of 2012 respectfully requests exemption from several provisions of the Federal Aviation Regulations (“FAR”), specifically portions of 14 C.F.R. Parts 45, 61, and 91 to allow, commercial operations of its unmanned aerial system in remote, rural, and closed production sets, areas of the United States, as further defined herein, by a Pilot in Command holding a Commercial and Certified Flight Instructor certifi cate, and the 

### Atlas Im ages Flight Operations Manual. Jeremy Bushnell , and his company 

### Atlas Im ages , is an experienced Commercial pilot and Certified Flight Instructor with numerous qualifications concerning UAS operations. Mr. Bushnell has experience with General Atomics a major UAS manufacturer providing UAS to various governmental entities and customers throughout the world. Mr. Bushnell is qualified as an MQ

- 1 UAV Pilot with numerous hours of flight time and possesses an in

- depth knowledge of the system limitations and UAS uses concerning the NAS

. Mr. Bushnell has extensive knowledge and respect for the F.A.R.s that govern and certify manned aircraft, as well as a B.S. in Aeronautical Technology concerning Unmanned Aircraft Systems from Kansas State University. Mr. Bushnell has been an avid R/C model flyer for over ten years . Jeremy Bushnell , 

### Atlas Im ages have been actively involved in the technical development of UAV/UAS service applications to provide high definition video, Near Infrared and surveying capability with small unmanned and light weight UASs. 

### Atlas Im ages exemption request would permit its operation of lightweight, unmanned (remotely c ontrolled in line of sight) UAS in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, cordoned off locations and corresponding enhancements to current safety controls will allow 

### Atlas Im ages to operate within current safety parameters and new ones being implemented. As identified, similar lightweight, commercially available remote controlled UASs are legally operated by amateurs with no flight experience, or practices in place to prevent accidents or incidents from occurring. 

### Atlas Im ages will employ fully licensed and current pilots that are also experts in the flight characteristics of the UAS/UAV in which 

### Atlas Im ages operates. A detailed training curriculum discussing the use and safe operation of UAS will also be implemented and adhered to. Granting 

### Atlas Im ages requests furthers the Secretary of Transportations responsibility and authority to not only integrate UAS’s into the national airspace system, but to “... establish requirements for the safe operation of such aircraft systems [UAS] in the nation airspace system” under section 333(c) of the Reform Act, specific to the use of UAS’s for high definition video and Near Infrared scientific purposes.2



### Atlas Im ages will conduct operations in compliance with the protocols described herein or as otherwise established by the FAA.

**I. Contact Information**  Jeremy L. Bushnell 

### Atlas Im ages Mobile: 719

- 659

- 9623 Email: jbushnell159@gmail. com **II. Specific Section of the Title 14 Code of Federal Regulations from which**  

### Atlas **Images requests exemption are:**  14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F .R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). **III. The extent of the relief**  **Atlas Images**  **seeks and reasons for relief.** 

### Atlas Im ages will operate as safely as possible, taking every precaution to minimize risk to the NAS or to persons and property on the ground. Jeremy Bushnell , is an experienced FAA Certified Flight Instructor and Commercial Pilot with numerous hours of actual UAV time in an MQ

- 1 Predator type aircraft . Mr. Bushnell has extensive knowledge and respect for the F.A.R.s that govern and certify manned aircraft. Mr . Bushnell has been an avid R/C model flyer for over ten years . Jeremy Bushnell and 

### Atlas Im ages exemption will not adversely affect safety to persons or property by following the strict guidance set forth by its procedures and the operator’s years of experience. By allowing 

### Atlas Im ages to operate, 

### Atlas Images pilots will be able to gain valuable real world experience that is unattainable any other way. Much like operating a c ommercial or corporate aircraft, experience is gained through practical and safe real world experience. With this experience 

### Atlas Im ages will develop existing techniques and protocols, as well as develop new ones. In addition, 

### Atlas Im ages submits its Flight operations Manual attached to this Exemption Request. Included in the 

### Atlas Im ages Flight Operations Manual: 1. General 2. Pilot in Command Qualifications and Duties 3. External Observer Qualifications and Duties 4. Preflight Action 5. Flight Operations 6. Maintenance and Logbook Records 7. Limitations 8. Section 333 Exemption Compliance


### Atlas Im ages strives to provide a level of safety that exceeds the existing regulations. 

### Atlas Im ages s trives to operate its UAS/UAV as closely and within practicality to the already proven safe F.A.R.s. It is3

significantly safer to operate a battery powered lightweight UAS piloted by FAA licensed pilots than the current helicopter based aerial cinematogra phy systems. First, and foremost the potential loss of life is zero because UASs do not carry an on board crew and 

### Atlas Im ages only operates them in specific areas away from dense populations. Our UAS are battery powered, carrying no flammable liquids, th us the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of DJI UASs allow our remote control pilots to avoid hazards. Given their small size and weight, they pose less of an environmental and noise impact than conventional manned helicopter based systems available today. 

### Atlas Im ages UAS systems produce less noise than ground power units used to power small corporate aircraft. Thus reducing the acoustic footprint.

• 

### Atlas Im ages UASs weigh less than 55 pounds Max Tax off Weight

• 

### Atlas Im ages only operates its UAS below 400 feet

• 

### Atlas Im ages UAS only operate for 5

- 25 minutes per flight

• 

### Atlas Im ages lands its UAS when they reach 30% batt ery power

• 

### Atlas Im ages remote control pilots operate 

### Atlas Im ages UAS by line of sight

• 

### Atlas Im ages remote control pilots have video backup should they somehow lose sight of the UAS

• 

### Atlas Im ages staffs each flight with a remote control pilot, and external observer

• 

### Atlas Im ages UAS have GPS flight modes whereby they hover and then slowly land if communication with the remote control pilot is lost or battery power is below 30%

• 

### Atlas Im ages actively analyses electronic flight data and other sources of information to constantly update and enhance safety protocols

• 

### Atlas Im ages only operates in secured areas that are strictly controlled, are away from airports and populated areas

• 

### Atlas Im ages conducts extensive briefing prior to flight, emphasizing safety 

### Atlas Im age s recognizes there is always a potential hazard to those on the ground. These people will be protected by the fact that the no one will be allowed entry into the operations area without prior permission. Security will be established for the operations area as part of the pre

- flight inspections. Each person within the operations area will be briefed about the UAS system’s flight and give consent to be in the operating area.


### Atlas Im ages UAS utilizes four counter

-rotating propellers for balance, control and stability in all segments of flight. Each craft weighs less than 55 pounds, including cinematic or other research equipment. 

### Atlas Im ages small unmanned aircraft are designed to primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations but operate only within the line of sight of the remote control pilot. In addition to the remote control pilot, 

### Atlas4



### Images uses an ext ernal observer

. Utilizing battery power and not combustible fuels, flights generally last between five and twenty minutes. 

### Atlas Im ages does not operate its UAS with less than 30 percent battery capacity. Safety systems in place include a GPS mode that all ows 

### Atlas Images UAS to hover in place if communication with the radio control pilot is lost and then slowly descend the UAS at 30 percent battery capacity. 

### Atlas Im ages aircraft are programmed, in some instances, to slowly follow a predetermined set of waypoints to return to a safety point predetermined by the Pilot

- In

- Command if communications are lost. 

### Atlas Im ages will not operate its UAS within 5 miles of airports without express ATC permission

. The UAS operating software and GPS navigation systems do not allow any of the 

### Atlas Im ages UAS vehicles to operate near airports or FAA mandated no

- fly zones. In the event an operation needs to be conducted closer to an airport, 

### Atlas Im ages will inform the airport operator and airport air traffic control tower of the contemplated operation and will comply with any directions issued by air traffic control at that airport

. 

### Atlas Im ages only operates its UASs in predetermined areas and only in compliance with safety protocols such as those contained within the its own Flight Operations Manual. 

### Atlas Im ages Flight Operations Manual is tailored to UAS flight, and as closely as practical follows guidelines set forth for the operation of the multi

- crew manned aircraft. 

### Atlas Im ages operation of its small unmanned aircraft will not "create a hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of 

### Atlas Images UAS , combined with their operation in cordoned off and well

- controlled areas, 

### Atlas Im ages flight operations fall within Congress's contemplated safety zone when it disseminated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. 

### Atlas Im ages UAS have a demonstrable safety record and do not pose any threat to the general public or national security.

**IV. How**  

### Atlas **Images request will**  **benefit the public as a whole:**  Granting 

### Atlas Im ages exemption request furthers the public interest in many ways. Congress has pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system. 

### Atlas Im ages will conduct research into safe UAS operations every time it flies one of its UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety procedures 

### Atlas Im ages intends on using their Near Infrared technology to work with golf courses to reduce and more efficiently use pesticides and water resources. This furthers the public interest by reducing the amount of chemicals put into the ground as well as precious fresh water supplies. Allowing 

### Atlas Images to provide high definition video of real estate for sale, will bring a non

invasive and non - dramatic use of UAS into the public’s everyday life. 

### Atlas Im ages believes that by seeing a UAS used in small applications will promote a positive view towards UASs, instead of historically known military applications. 

### Atlas Im ages also believes that UAS used for real estate will be beneficial to its local economy by offering a different and unique view to properties that would otherwise go unnoticed. Allowing 

### Atlas Im ages to fly commercially, will allow real world experience to help develop better and more robust safety procedures. The public has an interest in reducing the danger and emission associated with current aerial cinematic capture methods, namely, full size helicopters. 

### Atlas Images UAS are battery powered and create no emissions. If an 

### Atlas Images UAS crashes, there is no fuel to ignite and cause significant damage or injury. The impact of 

### Atlas Im ages lightweight UAS is far less than a full size helicopter or current aerial platforms. Although, the noteworthy safety record of full size helicopters5

used in the motion picture industry currently is impeccable. The public's interest is furthered, by minimizing ecological and crash impacts, by permitting motion picture capture through 

### Atlas Im ages lightweight UAS

. DJI has been analyzing flight data and other information into novel safety protocols. These procedures and lessons will be implemented into flight operations manual that exceeds currently accepted means and methods of safe flight. 

### Atlas Im ages and Jeremy Bushnell through years of command experience on unmanned aircraft, have based their Flight operations manual off of a flight manual for an MQ

- 1 unmanned aircraft, of which General Atomics ASI created and uses in daily operations under a COA in California. Jeremy B ushnell has also adapted and modified safety protocols from the Kansas State University Salina UAS program to ensure safety of flight is maintained. Congress mandated the integration of UASs into our national airspace system, in part, to achieve progression in this field. Permitting 

### Atlas Im ages to immediately fly within the United States furthers these goals. Whether it is the scientific discoveries applicable to feature film making to advancements in publicly usable technologies, or advancements in equipment available to law enforcement personnel I first responders that does not cost millions of dollars.

**V. Reasons Why**  

### Atlas **Images Exemption Will Not Adversely Affect Safety Or How The**  **Exemption Will Provide a Level of Safety At Least Equal To Exist ing Rule:**  

### Atlas Im ages strives to provide a level of safety that exceeds the existing regulations. 

### Atlas Im ages strives to operate its UAS/UAV as closely and within practicality to the already proven safe F.A.R.s. It is significantly safer to operate a battery powered lightweight UAS piloted by FAA licensed pilots than the current helicopter based aerial cinematography systems. First, and foremost the potential l oss of life is zero because UASs do not carry any crew and 

### Atlas Images only operates them in specific areas away from dense populations. UAS are battery powered, carrying no flammable liquids, thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of DJ I UASs allow our remote control pilots to avoid hazards. Given their small size and weight, they pose less of an environmental and noise impact than conventional manned helicopter based systems available today. 

### Atlas Im ages UAS systems produce less noise than ground power units used to power small corporate aircraft. Thus reducing the acoustic footprint.

• 

### Atlas Im ages UAS weigh less than 55 pounds Max Tax off Weight

• 

### Atlas Im ages only operates its UAS below 400 feet;

• 

### Atlas Im ages UAS only operate for 5

- 25 minutes per flight;

• 

### Atlas Im ages lands its UAS when they reach 30% battery power;

• 

### Atlas Im ages remote contro l pilots operate 

### Atlas Im ages UAS by line of sight;

• 

### Atlas Im ages remote control pilots have video backup should they somehow lose sight of the UAS

• 

### Atlas Im ages staffs each flight with a remote control pilot and external observer6

• 

### Atlas Im ages UAS have GPS flight modes whereby they hover and then slowly land if communication with the remote control pilot is lost or battery power is below 30%;

• 

### Atlas Im ages actively analyses electronic flight data and other sources of information to constantly update and enhance safety protocols;

• 

### Atlas Im ages only operates in secured areas that are strictly controlled, are away from airports and populated areas;

• 

### Atlas Im ages conducts extensive briefing prior to flight, emphasizing safety. 

### Atlas Im ages recognizes there is always a potential hazard to those on the ground. These people will be protected by the fact that the no one will be allowed entry into the operations area without prior permission. Security will be established for the operations are a as part of the pre

- flight inspections. Each person within the operations area will be briefed about the UAS system’s flight and give consent to be in the operating area. 

### Atlas Im ages UAS utilizes four counter

-rotating propellers for balance, control and stability in all segments of flight. Each craft weighs less than 55 pounds, including cinematic or other research equipment. Each of 

### Atlas Images small unmanned aircraft are designed to primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations but operate only within the line of sight of the remote control pilot. In addition to the remote control pilot, 

### Atlas Im ages uses an external observer to ensure LOS is maintained at all times

. Utilizing battery power and not combustible fuels, flights generally last between five and twenty minutes. 

### Atlas Im ages does not operate its UAS with less than 30 percent battery capacity. Safety systems in place include a GPS mode that allows 

### Atlas Im age s UAS to hover in place if communication with the radio control pilot is lost and then slowly descend the UAS at 30 percent battery capacity. 

### Atlas Im ages aircraft are programmed, in some instances, to slowly follow a predetermined set of waypoints to ret urn to a safety point predetermined by the Pilot

- In

- Command if communications are lost. 

### Atlas Im ages will not operate its UAS within 5 miles of airports without express ATC permission

. The UAS operating software and GPS navigation systems do not allow any of the 

### Atlas Im ages UAS vehicles to operate near airports or FAA mandated no

- fly zones. In the event an operation needs to be conducted closer to an airport, 

### Atlas Im ages will inform the airport operator and airport air traffic control tower of the contemplated operation and will comply with any directions issued by air traffic control at that airport 

### Atlas Im ages only operates its UASs in predetermined areas and only in compliance with safety protocols such as those contained within its own Flight Opera tions Manual. 

### Atlas Im ages Flight Operations Manual is tailored to UAS flight, and as closely as practical follows guidelines set forth for the operation of the multi

- crew manned aircraft. 

### Atlas Im ages operation of its small unmanned aircraft will not "create a hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of 

### Atlas Images UAS , combined with their operation in cordoned off and well

- controlled areas, 

### Atlas Im ages flight operations fall within Congress's contemplated safety zone when it disseminated the Reform Act and the corresponding directive to integrate UAS into the national airspace system. 

### Atlas Im ages UAS have a demonstrable safety record and do not pose any threat to the general public or national security.7

**VI. A Summary The FAA May Publish in the Federal Register:** A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of 

### Atlas Im ages , UAS permits exem ption from Part 21 because our UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f )) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. 

### Atlas Im ages , current and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. 10 The FAA ha s previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety wi ll be achieved by maintaining any such required certifications and registrations by 

### Atlas Images

. B. 4 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

### Atlas Im ages sUAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.
C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations:8 PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. 

### Atlas Ima ges can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing, 

### Atlas Im ages , to operate my UAS meet and exce ed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 4 00 AGL. 

### Atlas Im ages , will however operate its UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 10 Appendix E

- Safety

/Flight Manual The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and Shall between required inspections, except as provided in paragraph (c ) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply 

### Atlas Im ages UAS. However, as a safety precaution 

### Atlas Images will inspect its UAS before and after each flight. **A Summary The FAA May Publish in the Federal Register:** A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a) (1). The size, weight and enclosed operational area of 

### Atlas Im ages UAS permits exemption from Part 21 because 

### Atlas Im ages , UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from th e airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, s ize, speed, maneuverability and proximity to areas such as airports and dense populations. 

### Atlas Im ages UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.9

**In summary** 

### Atlas **Images seeks an exemption from the following Regulations:**  14 C.F.R. 21, subpart H; 14 C.F.R. 45.23 (b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. §91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate 

### Atlas Im ages’ , small unmanned vehicle/lightweight unmanned aircraft vehicle in favorable, safe community awareness projects, N ear Infrared spectrographic analysis, real estate operations, and small event photography. Currently Near Infrared spectrograph/videography/photography relies primarily on the use of larger aircraft running on combustible fuel flying low. Posing potential risk to the public. Granting 

### Atlas Im ages , request for exemption will reduce current risk levels and thereby enhance safety. 

### Atlas Im ages UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields. 

### Atlas Im ages has written and will work on refining current safety protocols, and flight manuals that exceed currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board 

### Atlas Images UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. 

### Atlas Im ages’ , operation of my UAS, weighing less than 55 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. 

### Atlas Images respectfully request that the FAA grant its exemption.

Sincerely,
Jeremy L. Bushnell 

### Atlas Im ages , LLC