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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 Images to assist in the safe capture of 

video, images, and surveying of persons and property for commercial use. 

Dear Sir or Madam 

Atlas Images 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 certificate, and the Atlas Images Flight 

Operations Manual. 

Jeremy Bushnell, and his company Atlas Images, 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 Images 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 Images exemption request 

would permit its operation of lightweight, unmanned (remotely controlled 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 Images 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 Images will 

employ fully licensed and current pilots that are also experts in the flight characteristics of the UAS/UAV 

in which Atlas Images operates. A detailed training curriculum discussing the use and safe operation of 

UAS will also be implemented and adhered to.

Granting Atlas Images 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. 
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Atlas Images will conduct operations in compliance with the protocols described herein or as otherwise 

established by the FAA. 

I. Contact Information

Jeremy L. Bushnell

Atlas Images

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 Images 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 Images

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 Images to operate, Atlas

Images pilots will be able to gain valuable real world experience that is unattainable any other way. 

Much like operating a commercial or corporate aircraft, experience is gained through practical and safe 

real world experience. With this experience Atlas Images will develop existing techniques and 

protocols, as well as develop new ones. In addition, Atlas Images submits its Flight operations Manual 

attached to this Exemption Request. Included in the Atlas Images 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 Images strives to provide a level of safety that exceeds the existing regulations. Atlas Images

strives to operate its UAS/UAV as closely and within practicality to the already proven safe F.A.R.s. It is 
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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 loss of life is 

zero because UASs do not carry an on board crew and Atlas Images only operates them in specific areas 

away from dense populations. Our 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 

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 Images UAS systems produce less noise than ground power units used to power small 

corporate aircraft. Thus reducing the acoustic footprint. 

• Atlas Images UASs weigh less than 55 pounds Max Tax off Weight 

• Atlas Images only operates its UAS below 400 feet

• Atlas Images UAS only operate for 5-25 minutes per flight

• Atlas Images lands its UAS when they reach 30% battery power

• Atlas Images remote control pilots operate Atlas Images UAS by line of sight

• Atlas Images remote control pilots have video backup should they somehow lose sight of the UAS

• Atlas Images staffs each flight with a remote control pilot, and external observer

• Atlas Images 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 Images actively analyses electronic flight data and other sources of information to constantly 

update and enhance safety protocols

• Atlas Images only operates in secured areas that are strictly controlled, are away from airports and 

populated areas

• Atlas Images conducts extensive briefing prior to flight, emphasizing safety

Atlas Images 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 Images 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 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
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Images uses an external observer. Utilizing battery power and not combustible fuels, flights generally last 

between five and twenty minutes. Atlas Images does not operate its UAS with less than 30 percent 

battery capacity. Safety systems in place include a GPS mode that allows 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 Images 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 Images 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 Images 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 Images 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 Images 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 Images 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 Images 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 Images

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 Images 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 Images 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 Images 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 Images 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 noninvasive and non-dramatic use of UAS into the public’s everyday life. Atlas Images believes that by 

seeing a UAS used in small applications will promote a positive view towards UASs, instead of 

historically known military applications. Atlas Images 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 Images 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 Images lightweight UAS is far less than a full 

size helicopter or current aerial platforms. Although, the noteworthy safety record of full size helicopters 
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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 Images

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 Images 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 Bushnell 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 Images 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 Existing Rule: 

Atlas Images strives to provide a level of safety that exceeds the existing regulations. Atlas Images

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 loss 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 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 Images UAS systems produce less noise than ground power units used to power small corporate 

aircraft. Thus reducing the acoustic footprint. 

• Atlas Images UAS weigh less than 55 pounds Max Tax off Weight 

• Atlas Images only operates its UAS below 400 feet; 

• Atlas Images UAS only operate for 5-25 minutes per flight; 

• Atlas Images lands its UAS when they reach 30% battery power; 

• Atlas Images remote control pilots operate Atlas Images UAS by line of sight; 

• Atlas Images remote control pilots have video backup should they somehow lose sight of the UAS

• Atlas Images staffs each flight with a remote control pilot and external observer
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• Atlas Images 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 Images actively analyses electronic flight data and other sources of information to constantly 

update and enhance safety protocols; 

• Atlas Images only operates in secured areas that are strictly controlled, are away from airports and 

populated areas; 

• Atlas Images conducts extensive briefing prior to flight, emphasizing safety. 

Atlas Images 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 Images 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 Images 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 Images does not 

operate its UAS with less than 30 percent battery capacity. Safety systems in place include a GPS mode 

that allows 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 Images 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 Images 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 Images 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 Images 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 Images only operates its UASs in predetermined areas and only in 

compliance with safety protocols such as those contained within its own Flight Operations Manual. 

Atlas Images 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 Images 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 Images

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 Images UAS

have a demonstrable safety record and do not pose any threat to the general public or national security. 
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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 Images, UAS permits exemption 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 Images, 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 has 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 will 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 Images 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: 
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PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. Atlas Images 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 Images, to operate my UAS 

meet and exceed 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 400 AGL. Atlas Images, 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 Images 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 Images UAS permits exemption from Part 21 because Atlas Images, UAS meets 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 Images 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. 
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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 Images’, small unmanned vehicle/lightweight unmanned aircraft vehicle in favorable, safe 

community awareness projects, Near 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 Images, request for exemption will reduce current risk levels and thereby enhance safety. 

Atlas Images 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 Images 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 Images’, 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 Images, LLC