December 20, 2015 

Auto Flight Systems, LLC 

Chris Dunn 

3790 El Camino Real, #165 

Palo Alto, CA 94306 

US Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 

11 of the Federal Aviation Regulations 

Dear Sir(s)/Madam(s), 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and C.F.R. Part 11, Auto Flight 

Systems, LLC ("Petitioner") seeks an exemption from the Federal Aviation Regulations as listed below. 

The requested exemption would allow Auto Flight Systems, LLC to provide aerial photography and video 

services to clients for use in; agriculture for crop analysis and protection, in search and rescue operations 

and in 3D imaging and data collection for crime scenes using a combination of DJI Matrice 100 and DJI 

Inspire 1 sUAS's. 

As detailed in this document, the requested exemption would permit the operation of sUAS under 

controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled as to access. 

Granting this request fulfills the Secretary of Transportation's (FAA Administrator's) responsibilities 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's] in the national airspace system" under Section 

333(c) of the Reform Act specific to the use of UAS's for real estate purposes. 

1. Name and Address of the Petitioner: 

Chris Dunn 

Auto Flight Systems, LLC 

3790 El Camino Real, #165 

Palo Alto, CA 94306 

Phone: (650) 752-1670 

Cell: (925) 321-544 7 

Email: chris@autoflightsystems.com 

2. Specific Sections of Title 14 of the Code of Federal Regulations from Which Petitioner 

Requests Exemption are: 
§21, Subpart H; Airworthiness Certificates 

§27; Airworthiness Standards: Normal Category Rotorcraft 

§36; Noise Standards: Aircraft Type and Airworthiness Certification 

§45.23; Display of Marks; general 

§45.27; Location of Marks; nonfixed-wing aircraft 

§61.23(a) and (c); Medical certificates: Requirement and duration 

§61.101(e)(4) and (5); Recreational pilot privileges and limitations 

§61.113; Private pilot privileges and limitations: Pilot in command 

§61.315(a); What are the privileges and limits of my sport pilot certificate? 

§91.7(a); Civil aircraft worthiness 

§91.9 (b)(2) and (c); Civil aircraft flight manual, marking, and placard requirements 

§91.103; Preflight action 

§91.119; Minimum safe altitudes: General 

§91.121; Altimeter Settings 

§91.151(a)(1); Fuel requirements for flight in VFR conditions 

§91.203; Civil aircraft: Certifications required 

§91.405(a); Maintenance required 

§91.407(a)(1); Operation after maintenance, preventive maintenance, rebuilding, or alteration 

§91.409(a)(1) and (a)(2); Inspections 

§91.417(a) and (b); Maintenance records 

3. Maintaining equivalent level of safety 

The components installed on sUAS's used by Auto Flight Systems, LLC to enhance the safety include; 

• Direct pilot intervention via remote control. 

• Navigation/orientation lighting. 

• GPS Based altitude and position sensors and flight stabilization system. 

• Barometric pressure and GPS altimeters. 

• Equipped with altitude and distance limiting features that inhibit the UAS from flying 

above certain altitudes or beyond a specified range. 

• Preprogrammed "No Fly Zones" prevent the sUAS from operating in designated areas such as 

within 5 miles of an airport or above a designate altitude 

• Lost link integration providing for automatic return to home system ensuring that in the 

unlikely event of a lost link occurrence (Fail Safe), the sUAS will safely 

return to the departure point. 

• Remote instrumentation at the mobile ground station relaying data back to the pilot, including, 

altitude, heading, airspeed (relative ground speed), GPS position and battery power levels, as 

well as warning messages of critical onboard systems. 

Auto Flight Systems, LLC will document and maintain all maintenance, overhaul and 

modification records for its sUAS. 

Auto Flight Systems, LLC submits that the recuested relief under Section 333 is proper in consideration of 

the limited size, weight, operating conditions, design safety features, and the imposed conditions and 

limitations by Auto Flight Systems, LLC, that an equivalent level of safety will be ensured. 

Auto Flight Systems, LLC in all flight operations will comply with airspace rules. Flight operations will not 

impede, delay or divert any other aircraft as the Auto Flight Systems, LLC flight operations will be 

conducted below 400 feet AGL. Any operations in airspace controlled by a control tower, will be 
coordinated with the tower to ensure there are no hazards to the NAS. A Letter of Authorization will be 

procured from appropriate airport managers to ensure compliance with airspace and ATC operations. 

Auto Flight Systems, LLC will adhere to all airspace rules. 

Class A No Operations Allowed 

Class B No Operations Allowed 

Class C per 91.130 

Class D per 91.219 

Class E per 91.127 

Class G per 91.126 

Auto Flight Systems, LLC has implemented procedures to address flight termination plans in the unlikely 

event of an unrecoverable system failure. As flight operation locations will vary considerably, Flight 

Termination Points (FTP's) will vary for each location (typically FTP's will be the point of departure). Each 

flight operations site will be assessed for acceptable risk FTP's (in order as follows); 

• Airspace classification 

• Risk to NAS operations 

• Risk impedance, delay or diversion of other aircraft due to flight operations 

• Risk to persons or property on the ground 

• Site assessment to determine hazards that could cause an unrecoverable system failure 

Lost Link Points (LLP's) will be established at each flight operations site. The flight control systems 

integrated into Auto Flight Systems, LLC's sUAS has lost link or Fail Safe procedures that in the event of a 

lost link, the sUAS will return to the origination point. This origination point is the point at which the sUAS 

departs the takeoff position and is recorded automatically as soon as the sUAS leaves the ground. 

All phases of flight with the sUAS are critical, as such 14 CFR 135.100 Flight crewmember duties will be 

strictly enforced. The areas surrounding where the PIC and the VO are working, including the ground 

station will be segregated from any nonparticipating individuals to ensure that distractions are kept at a 

minimum during all critical phases of flight. 

The sUAS's that will be operated by Auto Flight Systems, LLC will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration. 

4. How granting the petition would be in the public interest 

Until recently, the only way to obtain an aerial photograph or video was through either a low flying 

manned aircraft, or a ground based device that raised a person precariously high in the air. By utilizing 

proven modern technology, Petitioner will reduce the threat to both the photographer and the public writ 

large. As the FAA recognized in the Douglas Trudeau, Realtor® Exemption, No. 11138: 

"Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are 

operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons 

or more of fuel. The petitioner's [sUAS] weighs less than 3 lbs. The pilot and crew will be 

remotely located from the aircraft. The limited weight reduces the potential for harm to persons 

or damage to property in the event of an incident or accident. The risk of an onboard pilot and 

crew during an incident or accident is eliminated with the use of a (iv) (v) within Class G 

airspace; and outside of 5 statute miles from any airport, heliport, seaplane base, spaceport, or 

other location with aviation activities." 
In addition to reducing the risk to personal injury or death from these operations, the cost will be greatly 

reduced making the services once reserved for the wealthy available to middle class citizens. Additionally, 

aerial photography and video provides a positive eoonomic impact for the oommunity. 

5. The proposed operations 

Operational protocols include: 

• Flight in Day VFR weather conditions only. 

• Operated at an altitude of no more than 400 feet above ground level (AGL), though most flights 

will occur below 200 feet AGL. Speed will not exceed 30 mph over the ground. The 

• Pilot in Command will maintain Visual Line of Sight capability at all times. 

• A thorough pre-flight inspection will be accomplished in accordance with manufacturer 

instructions. A survey of the area in the vicinity of the flight operation will be conducted making 

note of any potential hazard(s) and a risk mitigation plan will developed for each hazard. 

• Any time the sUAS has undergone maintenance or alteration, a qualified Pilot in Command will 

conduct a Functional Check Flight to ensure airworthiness. This flight will occur in a sparsely 

populated area, free of hazards. 

• Flight will plan to terminate with no less than 25% battery power remaining. 

• All training flights will occur in sparsely populated areas free of hazards. 

• No individual will act as Pilot in Command (PIC) of the sUAS (except during training conducted in 

designated areas) without either an airline transport, commercial, private, recreational, or sport 

pilot certificate, and written certificate of qualification by the Petitioner's Chief Pilot. In order to 

receive a certificate of qualification, a PIC will be required to demonstrate proficiency in operating 

the sUAS in a manner consistent with the exemption, including normal, evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

• All operations shall be conducted over private or controlled-access property with permission from 

the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

• All operations will utilize at least one visual observer (VO). The VO and PIC must be able to 

communicate verbally at all times; electronic messaging or texting is not permitted during flight 

operations. The PIC will be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO. 

• All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: 

o Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. If a situation arises where the PIC 

becomes aware of nonparticipating persons leaving such protection and are within 500 

feet of the sUAS, flight operations will cease immediately in a manner ensuring the safety 

of nonparticipating persons. 

• The sUAS will not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport's management is obtained or otherwise permitted by a COA 

issued to the exemption holder. 

6. Make and Model of aircraft for proposed operations 
Auto Flight Systems, LLC will be using DJI Matrice 100 and DJI Inspire 1 sUAS's in our operations. 

If additional information is required, or if you have any questions regarding this Petition fo Exemption, 

please contact the undersigned at: 

Very Respectfully, 

Chris Dunn 

Auto Flight Systems, LLC 

Phone: (650) 752-1670 

Cell: (925) 321-5447 

chris@autoflightsystems.com 

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