December 20, 2015 Auto Flight Systems, 

### LLC Chris Dunn 3790 El Camino Real, #165 Palo Alto, CA 94306 US DepartmentofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590

RE: Request for Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations

Dear Sir(s)/Madam(s),

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 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 forcrop 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 permitthe operation ofsUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled as to access. Granting this request fulfills the Secretary ofTransportation's (FAA Administrator's) responsibilities and authorityto notonly integrate UAS's intothe national airspace system, butto "

...establish requirements for the safe operation ofsuch aircraftsystems [UAS's] in the national airspace system" under Section 333(c) ofthe Reform Act specific to the use of UAS's for real estate purposes. 

### 1. Name and Address ofthe Petitioner: Chris Dunn Auto Flight Systems, 

### LLC 3790 El Camino Real, #165 Palo Alto, CA 94306 Phone: (650) 752-1670 Cell: (925) 321-5447 Email: chris@autoflightsystems.com



### 2. SpecificSections ofTitle 14ofthe Codeof Federal Regulationsfrom Which Petitioner Requests Exemptionare:§21, Subpart H; Airworthiness Certificates §27; Airworthiness Standards: Normal Category Rotorcraft §36; Noise Standards: AircraftType and Airworthiness Certification §45.23; Display ofMarks; 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 aircraftworthiness §91.9 (b)(2) and (c); Civil aircraftflight 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 ofsafety 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 inhibitthe 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 ofan airportorabove a designate altitude • Lost link integration providing forautomatic return to home system ensuring that in the unlikely event ofa lost link occurrence (Fail Safe), the sUAS will safely return tothe departure point. • Remote instrumentation atthe mobile ground station relaying data backtothe pilot, including, altitude, heading, airspeed (relative ground speed), GPS position and battery power levels, as well as warning messages ofcritical onboard systems. Auto Flight Systems, LLC will documentand maintain all maintenance, overhaul and modification records for its sUAS. Auto Flight Systems, LLC submits thatthe recuested relief under Section 333 is proper in consideration of the limited size, weight, operating conditions, design safetyfeatures, and the imposed conditions and limitations by Auto Flight Systems, LLC, that an equivalent level ofsafety will be ensured. Auto Flight Systems, LLC in all flightoperations will complywith airspace rules. Flight operations will not impede, delay ordivertany other aircraft as the Auto Flight Systems, LLC flightoperations will be conducted below 400 feetAGL. Any operations in airspace controlled by a control tower, will becoordinated with the towerto ensure there are no hazards tothe NAS. A Letter ofAuthorization 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 Eper 91.127 Class G per 91.126 Auto Flight Systems, LLC has implemented procedures to address flight termination plans in the unlikely eventofan 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 ofdeparture). Each flight operations site will be assessed for acceptable risk FTP's (in order as follows);

• Airspace classification • Riskto NAS operations • Risk impedance, delay or diversion ofother aircraft due toflight 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 ateach flight operations site. The flight control systems integrated intoAuto Flight Systems, LLC's sUAS has lost link or Fail Safe procedures that in the event ofa lost link, the sUAS will return tothe origination point. This origination point is the pointatwhich the sUAS departs the takeoff position and is recorded automatically as soon as the sUAS leaves the ground. All phases offlightwith the sUAS are critical, as such 14 CFR 135.100 Flightcrewmember duties will be strictly enforced. The areas surrounding where the PIC and theVO are working, including the ground station will be segregated from any nonparticipating individuals to ensure that distractions are kept ata minimum during all critical phases offlight. The sUAS's thatwill be operated by Auto Flight Systems, LLC will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part47, Aircraft Registration.



### 4. Howgranting the petitionwould be in the public interest Until recently, the only way to obtain an aerial photograph orvideo was through either a lowflying manned aircraft, ora ground based device that raised a person precariously high in the air. By utilizing proven modern technology, Petitioner will reduce thethreatto both the photographerand 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 offuel. 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 ofan incident oraccident. The risk ofan onboard pilotand crew during an incident oraccident is eliminated with the use ofa (iv) (v) within Class G airspace; and outside of5 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 costwill be greatly reduced making the services once reserved forthe wealthy available to middle class citizens. Additionally, aerial photography and video provides a positive eoonomic impactforthe oommunity.



### 5. The proposed operations Operational protocols include:

• Flight in Day VFR weather conditions only. • Operated atan altitude of no more than 400 feet above ground level (AGL), though most flights will occur below 200 feet AGL. Speed will notexceed 30 mph overthe ground.The • Pilot in Command will maintain Visual Line ofSight capability atall times. • Athorough pre-flight inspection will be accomplished in accordance with manufacturer instructions. A survey ofthe area in thevicinity oftheflight operation will be conducted making note ofany potential hazard(s) and a risk mitigation plan will developed for each hazard. • Anytimethe sUAS has undergone maintenance oralteration, a qualified Pilot in Command will conducta Functional Check Flightto ensure airworthiness. This flight will occur in a sparsely populated area, free of hazards. • Flight will plan toterminate 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) ofthe sUAS (except during training conducted in designated areas) without eitheran airline transport, commercial, private, recreational, or sport pilot certificate, and written certificate ofqualification bythe Petitioner's Chief Pilot. In order to receive acertificate ofqualification, a PIC will be required todemonstrate 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 orcontrolled-access property with permission from the property owner/controller orauthorized representative. Permission from property owner/controller orauthorized representative will be obtained for each flightto be conducted. • All operations will utilize at least onevisual observer (VO). The VO and PIC must be able to communicate verbally atall times; electronic messaging ortexting is not permitted during flight operations. The PIC will be designated before theflight and cannottransfer his or her designation forthe duration oftheflight. The PIC must ensure thatthe VO can perform the duties required ofthe VO. • All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: o Barriers orstructures are presentthatsufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. Ifa situation arises where the PIC becomes aware of nonparticipating persons leaving such protection and are within 500 feet ofthe sUAS, flightoperations will cease immediately in a manner ensuring the safety ofnonparticipating persons. • The sUAS will notoperate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) orfor airports notdenoted with an ARP, the center ofthe airportsymbol as denoted on the current FAA-published aeronautical chart, unless a letterofagreementwith thatairport's management is obtained orotherwise permitted by a COA issued tothe exemption holder.



### 6. Makeand Model ofaircraftfor proposed operationsAuto Flight Systems, LLC will be using DJI Matrice 100 and DJI Inspire 1 sUAS's in our operations.



### Ifadditional information is required, or ifyou 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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