U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue,	S.E.

West	Building	Ground	Floor,	Room	W12-140

Washington	DC	20590

RE:		Petition	for	Exemption	under	Section	333	of	the	FAA	Modernization	and	

Reform	Act	and	Part	11.81	of	the	Federal	Aviation	Regulations

January	26, 2016

Petitioner:

GSI	Universal	LLC

Robert	Coucher	CEO

28001	NW	Dorland	Road

North	Plains,	OR	97133

Phone:		503-647-7777

Cell	Phone:		503-970-5206

Email:		rcphantom3@gmail.com

Website:		GSIUniversal.com

Dear	Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	

Reform	Act)	and	14	CFR	Part	11.81,	GSI	Universal	LLC,	hereby	applies	for	exemption	

from	the	listed	Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial	

operation	of	its	small,	unmanned	aircraft	for	HD	Video	production,	

photogrammetry,	inspection,	and	analysis.		All	operations	shall	be	conducted	within	

and	under	the	conditions	and	limitations	outlined	previously	by	the	FAA	as	required	

by	Section	333	and	conducted	in	compliance	with	operator’s	manual	“Phantom	3	

Advanced	User	Manual	(EN)	v1.6” (located	at	URL	DJI.com	under	“download”	

tab).

1. Sections	from	which	exemptions	are	sought:

a. 14	CFR	Part	21,	subpart	H – Airworthiness Certificates

b. 14	CFR	Part	45.23 – Display	of	Marks,	General

c. 14	CFR	Part	45.29	– Size	of	Marks

d. 14	CFR	Part	61.113(a)	and	(b) - Private	Pilot	Privileges	and	

Limitations:	Pilot	In	Command.

e. 14	CFR	Part	91:

i. 91.103	(b)(2)	– Preflight	Action

ii. 91.105	– Flight	Crewmembers	at	Stations

iii. 91.109	– Flight	Instruction

iv. 91.119	– Minimum	Safe	Altitudes

v. 91.121	– Altimeter	Settings

vi. 91.151	– Fuel	Requirements	for	Flight	in	VFR	Conditions

vii. 91.203	– Certifications	Required

viii. 91.405	– Maintenance	Required
ix. 91.407	– Operation	After	Maintenance,	etc.

x. 91.409	– Inspections

xi. 91.417	– Maintenance	Records

2. Relief	sought:

a. GSI	Universal	hopes	to	operate	small	Unmanned	Aircraft	Systems	

(sUAS)	for	commercial	purposes	including	(but	not	limited	to)	

business	performing aerial	filming	of	real	estate	to	assist	realtors	in	

promoting	properties	they	are	selling.		We	hope	to	market the	

production	of	HD	Video	(taken	with	sUAS	for	example: DJI	Phantom	

3).		We	are	seeking	relief	because	such	commercial	use	of	sUAS	is	not	

allowed	except	under	exemption.		Other	possible	commercial	uses	

may	include	video	for	infrastructure	and	building	inspections,	roof	

inspections,	photogrammetry,	videography,	and	miscellaneous	

advertising.

b. This	exemption	will	cover	use	of	airframes	weighing	less	than 55	lbs.	

including	any	payload	and	energy	sources.

i. Quad-copter	DJI	Phantom	3	Advanced.

ii. Other	airframes	to	be	added	by	future	amendment	to	this	

exemption.

3. Public	Benefit:

a. Realtors	will	benefit	by	enabling	them	to	provide	clients	and	

prospective	clients	with	high	definition	videos	of	properties,	

neighborhoods,	approaches	to	neighborhoods	and	so	on.		This	will	

provide	them	with	additional marketing	tools	and	increase	their	

competitiveness	in	their	markets.		

b. Also,	the	use	of	sUAS vastly	reduces	the	cost	of	producing	HD	real	

estate	and	advertising	videos	otherwise	made	using	helicopters	or	

fixed	wing	aircraft.	

c. Prospective	buyers	of	properties	will	benefit	by	being	able	to	view	

candidate	properties	to	ascertain	whether	or	not	they	appear	to	meet	

buying	criteria,	saving	them	time	and	expenses.

d. Reduces	human	risk	due	to	manned	aircraft	accidents.

e. Reduces	environmental	impacts	from	manned	aircraft	emissions.

4. Safety	not	adversely	affected:

a. All	GSI	Universal	aircraft	will	be	(are)	registered	and	marked	as	

required	by	Section	4471	and	Part	47	and	Part	45	Subpart	C.

b. All	flight	operations	will	be	conducted	with	a	minimum	of	two	

crewmembers	(Pilot	in	Command	(PIC)	and	Observer(s)).		All	crew	

will	remain	stationary	and	maintain	continuous verbal	contact	

throughout	flight	duration.		All	crew	will	have	undergone	

comprehensive	UAV	/	UAS	/	Drone	flight	training	for	competency	and	

new	FAA	333	and	Part	107	commercial	compliance	requirements.

c. sUAS	will	only	operate	in	designated	and	confined	safe	areas.

d. All	manufacturer	recommended	maintenance,	inspection	and	repair	

will	be	done	per	manufacturer	instructions.		Repairs	which	are	
beyond	the	abilities	of	GSI	Universal	personnel	will	only	be	done	by	

technicians	qualified	by	the	manufacturer (e.g.,	EZDrone Inc.).

e. All	maintenance,	inspection, and	repair	will	be	logged	by	GSI	

Universal.

f. While	videos	can	be	produced	using helicopters	or	airplanes	the	

practicality of	doing	so is	limited	by	allowable	elevation,	proximity	to	

properties,	and	expense.		Using	sUAS for	producing	videos	can	be	

done	in	a manner	that	ensures	the	safety	of	those	on	the	ground	and	

other	aircraft	in	the	vicinity.		Flight	ceilings	for	GSI	Universal’s sUAS

will	never	exceed	400ft.	AGL.		

g. Flight	ground	speeds	will	not	exceed	30	knots.

h. In	proximity	to	airports	other	FAA	flight	restraints	on	sUAS will	

always	be	observed.		

i. Checking	in	with	control	towers to	obtain	consent	to	fly	will	always	be	

performed	as	required.		

j. Observers	will	ensure that	people	or	potentially	damageable	objects	

on	the	ground	are	never	beneath	the	flight	paths	of	our	sUAS.	

k. Real	time	video	links	to	the	ground	based	PIC will	be	used	at	all	times	

to	ensure	flight	paths	avoid	endangering	those	on	the	ground	as	well	

as	surrounding	properties.	

l. All	flights	will	be	conducted	in	accordance	with	visual	line	of	sight	to	

the	sUAS.	

m. GSI	Universal’s	sUAS	are	all	equipped	with	automatic	return	to	home	

(RTH)	in	the	event	communication	between	controller	and	sUAS	is	

lost.			Also,	RTH	can	be	manually	triggered	by	the	PIC	in	the	event	this	

appears	necessary	to	avoid	any	potentially	unsafe	conditions.

n. In	the	event	of	any	accident	GSI	Universal	will	immediately	cease	

operations	and	report	the	incident	to	the	NTSB and	AFS80.

5. Privacy:

a. All	persons	shall	be notified	in	advance	of	operations	in	their	

respective areas.	GSI	Universal	sUAS	will	never	be permitted	to	fly

over	residential	or	commercial	or	other establishments	unless	

granted prior	written	approval.

6. Summary:

In	summary GSI	Universal	seeks exemption	under	Section	333	of	14	CFR	to	

enable	its use	of	sUAS to	safely	produce	High	Definition	real	estate	videos

(and	other	types	of	videos	as	noted	above) to	aid	realtors,	prospective	

buyers,	and	sellers, to	more	efficiently	and	effectively	market,	purchase	and	

sell	properties.		By	observing	flight	rules	to	ensure	the	safety	of	people and	

property	on	the	ground	or	airborne,	this	will	be	done	safely,	more	easily,	and	

less expensively	than	other	means	of	producing	such	videos.

Additionally,	there	is	a	burgeoning	market	in	the	US	for	exactly	this	type	of	

video.		Many	exemption	requests	under	Section	333	have	already	been	

granted	to	other	individuals	and	companies	with	business	plans	similar	to	
GSI	Universal’s.		GSI	Universal	is petitioning	to	enable	it to	participate	in	this	

growing	market.

7. Use	outside	of	the	United	States:

If	our petition	is	granted,	GSI	Universal	has no	intention	of	exercising	the	

privileges	outside	the	United	States.

8. Conclusion:

a. GSI	Universal	respectfully	requests	that	its	petition	for	exemption	be	

granted so that	we	can	move	forward	with	our	intended	business	

operations.

If	any	further	explanation	or	information	is	required	for	the	approval	of	our	

petition	for	exemption	please	contact	me	directly	and	I	will respond	

promptly.

Best	Regards,

Robert J.Coucher

Robert	Coucher

CEO,	GSI	Universal	LLC