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	Regul ations January	26, 2016 **Petitioner:** GSI	Universal	LLC Robert	Coucher	CEO 28001	NW	Dorland	Road North	Plains,	OR	97133 Phone:		503

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- 7777 Cell	Phone:		503

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- 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	Regul ations	(“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,	G eneral c. 14	CFR	Part	45.29

– Size	of	M arks d. 14	CFR	Part	61.113(a)	and	(b)

- Private	Pilot	Privileges	and Limitations:	Pilot	In	C ommand. e. 14	CFR	Part	91: i. 91.103	(b)(2)

– Preflight	Action ii. 91.105

– Flight	C rewme mbers	at	Stations iii. 91.109

– Flight	Instruction iv. 91.119

– Minimum	Safe	Altitudes v. 91.121

– Altimeter	S ettings vi. 91.151

– Fuel	Requirements	for	Flight	in	VFR	C onditions vii. 91.203

– Certifications	Required viii. 91.405

– Maintenance	Requiredix. 91.407

– Operation	After	M aintenance,	etc. x. 91.409

– Inspections xi. 91.417

– Maintenance	Records 2. **Relief	sought:** a. GSI	Universal	hopes	to	operate	s mall 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	f or	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	addition al marketing	tools	and	increase	their competitiveness	in	their	markets. b. Also,	the	use	of	sUAS vastly	reduces	the	cost	of	producing	HD	real estate an d	advertising videos otherwise made u sing	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	4 7	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,	inspecti on	and	repair will	be	done	per	manufacturer	instruction s .		Repairs which	arebeyond	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	re straints	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	path s	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	s UAS	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	potenti ally	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	the ir respective area s . GSI	Universal sUAS	will	never	be permitted	to	fly over	residential	or	commercial	or	other establish ments	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	video s . Additionally,	there	is	a	burgeoning	market	in	the	US	for	exactly	this	type	of video.		Many	exemption	requests	u nder	Section	333	have	already	been granted	to	other	individuals	and	companies	with	business	plans	similar	toGSI	Universal’s

. GSI	Universal	is petitioning	to	enable it to	participate	in	this growing	market. 7. **Use	outside	of	the	United	States :**  If our petiti on	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