1 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

April 3, 2015

U. S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140 Electronically Submitted via

1200 New Jersey Ave., SE www.regulations.gov

Washington, DC 20590

Regarding: 

Petition to amend GCUAS’s previous submission dated November 25, 2014:

Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part 11 

of the Federal Aviation Regulations from 14 CFR Part 21; 61.113(a) and (b); 91.103; 

91.109(c); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 

91.417(a) and (b).

Dear Sir or Madam:

Pursuant to the previous request for exemption of Section 333 of the FAA Modernization and 

Reform Act of 2012 (Reform Act) and 14 CFR Part 11, Gulf Coast Unmanned Aerial Services,

LLC (GCUAS) which is an owner and operator of Small Unmanned Aircraft Systems (sUAS) 

equipped to conduct commercial aerial photography and videography for specific Agricultural

and Industrial Inspection, Aerial Data collection, and sUAS Flight Training hereby amends its 

application for exemption from the listed Federal Aviation Regulations (FAR) to allow 

commercial operation of its sUAS, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333.

Clarification of our requested sUAS operations follows:

1. Operations will consist of operating DJI Phantoms and Inspires when weighing less than 

55 pounds including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption.
2 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

2. The UA shall not be operated at a speed exceeding 87 knots (100 miles per hour). 

GCUAS shall use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater 

than the maximum UA operating airspeed recommended by the aircraft manufacturer.

3. The UA shall be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

4. The UA shall be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

5. All operations shall utilize a visual observer (VO). The UA shall be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting shall not be used during flight operations. The PIC shall be designated before the 

flight and will not transfer his or her designation for the duration of the flight. The PIC 

shall ensure that the VO can perform the duties required of the VO.

6. All FAA documentation and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in proposed grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents shall be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the FAA exemption and the procedures outlined in the operating 

documents, the conditions and limitations in the FAA exemption take precedence and 

shall be followed. Otherwise, the operator shall follow the procedures as outlined in its 

operating documents. GCUAS may update or revise its operating documents. It is 

GCUAS’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. GCUAS 

shall also present updated and revised documents if it petitions for extension or 

amendment to this grant of exemption. If GCUAS determines that any update or revision 

would affect the basis upon which the FAA granted this exemption, then the operator 

must petition for an amendment to its grant of exemption. 
3 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

7. Any UAS that undergoes maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, shall undergo a 

functional test flight prior to conducting further operations. Functional test flights shall

only be conducted by a PIC with a VO and must remain at least 500 feet from other 

people. The functional test flight shall be conducted in such a manner so as to not pose an 

undue hazard to persons and property. 

8. GCUAS is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

9. Prior to each flight, the PIC shall conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection shall account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft shall be prohibited 

from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight.

10. GCUAS shall follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

11. Each UAS operated under the anticipated exemption shall comply with all manufacturer 

safety bulletins.

12. The PIC shall hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC shall also hold a current FAA airman medical certificate or a 

valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC shall also meet the flight 

review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate.
4 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

13. GCUAS shall not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS shall be operated under 

the anticipated exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, 

and experience-building) and determining the PIC’s ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under the anticipated exemption 

shall be permitted. Training operations shall only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC shall operate 

the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 

91.119.

14. UAS operations shall not be conducted during night, as defined in 14 CFR § 1.1. All 

operations shall be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) will not be conducted.

15. The UA shall 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. The letter of 

agreement with the airport management shall be made available to the Administrator or 

any law enforcement official upon request.

16. The UA shall not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

17. If the UAS loses communications or loses its GPS signal, the UA shall be able to return 

to a predetermined location within the private or controlled-access property.

18. The PIC shall abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC shall be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater.
5 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. GCUAS may 

apply for a new or amended COA if it intends to conduct operations that cannot be 

conducted under the terms of the issued COA.

21. All aircraft operated in accordance with the anticipated exemption shall be identified by 

serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings shall be as 

large as practicable.

22. Documents used by GCUAS to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 shall be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents 

shall be made available to the Administrator or any law enforcement official upon 

request.

23. The UA shall remain clear and give way to all manned aviation operations and activities 

at all times.

24. The UAS shall not be operated by the PIC from any moving device or vehicle.

25. All Flight operations shall be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present 

an undue hazard. The PIC, VO, operator trainees or essential persons are not 

considered nonparticipating persons under this exemption.

26. 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. 
6 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

27. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

The name and address of the applicant is:

Gulf Coast Unmanned Aerial Services, LLC (GCUAS)

Attention: Clayton L. Mounger

Phone: (989) 859-6737

Email: ClaytonLMounger@gmail.com

Address: 4490 Blanche Noyes

Baton Rouge Metropolitan Airport

Baton Rouge, LA 70807

GCUAS appreciates your consideration in this matter.

Clayton L. Mounger 

Clayton L. Mounger

President

Gulf Coast Unmanned Aerial Services