1 Gulf Coast Unmanned A eria l 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 Modernizat ion 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 U nmanned Aircraft Systems ( sUAS )

equippe d to conduct commercial aerial photography and videography for specific Agricultural

and Industrial Inspection

, Aerial D ata collection , and sUAS Flight Training hereby amends its

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

c ommercial operation of its sUAS , so long as such operations are condu cted 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 A eria l 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 o r 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 b y the aircraft manufacturer.

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

(AGL). Altitude m ust 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 certifica te 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 maintai ns VLOS capability. The

VO and PIC must be able to communicate verbally at all times. E lectronic 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 fo r 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 st ated 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 conditi ons 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 i ts

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 p resent 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 fo r an amendment to its grant of exemption.3 Gulf Coast Unmanned A eria l 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 con ducting 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 haz ard to persons and property.

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

co ndition 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

f rom operating until the necessary maintenance has been performed and the UAS is

found to be in a c ondition for safe flight.

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

inspection, and life limit requirements for th e aircra ft and aircraft components.

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

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 hi s or her pilot certificate.4 Gulf Coast Unmanned A eria l Services

– 4490 Blanche Noyes, Baton Rouge, LA 70807

13. GCUAS shall not permit any PIC to ope rate 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) an d 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 . T raining operations shall only be conducted during dedicated training

sessions. During tr aining, 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 accor dance with 14 CFR §

91.119.

14. UAS op erations 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 sta tute miles from the PIC.

17. If the UAS loses communications or loses its GPS signa l, 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 unpredicte d 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 t he manufacturer if greater.5 Gulf Coast Unmanned A eria l 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

conduct ed under the terms of th e 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 (N

Number) markings in accordance wi th 14 CFR part 45, Subpart C. Markings shall be as

large as practicable.

22. D ocuments 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

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

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

request.

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

at all times.

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

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

persons, vessels, v ehicles, 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

o f 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 hazar d. The PIC, VO, operator trainees or essential persons are not

considered nonparticipating persons under th is 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 e ach

flight to be conducted.6 Gulf Coast Unmanned A eria l 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 W eb 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 appreciate s your consideration in this matter.



## Clayton L. Mounger

Clayton L. Mounger

President

Gulf Coast Unmanned Aerial Services