U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave, SE Washington, DC 20590

RE: ExemptionRequest under Section 333 ofthe FAAModernization and Reform Act of 2012 and 14 C.P.R. Part 11

Dear Sir or Madam,

GulfCoast State College (GCSC), a nonprofit educational institution located at 5230 W. Hwy 98, Panama City, Florida 32401, and Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 ("FAA Reform Act") and 14 C.P.R. Part 11, respectfully requests exemptions from several provisions ofthe Federal Aviation Regulations ("FAR"), specifically Section 333 which authorizes the FAAto determine:

1. Ifcertain unmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe national airspace system orthe public orpose a threat to national security; and

2. Whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certification under section44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified underparagraph (1)

We are requesting GCSC, an owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations (PARs) listed below so that GCSC may operate its small unmanned aircraft systems (UAS) for research and educational purposes onits ownbehalfand

on behalfofother research groups in airspace regulated bythe Federal AviationAdministration (FAA) as long as such operations are conducted within and under the conditions outlined herein

or as maybe established bythe FAA as required by Section 333. We seek approval ofthis petition in alignment withyour consideration ofa similar exemption grantedto Franklin W. Olin College ofEngineering. GCSC has been actively involved inthe curricular andtechnical development ofautonomous and unmanned systems to address currentregional and national problems and develop applications for the scientific and research communities; inparticularrip-tide detection, coastal ecology, defense systems, and other autonomy and physical science communities. GCSC has a growing number ofsmall commercialUAS/UAV platforms, and projects a small number ofsmall fixed wing UAV platforms. Representative vehicles are:

Typhoon Q500

DJI Inspire

ParrotARDrone

Trimble UX5 Wingspan: 565 mm Weight: 1,100 grams Dimensions: 565 x 420 x 240mm Body Material: CarbonFiber RotorMaterial: CarbonFiber Wingspan: 559 mm Weight: 2,935 grams Dimensions: 438 x 451 x 301 mm BodyMaterial: CarbonFiber Rotor Material: CarbonFiber Wingspan: 731 mm Weight: 420 grams Dimensions: 517 x 517 x 127 mm Body Material: CarbonFiber Rotor Material: Plastic

Wingspan: 100 em Weight: 5.5 lbs Dimensions: 100 x 65 x 10.5 em BodyMaterial: EPP foam & carbon Propulsion: Brushless Motorapplications ofUVS technology to support agriculture, particularly peanut, cotton, and citrus

across the state ofFlorida. Research operations ofsmall unmanned aerial systems will be strictly supervised bytrained GCSC faculty and staff, and in partnership with qualified operators in area defense and agriculture industry sectors where such partnerships merit engagement and meetthe safety and operational guidelines ofthe college and FAA.

Non-research outdoor operations ofUAVs are restricted to GCSC campus properties and occasional field operation locations for recruiting and demonstration purposes focused solely on teaching students howto operate unmanned systems (aerial, surface, and subsurface) in a manner consistent withthe developing college and AUVSI safety standards. GCSC's exemptionrequest would permit its operation oflightweight, unmanned (remotely controlled in line ofsight) UAS's in tightly controlled and limited airspace, specifically over GCSC College property and with writtenpermission ofowners, over local farms, woodlands, and coastal areas where applicable. None ofsaid properties are within 5 miles ofany airport. Each applicationrequiring flight will be preceded by a predetermined, specifically marked, area(s) ofoperation in strict compliance with FAAregulations.

Granting GCSC's request comports withthe Secretary ofTransportation's (FAA Administrator's) responsibilities to not only integrate UAS's into the national airspace system, but to"

... establish requirements for the safe operation ofsuch aircraft systems [UAS's] inthe national airspace system" under Section 333 ofthe Reform Act. Further, GCSC will conduct its operations in compliance withthe protocols described herein or as otherwise established by the FAA.

The Extent ofReliefGCSC Seeks andthe Reason It Seeks Such Relief:

GCSC submits this application in accordance withthe Reform Act, 112 P.L. 95 §§ 331-334, seeking relieffrom any currently applicable FAR's operatingto prevent GCSC contemplated research and other flight operations withinthe national airspace system. The Reform Act in Section 332 provides for such integration ofcivilunmanned aircraft systems into our national airspace system as it is in the public's interestto do so, therefore aligning with the overall mission ofthe college. GCSC lightweight UAS'smeet the definition of"small unmanned aircraft" as defined in Section 331 andtherefore the integration ofGCSC lightweightUAS's are expressly contemplatedbythe Reform Act. GCSC would like to operate its lightweight UAS's prior to the time periodbywhichthe Reform Actrequires the FAAto promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types ofUAS'sThe FAA has the authority to issue the exemptionto GCSC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting GCSC exemptionrequest furthers the public interest. First, Congress has already pronouncedthat it is in the public's interestto integrate commercially flown UAS's into the national airspace system, hence the passing ofthe Reform Act. Second, GCSC conducts research into safe UAS operations every time it flies one ofits UAS's. Flight data, visual inspections, recorded observations and flight analyses are compiled and analyzed as a part ofthe research effort to further enhance
current safetyprotocols. Allowing GCSC to log more flight time directly relates to its research and its ability to further enhance current safety measures. Third, GCSC has received requests to assist in the development ofsystems and solutions capable ofsupplying mission data to US Government agencies, including our partnership with the local NA VSEA (Naval Sea Systems Command) Warfare Center. Allowing GCSC to conductthese flights will assist in furthering the research efforts and lies clearly in the common interest ofnational defense capabilities.

Granting GCSC's exemptionrequest substantially furthers the public's interest in ways known and currently unknown. Permitting GCSC to immediately fly withinthe United States furthers advancements inpublicly usable technologies or advancements in equipment available to law enforcementpersonnel, the military, and first responders with state ofthe art equipmentthat has the virtue ofbeing cheaply and quickly available.

Reasons Why GCSC's Exemption Will Not Adversely Affect Safety orHowThe Exemption Will Provide a Level ofSafety At Least Equal To Existing Rule:

GCSC's exemption will not adversely affect safety. Permitting GCSC to log more flight time will allow GCSC to innovate and implementnew and continue to develop and refine safety protocols. To that end, GCSC agrees to operate throughthis exemption under the following conditions:

• GCSC's UAS's weigh less than 55 pounds complete with cameras and sensors.

• GCSC only operates its UAS's below400 feet.

• GCSC's UAS's only operate for 5-50 minutes perflight.

• GCSC lands its UAS's whenthey reach 25% battery power.

• GCSC's remote control pilots operate all GCSC UAS's by Visual Line ofSight.

• GCSC remote control pilots have a second spotter (as part ofour CRM implementation), plus waypoint return and/or geo-fencing software should loss ofsight ofUAS occur.• GCSC staffs each flight with a remote control pilot and camera operator and, ifthe testing team is all-student, a faculty supervisor.

• GCSC UAS's have GPS flight modes wherebythey return to home (failsafe) if communication withthe pilot is lost, batterypower is below 25% orthe vehicle leaves the pre-determined flight area.

• GCSC actively analyses electronic flight data and other sources ofinformationto constantly update and enhance safetyprotocols.

• GCSC only operates in secured areas that are strictly controlled, are away from airports and populated areas and have writtenpermission from the property owner where applicable.

• GCSC conducts extensive briefings priorto and after each flight, during which safety carries primary importance.

• GCSC always obtains all necessarypermissions and permits priorto operation.

• GCSC ensures that all staffand related personnel operating UASs have successfully completedthe UVS safety training in development with ERAU and the Unmanned Safety Institute.

Summarythe FAA may publish inthe Federal Register:

14 .F.R. 21 and 14 C.P.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.P.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates inrelation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area ofGCSC's UAS's permits exemption from Part 21 because GCSC UAS's meet an equivalent level ofsafety pursuantto Section 3 3 3 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement underboththe Act (49 U.S. C.§ 44701 (f)) and A. Section 333 ofthe Reform Act. Bothpieces oflegislationpermit the FAAto exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. GCSC's UAS's meet or exceed each ofthe elements. 14 C.P.R. 91.7 (a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable inthe form contemplated bythe FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual inthe aircraft. As there are no pilots orpassengers, and giventhe size ofthe UAS's, this Regulation is inapplicable. An equivalent level ofsafety will be achieved bymaintaining a manual at the flight operations center. The FAAhaspreviously issued exemptions to this regulation in ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as GCSC's UAS's utilize electronic global positioning systems and internal gyroscopes to provide spatial coordination. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level ofsafety will be achieved by maintaining such certifications and registrations at the GCSC research laboratory/flight operations center.

B. 14 C.F.R. §45.23: Marking ofthe Aircraft. Applicable Codes ofFederal Regulationrequire aircraft to be marked according to certain specifications. GCSC's UAS's are, by definition, unmanned. They therefore do not have a cabin, cockpit orpilot station onwhichto mark certain words orphrases. Further, two-inch lettering is difficult to place on such small aircraft. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738,10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. Pursuantto 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. GCSC can achieve an equivalent level ofsafety as achieved by current Regulations because GCSC's UAS's do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. GCSC's model aircraft pilot vetting and training programs (based upon completion ofan Academy ofModel Aircraft recommended and a self-administered UAS flight training program and internal procedures) will. Also, the risks attendant to the operation of GCSC's UAS's is far less than the risk levels inherent inthe commercial activities outlined in 14 C.F.R. 

### § 61, et seq.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C. F. R. 

### § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. Itallows Helicopters to be operated at lower altitudes in certain conditions. GCSC's UAS's will never operate at an altitude greater than 400 AGL. GCSC will, however, operate its UAS's in sectioned offareas with securityperimeters, providing a level of safety at least equivalentto those inrelation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofGCSC's UAS's, an equivalent level ofsafety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. Theabove-cited Regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph C ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter." These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to GCSC should its requested exemption be granted. Even so, GCSC conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment and replacement/repair ofany damaged hardware. All ofGCSC UVS inventory is managed and maintained strictly by the college. Therefore, an equivalent level ofsafety will be achieved. GCSC is using currently manufactured UAS's for its research whichhave beenproduced in significant numbers, which also allows GCSC to avail itselfofthe higherreliability and expertise ofthe vehicle manufacturers which will further help inkeeping all vehicles safe.

F. Summary GCSC seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(l); 14 C.P.R.§ 91.409 (a)(2); 14 C.P.R.§ 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to commercially operate its fleet ofsmall unmanned hovering and lightweight unmanned fixed-wing aircraft and to conduct its own research and to supply datato other groups that request it, such as NASA, The US Army, NOAA, physical scientists, biologists, search and rescue. Granting GCSC's request for exemption will reduce currentrisk levels and thereby enhance safety.

Further, GCSC operates at lower altitudes and in controlled airspace. GCSC has beenpartnering with Embry Riddle Aeronautical University (ERAU) and the Association ofUnmanned Vehicle Systems International (AUVSI) in compiling safety protocols and the implementation ofa flight operational procedures and training that exceeds currently accepted means and methods ofsafe flight for these vehicles. There are no people onboard GCSC UAS's and therefore the likelihood ofdeath or serious bodily injury is significantly limited. GCSC's operation ofits UAS's, weighting less than 55 pounds and traveling at speeds lower than 50 knots, in defined areas will provide at least an equivalent level ofsafety as that achieved under current FARs.GCSC respectfully requests that the FAA grant its exemptionrequest without delay. The FAA has the authority to issue the exemption sought by GCSC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

# ~'

# u\~a~ Loretta Costin, Dean Occupation Education GulfCoast State College

LBC/cmg