U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

RE: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.P.R. Part 11 

Dear Sir or Madam, 

Gulf Coast State College (GCSC), a nonprofit educational institution located at 5230 W. Hwy 

98, Panama City, Florida 32401, and Pursuant to 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 FAA to determine: 

1. If certain unmanned aircraft systems, if any, as a result oftheir size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

visual line of sight do not create a hazard to users of the national airspace system or the 

public or pose a threat to national security; and 

2. Whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 oftitle 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1) 

We are requesting GCSC, an owner and operator of small 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 on its own behalf and 

on behalf of other research groups in airspace regulated by the Federal Aviation Administration 

(FAA) as 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. We seek approval ofthis 

petition in alignment with your consideration of a similar exemption granted to Franklin W. Olin 

College of Engineering. GCSC has been actively involved in the curricular and technical 

development of autonomous and unmanned systems to address current regional and national 

problems and develop applications for the scientific and research communities; in particular rip-
tide detection, coastal ecology, defense systems, and other autonomy and physical science 

communities. GCSC has a growing number of small commercial UAS/UAV platforms, and 

projects a small number of small fixed wing UAV platforms. Representative vehicles are: 

Typhoon Q500 

DJI Inspire 

Parrot AR Drone 

Trimble UX5 

Wingspan: 565 mm 

Weight: 1,100 grams 

Dimensions: 

565 x 420 x 240 mm 

Body Material: 

Carbon Fiber 

Rotor Material: 

Carbon Fiber 

Wingspan: 559 mm 

Weight: 2,93 5 grams 

Dimensions: 

438 x 451 x 301 mm 

Body Material: 

Carbon Fiber 

Rotor Material: 

Carbon Fiber 

Wingspan: 731 mm 

Weight: 420 grams 

Dimensions: 

517 x 517 x 127 mm 

Body Material: 

Carbon Fiber 

Rotor Material: 

Plastic 

Wingspan: 100 em 

Weight: 5.5 lbs 

Dimensions: 

100 x 65 x 10.5 em 

Body Material: 

EPP foam & carbon 

Propulsion: 

Brushless Motor 
applications ofUVS technology to support agriculture, particularly peanut, cotton, and citrus 

across the state of Florida. Research operations of small unmanned aerial systems will be strictly 

supervised by trained GCSC faculty and staff, and in partnership with qualified operators in area 

defense and agriculture industry sectors where such partnerships merit engagement and meet the 

safety and operational guidelines of the 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 how to operate unmanned systems (aerial, surface, and subsurface) in a manner 

consistent with the developing college and AUVSI safety standards. GCSC's exemption request 

would permit its operation of lightweight, unmanned (remotely controlled in line of sight) UAS's 

in tightly controlled and limited airspace, specifically over GCSC College property and with 

written permission of owners, over local farms, woodlands, and coastal areas where applicable. 

None of said properties are within 5 miles of any airport. Each application requiring flight will 

be preceded by a predetermined, specifically marked, area(s) of operation in strict compliance 

with FAA regulations. 

Granting GCSC's request comports with the 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 of such aircraft systems [UAS's] in the national airspace 

system" under Section 333 of the Reform Act. Further, GCSC will conduct its operations in 

compliance with the protocols described herein or as otherwise established by the FAA. 

The Extent of Relief GCSC Seeks and the Reason It Seeks Such Relief: 

GCSC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FAR's operating to prevent GCSC contemplated 

research and other flight operations within the national airspace system. The Reform Act in 

Section 332 provides for such integration of civil unmanned aircraft systems into our national 

airspace system as it is in the public's interest to do so, therefore aligning with the overall 

mission of the college. GCSC lightweight UAS's meet the definition of "small unmanned 

aircraft" as defined in Section 331 and therefore the integration of GCSC lightweight UAS's are 

expressly contemplated by the Reform Act. GCSC would like to operate its lightweight UAS's 

prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft. The Reform Act guides the Secretary in determining the types ofUAS's 
The FAA has the authority to issue the exemption to GCSC pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting GCSC 

exemption request furthers the public interest. First, Congress has already pronounced that it is in 

the public's interest to integrate commercially flown UAS's into the national airspace system, 

hence the passing of the Reform Act. Second, GCSC conducts research into safe UAS operations 

every time it flies one of its UAS's. Flight data, visual inspections, recorded observations and 

flight analyses are compiled and analyzed as a part of the research effort to further enhance 

current safety protocols. 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 of systems and solutions capable of supplying mission data to US 

Government agencies, including our partnership with the local NA VSEA (Naval Sea Systems 

Command) Warfare Center. Allowing GCSC to conduct these flights will assist in furthering the 

research efforts and lies clearly in the common interest of national defense capabilities. 

Granting GCSC's exemption request substantially furthers the public's interest in ways known 

and currently unknown. Permitting GCSC to immediately fly within the United States furthers 

advancements in publicly usable technologies or advancements in equipment available to law 

enforcement personnel, the military, and first responders with state of the art equipment that has 

the virtue of being cheaply and quickly available. 

Reasons Why GCSC's Exemption Will Not Adversely Affect Safety or How The 

Exemption Will Provide a Level of Safety 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 implement new and continue to develop and refine safety 

protocols. To that end, GCSC agrees to operate through this 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 below 400 feet. 

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

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

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

• GCSC remote control pilots have a second spotter (as part of our CRM implementation), 

plus waypoint return and/or geo-fencing software should loss of sight ofUAS occur. 
• GCSC staffs each flight with a remote control pilot and camera operator and, if the 

testing team is all-student, a faculty supervisor. 

• GCSC UAS's have GPS flight modes whereby they return to home (failsafe) if 

communication with the pilot is lost, battery power is below 25% or the vehicle leaves 

the pre-determined flight area. 

• GCSC actively analyses electronic flight data and other sources of information to 

constantly update and enhance safety protocols. 

• GCSC only operates in secured areas that are strictly controlled, are away from airports 

and populated areas and have written permission from the property owner where 

applicable. 

• GCSC conducts extensive briefings prior to and after each flight, during which safety 

carries primary importance. 

• GCSC always obtains all necessary permissions and permits prior to operation. 

• GCSC ensures that all staff and related personnel operating UASs have successfully 

completed the UVS safety training in development with ERAU and the Unmanned Safety 

Institute. 

Summary the FAA may publish in the 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 in relation 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 of safety pursuant to Section 3 3 3 ofthe Reform Act. The FAA 

is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act 

(49 U.S. C.§ 44701 (f)) and A. Section 333 of the Reform Act. Both pieces oflegislation permit 

the FAA to exempt U AS's from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. GCSC's UAS's meet or exceed each of the elements. 14 C.P.R. 91.7 (a) prohibits 

the operation of an aircraft without an airworthiness certificate. As no such certificate will be 

applicable in the form contemplated by the F ARs, this Regulation is inapplicable. 14 C.F .R. § 

91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, 

and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining a manual at the flight operations center. The FAA has 
previously issued exemptions to this regulation in Exemption Nos. 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 of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety 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 of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. GCSC's UAS's are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain 

words or phrases. 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. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. GCSC can achieve an 

equivalent level of safety 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 of an Academy of Model 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 in the 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 of civil aircraft. It allows 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 off areas with security perimeters, providing a level of 

safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed ofGCSC's UAS's, an equivalent level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The 
above-cited Regulations require, amongst other things, aircraft owners and operators to "have 

[the] aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph C of this section, have discrepancies repaired as 

prescribed in part 43 of this 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 of any damaged 

hardware. All of GCSC UVS inventory is managed and maintained strictly by the college. 

Therefore, an equivalent level of safety will be achieved. GCSC is using currently manufactured 

UAS's for its research which have been produced in significant numbers, which also allows 

GCSC to avail itself of the higher reliability and expertise of the vehicle manufacturers which 

will further help in keeping 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 of small unmanned hovering and 

lightweight unmanned fixed-wing aircraft and to conduct its own research and to supply data to 

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 current risk 

levels and thereby enhance safety. 

Further, GCSC operates at lower altitudes and in controlled airspace. GCSC has been partnering 

with Embry Riddle Aeronautical University (ERAU) and the Association of Unmanned Vehicle 

Systems International (AUVSI) in compiling safety protocols and the implementation of a flight 

operational procedures and training that exceeds currently accepted means and methods of safe 

flight for these vehicles. There are no people on board GCSC UAS's and therefore the likelihood 

of death or serious bodily injury is significantly limited. GCSC's operation of its 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 of safety as that achieved under current F ARs. 
GCSC respectfully requests that the FAA grant its exemption request without delay. The FAA 

has the authority to issue the exemption sought by GCSC pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act"). 

~' 

u\~a~ Loretta Costin, Dean 

Occupation Education 

Gulf Coast State College 

LBC/cmg