April 8, 2015

 Exemption No. 11301

 Regulatory Docket No. FAA−2014−1024

Mr. Clayton L. Mounger

Gulf Coast Unmanned Aerial Services, LLC

4490 Blanche Noyes

Baton Rouge Metropolitan Airport

Baton Rouge, LA 70807

Dear Mr. Mounger:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated December 8, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Gulf Coast Unmanned Aerial Services, LLC (hereinafter petitioner or operator) 

for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft 

system (UAS) to conduct aerial photography and videography for agricultural inspections and 

flight training.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA determined that good cause exists for not publishing a summary of the petition in 

the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, the FAA 

received one comment opposing the petition. In granting this exemption, the FAA has 

determined that the proposed operations can safely be conducted under the conditions and 

limitations of this exemption. As with exemptions issued to Aeryon Lab, Astraeus Aerial, 
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Clayco, Inc., and VDOS Global, LLC, failure to comply with the document’s conditions and 

limitations is grounds for immediate suspension or rescission of the exemption.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom and DJI Inspire.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption No. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Lab, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Gulf Coast Unmanned Aerial Services, LLC is granted 

an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 
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91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Gulf Coast Unmanned Aerial Services, LLC is hereafter referred 

to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom and 

DJI Inspire 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. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

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

exemption holder may 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.

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

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

5. The UA must 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.

6. All operations must utilize a visual observer (VO). The UA must 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 is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 
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exemption, are hereinafter referred to as the operating documents. The operating 

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

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

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

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

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

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator 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. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must 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 is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
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government. The PIC must 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.

14. The operator may 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 will be 

operated under this 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 this exemption are permitted under the terms of this exemption. However, 

training operations may 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 must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may 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 FAApublished 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 must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is 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.

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

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must 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 must be 

as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must 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.

27. 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.

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

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

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service
1 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

December 8, 2014

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: 

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 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 Inspection and sUAS Aircraft Flight Training hereby applies for an 

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.

The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS may 

operate safely in the national airspace system (NAS) before completion of the FAA’s plan and 

rulemaking to integrate sUAS into the NAS. The Reform Act directs the Secretary to consider which 

types of sUAS as a result of their 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 or a threat to national security. If the Secretary determines that such vehicles may operate safely 

in the NAS, the Secretary “shall establish requirements for the safe operation of such aircraft.”

The granting of this exemption request will provide immediate benefit to both the agricultural and aircraft 

flight training industries by authorizing highly controlled sUAS operations within Class G airspace, at or 

below 400 feet above ground level (AGL), in line of sight of an FAA Certificated Private Pilot during 

daylight hours and above controlled privately owned and operated property.

GCUAS’s sUAS shall weigh less than 10 pounds including the payload. They will operate at no more 

than 50 knots and have the capability to hover, and move vertically and horizontally simultaneously.
2 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

Operations would be conducted above privately owned and operated properties, with the consent of the 

owner/operator. GCUAS operations will be performed by professional pilots; this will insure that the 

sUAS will “not create a hazard to users of the national airspace system or the public.”

The grant of this exemption request is in the public interest, does not create a hazard to users of the NAS 

or the public, or pose a threat to national security. 

In the following pages GCUAS addresses all areas of concern to include;

 Equivalent levels of safety

 Exemptions requested

The name and address of the applicant is:

Gulf Coast Unmanned Aerial Services, LLC (GCUAS)

Attention: Clayton L. Mounger

Phone: (989) 859-6737

Email: info@gulfcoastuas.com

Address: 4490 Blanche Noyes

Baton Rouge Metropolitan Airport

Baton Rouge, LA 70807

GCUAS appreciates your consideration in this matter.

Best Regards,

Clayton L. Mounger 

Clayton L. Mounger

President

Gulf Coast Unmanned Aerial Services

Included in this Exemption Letter - Exhibit A

 Regulations for which exemptions are requested

To follow this Exemption Letter and/or on request:

 GCUAS Operating Manual

 GCUAS Aircraft Inspection Program

 GCUAS Training Syllabus

 GCUAS Civil COA

 Aircraft Manufacturer’s Users Guide’s
3 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

Agricultural Inspection by sUAS serves the Public Interest

 SUAS inspection is of higher quality, more reliable, and can be reviewed in real time. 

SUAS inspections allow for the collection, dissemination and permanent storage of 

photos and videos of agricultural inspections.

 SUAS inspection is more efficient and less costly.

 SUAS inspection is safer than traditional manned commercial aircraft. SUAS’s are less 

likely to cause damage to property or life in the event of an accident.

Professional Flight Training by sUAS serves the Public Interest

 SUAS integration into the NAS without proper flight training is inherently dangerous.

 SUAS pilot flight training and experience can only be obtained as a “hobbyist.” There is 

no professional mechanism where FAA pilots can receive sUAS aircraft flight training 

and compensation within the United States under the current rules and regulations.

 Providing an avenue of professional flight training for sUAS aircraft in a controlled 

environment, by professional flight instructors is crucial to the safe integration of sUAS

into the NAS.

 Training in rural areas, within Class G airspace, at or below 400 feet AGL, away from 

any non-participating personnel provides for an increased level of safety.

Gulf Coast Unmanned Aerial Services (GSUAS, LLC.)

 Gulf Coast Unmanned Aerial Services is led by Clayton L. Mounger a graduate of 

Louisiana State University. The GCUAS’s team has extensive experience in the areas of 

Agriculture and Aircraft Flight Training. 

 The GCUAS team’s expertise consists of two Airline Transport Pilots, one Commercial 

Pilot, a Certified Flight Instructor, an Aeronautical Engineer, greater than 30,000 flight 

hours, and 35 years of aviation management experience.

 GCUAS has extensive knowledge and experience in Commercial Aviation and Remote 

Controlled (RC) aircraft operations.

 GCUAS sUAS are outfitted for aerial photography and videography for use in Agricultural 

Inspection and sUAS Aircraft Flight Training.
4 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

GCUAS Experience

As professional pilots, GCUAS understands safety is paramount and will always hold Safety 

ahead of any commercial endeavor.

 Individuals within GCUAS have only operated sUAS as hobbyists. To date, GCUAS

members have not engaged in any commercial activity to ensure it is in compliance 

with any applicable FARs or local, state, and federal laws.

 GCUAS has a detailed sUAS Operating Manual which includes a Safety 

Management System (SMS), Aircraft Inspection Program and Training Syllabus that 

it shall follow, should this exemption be approved.

GCUAS sUAS Description

GCUAS intendeds to operate DJI sUAS multirotor aircraft for the purpose of obtaining 

photographs and video for agricultural inspection and sUAS aircraft flight training. 

These aircraft have fail safe features to include geo fencing and lost link return home

capability. DJI is the manufacturer of multirotors weighing less than 25 pounds and has 

developed technology that will enhance safe sUAS operations within the NAS.

DJI Phantom

Model Phantom

Weight (Battery Included) 1242 g 43.8 ounces

2.7 pounds

Hovering Accuracy Vertical: 0.5 m 1.6 feet

Horizontal: 2.5 m 8.2 feet

Max Angular Velocity Yaw: 200°/s

Max Tilt Angle 35°

Max Ascent Speed 6 m/s 19.7 feet/s

Max Descent Speed 2 m/s 6.7 feet/s

Max Speed 22 m/s 49.2 feet/s

Max Flight Time 25 minutes

Operating Temperature Range -10° to 40° C

Dimensions 350x350 mm 14x14 inches
5 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

DJI Inspire

Model T600

Weight (Battery Included) 2935 g 103.5 ounces

6.5 pounds

Hovering Accuracy Vertical: 0.5 m 1.6 feet

Horizontal: 2.5 m 8.2 feet

Max Angular Velocity Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s 16.4 feet/s

Max Descent Speed 4 m/s 13.1 feet/s

Max Speed 22 m/s 72.2 feet/s

Max Flight Time 18 minutes

Operating Temperature Range -10° to 40° C

Dimensions 438x451x301 mm 18x18x12 inches

Aircraft and an Equivalent Level of Safety

GCUAS proposes that the exemption requested applies to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or higher level of safety to operations under 

the current regulatory structure because the proposed operations represent a safety enhancement 

to the already safe operations conducted with conventional aircraft.

This Exemption Request is for Use of sUAS subject to Extensive 

Operational and Safety Requirements

These limitations and conditions to which GCUAS agrees to be bound when conducting 

commercial operations under an FAA issued exemption at a minimum include:

Safety

A. The sUAS Pilot in Command (PIC) shall possess at a minimum, a private pilot 

certificate and current third-class medical certificate.

i. 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 their pilot 

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

ii. The PIC shall be trained in the operation of the specific make and model 

of the sUAS being piloted and successfully completed all training 

required.

iii. The PIC shall have accumulated and logged, in a manner consistent with 

14 CFR §61.51 (b), a minimum of 200 flight cycles and 25 hours of total 

time as a sUAS rotorcraft pilot and at least five hours logged as a sUAS 

pilot with a similar sUAS type (multirotor or helicopter). Prior 

documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement.

iv. The PIC shall have accumulated and logged, in a manner consistent with 

14 CFR §61.51 (b), a minimum of five hours as sUAS pilot operating the 

make and model of sUAS to be utilized for operations under the 

exemption and three take-offs and three landings in the preceding 90 days.

v. Training, proficiency, and experience-building flights can also be 

conducted under this grant of exemption to accomplish the required flight 

cycles and flight time.

1. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC must operate the sUAS with appropriate 

distance from non-participants in accordance with 14 CFR 

§91.119.

B. The sUAS Safety Observer (SO) shall meet all training requirements and be 

responsible for all of his/her duties as set forth by GCUAS sUAS Operating 

Manual. 

C. The PIC and SO will be designated before each flight

i. Minimum crew for each flight operation will consist of the sUAS PIC and

SO.

D. The PIC and SO shall always be within visual line of sight (VLOS) of each other 

and in direct verbal communication at all times.

E. Safety Briefings shall be conducted before each day’s activities to include, but not 

limited to:

i. Designated roles of PIC and SO

ii. Risk Management and Mitigation
7 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

SUAS Specifications and Design:

A. All sUAS flown under this exemption shall be less than 10 pounds including 

aircraft and payload. This exemption requests permission only with respect to the 

specific use of the DJI Phantom and Inspire, which weigh less than 10 pounds 

including payload.

B. The radio frequency spectrum used for operation and control of the sUAS shall 

comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements.

C. Maximum speed shall be less than 50 knots.

D. The sUAS shall be equipped with Inertial Navigation Sensor(s) and Gyroscopes

(IRS/IRU/Accelerometer/MEMS Gyroscopes).

E. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source).

F. The sUAS shall be equipped with a Global Positioning System (GPS) guidance 

system.

G. The sUAS shall be designed, should it lose communications or lose its GPS 

signal, to return to a pre-determined location within the Operations Area and land 

or be recovered in accordance with GCUAS’s sUAS Operating Manual.

SUAS Maintenance

A. SUAS shall be maintained in accordance with the manufacturer’s 

recommendations and GCUAS sUAS Operating Manual and Inspection Program.

B. GCUAS will document and maintain a record of the sUAS maintenance, preventative 

maintenance, alterations, and status of replacement, overhaul component parts, and 

the total time in service of the sUAS. These records will be maintained at the 

principle base for operation for the life of the aircraft or as required by Federal 

Aviation Regulations. See GCUAS sUAS Operating Manual and Inspection 

Program.

C. GCUAS shall comply with all manufacturer Safety / Service Bulletins or equivalent 

pertaining to the sUAS aircraft.

D. The PIC shall perform a preflight inspection of the sUAS, controller, and ground 

control station prior to each flight to ensure it is operational with no discrepancies.

If the preflight inspection reveals discrepancies, repairs or maintenance shall be 

performed prior to flight. The sUAS will only be operated if all systems are 

operating per manufacture’s specifications an in a discrepancies free condition.
8 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

E. Maintenance or repairs that may affect the sUAS operation or flight 

characteristics shall undergo a functional test flight when required in accordance 

with manufactures recommendations and GCUAS’s sUAS Operating Manual. 

This functional test flight shall be recorded in the sUAS’s records. If the 

functional test flight is completed successfully, the sUAS can be returned to 

service by the PIC.

F. GCUAS shall follow the manufacturer’s sUAS maintenance, overhaul, 

replacement, inspection, and life limit requirements. When not provided by the 

manufacturer aircraft maintenance, component, overhaul, replacement, and 

inspection maintenance requirements shall be established and included in 

GCUAS’s sUAS Operating Manual and Inspection Program. 

i. At a minimum the following will be meet: 

1. Actuators / Servos 

2. Powerplant(s) (motors) 

3. Propellers 

4. Electronic speed controller(s)

5. Batteries 

6. Remote controllers and Ground control station

G. All sUAS shall be identified by serial number, registered in accordance with 14 CFR 

Part 47, and have identification (N-Number) markings in accordance with 14 CFR 

Part 45, Subpart C, except with respect to the size of the markings. Markings shall be 

as large as practicable. 

Permissions and Permitting 

A. All required permissions and permits shall be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, or other appropriate

governmental agencies.

B. At least three days before a scheduled operational flight, GCUAS shall submit a 

written plan of activities to the local flight standards district office (FSDO) with 

jurisdiction over the area of the proposed flight. The 3-day notification may be 

waived with the concurrence of the FSDO.

i. The plan of activities shall include at least the following:

1. Dates and times for all requested flights 

2. Name and phone number of GCUAS sUAS Flight Operations 

3. Name, certificate, phone number of the PIC responsible 

4. Make, model, and serial and N-number of sUAS to be used 
9 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

5. Statement from GCUAS that it will be operating on approved 

privately owned and operated property; the list of those who gave 

permission shall be made available to the inspector upon request. 

6. Description of the flight activity, including maps or diagrams of 

any area over which flights will be conducted, the relationship of 

that area to any nearby city, town, etc., and the altitudes essential 

to accomplish the operation

7. Signature of exemption-holder or representative 

C. Documents required under 14 CFR §91.9 and §91.203 shall be readily available to 

the PIC any time the aircraft is in operation. These documents shall be made 

available to the Administrator or any law enforcement official upon request.

D. GCUAS shall obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this 

grant of exemption.

E. GCUAS shall also request a Notice to Airman (NOTAM) not more than 72 hours 

in advance, but not less than 48 hours prior to the operation.

F. GCUAS shall obtain the consent of all persons involved in the operation and 

ensure that only consenting persons be allowed within 500 feet of the Operations 

Area.

Operations

A. The sUAS shall not operate within 5 nautical miles of the geographic center of 

any airport as denoted on the current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management is obtained, and the operation 

is conducted in accordance with a NOTAM as required by the operator’s COA. 

This letter of agreement with the airport management shall be made available to 

the Administrator upon request.

B. The sUAS will only operate within the lateral boundaries of approved privately 

owned and operated property. An Operations Area within those boundaries will 

be established for each flight. These areas will be free of unnecessary hazards or 

risks and non-participating personnel.

i. The sUAS shall only operate within a pre-defined Operations Area that 

shall be thoroughly inspected by the PIC for buildings, overhangs, 

obstacles, wires, poles, people, vehicles, sun angle, shadows, glare, 

reflective surfaces, clouds, smoke, and terrain among other potential 

hazards.
10 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

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

i. In addition, the sUAS 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.

ii. SUAS operations shall not be conducted during night, as defined in 14 CFR 

§1.1. 

iii. Flights shall not be conducted under special visual flight rules (SVFR).

D. Flights shall be operated at an altitude at or below 400 feet AGL, as indicated by 

the procedures specified in GCUAS’s sUAS Operating Manual.

E. The PIC shall be prohibited from operating the sUAS from any moving device or 

vehicle.

F. The sUAS shall be operated within VLOS of the PIC.

i. The PIC shall maintain VLOS without the aid of telescopes, cameras or 

other devices.

ii. The PIC will maintain VLOS with their own vision, which includes the 

use of eyeglasses or corrective lenses as specified on the PIC’s medical 

certificate.

G. The sUAS shall remain clear and yield the right of way to manned operations and 

activities at all times including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc. 

H. GCUAS will require the PIC and SO to have successfully completed a 

qualification process which will include ground and flight training, as outlined in 

the GCUAS sUAS Operating Manual.

I. The PIC’s primary responsibility while in flight is the safe operation of the sUAS.

SUAS Flight Time and Flight Durations

A. DJI Phantom operations shall be completed within 25 minutes flight time or with 

25% battery power remaining whichever occurs first.

B. DJI Inspire operations shall be completed within 18 minutes flight time or with 25% 

battery power remaining whichever occurs first.
11 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

Exhibit A

Regulations for Which Exemptions are Requested

Unless otherwise requesting an exemption, GCUAS, the PIC, the SO, and the sUAS shall comply 

with all applicable parts of 14 CFR including, but not limited to, Parts 45, 47, 61, and 91.

GCUAS is requesting exemptions from the following Federal Aviation Regulations to the extent 

necessary to enable the requested sUAS operations for the reasons detailed below.

Relief sought from 14 CFR GCUAS Statement

21 Stated Below

61.113(a) and (b) Stated Below

91.103 Stated Below

91.119(c) Stated Below

91.121 Stated Below

91.151(a)(1) Stated Below

91.405(a) Stated Below

91.407(a)(1) Stated Below

91.409(a)(1) and (2) Stated Below

91.417(a) and (b) Stated Below

14 CFR 21 – Requirements to Secure Airworthiness Certificates

1. Certificate exemptions should be given because size, weight, and operation areas of the 

sUAS meet the level of safety necessary for exemption under Section 333 of the Reform 

Act.

2. FAA has the authority to exempt aircraft from airworthiness certificate requirements 

under the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act.

14 CFR 61.113 (a) and (b) – Private Pilot Privileges and Limitations; Pilot in Command

1. Due to the fact that there are no standards for private or commercial sUAS operations, 

GCUAS requests to utilize at least private pilots with a third class medical in support of 

its own operations.

2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along 

with the ability to physically manipulate the controls of the sUAS are the critical aspects 

of the requested operation. GCUAS feels this can be accomplished by a private pilot that 

has specific training on the sUAS aircraft and operates in accordance with the GCUAS

sUAS Operating Manual, Federal Aviation Regulations, local, state and federal laws.
12 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

3. The risks associated with the operation of a sUAS are so diminished from the level of risk 

associated with commercial aviation operations contemplated by Part 61 when drafted, 

that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds 

the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

4. Equivalent or better safety levels will be achieved as there will be no human beings on 

board the sUAS aircraft. 

5. FAA has authority to waive pilot requirements for commercial operations under 49 U.S.C 

§44701(f).

14 CFR 91.103 – Preflight Action

1. The PIC shall perform a preflight inspection in accordance with the manufacturer’s

recommendations and the GCUAS sUAS Operating Manual of the controller, ground 

control station and associated equipment prior to each flight to ensure it is free of all 

discrepancies.

2. Equivalent safety levels will be met through preparation and compliance according to 

GCUAS’s sUAS Operating Manual; including but not limited to, weather reports,

forecasts, wind, temperature, battery requirements and other information, relating to 

aircraft performance, gross weight, shall be considered.

14 CFR 91.119(c) – Requirements for Minimum Safe Altitudes for Civil Aircraft Operation

1. The sUAS will be operated at or below 400 feet AGL.

2. GCUAS shall obtain the consent of all persons involved in the operation and ensure that 

only consenting persons be allowed within 500 feet of the Operations Area.

3. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel.

4. Given the size, weight, speed, material, and operation of the sUAS aircraft, equivalent 

levels of safety will be achieved.
13 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

14 CFR 91.121 – Altimeter Settings

1. SUAS will not have a barometric altimeter, and may use a GPS altitude read out 

indication instead, so an exemption may be needed.

2. An equivalent level of safety will be achieved by the operator as the sUAS uses AGL height 

from its initialization/takeoff point.

14 CFR 91.151 (a) (1) – Fuel Requirements for Flights in VFR Conditions

1. The FAA has previously issued exemptions for fuel requirements in VFR conditions 

including Exemptions 2689F, 5745, 10673, and 10808.

2. GCUAS feels an equivalent level of safety can be obtained by terminating the flight prior 

to the following.

Aircraft Fuel (Battery) Requirements

DJI Phantom - 25 minutes or 25% whichever occurs first which allows for 6.2 minutes reserve

DJI Inspire - 18 minutes or 25% whichever occurs first which allows for 4.5 minutes reserve

1. The DJI Phantom and Inspire have a second level of safety that is achieved through the 

use of an aircraft battery monitoring system. The aircraft system will alert the operator of 

low battery voltage and return the aircraft to its take off location before battery capacity 

is depleted. 

2. GCUAS will not operate sUAS at night in accordance with 14 CFR 1.1

3. An equivalent level of safety will be achieved because these sUAS are limited in size, 

operational purposes of the sUAS, and shall only fly above approved privately owned and 

operated property at or below 400 feet AGL, it does not bear the same risks associated 

with this section’s requirements.

14 CFR 91.405 (a) – Maintenance Required

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply.

In the absence of regulatory provisions dealing with sUAS operation for maintenance required.

See GCUAS sUAS Operating Manual, Inspection Program and Manufactures Maintenance 

Recommendations for maintenance required.

1. Maintenance will be accomplished by GCUAS pursuant to the manufacturer’s 

recommendations and GCUAS’s sUAS Operating Manual and Inspection Program.
14 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only.

3. The GCUAS sUAS Operating Manual and Inspection Program details how to enter 

worked preformed in the maintenance log for scheduled, unscheduled maintenance or 

functional test flights that are performed.

4. GCUAS shall only operate its sUAS with all systems functioning per manufactures 

specification in a discrepancy free condition.

5. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

GCUAS and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. This maintenance process allows for an 

equivalent level of safety to be achieved due to the limited size, scope and area of operations. 

14 CFR 91.407 (a) (1) – Operation after Maintenance, Preventive Maintenance, Rebuilding 

or Alteration

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply.

 

In the absence of regulatory provisions dealing with sUAS operation after maintenance, 

preventive maintenance, rebuilding, alteration or functional test flights, GCUAS has developed 

requirements to address these topics. See GCUAS sUAS Operating Manual, Inspection Program

and Manufactures User Guides.

1. Maintenance will be accomplished by GCUAS pursuant to the manufacturer’s 

recommendations and GCUAS’s sUAS Operating Manual and Inspection Program.

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only.

3. Functional test flights will be performed by the PIC when required, the sUAS shall only

be returned to service when this functional test flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the Operations 

Area.

4. The GCUAS sUAS Operating Manual details how to enter in the maintenance log 

scheduled and unscheduled maintenance or functional test flights that are performed.

5. GCUAS shall only operate its sUAS with all systems functioning per manufactures 

specification in a discrepancy free condition.
15 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

GCUAS and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance procedures allow for 

an equivalent level of safety to be achieved due to the limited size, scope and area of operations.

14 CFR 91.409 (a) (1) and (2) – Inspections

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply. 

In the absence of regulatory provisions dealing with sUAS inspections, GCUAS has developed 

requirements to address this topic. See GCUAS sUAS Operating Manual, Inspection Program

and the Manufactures User Guides.

1. Maintenance will be accomplished by GCUAS pursuant to the manufacturer’s 

recommendations and GCUAS’s sUAS Operating Manual and Inspection Program.

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only.

3. The GCUAS sUAS Operating Manual details how to enter into the maintenance log all 

inspections that are performed.

4. Functional test flight will be performed by the PIC when required after inspections, the 

sUAS shall be returned to service when the flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the Operations 

Area.

5. GCUAS shall only operate its sUAS with all systems functioning per manufactures 

specification in a discrepancy free condition.

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

GCUAS and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance inspections allow for 

an equivalent level of safety to be achieved due to the limited size, scope and area of operations. 
16 Gulf Coast Unmanned Aerial Services – 4490 Blanche Noyes, Baton Rouge, LA 70807

14 CFR 91.417(a) and (b) – Maintenance Records

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply. 

In the absence of regulatory provisions dealing with sUAS maintenance records, GCUAS has 

developed requirements to address this topic. See GCUAS sUAS Operating Manual and 

Inspection Program.

1. Maintenance will be accomplished by GCUAS pursuant to the manufacturer’s 

recommendations and GCUAS’s sUAS Operating Manual.

2. Maintenance, preventive maintenance, rebuilding, and alteration maintenance recording 

keeping will be performed by trained personnel and entered in the respective aircraft 

maintenance log at completion of each event. The GCUAS sUAS Operating Manual

details how entries are to be made in the aircraft maintenance log for scheduled and 

unscheduled maintenance or functional test flights that are performed.

3. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

GCUAS and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition. These maintenance records allow for an 

equivalent level of safety to be achieved due to the limited size, scope and area of operations.