Joshua	Gunsett	

Gunsett	Tech	Solutions LLC

1881	Hillview	Ct

Xenia,	OH	45385

Phone:	(937)	736-0018

Website:	www.gunsettTech.com

January	4th,	2016

U.S.	Department	of	Transportation,	Docket	Operations

West	Building	Ground	Floor,	Room	W12-140

1200	New	Jersey	Ave,	SE

Washington,	DC	20590

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of2012	(the	Reform	Act)	

and	14	C.F.R.	Part	11,	Gunsett	Tech	Solutions herein	after	also	known	as	the	operator,	is	an	

operator	of	small	Unmanned	Aircraft	Systems	(UAS).	Gunsett	Tech	Solutions requests	these	

exemptions	in	order	to	pursue	UAS	applications	in	the	following	areas:

• Real	estate	and	marketing

• Educational	and	research	operations

• Aerial surveying,	mapping	and	data	collection

• Aerial	imagery	evidence	for	property	insurance	claims

• Remote	sensing

• Wildlife	and	forestry	monitoring

• Aid	in	disaster	and	emergency	management	and	monitoring,	civil	first	response,

• communications	relay,	search	and	rescue,	monitoring	fire	hazards,	cleanup	effort

• supervision,	damage	assessment	and	estimation

• Aid	civil	engineering:	waterways	and	shipping,	forestry,	fishery	protection,	pollution

• control	and	air	sampling	and	crop	performance

• Railroad	and	motor	vehicle	road	inspection

• Telecommunications	infrastructure	inspection

• Utility,	Energy	systems	and	electrical	engineering	inspections	and	asset	

management

• Agricultural	surveying	and	produce	field	management

• Livestock	management	and	accountability

• Construction	site	inspections	and	monitoring

• Oil	and	gas	pipeline	inspection/patrolling	and	oil-field	inspection

• Aerial	event	security,	surveillance	and	crowd	management

• Structure	Inspection

• Training	to	persons	individually	or	belonging	to	both	private	and/or	public	

organizations	to	increase	awareness	and	improve	safety	for	current	and	future	UAS	

operations	within	the	NAS.	
Regulations	from	which	exemption	is	requested:

 14	C.F.R.	Part	21

 14	C.F.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.	91.109

 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)	&	(b)

 14	C.F.R.	91.205(b)

 14	C.F.R.	91.215

 14	C.F.R.	91.401	– 91.417

Gunsett	Tech	Solutions	LLC	hereby	applies	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations	(FARs)	to	allow	commercial	operation	of	their	U	A,	with	full	

understanding	that	operations	are	conducted	within	and	under	the	conditions	outlined	

herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333.	As	described	more	

fully	below,	the	requested	exemption	would	permit	the	operation	of	small,	unmanned	and	

relatively	inexpensive	UAS	under	controlled	conditions	in	the	National	Airspace	System	

(NAS)	regulated	by	the	Federal	Aviation	Administration	(FAA).

Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of

Transportation's	(the	FAA	Administrator's)	responsibilities	to	“... establish	requirements	

for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace	system."	Section	

333(c)	of	the Reform	Act.

The	name	and	address	of	the	applicant	is:

Gunsett	Tech	Solutions	LLC

Attn:	Josh	Gunsett

1881	Hillview	Ct

Xenia,	OH	45385

Phone:	(937)	736-0018

Email:	josh@gunsettTech.com

As	 described	 fully	 below,	 the	 requested	 exemption	 would	 permit	 the	 operation	 of	

designated	UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	that	

would	be	a) limited	b)	controlled	c)	predetermined	and	d)	safe.	Approval	of	this	exemption	

would	increase	public	awareness	of	UAS	operations	and	enhance	safety	to	aid	in	fulfilling	

the	Secretary	 of	Transportation’s	(the	 FAA	Administrator’s)	 responsibilities	to	“establish	

requirements	 for the	 safe	 operation	 of	 such	 aircraft	 systems	 in	 the	 national	 airspace	

system.”	 Gunsett	Tech	Solutions	request	that the	current	exemption	include	the	following	

aircraft.	 	 All	 of	 these	 aircraft	 have	 been	 granted	 333	 exemptions	 by	 the	 FAA	 to	 other	

companies.	All	aircraft	are	under	55	lbs.	Gunsett	Tech	Solutions plan	to	operate	a	UAS,	the	
DJI	 PHANTOM	 3	 Professional,	 3D	 Robotics	 Solo,	 Sensefly	 Ebee,	 Yuneec	 Q500, DJI	 S900,	

DJIS1000 and	DJI	Inspire.		Also,	given	the	small	size	of	the	UAS’s	involved	and	the	restricted

controlled	environment	within	which	they	will	operate,	the	applicant	fits	within	that	zone	

of	safety	(an	equivalent	level	of	safety)	in which	Congress	envisioned	that	the	FAA	must,	by	

exemption,	 allow	 commercial	operations	of	UASs to	 commence	immediately.	Also	 due	to	

the	 size	 of	 the	 UASs	 and	 the	 controlled	 areas	 in	 which the	 relevant	 UASs	 will	 operate,	

approval	 of the	 application presents	 no	 national	 security	 issue.	 Given	 the	 following,	 the	

grant	of	the	requested	exemptions	is	clearly	in	the	public	interest:	

Gunsett	Tech	Solutions proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	

that	have	the	characteristics and	that	operate	with	the	limitations	listed	herein.	These	

limitations	provide	for	an	exceptional level	of	safety	to	operations.	These	limitations	and	

conditions	to	which	Gunsett	Tech	Solutions	agrees	to	be	bound	when	conducting	

commercial	operations under	an	FAA	issued	exemption	including:	

1. The	UAS	will	weigh	less	than	55	lbs.	

2. Flights	will	be	operated	within	line	of	sight	of	operator.	

3. Flights	will	be	terminated	at	15%	battery	power	reserve.	

4. Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	

5. UAS	operator	will	be	trained	and	certified	in	the	proper	safety	and	operations	of	the	

UAS.	

6. The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	Procedures.	

7. The	operator will	post	advisor	notice	around	the	controlled	area.	

8. The	operator	will	have	been	trained	in	operation	of	UAS	generally	and	received	upto-date	information on	the	particular	UAS	to	be	operated	as	required.	

9. If	the	UAS	loses	communications	or	loses	its	GPS signal,	the	UAS	will	have	capability	

to	return to	a	pre-determined	location	within	the	Security	Perimeter	and	land.	

10. The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	

emergencies.	

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	

exemption	and	 are	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	the	

need	for	an	equivalent	 level	of	safety.	Please	contact	us	at	any	time	if	additional

information or	clarifications	are	needed.	

Sincerely,	

Joshua	Gunsett

Gunsett	Tech	Solutions LLC