## Gulf Unmanned Systems Center P.OBox635

24August 2015
U.S. Department ofTransportation Docket Operations Carrabelle, Florida 32322

West Building Ground Floor, Room W12-140 1200 NewJersey Ave., SE Washington, DC 20590 Regarding: The Gulf Unmanned Systems Center, Inc. Petition for Exemption pursuantTo Section 333 of the FAA Modernization Reform Act ofZ012 (FMRA)

Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. as noted above, the Gulf Unmanned Systems Center, Inc. ("Petitioner") hereby submitsthis petitionfor exemption to authorize civil operations ofsmall Unmanned Aircraft Systems ("sUAS") forthe commercial use purposes ofaerial surveying, aerial mapping, agricultural surveying and application, construction aerial inspection, environmental wetland mitigation monitoring, remote sensing, sUAS academics and training, wildlife monitoring, and aeronautical research within private properties and public properties owned by State or Local governments within the Continental United States. The Gulf Unmanned Systems Center (GUSC) is a Florida based limited liabilitycompany operating Small Unmanned Aircraft System equipped to conduct aerial photography and surveyforvarious industries and applications. As such, and in the spirit ofthe ofthe FAA Modernization and Reform Act of2012 (the "Reform Act"), GUSC hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed belowto allowoperation ofour sUAS commercially in airspace regulated bythe Federal Aviation Administration (FAA) so longas such operations are conducted with and underthe conditions outlined herein oras may be established by the FAA as required by Section 333. The requested exemption is similarto previous FAA issued grants ofexemption including but not limitedto Exemption Nos. 11062, 11109, 11112, 11213, 11295, 12084, 12194, and 12504. In addition, GUSC has teamed withTallahassee Community College (TCC) to develop and present an unmanned systems technology course of instruction that includes UAS in the curriculum. An exemption supportive ofthis application is similartothat issued to Auburn University, 11304.The GUSC-TCC curriculum is proprietaryand not included in this petition but is available tothe FAA upon request.

All GUSC sUAS flights thatwill occur over private or controlled access propertywill do so with the property owner's prior consent and knowledge. Additionally, all GUSC pilots will hold an airline transport, commercial, private, recreational, orsport pilotcertificate and also hold a current FAA airman medical certificate oravalid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, aterritory, a possession, orthe Federal government. Ifan observer is not a qualified pilot, theywill be trained by GUSC pilotsto understand the proper roles ofan observer, communication procedures, propervisual scan techniques, operations at non-towered airports, and appropriate sections ofthe Aeronautical Information Manual. The GUSC pilots and instructors have extensive UAS fligt and training experience having held similar positions while on active militaryduty and as Department of Defense contractors.


### GLOSSARY OF ABBREVIATIONS AGL Above Ground level COA Certificate ofAuthorization CFR Code of Federal Regulations FAA Federal Aviation Administration FAR Federal Aviation Regulation GUSC Gulf Unmanned Systems Center (Petitioner) NAS National Airspace System NTSB National Transportation Safety Board PIC Pilot in Command Section 333 FAA Modernization and Reform Act of2012, Section 333 sUAS Small Unmanned Aircraft Systems VFR Visual Flight Rules VMC Visual Meteorological ConditionsThe Petitioner requests relieffrom the following regulationstothe extent necessaryto allow GUSC to operate a UAS to perform training, research, and aerial data collection. 14C.F.R. Part 21 14C.F.R. 45.23 (b) 14 C.F.R. 61.23 (a) and (c) 14C.F.R. 61.101 (e)(4} and (5) 14C.F.R. 61.113(a) and (b) 14C.F.R. 315 (a) 14C.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 14C.F.R. 91.121 14C.F.R. 91.151(a) 14C.F.R. 91.203 (a} 

### & (b) 14C.F.R. 91.205 (b) 14C.F.R. 91.215 14C.F.R. (91.401- 91.417}

We are petitioningfor exemption to enable GUSC to operate a series of UAS platformsthat have been previously approved by exemption. Namely: DJI Phantom 2 - Exemption 11398 DJI Phantom 2 Vision - Exemption 11310 DJI Phantom 2 Vision+- Exemption 11398 DJIInspire- Exemption 11398

### DJI S1000- Exemption 11416 DJI S900- Exemption 11401 3D Robotics X8- Exemption 12084 3DRobotics IRIS+- Exemption 11419, 12084, 12194

These sUAS all weigh less than 55 lbs, have a built- in capabilityto limitthe height flown above the ground, to limitthe radius ofthe distance itflies from the operator and to exclude itfrom Class B, Cand D airspace including a no fly zone feature. Each system also has the failsafe function ofthe autopilot system, which means when the communication between the Main Controller and the transmitter is lost; the system will automaticallytrigger Return to Home and will land safely. This submission does not include the Operating Manuals for each model requested above, as they have been reviewed by the Administrator in granting previous exemptions. Copies ofall Operating Manuals for the individual models listed will be submitted on request. The above specifications meet standards listed below:
• GUSC will only operate sUAS in line ofsight ofa pilot and/orobserver and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the operator's manual. Such operations will insure that the sUAS will"not create a hazard to users ofthe national airspace system orthe public."
• GUSC will not operate sUAV within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless a letter ofagreement with that airport's management is obtained or otherwise permitted by a COA issued to GUSC.
• Maximum flight time for each operational flight will be 60 minutes.
• Flights will be terminated at 25% battery power reserve should that occur priorto the 60 minute limit.
• The sUAV will be programmed so that itwill be operated at an altitude of no more than 400 feetAGL.
• Minimum crew for each operation will consist ofthe sUAS Pilot and the Visual Observer.
• The sUAS PIC's (Pilot in Command) will be an airline transport, commercial, private, recreational, or sport pilot certificate and also hold a current FAA airman medical certificate or avalid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, aterritory, a possession, orthe Federal government. • The sUAS operated bythe petitionerweighs less than 55 pounds, includingthe payload (i.e. camera, lens, and gimbal).• The sUAS will operate at speeds of no more than 55 knots.
• Given the small size ofthe sUAS and the restricted sterile environmentwithin which theywill operate, our sUAS operations adhere to the Reform Act's safety requirements Underthe requested exemption GUSC ensuresthat all operators have completed a small unmanned aircraft systems {UAS) education and training program including all applicable regulations and guidance documents; including aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weatherfactors; Airmanship and Decision-making and Safe Operating Procedures.

The Gulf Unmanned Systems Center is uniquely positioned to lead thetransition ofthefull range of unmanned technologies into commercial applications. The safe and effective operation ofsUAS by GUSC personnel is central tothe success ofthe corporation and might ultimatelycontribute tothe FAA objectives ofsafe and efficient operation of UAS within the National Airspace System. Approval ofthis petition will enable GUSC to perform avariety ofoperational missions currently reserved for manned aircraft, but at afraction ofthe cost and with significant gains in safety and efficiency. Your consideration is greatlyappreciated.
Respectfully submitted,

Lawrence M. Harvey Senior Vice President, CTO Gulf Unmanned Systems Center www.guscenter.com 

### 321-213-7193



### Gulf Unmanned Systems Center P.O Box635 Carrabelle, Florida 32322