Gulf Unmanned Systems Center

P.O Box 635 Carrabelle, Florida 32322

24 August 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140 1200 New Jersey Ave., SE

Washington, DC 20590

Regarding: The Gulf Unmanned Systems Center, Inc. Petition for Exemption pursuant To Section 333 of 

the FAA Modernization Reform Act of Z012 (FMRA) 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14

C.F.R. as noted above, the Gulf Unmanned Systems Center, Inc. ("Petitioner") hereby submits this 

petition for exemption to authorize civil operations of small Unmanned Aircraft Systems ("sUAS") for the 

commercial use purposes of aerial 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 liability company operating Small 

Unmanned Aircraft System equipped to conduct aerial photography and survey for various industries 

and applications. As such, and in the spirit of the of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act"), GUSC hereby applies for an exemption from the Federal Aviation Regulations (FARs) 

listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. The requested exemption is 

similar to previous FAA issued grants of exemption including but not limited to Exemption Nos. 11062, 

11109, 11112, 11213, 11295, 12084, 12194, and 12504. In addition, GUSC has teamed with Tallahassee 

Community College (TCC) to develop and present an unmanned systems technology course of 

instruction that includes UAS in the curriculum. An exemption supportive of this application is similar to 
that issued to Auburn University, 11304. The GUSC-TCC curriculum is proprietary and not included in this 

petition but is available to the FAA upon request. 

All GUSC sUAS flights that will occur over private or controlled access property will do so with the 

property owner's prior consent and knowledge. Additionally, all GUSC pilots will hold an airline 

transport, commercial, private, recreational, or sport pilot certificate and also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, 

a territory, a possession, or the Federal government. If an observer is not a qualified pilot, they will be 

trained by GUSC pilots to understand the proper roles of an observer, communication procedures, 

proper visual scan techniques, operations at non-towered airports, and appropriate sections of the 

Aeronautical Information Manual. The GUSC pilots and instructors have extensive UAS fligt and training 

experience having held similar positions while on active military duty and as Department of Defense 

contractors. 

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

COA Certificate of Authorization

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 of 2012, Section 333

sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules

VMC Visual Meteorological Conditions
The Petitioner requests relief from the following regulations to the extent necessary to allow GUSC to 

operate a UAS to perform training, research, and aerial data collection.

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.23 (a) and (c)

14 C.F.R. 61.101 (e)(4) and (5)

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 315 (a)

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)

We are petitioning for exemption to enable GUSC to operate a series of UAS platforms that have been 

previously approved by exemption. Namely: 

DJI Phantom 2 - Exemption 11398 

DJI Phantom 2 Vision - Exemption 11310 

DJI Phantom 2 Vision+ - Exemption 11398 

DJI Inspire - 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 capability to limit the height flown above the 

ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and 

D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot 

system, which means when the communication between the Main Controller and the transmitter is lost;

the system will automatically trigger 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 of all 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 of sight of a pilot and/or observer 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 of the national airspace 

system or the public." 

• GUSC will not operate sUAV within 5 nautical miles of an airport reference point (ARP) as denoted in 

the current FAA Airport/Facility Directory (AFD), unless a letter of agreement 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 prior to the 60 minute limit. 

• The sUAV will be programmed so that it will be operated at an altitude of no more than 400 feet AGL. 

• Minimum crew for each operation will consist of the 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 a valid U.S. driver’s 

license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal). 
• The sUAS will operate at speeds of no more than 55 knots. 

• Given the small size of the sUAS and the restricted sterile environment within which they will operate, 

our sUAS operations adhere to the Reform Act's safety requirements 

Under the requested exemption GUSC ensures that 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; Weather factors; Airmanship and Decision-making and Safe Operating 

Procedures.

The Gulf Unmanned Systems Center is uniquely positioned to lead the transition of the full range of 

unmanned technologies into commercial applications. The safe and effective operation of sUAS by GUSC 

personnel is central to the success of the corporation and might ultimately contribute to the FAA 

objectives of safe and efficient operation of UAS within the National Airspace System. Approval of this 

petition will enable GUSC to perform a variety of operational missions currently reserved for manned 

aircraft, but at a fraction of the cost and with significant gains in safety and efficiency. Your 

consideration is greatly appreciated.

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 Box 635 Carrabelle, Florida 32322