## 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 t he FAA Modernization Reform Act of Z012 (FMRA)

Dear Sir or Madam: Pursuant to Section 333 of the FAA Moderniza tion 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, a gricultural s urveying and a pplication , construction aerial inspection, environmental wetland mitigation monitoring, remote sensing, sUAS academics and t raining, wildlife monitoring, and aeronaut ical research within private properties and public properties owned by State or Local governments within the Continental United States. T h e Gulf Unmanned Systems Center ( **GUSC** ) is a Florida based limited liability company operating Small Unmanned Aircraft System equipped to conduct aerial photography an d 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 Avi ation 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 establi shed 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 w ith 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 tothat 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 knowle dge. 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 Colo mbia, 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, op erations 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 Departmen t 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 (Peti tioner) 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 Meteorologic al ConditionsThe 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. 9 1.215 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 P hantom 2 Vision+
- Exemption 11398 DJI Inspire
- Exemption 11398DJI 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 bu ilt
- 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 th e 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 mode l 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:
• GUS C 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 agree ment 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 b e 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 possessio n, 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) educati on 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; B asic Small UAS Aerodynamics; Weather factors; Airmanship and Decision
- making and Safe Operating Procedures.

T h e Gulf Unmanned Systems Center is uniquely positioned to lead the transition of the full range of unmanned technologies into commercial applicati ons. 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 submi tted,

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**