December 1, 2015

U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request under Section 333

- Small UAS

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rule making required by section 332(b)(1) ofthis Act or the guidance required by section 334 ofthis Act." In Section 332(b)(1), The Petitioner" GNAT INTERNATIONAL INC, GNAT SHOOT" proposes the following exemptions and meets all requirements to permit FAA approval ofcommercial UAS operations. The proposed exemption, if granted, would allow Petitioner to conduct commercial operations ofsmall unmanned aircraft systems ("UAS") meeting or exceeding all ofthe operational and safety requirements Congress has set forth in Section 333.

Petitioner is an aerial and technical photography company that plans to exploit the capabilities of Unmanned Aerial Systems to offer a multitude ofservices, including:

- Aerial surveying

- Agriculture -Aerial filmmaking and photography

- Real Estate

- Construction site inspections and monitoring

- Educational and research operations

- Aerial target support
(a) The name and contact information ofthe applicant are:

Attn: Rick McGee GnatInternational Sabrecross, Inc. P.O. Box2241 Eagle, ID 83616 Businessphysical Addresses: 300 E. Frontage Rd. Caldwell, ID 83605 2024N. Rambo Rd Spokane, WA, 99224

Regulations from which the exemption is requested:

14 CFRPart 21 14 CFR3614 CFR. 45.23(b), 45.27, 45.29 14 CFR 61.113 (a) & (b) 14 CFR. 91.7 (a) 14 CFR91.9 (b) (2) 14 CFR. 91.103 14 CFR. 91.109 14 CFR. 91.119 14 CFR. 91.121 14 CFR91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR91.405 (a) 14 CFR407 (a) (1) 14 CFR409 (a) (2) 14 CFR417 (a) & (b)


### (c) The extentof reliefsought is forthe duration ofthe Grantof Exemption,· unless otherwise specified.

The reason to seek the relief is as follows:



### I. 14 CFR 21 i. The petitioner requests relieffrom 14 CFR part 21. The UAV is a small rotor craft weighing less than 25 pounds during operation. The UAV maximum speed is under 50 mph. The PIC will maintain VFR Rules flying at no more than 400 feet and will operate the UAV during the day in line-of-sight so as notto create a hazard to users ofthe National Airspace System orthe Public or pose a threat to national security.

II. 14 CFR 36 The Petitioner requests relieffrom any associated noise certification and testing requirements of part 36. As a note, according to the manufacturer's specifications, the UAV operates below 40db within 50 meters.

Ill. 14 CFR 45.23 The UAV does not currently display,marks consisting ofthe Roman capital letter "N" followed by the registration number ofthe aircraft in compliance with 14' CFR 45.23 and 14 CFR 45.27. The Petitionerwill register the UAVwith the FAA and ensure UAV is marked as appropriate before using the UAV in the NAS for commercial purposes.

IV. 14 CFR 45.29 The Petitioner request relieffrom the size requirements underthis section dueto the size limitations ofthe UAV. 

### \f\Je propose to use marks as large as possible on the UAV
as well as keep registration information with the PIC during operation.

V.14CFR61.113 The Petitioner requests relieffrom 14 CFR part 61.113 The flight is only incidental to the proposed business or employment; and the aircraft does not carry passengers or property for compensation or hire. However, The applicant contact is a fixed wing S/ME IFR rated US airman with a second class medical.VI. 14 CFR 91.9 Relevant materials shall be kept in a location accessible to the PIC in compliance with the regulations.

VII. 14 CFR 91.103 This section does not apply to small UAV due to restrictions already imposed under 333. All flights are VFR. However, The PIC will follow all other applicable pre-flight actions as recommended by the manufacturer, including reviewing weather, flight requirements, and aircraft performance data before initiation a flight.

i. VIII. 14 CFR 91.119(b,c) The Petitioner requests relieffrom this section because altitude restrictions are already provide within 333 and minimum vertical obstacle clearances are greaterthan currently approved for 333 UAS operations. The PIC will ensure the UAV is operated in controlled environment and as defined in section (d), If**th~ oper'ation·rs~** con'ducted without hazard to persons or property on the surface. ·,, :·.: ·:,·.:

IX. 14 CFR 91.151 ;;.• .,: 1 ,': The Petitioner requests exemption from this section due to the maximum flight time available from**thi~** UAV. The UAVtotal flight time is limited to 30 minutes andtherefore the PIC would not be able to meet the minimum standards and still conduct the inspections. The. UAS is equipped with a visual battery indicatorthatdisplaysthe battery levels atall time.
Additionally, the UAS has a visual alarm that indicates whenthe battery reaches a state of20% battery life, or approximately 7 minutes offlight time. These indicators, coupled with pilot awareness and the emergency return-to- station setting will supply ample time to land the. UAV safely inthe event of low battery

.. X. 14 CFR 91.203 The Petitioner requests relieffrom 14 CFR 91.203 as the appropriate airworthiness certificate does not exist for this UAS. Additionally, the certificate cannot be displayed in the aircraft due to the size and physical structure**oq~e** UAV. '

XI. 14 CFR 91.405,407,409,417 The Petitioner requests relieffrom 14 CFR 91.405: 407,.409, and 417 The above-cited regulations require, in general, aircraft owners and operators to inspect the aircraft "

...as prescribed in subpart E ofthis part and shall between required inspections·, exceptas provided in paragraph (c) ofthis section,

### ~av·e**discrepan·~;~s ,r~·p~ire9** 

## as prescribed ·in part 43 ofthis chapter."These.

### regul~tipns.a'pplyt~'~irc~~jl**~ith'a~** AirWortliiness 1 Certificate. Therefore, theseseCtions are

### ~ot applicabl'e

## t61 this'

## UAS, Operators will adhere to requirements located within the operations manual.


### (d) The reasons why

## gr~O,t~q~.this

## r~~~~st**~~~l~l~f~~r t~e** **·p:~~ic '.i~terest;**  that is, how itwould benefit**th~** 

### pubhc asra**~hole** ;i ·' ,;· .·· . ·,·:.: , ·· · ·

. :'-.•JI. Personnel Safety Construction sites and land movements are areas of his risk for inspector and any foot traveler. With the help of UAS more complete site inspections can be performed without risking the life and safety ofemployees.

II. Access toremote or Unreachable areas Segments of Construction Sites, dams, farms, pipelines, and bridges may currently be or become unreachable, partially obscured, or impracticable for inspection by conventional means, such as physically walking the line, or utilizing airplane or helicopters for inspections. Access to assets can also be partially or completely blocked by environmental singularities, such as vegetation growth, or blocked by mechanical means such as vehicle accidents, new construction, or road maintenance. The use ofour UAVwill ensuie access to remote or impassable areas on an as-needed basis as well as during or after uncontrolled singular events.

Ill. Cost Effectiveness Currently, multiple personnel consisting ofagency officials, employees and/or contractors are often required to conduct field inspections on large projects over vast amounts ofterrain in orderto ensure public safety and meetregulatory requirements. Inspections can require a substantial amount of person-hours and persist for days orweeks at a time due to terrain and accessibility issues. Factoring in engineering, planning & scheduling, safety meetings, mileage, recovered man:..hours, potential down time due to injury, potential worker's compensation savings, and the intangible consideration of keeping employees injury-free, the current system of inspecting these assets becomes cost prohibitive. UAV inspections in select areas are timelier, safer and more efficient than the conventional methods for conducting these inspections. Our UAV inspections will free up otherwise occupied employees, and provide a more economic approach to the traditional inspection, thus lowering operational costs. Lower overhead for corporations could lead to end-usersavings such as decreased utility bills.
(e) The reasons why granting the exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety at leastequal to that provided by the rule from which the exemption is sought The petitioner states that

## the unmanned aircraft (UA) to be operated underthis request is less than25 fbs. fully" loaded, flies at a speed of no more than 44 knots, carries neither a pilot nor passenger and operates exclusively within a secured area as set out in the POH.

The crafts are the 9hroma, 

# aquad-rotor (with4 motors), manufactured by Horizon Hobby. TheTarot**680,i~fa** hex rotor-type design that has six motors,**manufac~ured** by Sabrecross, Inc. OThe lnfinity-9 and Cine:-wing 8E crafts are an

### Octorotor~type design that h'as· eight motors. All systems include GPS system,• 

# ..

full autonomous autopilot capabilities, telemetry and manual ground control.

In addition, each**cr~ft** has integrated safety features built into the design ofthe UAS, as described in the POH, to ensure the safety ofpersons and property within and surrounding the limited operating area. In the event ofa communication loss in manual control, the UAS.switches to GPS. CQI')trgl**~nd** 

### .. return to its takeoff coordinates to perform a "Fall Safe Landing" within-'the •·-' ···' Security Perimeter. It will also have the capability,to abort a flight .in the event of unpredicted obstacles oremergencies. · · · · · ··

·.. .;**~** :**~** ' • t • ' • ; • ·: '**~::** ,. • : • i • ' "' II. The aircraft will be operated with both a PIC :and.a**groun.q-b~se~** Visual

If ,;' Observer (VO)·in accordance with FAA Policy

## N. 8900.227 Section 14, Operational Requirements for UAS. Operatlpns will be

..conducted with the

, . permission ofthe land owner. A Observerwill be.present duiing

### ·uA:~ flight operations The PIC will file a Notice to Airmen (NOT AM) pro"'iding location and a date/time ofthe flight.

Ill. This exemption 

### .will

## provi~e a

## great~r level ofsafety to

..that

## pr~vide,~):>y the rule from which th'e exemption**is~so~:-~ght** Because UAS flights are.not,currently aathorized for commerciai(Jse, .methods for inspecting, surveying

### ~·ssets are limited to pedestrian or helicopter operaijons. Where helicopter O'perations are not feasible due to environmental.or mechanical obstructions, ·and or Structural elements, utilizing the UAVwill. provide a safe alternative to the inherent dangers ofwalking through these regions·to conduct the required inspections. The small size, extrememaneuverability and**~oom**capabilities on the camera allow for a safe, unimpeded inspection ofcritiealinfrastructure assets.


### (f) Summary to publish in the Federal Register

l

.... ·.··

.. Gnat International seeks exemption under §333 oHhe FAA Modernization and Reform Act of2012 (Public Law 112-95) from 14 CFR 21; 14 CFR 36, 45.23; 45.27, 45.2.9; 61.113; 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) II.

The exemption would allow commercial operation of SfllaU Unmanned Aircraft Systems (UAS) for aerial surveillance and observati,<:>n,**ciner:na~p,graphy,** aerial photography, inspection focused on Constructipn and Technicai,,Applipations; surveying, mapping, Aerial target supportfor controlle<;l eyen!s**~nd o~h~rlel~te~**  services. · · ·

: ,:· ..

... ' •: ·""

. CONCLUSION

Satisfaction ofthe criteriaprovide9 in Section 333**ofili.tt~eform** A.ct,pf2012- size,**w~ig~t,** speed, operating capabilities, prqxijni}Y

### ·!9·**~irpotts'.l;lnd i>.o.pulafe~** **~~a~ a~** 

# a**()Pe~ati?n**withiii:'yisual line of sight and national security

-**provid~**more

### th;m a!iequate**Jllstific~tion** for the grant ofthe requested exemptions_allowing commercial operation

### or'Rgail~t~~~~ild~~.t,•..

### Q~~ for

### ~erial surveys,Aerialtarget support, cmematography and photography. · · ·