December 1, 2015 

U.S. Department of Transportation 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 of safe 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 of the (comprehensive) plan and rule making 

required by section 332(b)(1) of this Act or the guidance required by 

section 334 of this 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 of commercial UAS operations. 

The proposed exemption, if granted, would allow Petitioner to conduct commercial 

operations of small unmanned aircraft systems ("UAS") meeting or exceeding all of the 

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 of services, 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 of the applicant are: 

Attn: Rick McGee 

Gnat International 

Sabrecross, Inc. 

P.O. Box 2241 

Eagle, ID 83616 

Business physical Addresses: 

300 E. Frontage Rd. 

Caldwell, ID 83605 

2024 N. Rambo Rd 

Spokane, W A, 99224 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR36 
14 CFR. 45.23(b), 45.27, 45.29 

14 CFR 61.113 (a) & (b) 

14 CFR. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR. 91.103 

14 CFR. 91.109 

14 CFR. 91.119 

14 CFR. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

(c) The extent of relief sought is for the duration of the Grant of Exemption,· 

unless otherwise specified. 

The reason to seek the relief is as follows: 

I. 14 CFR 21 

i. The petitioner requests relief from 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 not to create a hazard to users of the 

National Airspace System or the Public or pose a threat to national security. 

II. 14 CFR 36 

The Petitioner requests relief from 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 of the Roman capital letter "N" 

followed by the registration number of the aircraft in compliance with 14' CFR 45.23 and 

14 CFR 45.27. The Petitioner will register the UAV with 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 relief from the size requirements under this section due to the 

size limitations of the 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 relief from 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 relief from this section because altitude restrictions are already 

provide within 333 and minimum vertical obstacle clearances are greater than 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 UAV total flight time is limited to 30 minutes and therefore 

the PIC would not be able to meet the minimum standards and still conduct the 

inspections. The. UAS is equipped with a visual battery indicator that displaysthe 

battery levels at all time. 

Additionally, the UAS has a visual alarm that indicates whenthe battery reaches a state 

of 20% battery life, or approximately 7 minutes of flight time. These indicators, coupled 

with pilot awareness and the emergency return-to- station setting will supply ample time 

to land the. UAV safely in the event of low battery .. 

X. 14 CFR 91.203 

The Petitioner requests relief from 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 relief from 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 of this part and shall between required inspections·, except as 

provided in paragraph (c) of this section, ~av·e discrepan·~;~s ,r~·p~ire9 as prescribed ·in 

part 43 of this chapter."These. regul~tipns.a'pplyt~'~irc~~jl ~ith'a~ AirWortliiness 1 

Certificate. Therefore, these seCtions 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 it would benefit th~ pubhc asra ~hole ;i ·' ,;· .·· . ·,·:.: , · · · · 

. :'-.•J 
I. 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 of employees. 

II. Access to remote 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 of our UAV will 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 of agency officials, employees and/or 

contractors are often required to conduct field inspections on large projects over 

vast amounts of terrain in order to ensure public safety and meet regulatory 

requirements. Inspections can require a substantial amount of person-hours and 

persist for days or weeks 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-user savings such as 

decreased utility bills. 

(e) The reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that provided 

by the rule from which the exemption is sought 

The petitioner states that the unmanned aircraft (UA) to be operated under this 

request is less than 25 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, a quad-rotor (with 4 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 of the 

UAS, as described in the POH, to ensure the safety ofpersons and property 

within and surrounding the limited operating area. In the event of a 

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 or emergencies. · · · · · ·· ·.. .; 

~ : ~ ' • 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 of the land owner. A Observer will be. present duiing ·uA:~ flight 

operations The PIC will file a Notice to Airmen (NOT AM) pro"'iding location and a 

date/time of the flight. 

Ill. This exemption .will provi~e a great~r level of safety 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 UAV will. provide a safe alternative to the inherent dangers 

of walking through these regions·to conduct the required inspections. The small 

size, extreme maneuverability and ~oom capabilities on the camera allow for a 

safe, unimpeded inspection of critiealinfrastructure assets. 

(f) Summary to publish in the Federal Register 

l .... 

·.·· .. 

Gnat International seeks exemption under §333 oHhe FAA Modernization and Reform 

Act of 2012 (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 support for controlle<;l eyen!s ~nd o~h~rlel~te~ services. · · · 

: ,:· .. ... ' •: ·"" . CONCLUSION 

Satisfaction of the 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 with iii: 'yisual line of 

sight and national security - provid~ more th;m a!iequate Jllstific~tion for the grant of the requested 

exemptions_ allowing commercial operation or'Rgail~t~~~~ild~~.t, •.. Q~~ for ~erial surveys, Aerial target 

support, cmematography and photography. · · ·