June 2, 2015 John Cloud Gorilla Kleen P.O. Box 25427 Sarasota, Florida 34235 John@Gorillakleen.com U.S. Department ofTransportation Docket Management System 1200 New JerseyAvenue, SE Washington, DC 20590 Re: Exemption request, Section 333 ofthe FAA Reform Act ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F
.R. Part 21; 14 C.F.R. 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b)(2); 91.109; 119.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417 (a) & (b). Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F
.R. Part 11, Gorilla Kleen, LLC, a Florida Corporation, and its owner, John V
. Cloud herebyapply for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits Small Unmanned Aircraft Systems ("sUAS") for aerial imaging. Gorilla Kleen is an exterior cleaning company and will beutilizing the sUAS for safety inspections, roofinventory, promotional photography and project monitoring

. These operations will be conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As detailed in this documentand the attached Flight Manual, the requested exemption would permitthe operation ofsUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safetyenhancements to the alreadybestpractices safetyprotocols followed by Gorilla Kleen in conducting each ofits cleaning and evaluation projects. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA administrator's) responsibilities to "
.. . establish requirements for the safe operation ofsuch aircraft systems in the national airspace system
." Section 333 (c) ofthe Reform Act. The name and address ofthe applicantis: Gorilla Kleen, LLC John Cloud, President P.O
. Box 25427 Sarasota, Florida 34277Physical address: Gorilla Kleen, LLC 1663 11th Street Sarasota, Florida 34236
John Cloud Phone: 941-724-2000 E-mail: John@Gorillakleen

.com Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F
.R. 45.23 (b) 14 C.P.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14C.P.R. 91.9 (b)(2) 14 C.F.R. 91.103 14 C.P.R. 91.109 14 C.F.R. 91.119 14 C.P
.R. 91.121 14 C.P
.R. 91.203 (a) & (b) 14 C.P.R. 91.405 (a) 14 C.P.R. 407 (a) (1) 14 C.P.R. 490 (a) (2) 14 C.P.R. 417 (a) & (b) While for the sake of simplicity I have requested an exemption for 14C.F.R. 61
.113 (a) and (b), I, John Cloud, am a licensed pilot, single engine airplane land and sea, multi-engine land and instrumentwith over 5,000 hours ofpiston and turbine flight time. I believe that these credentials, almost more than anything, demonstrates an ability to undertake matters relatingto safety and discipline in a prudent manner. I. StatutoryAuthorityfor Exemptions The Federal Aviation Act expresslygrants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 oftheAct, including sUASs, from the requirementthat all civil aircraft must have a currentairworthiness certificate. The administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U
.C. §44701(f) See also 49 USC §44711 (a); 49 USC §44704; 14 C.P.R. §91
.203 (a)(1).Section 333(b) ofthe Reform Act assists the Secretary in determining whether sUAS may operate in the National Airspace System (NAS) without creating a hazard to the 

### user, the public, or a threatto national security. In making this determination, the Secretary must consider: The sUAS size, weight, speed and operational capability Whether the sUAS operates within the visual line ofsight ofthe operator Whether the sUAS operates outside ofhighly populated areas and away from close proximity to airports Reform Act §333(a). Ifthe Secretary determines that a sUAS "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ld. §333(c). Gorilla Kleen's sUAS are multi-rotor vehicles, weighing 5 or fewer pounds, including payload. They operate under normal conditions ata speed ofno more than 10 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. The sUAS will operate only in the pilot's visual line ofsight atall times and will operate only within the sterile area described in the DJI Phantom One Flight manual, attached as Exhibit 1 (hereinafter "the manual"). Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public." Reform Act Section 333 (b). Given the small size ofthe sUAS involved and the restricted and sterile environment within which theywill operate, our application falls squarelywithin the zone of safety (an equivalentlevel ofsafety) in which Congress envisioned thatthe FAA 

### must, by exemption, allow commercial operations ofsUAS to commence immediately. Also due to the small size ofthe sUAS and the low altitudes and restricted areas in which the sUAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significantpublic benefit, including enhanced safety, the grant ofthe requested exemptions is in the public interest. Accordingly, Gorilla Kleen respectfully requests thatthe FAA grant the requested exemption without delay. 

### II. Public Interest This exemption application is expressly submitted to fulfill congress' goal in passing Section 333 (a) through (c) ofthe Reform Act This lawdirects the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required underSection 332 ofthe Reform Act. By granting an exemption the FAA will fulfill Congress's intent ofallowing UAS to operate with significant safety precautions in low risk environments. The use ofsUAS to inspect roofand working environments can significantly reduce the riskto workers offalls while inspecting, surveying or monitoring work environments and progress. sUAS can inspect, photograph and collect date on hard to access work areas, inventory the hazards and help us createproper worker protocol and protections priorto entering the workenvironment. Additionally, sUAS could replace the use ofhelicopters and or small aircraftthat would otherwise be a logical choice to provide the aforementioned inspection services. The sUAS we propose to fly in this application weigh less than five pounds, and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. Shifting to sUAS from helicopters presents a marked safety increase for our workers and the public

. Lastly, sUAS reduce the environmental impactby dramatically decreasing the energy used for aerial imaging and data collection over a job site. Our sUAS use rechargeable lithium ion batteries, as opposed to fossil fuels burned in the operation ofsmall aircraft thatare many times heavier. III. Equivalent Level OfSafety Gorilla Kleen proposes that the exemption requested herein apply to sUAS that have the characteristics and that operate within the limitations listed herein

. These limitations provide for atleastan equivalent or even higherlevel ofsafetyto operations under the currentregulatory structure because the proposed operations represent a safety enhancementto the already safe protocols followed onjob sites and imaging and surveying operations conducted with helicopters and other conventional aircraft

. Gorilla Kleen will bebound bythe following limitation when conducting its sUAS operations under an FAA issued exemption: 1. The sUAs will be less than 10 pounds 2. Flights will be operated within visual line ofsight ofa pilot 3. Maximum total flight time for each operational flight will be 30 minutes. The UAS calculates batteryreserve in real time and will return to its ground station with atleast 20% batterypower reserve should that occur prior to the 30 minute limit. 4. Flights will normally be operated at an altitude of200 feetAGL or lower, never exceeding 400 feet AGL. 5. Crew for each operation will consist ofthe sUAS pilotwho will keep the sUAS within his visual line ofsightat all times.6. The sUAS pilot will be trained in flight, operation, and safety procedures as detailed in the flight manual. 7. The sUAS will only operate within a confined "sterile area" as defined in the manual. The manual also requires the establishment ofa "Security Perimeter" for the flight operations area. 8. Abriefing will be conducted in regard to the planned sUAS operations prior to each day's production activities. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be presentfor this briefing. 9. All onsite personnel will consentto the UAS flyover on site by waiver, and the operator will obtain additional verbal orwritten consent ofall persons who will be allowed within 100 feet ofthe flight operation. 10. Pilot will have been trained in operation ofUASs generally and received up to date information on the particular UAS to be operated as required by Section Fofthe manual. 11.Written and or oral permission from the relevant propertyholders will be obtained. 12. All required permissions and permits will be obtained from state, county or cityjurisdictions includinglocal law enforcement, fire, or other appropriate governmental agencies. 13. Ifthe sUAS loses communications or loses its GPS signal, itwill have capabilityto enter "loiter mode" and hover, reestablish GPS connection and return to a pre-determined location within the security perimeter, and land. IV. 

### Description ofSpecific Regulations 14 C.F.R. 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command I, John Cloud, am an FAA licensed pilot,#-------, single engine land and sea, multiengine land and instrument. Ihave flown over 5,000 hours in both piston and turbine aircraftthat I have owned. Despite seeking an exemption under this section for expedience, the same levels ofplanning, safety considerations and skill that allowed me to acquire 5,000 hours offlight time withouta single incident will continue to imbue to the control of, and use ofa drone. Because the sUAS will not carry a pilotor passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrentoperations byinsuring that the pilot has been well trained and has experience in flying the drone safely. Unlike a conventional aircraftthat carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The Phantom 1 sUAS also has an automatic "returnto land" function which helps further insure safety (perhaps in much the same way that a parachute provides safety in the Cirrus), which greatly reduces the danger ofhuman error. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the manual.The sUAS to be operated hereunder is less than 5 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive or flammable liquid fuels, and operates exclusively within a secured area as setoutin the manual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored bythe operator pursuant to the manual's requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area ofoperation as is currently done on activejob sites. 14 C.F.R. 91.103: PreflightAction This regulation requires each pilotin command take certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement as the pilotwill take separate preflight actions, including checking for weather conditions checking flight batteryrequirements, checking takeoffand landingdistances, and all other actions in the preflight checklistin the manual

- thatare appropriate for this type ofaircraft. These actions will provide an equivalentlevel ofsafety. 14 C.F.R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft Section 91.119 (d) allows helicopters to be operated atless than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. This exemption is for a multi-rotor craftthat flies similarly to a helicopter, with vertical take offand vertical landing, which will typically operate at altitudes of200' AGL orbelow, so an exemption may be needed to allow such operations. The sUAS will never operate atan altitude higher than 

### 400' AGL and will be in a restricted area with security perimeter,where buildings and people will not be exposed to operations withouttheir pre-obtained consent. See manual for detailed procedures. The equivalent level ofsafety will be achieved given the size, weight and speed of the sUAS as well as the location where itis operated. No flight will be taken without the permission ofthe propertyowner or local officials. Because ofthe advance notice to the property owner and anyonsite personnel as outlined in the manual all affected individuals will be aware ofthe planned flight operations. Unlike flight operation with aircraft or rotorcraftweighing far more than the maximum 10 pounds proposed herein, our sUAS will not carry flammable fuel. In addition, the low altitude operations ofthe sUAs will ensure separation between sUAS operations ofconventional aircraft that must comply with section 91.119. 14 C.F.R. 91.121: AltimeterSettings This regulation requires each person operatingan aircraft to maintain cruising altitude byreference to an altimeter that is set"
.. ..to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." sUAS's donot have a barometric altimeter so an exemption is needed to this section. Instead, they do notfly until they are coordinated with up to 6 GPS satellites that provide any altitude date thatthey require to fly safely. The sUAS will only be flown in the line ofsite and as such, it is not necessaryto know the exact altitude as itwould be for a piloted plane. 14 C.F.R. 91.151 (a): Fuel requirements for flight in VFR conditions. Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited to operations in sterile and controlled environments as outlined in the manual, and has a limited range and flight time which require an exemption from 14 C.F.R. 91.151 (a). Piloted aircraft require 30 minutes ofreserve fuel as that is a logical and safe amount offuel to allow for safe transitto an appropriate alternate landing site. sUAS's are capable oflandingessentially anywhere within the area in which they will be operating because they are small, light and capable ofvertical landing. They can he landed in a matter of30 seconds or less in mostinstances. Warning systems on the aircraft provide warningwhen approximately 20% ofthe flight time remains, which provides more than a substantial margin oftime in which to safely land the aircraft. Gorilla Kleen believes thatan exemption from 14 C
.F

.R. §91.15 (a) falls within the scope ofprior exemptions. See explanation 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small sUAS in a tightly controlled area where only people and property owners or official representative thathave signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender the type ofrisks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe small UAS. An equivalentlevel ofsafety can be achieved by limiting flights to 30 minutes, or enough battery reserve to ensure thatthe sUAS lands at the ground station with at least 20% ofbatterypower (as determined by the onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. 91.405 (a)(1); 409 (a)(2); 417 (a) & 

### (b): Maintenance inspections These regulations require that an aircraftoperator or owner "shall have that aircraft inspected as prescribed in subpart Eofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepanciesrepaired as prescribed in part 43 ofthis chapter
..." and others shall inspect or maintain the aircraft in compliance with part 43. Given thatthese sections and Part 43 apply only to aircraftwith an airworthiness certificate, these sections will notapply to Gorilla Kleen. Maintenance will be accomplished by the operatorpursuant to the flight manual and operating handbook as referenced in the manual. An equivalentlevel ofsafety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the sUAS can land immediately and will be operating from no higherthan 400' AGL. As provided in the manual, the pilot will ensure thatthe sUAS is in working orderprior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the pilot is the person most familiar with the aircraft best suited to maintain the aircraft in an airworthy condition to provide the equivalentlevel ofsafety. 

### ******* Pursuant to 14 C.F
.R. Part 11, the following summary is provided for publication on the Federal Register, should itbe determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C

.F.R. 45
.23(b); 14 C.F
.R. §§61

.113(a)&(b); 91.79(a); 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); 91.409(a)(2); 91.417(a)&(b) to operate commercially a small unmanned vehicle (55 pounds or less) in monitoring and evaluating cleaning operations. Approval ofexemptions allowing commercial operations ofa sUAS in the cleaning industry enhances safety while reducingrisk. Manned aircraft monitoring and surveying creates a greater riskbecause the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewerthan 10 lbs
. and powered bybatteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofsmall 

### SUAS, weighing less than 10 

### lbs., conducted in the strict conditions outlined above, will provide an equivalentlevel ofsafety supporting the grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements ofPart 21 and allowing commercial operations

. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.Privacy All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Images taken will be ofindividuals who have consented to being filmed or otherwise have agreed to be in the area where aerial photographywill take place. 

### ************* Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 -size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsightand national security- provide more than adequatejustification for the grant ofthe requested exemptions allowing commercial operation ofapplicants sUAS in the cleaningindustry pursuant to the manual appended hereto. Sincerely,

President Gorilla Kleen 

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