June 2, 2015 

John Cloud 

Gorilla Kleen 

P.O. Box 25427 

Sarasota, Florida 34235 

John@Gorillakleen.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption request, Section 333 of the FAA Reform Act of the 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: 

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

Reform Act) and 14 C.F.R. Part 11, Gorilla Kleen, LLC, a Florida Corporation, and its 

owner, John V. Cloud hereby apply for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its Small Unmanned Aircraft 

Systems ("sUAS") for aerial imaging. Gorilla Kleen is an exterior cleaning company 

and will be utilizing the sUAS for safety inspections, roof inventory, 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 document and the attached Flight Manual, the requested 

exemption would permit the operation of sUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would 

provide safety enhancements to the already best practices safety protocols followed 

by Gorilla Kleen in conducting each of its cleaning and evaluation projects. Approval 

of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA administrator's) responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system." Section 333 (c) of the Reform Act. 

The name and address of the applicant is: 

Gorilla Kleen, LLC 

John Cloud, President 

P.O. Box 25427 

Sarasota, Florida 34277 
Physical 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) 

14 C.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 14 C.F.R. 61.113 

(a) and (b), I, John Cloud, am a licensed pilot, single engine airplane land and sea, 

multi-engine land and instrument with over 5,000 hours of piston and turbine flight 

time. I believe that these credentials, almost more than anything, demonstrates an 

ability to undertake matters relating to safety and discipline in a prudent manner. 

I. Statutory Authority for Exemptions 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. 

This statutory authority includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, including sUASs, from the requirement that all civil aircraft 

must have a current airworthiness certificate. 

The administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 

of this title if the 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 threat to 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 of sight of the operator 

Whether the sUAS operates outside of highly populated areas and away from close 

proximity to airports 

Reform Act §333(a). If the Secretary determines that a sUAS "may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe 

operation of such 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 at a speed of no 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 of sight at all 

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 that the sUAS will "not create a hazard to users of the national airspace 

system or the public." Reform Act Section 333 (b). 

Given the small size of the sUAS involved and the restricted and sterile environment 

within which they will operate, our application falls squarely within the zone of 

safety (an equivalent level of safety) in which Congress envisioned that the FAA 

must, by exemption, allow commercial operations of sUAS to commence 

immediately. Also due to the small size of the sUAS and the low altitudes and 

restricted areas in which the sUAS will operate, approval of the application presents 

no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in 

the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, the grant of the requested exemptions is in the public interest. 

Accordingly, Gorilla Kleen respectfully requests that the 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) of the Reform Act This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the NAS before completion of the rulemaking required under 
Section 332 of the Reform Act. By granting an exemption the FAA will fulfill 

Congress's intent of allowing UAS to operate with significant safety precautions in 

low risk environments. 

The use of sUAS to inspect roof and working environments can significantly reduce 

the risk to workers of falls 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 create proper worker 

protocol and protections prior to entering the work environment. 

Additionally, sUAS could replace the use of helicopters and or small aircraft that 

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 impact by 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 

of small aircraft that are many times heavier. 

III. Equivalent Level Of Safety 

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 at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe protocols followed on job sites 

and imaging and surveying operations conducted with helicopters and other 

conventional aircraft. 

Gorilla Kleen will be bound by the 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 of sight of a pilot 

3. Maximum total flight time for each operational flight will be 30 minutes. The 

UAS calculates battery reserve in real time and will return to its ground 

station with at least 20% battery power reserve should that occur prior to 

the 30 minute limit. 

4. Flights will normally be operated at an altitude of 200 feet AGL or lower, 

never exceeding 400 feet AGL. 

5. Crew for each operation will consist of the sUAS pilot who will keep the sUAS 

within his visual line of sight at 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 of a "Security 

Perimeter" for the flight operations area. 

8. A briefing 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 of the safety perimeter 

be present for this briefing. 

9. All onsite personnel will consent to the UAS flyover on site by waiver, and the 

operator will obtain additional verbal or written consent of all persons who 

will be allowed within 100 feet of the 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 

F of the manual. 

11. Written and or oral permission from the relevant property holders will be 

obtained. 

12. All required permissions and permits will be obtained from state, county or 

city jurisdictions including local law enforcement, fire, or other appropriate 

governmental agencies. 

13. If the sUAS loses communications or loses its GPS signal, it will have 

capability to enter "loiter mode" and hover, reestablish GPS connection and 

return to a pre-determined location within the security perimeter, and land. 

IV. Description of Specific 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. I have flown over 5,000 hours in both piston and 

turbine aircraft that I have owned. Despite seeking an exemption under this section 

for expedience, the same levels of planning, safety considerations and skill that 

allowed me to acquire 5,000 hours of flight time without a single incident will 

continue to imbue to the control of, and use of a drone. 

Because the sUAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by insuring that the pilot 

has been well trained and has experience in flying the drone safely. Unlike a 

conventional aircraft that 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 "return to 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 of human error. The area of operation is controlled and 

restricted, 

manual. 

and all flights are planned and coordinated in advance as set forth in the 
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 set out in the manual. Like other civil 

aircraft, operations under this exemption will be tightly controlled and monitored 

by the 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 of operation as is currently done on active job sites. 

14 C.F.R. 91.103: Preflight Action 

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. An exemption is needed from this requirement as the 

pilot will take separate preflight actions, including checking for weather conditions 

checking flight battery requirements, checking takeoff and landing distances, and all 

other actions in the preflight checklist in the manual - that are appropriate for this 

type of aircraft. These actions will provide an equivalent level of safety. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. This exemption is for a multi-rotor craft that 

flies similarly to a helicopter, with vertical take off and vertical landing, which will 

typically operate at altitudes of 200' AGL or below, so an exemption may be needed 

to allow such operations. The sUAS will never operate at an 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 without their pre-obtained consent. 

See manual for detailed procedures. 

The equivalent level of safety will be achieved given the size, weight and speed of 

the sUAS as well as the location where it is operated. No flight will be taken without 

the permission of the property owner or local officials. Because of the advance 

notice to the property owner and any onsite personnel as outlined in the manual all 

affected individuals will be aware of the planned flight operations. Unlike flight 

operation with aircraft or rotorcraft weighing far more than the maximum 10 

pounds proposed herein, our sUAS will not carry flammable fuel. In addition, the 

low altitude operations of the sUAs will ensure separation between sUAS operations 

of conventional aircraft that must comply with section 91.119. 

14 C.F.R. 91.121: Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set" .... to the elevation of the departure 

airport or an appropriate altimeter setting available before departure." sUAS's do 
not have a barometric altimeter so an exemption is needed to this section. Instead, 

they do not fly until they are coordinated with up to 6 GPS satellites that provide 

any altitude date that they require to fly safely. The sUAS will only be flown in the 

line of site and as such, it is not necessary to know the exact altitude as it would 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 of reserve fuel as that is a logical and safe 

amount of fuel to allow for safe transit to an appropriate alternate landing site. 

sUAS's are capable of landing essentially anywhere within the area in which they 

will be operating because they are small, light and capable of vertical landing. They 

can he landed in a matter of 30 seconds or less in most instances. Warning systems 

on the aircraft provide warning when approximately 20% ofthe flight time remains, 

which provides more than a substantial margin of time in which to safely land the 

aircraft. 

Gorilla Kleen believes that an exemption from 14 C.F.R. §91.15 (a) falls within the 

scope of prior 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 that have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risks that Section 91.151 (a) 

was intended to alleviate given the size and speed of the small UAS. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or 

enough battery reserve to ensure that the sUAS lands at the ground station with at 

least 20% of battery power (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 aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 
repaired as prescribed in part 43 of this chapter ... " and others shall inspect or 

maintain the aircraft in compliance with part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Gorilla Kleen. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating 

handbook as referenced in the manual. An equivalent level of safety 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 of time. If 

mechanical issues arise the sUAS can land immediately and will be operating from 

no higher than 400' AGL. As provided in the manual, the pilot will ensure that the 

sUAS is in working order prior to initiating flight, perform required maintenance, 

and keep a log of any 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 equivalent level of safety. 

******* 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication on 

the Federal Register, should it be 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 of exemptions allowing commercial operations of a sUAS in the cleaning 

industry enhances safety while reducing risk. Manned aircraft monitoring and 

surveying creates a greater risk because the craft are much larger, have combustible 

fuel, and carry an on board human pilot. In contrast, a sUAS weighing fewer than 10 

lbs. and powered by batteries eliminates virtually all of that risk given the reduced 

mass and lack of combustible 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 of small SUAS, weighing less than 10 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from 

the requirements of Part 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 of individuals who have 

consented to being filmed or otherwise have agreed to be in the area where aerial 

photography will take place. 

************* 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 -size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security- provide more than 

adequate justification for the grant of the requested exemptions allowing 

commercial operation of applicants sUAS in the cleaning industry pursuant to the 

manual appended hereto. 

Sincerely, 

President 

Gorilla Kleen 

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