December 6, 2015 United States Department ofTransportation Docket Management System 1200 NewJersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590 

### Re: ExemptionRequest Pursuant To Section 333 oftheFAAReform Act of2012 Dear Sir or Madam: Iam writing pursuanttothe FAA Modernization and Reform Act of2012 (the "Reform Act") and the procedures contained in 14 C.F.R. 11, to request that GNARLYCAT PRODUCTIONS, owned and operated by Gregory Nolan, and as ownerand operator ofsmall unmanned aircraft be exempted from the Federal Aviation Regulations ("FARs") listed below so that GNARLYCAT PRODUCTIONS may operate its small unmanned aircraft/lightweight unmanned aircraft systems )"UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA"). Primary uses will be low altitude aerial photographyfor use on websites, print pieces and video for client use. Gregory Nolan has operated his current UAS on many occasions non-commerciallywithout incident. The UAS utilizes battery power, not combustible fuels. Flight time ranges between five and twenty minutes. The UAS has GPS functionalityto hover in place as well as a return to home function in case of loss ofcontact with the radio. It has an audible and visual warning system and will startto descend slowly ifbattery power reaches 25%. The failsafe software will disable the UAS from taking offand also limitthe UAS system from operating within specific GPS preset no-fly zones. GNARLYCAT PRODUCTIONS exemption request would permit its operation of lightweight, unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace. Currently, similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, safety plan or controls in place to prevent catastrophe. It is only logical to allow GREGORY NOLAN, an experienced remote control pilot, to operate similar lightweight UASs. This will act to furthersafety protocols specific to lightweight UASs as GNARLYCAT PRODUCTIONS research flight data and other information gained through permitted flight operation. Grantingthis request comports with the Secretary of Transportation's (FAA Administrator's) responsibilities to not only integrate UASs intothe national airspace system, butto "

...establish requirementsforthe safe operation ofsuch aircraft systems (UASs) in the national airspace system" underSection 333© ofthe reform ACT. Further, GNARLYCAT PRODUCTIONS will conduct its operations in compliance with the protocols described herein oras otherwise established by the FAA. Forthe reasons stated below, GNARLYCAT PRODUCTIONS respectfully request the grant ofan exemption allowing itto operate lightweight, remote controlled UASs. 

### 1. ContactInformation:GREGORY NOLAN
2257 Lake Drive Dunedin, Florida 34698 Tel: (727) 785-2006 E-mail: canudigitbro@yahoo.com 

### 2. The Specific Sections ofTitle 14 ofthe Code ofFederalRegulations from Which I Request Exemption are: 14CFR 21: 14 C.F.R. 45.23 (b):
14CFR 61m113 (a) 

### &(b): 14 C.F.R. 91, etseq.: 14CFR 407 (a) (1): 14 CFR 409 (a) (2):
14CFR 417 (a) 

### & (b). U.S Dep'tofTrans. 

### 3. TheExtentofReliefGNARL YCATPRODUCTIONS Seeks and the Reason It

### Seeks Such Relief: GNARLYCAT PRODUCTIONS submits thisapplication in accordance withthe Reform Act, 112 P.L. 95§§ 331-334, seeking relieffrom any currently applicable FARs operating incinematic, research and otherflight operations withinthe national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems intoour National airspace system as it is in the public's interestto do so. My lightweight UAS meetsthe definition of 11Small unmanned aircraft" as defined in Section 331 and thereforethe integration of my lightweight UAS is expressly contemplated bythe Reform Act. Iwould liketooperate ou;r lightweight UAS priortothetime period bywhich the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determiningthetypes of UASs that may operate Safely in our national airspace system. Considerations include:

• The weight, size, speed and overall capabilities ofthe UAS: • Whetherthe UAS will be operated nearairports or populated areas: and, • Whetherthe UAS will be operated by line ofsight.
112 P.L. 95 § 333 (a). Each ofthese items militates in favor ofan exemption forGNARLYCAT PRODUCTIONS. My UAS utilizes four counter-rotating propellers forextreme balance, control and stability. It weighs less than 7 pounds, including batteryand all equipment.This small unmanned aircraft is designed to primarily hover in place and operate at less than a SO knot maximum speed. It is,- 

### '""

capable ofvertical and horizontal operation but operate onlywithin the line ofsight ofthe remote control pilot. In addition to the remote control pilot, I use a spotter, such that, at minimum, two GNARLYCAT PRODUCTIONS personnel govern the safe flight ofthe aircraft at all times. Utilizing battery power and not combustible fuels, flights generally last between five and twenty minutes. I do not operate the UAS with less than twentyfive percent battery capacity. Safety systems in place include a GPS modethat allowsthe UAS to hover in place or return totakeoff location ifcommunication with the radio control pilot is lost and then slowly descend the UAS at twentyfive percent battery capacity. I generally do not operate the UAS near airports or near populated areas. To date, I have onlyoperated the UAS in a non-commercial manner. My operation ofthis small unmanned aircraft will not "create a hazard to users ofthe national airspace system orthe public." 112 P.L. 95 § 

### 333 (b). Given the small size and weight ofthe UAS, combined with its operation in cordoned offand well-controlled areas, thisfalls within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UASs intothe national airspace system. Indeed, our UAS will not pose anythreattothe general public or national security. The FAA has the authorityto issue the exemption sought by GNARLYCAT PRODUCTIONS pursuanttothe Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

### 4. How this RequestWill BenefitthePublic As A Whole: Granting this exemption request furthersthe public interest. Congress has already pronounced that it is in the public's interestto integrate commercially flown UASs intothe national airspace system, hence the passing ofthe Reform Act. GNARLYCAT PRODUCTIONS conduct research into safe UAS operations everytime itflies its UAS. Flight data, visual inspections, recorded observations and flight analyses are compiled tofurtherenhance current safety protocols. Allowing us to log moreflight time directly relates to my research and my abilityto further enhance current safety measures. Furthermore, the public has an interest in reducing the dangerand emission associated with current aerial cinematic capture methods, namely, full size helicopters. My UAS is battery powered and creates no emissions. Ifmy UAS crashes there is no fuel to ignite and explode. The impact of my lightweight UAS is negligible when compared to a full size helicopter, notwithstandingthe statistically noteworthysafety record offull size helicopters used in motion picture capture. The public's interest is furthered by minimizing ecological and crash impacts by permitting photo and motion picture capture through my lightweight UAS. Progression ofthe arts and sciences has been fundamental to oursociety since its inclusion in the United States Constitution. Congress mandated the integration of UASs into our national airspace system, in part, to achieve progression in this noteworthyand inevitable field. Permitting GNARLYCAT PRODUCTIONS to immediatelyfly withinthe United States furthers these goals. Whether it is the amalgam ofscientific discoveries applicable to feature film making (including those drawing upon architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies oradvancements in equipmentavailable to law enforcement personnel, first responders thatdoes notcost millions ofdollars, grantingthisexemption request substantially furthersthe public's interest in ways known and currently unknown. Grantingthis request will also allow small business owners and home owners to be able to afford high qualityaerial images and videothattheywould otherwise have no access to due to several factors, cost being the biggest. 

### 5. Reasons Why GNARLYCATPRODUCTIONS Exemption Will NotAdversely Affect Safety OrHow TheExemption Will Provide a Level ofSafety AtLeastEqual To ExistingRule: This exemption will not adversely affect safety. Quite the contrary, forthe reasons stated previously, permittingGNARLYCAT PRODUCTIONS to log moreflighttime in FAA controlled airspace will allow us to innovate and implement newand novel, as ofyet undiscovered safety protocols. In addition, I submit the following representations ofenhancements to current aerial photo and motion picture capture techniques:

• My UAS weighs less than 7 pounds complete with all mounted equipment and battery: • I only operate My UAS below400feet: • My UAS only operates for 5-20 minutes perflight: • I land my UAS when it reaches 25% battery power:

• I operate the UAS by line ofsight:

• I have video backup should I somehow lose sight ofthe UAS:

• I use a spotterwith communication systems Enabling real time communication between us:

• My UAS has GPS flight modes whereby it hovers, returns totakeoff position and then Slowly lands ifcommunication with the remote control pilot is lost or battery power Is below 25%:

• I actively analyze electronicflight data and othersources ofinformation to constantly Update and enhance safety protocols:

• I conduct extensive briefings priortoflight during which safety carries primary importance:

• I have procedures in place to abortflights in the event ofsafety breaches or potential Danger. 

## * I have alreadytaken a college level informational class on drone operations and safety and plan to get myground pilots license as soon as possible. Mysafety protocols provide a level ofsafety at least equal to existing rules and in nearly every instance greaterthan existing rules. It is importantto notethat absentthe integration of commercial UASs into our national airspace system, helicopters are the primary means ofaerial motion picture capture. While the safety record ofsuch helicopters is remarkably astounding, it is far saferto operate a battery powered lightweight UAS. The potential loss of life is diminished because UASs carry no people on board and GNARLYCAT PRODUCTIONS only operatesthem in specific areas away from mass populations. There is no fuel on board a UAS and thus thepotential forfire orexplosions is greatly diminished. The small size and extreme maneuverability ofour UAS allows our remote control pilotto avoid hazards. Given their small size and weight, even when close enough to capture amazing images, our UAS needs not be so close tothe objects it is focused on. Accordingly, my UAS has operated and will continue tooperate at and above current safety levels. 

### 6. Summary: A. 14C.F.R. 21 and 14 C>F>R> 91: Airworthiness certificates and Manuals.
14C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(1). The size, weight and enclosed operational area ofGNARLYCAT PRODUCTIONS UAS permits exemption from Part 21 because GNARLYCAT PRODUCTIONS UAS meets an equivalent level ofsafety pursuant to Section333 ofthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAA to exempt UASs from the airworthiness certificate requirement in consideration ofthe weight, size speed, maneuverabilityand proximityto areas such as airports and dense populations. GNARLYCAT PRODUCTIONS UAS meets orexceeds each ofthe elements.
14 C.F.R. 91.7(a) prohibitsthe operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated bythe FARs, this Regulation is inapplicable.
14 C.F.R § 91.9(b) (2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual atthe flight operations center. The FAA has previously issued exemptions totheir regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700and 32827. 14C.F.R. § 91.121 regarding altimetersettings is inapplicable insofar as GNARLYCAT PRODUCTIONS utilizes electronic global positioning systems and internal gyroscopes to provide spatial coordination.
14 C.F.R. § 91.203 (a)) and (b) provides forthe carrying ofcivil aircraft certifications and registrations. They are inapplicable forthe same reasons described above. The equivalent level ofsafetywill be achieved by maintaining such certifications and registrations atGNARLYCAT PRODUCTIONS flight operations center. B. 14C.F.R § 45.23: Marking ofthe Aircraft. Applicable Codes of Federal Regulation require aircraftto be marked according to certain specifications. GNARLYCAT PRODUCTIONS UAS is, by definition, unmanned. Ittherefore does not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficultto place on such small aircraft. Regardless, GNARLYCAT PRODUCTIONS will mark its UAS in the largest possible lettering by placingthe wordv'

"EXPERIMENTAL" on its fuselage as required by 14 C.F.R. § 45.29(f) so thatthe pilot, technician, spotter and others working with the UAS will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuantto 14 C.F.R.§§ 61.113 (a) 

### & (b) private pilots are limited to non-commercial operations. GNARLYCAT PRODUCTIONS can achieve an equivalent level ofsafetyas achieved by current regulations because GNARLYCAT PRODUCTIONS UAS does not carry any pilots or passengers. Furthermore, while helpful, a pilot license will not ensure remote control piloting skills. The risks attendantto the operation of GNARLYCAT PRODUCTIONS UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R.§ 61, et seq. Thus, allowing GNARLYCAT PRODUCTIONS to operate its UAS with a private pilot as the pilot in control will exceed current safety levels in relation to 14 C.F.R. § 61.113 (a) 

### & (b). D. 14 C.F.R. 91.119: Minimum Safe Altitudes.
14 C.F.R. § 91.119 prescribes safe altitudesforthe operation ofcivil aircraft. It allows helicopters to be operated at loweraltitudes in certain conditions. GNARLYCAT PRODUCTIONS will never operate atan altitude greaterthan 400AGL GNARLYCAT PRODUCTIONS will, however, operate its UAS in cordoned offareas with security perimeters, providing a level ofsafety at least equivalentto those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofGNARLYCAT PRODUCTIONS UAS, an equivalent level ofsafety will be achieved.
E. 14 C.F.R. 91.405 (a) (2); 417 (a) 

### & (b): Maintenance Inspections. The above cited Regulations require, amongst otherthings, aircraft owners and operatorsto "have aircraft inspected as prescribed in subpart Eofthis part and shall between required inspection, except as provided in paragraph 

### © ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter.

..." These Regulations only applyto aircraftwith an airworthiness certificate. Therefore, they will not applyto GNARLYCAT PRODUCTIONS should its requested exemption be granted. GNARLYCAT PRODUCTIONS conducts as extensive maintenance program that involves regular software updates and curative measuresfor any damaged hardware.Therefore, an equivalent level ofsafety will be achieved. F. Summary GNARLYCAT PRODUCTIONS seeks an exemption from the following Regulations: 14C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) 

### & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R § 91.9 (b)(2); 14 C.F.R.§ 91.103(b); 14 C.F.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; C.F.R. § 91.151 (a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a)(2);14 C.F.R. § 91.409 (a)(2);and 14 C.F.R.§§ 91.417 (a) 

### & (b) to commercially operate its lightweight unmanned aircraft in motion picture or photography operations and to conduct its own research. Granting GNARLYCAT PRODUCTIONS requestfor exemption will reduce current risk levels and thereby enhance safety. Currently motion picture image captureJ,- •

relies primarily on the use of larger aircraft running combustible fuel. GNARLYCAT PRODUCTIONS aircraft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional motion picture aircraft. GNARLYCAT PRODUCTIONS operates at loweraltitudes and in controlled airspace. GNARLYCAT PRODUCTIONS has been analyzing flight data and other information in compiling novel safety protocols and the implementation of aflight operations manual that exceeds currently accepted means and methods ofsafe flight. There are no people on board GNARLYCAT PRODUCTIONS UAS and thereforethe likelihood of death orserious bodily injury is significantly limited. GNARLYCAT PRODUCTIONS operation ofits UAS, weighing less than 5 pounds and travelling at speeds lowerthan SO knots in cordoned off areas will provide at least an equivalent level ofsafety as that achieved under current FARs. Accordingly, GNARLYCAT PRODUCTIONS respectfully requests thatthe FAA grant its exemption request without delay. The FAA has the authorityto issue the exemption sought by GNARLYCAT PRODUCTIONS pursuant tothe Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act"). In closing, GNARLYCAT PRODUCTIONS would like to state that itwould be very easy to ignore the FAA and operate a UAS commercially without applying for any consideration from them. I have seen and spoken with several people who are already doing so.I hope the simple factthat someone such as myself, who operates avery small business and will be operating a UAS on a very small scale is applying forthis exemption shows how serous I am about safety and doing things properly. Thank you foryourtime and consideration. Respectfully submitted, Gregory Nolan Owner/Operator2257 Lake Drive, Dunedin, Florida 34698

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# IS Appendix Specifications

Aircraft Model Weight (Battery Included) Hovering Accuracy (P Mode)

Max AngularVelocity Max Tilt Angle Max Ascent Speed Max Descent Speed Max Speed Max Flight Altitude Max Wind Speed Resistance Max Flight Time Motor Model Propeller Model Indoor Hovering Operating Temperature Range Diagonal Distance Dimensions Gimbal Model Output Power (With Camera) Operating Current Angular Vibration Range Mounting Controllable Range

Mechanical Range

Max Controllable Speed T600 2935 g Vertical: 0.5 m Horizontal: 2.5 m Pitch: 300°/S Yaw: 150°/S

5m/s 4 m/s 22 m/s (A Til mode, no wind) 4500m 10 m/s Approximately 18 minutes DJI3510 DJI 1345 Enabled by default -10° to 40° C 559to 581 mm 438x451x301 mm

ZENMUSEX3 Static: 9 W; In Motion: 11 W Station: 750 rnA; Motion: 900 rnA

Detachable Pitch: -90° to +30° Pan: ±320° Pitch: -125° to +45° Pan: ±330° Pitch: 120°/S Pan: 180°/S (.",.J'l '**~-.)**

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