December 6, 2015 

United States Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 Washington, DC 20590 

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 

Dear Sir or Madam: 

I am writing pursuant to the FAA Modernization and Reform Act of 2012 (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 owner and operator of small 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 photography for use on websites, print pieces and video 

for client use. 

Gregory Nolan has operated his current UAS on many occasions non-commercially without 

incident. The UAS utilizes battery power, not combustible fuels. Flight time ranges between five 

and twenty minutes. The UAS has GPS functionality to hover in place as well as a return to home 

function in case of loss of contact with the radio. It has an audible and visual warning system 

and will start to descend slowly if battery power reaches 25%. The failsafe software will disable 

the UAS from taking off and also limit the UAS system from operating within specific GPS preset 

no-fly zones. 

GNARL YCAT 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 further safety protocols specific to lightweight UASs as 

GNARLYCAT PRODUCTIONS research flight data and other information gained through 

permitted flight operation. Granting this request comports with the Secretary of 

Transportation's (FAA Administrator's) responsibilities to not only integrate UASs into the 

national airspace system, but to " ... establish requirements for the safe operation of such aircraft 

systems (UASs) in the national airspace system" under Section 333© of the reform ACT. Further, 

GNARLYCAT PRODUCTIONS will conduct its operations in compliance with the protocols 

described herein or as otherwise established by the FAA. 

For the reasons stated below, GNARLYCAT PRODUCTIONS respectfully request the grant of an 

exemption allowing it to operate lightweight, remote controlled UASs. 

1. Contact Information: 
GREGORY NOLAN 

2257 Lake Drive 

Dunedin, Florida 34698 

Tel: (727) 785-2006 

E-mail: canudigitbro@yahoo.com 

2. The Specific Sections of Title 14 of the Code ofFederal Regulations from Which I Request 

Exemption are: 

14CFR 21: 

14 C.F.R. 45.23 (b): 

14 CFR 61m113 (a) & (b): 14 C.F.R. 91, et seq.: 

14 CFR 407 (a) (1): 

14 CFR 409 (a) (2): 

14 CFR 417 (a) & (b). U.S Dep't ofTrans. 

3. The Extent ofReliefGNARL YCAT PRODUCTIONS Seeks and the Reason It Seeks Such 

Relief: 

GNARLYCAT PRODUCTIONS submits this application in accordance with the Reform Act, 112 P.L. 

95§§ 331-334, seeking relief from any currently applicable FARs operating in cinematic, research 

and other flight operations within the national airspace system. The Reform Act in Section 332 

provides for such integration of civil unmanned aircraft systems into our National airspace 

system as it is in the public's interest to do so. My lightweight UAS meets the definition of 11Small 

unmanned aircraft" as defined in Section 331 and therefore the integration of my lightweight 

UAS is expressly contemplated by the Reform Act. I would like to operate ou;r lightweight UAS 

prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft. 

The Reform Act guides the Secretary in determining the types of UASs that may operate Safely 

in our national airspace system. Considerations include: 

• The weight, size, speed and overall capabilities of the UAS: 

• Whether the UAS will be operated near airports or populated areas: and, • Whether the UAS 

will be operated by line of sight. 

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for GNARLYCAT 

PRODUCTIONS. 

My UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It 

weighs less than 7 pounds, including battery and 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 
,-

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capable of vertical and horizontal operation but operate only within the line of sight of the 

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 twenty five percent battery capacity. Safety 

systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff 

location if communication with the radio control pilot is lost and then slowly descend the UAS at 

twenty five percent battery capacity. I generally do not operate the UAS near airports or near 

populated areas. To date, I have only operated the UAS in a non-commercial manner. 

My operation ofthis small unmanned aircraft will not "create a hazard to users ofthe national 

airspace system or the public." 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS, 

combined with its operation in cordoned off and well-controlled areas, this falls within 

Congress's contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UASs into the national airspace system. Indeed, our UAS 

will not pose any threat to the general public or national security. 

The FAA has the authority to issue the exemption sought by GNARL YCAT PRODUCTIONS 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

4. How this Request Will Benefit the Public As A Whole: 

Granting this exemption request furthers the public interest. Congress has already pronounced 

that it is in the public's interest to integrate commercially flown UASs into the national airspace 

system, hence the passing ofthe Reform Act. GNARLYCAT PRODUCTIONS conduct research into 

safe UAS operations every time it flies its UAS. Flight data, visual inspections, recorded 

observations and flight analyses are compiled to further enhance current safety protocols. 

Allowing us to log more flight time directly relates to my research and my ability to further 

enhance current safety measures. Furthermore, the public has an interest in reducing the 

danger and emission associated with current aerial cinematic capture methods, namely, full size 

helicopters. My UAS is battery powered and creates no emissions. If my 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, notwithstanding the statistically noteworthy safety record of full 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 of the arts and sciences has been fundamental to our society 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 noteworthy and inevitable field. 

Permitting GNARLYCAT PRODUCTIONS to immediately fly within the United States furthers 

these goals. Whether it is the amalgam of scientific discoveries applicable to feature film making 

(including those drawing upon architecture, physics, engineering and cultural inclusiveness) to 

advancements in publicly usable technologies or advancements in equipment available to law 

enforcement personnel, first responders that does not cost millions of dollars, granting this 
exemption request substantially furthers the public's interest in ways known and currently 

unknown. 

Granting this request will also allow small business owners and home owners to be able to 

afford high quality aerial images and video that they would otherwise have no access to due to 

several factors, cost being the biggest. 

5. Reasons Why GNARL YCAT PRODUCTIONS Exemption Will Not Adversely Affect Safety 

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

This exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

previously, permitting GNARLYCAT PRODUCTIONS to log more flight time in FAA controlled 

airspace will allow us to innovate and implement new and novel, as of yet undiscovered safety 

protocols. In addition, I submit the following representations of enhancements 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 below 400 feet: 

• My UAS only operates for 5-20 minutes per flight: 

• I land my UAS when it reaches 25% battery power: 

• I operate the UAS by line of sight: 

• I have video backup should I somehow lose sight of the UAS: 

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

• My UAS has GPS flight modes whereby it hovers, returns to takeoff position and then Slowly 

lands if communication with the remote control pilot is lost or battery power Is below 25%: 

• I actively analyze electronic flight data and other sources of information to constantly Update 

and enhance safety protocols: 

• I conduct extensive briefings prior to flight during which safety carries primary importance: 

• I have procedures in place to abort flights in the event of safety breaches or potential Danger. 

* I have already taken a college level informational class on drone operations and safety and 

plan to get my ground pilots license as soon as possible. 

My safety protocols provide a level of safety at least equal to existing rules and in nearly every 

instance greater than existing rules. It is important to note that absent the integration of 

commercial UASs into our national airspace system, helicopters are the primary means of aerial 

motion picture capture. While the safety record of such helicopters is remarkably astounding, it 

is far safer to operate a battery powered lightweight UAS. The potential loss of life is diminished 

because UASs carry no people on board and GNARLYCAT PRODUCTIONS only operates them in 

specific areas away from mass populations. There is no fuel on board a UAS and thus the 
potential for fire or explosions is greatly diminished. The small size and extreme maneuverability 

of our UAS allows our remote control pilot to avoid hazards. Given their small size and weight, 

even when close enough to capture amazing images, our UAS needs not be so close to the 

objects it is focused on. Accordingly, my UAS has operated and will continue to operate at and 

above current safety levels. 

6. Summary: 

A. 14 C.F.R. 21 and 14 C>F>R> 91: Airworthiness certificates and Manuals. 

14 C.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 of GNARL YCAT PRODUCTIONS UAS permits exemption 

from Part 21 because GNARLYCAT PRODUCTIONS UAS meets an equivalent level of safety 

pursuant to Section333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the 

airworthiness certificate requirement in consideration of the weight, size speed, 

maneuverability and proximity to areas such as airports and dense populations. GNARL YCAT 

PRODUCTIONS UAS meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 C.F.R § 91.9(b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a manual at the flight operations center. The FAA has 

previously issued exemptions to their regulation in Exemption Nos 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14C.F.R. § 91.121 regarding altimeter settings 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 for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining such certifications and registrations at GNARLYCAT 

PRODUCTIONS flight operations center. 

B. 14 C.F.R § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. GNARLYCAT PRODUCTIONS UAS is, by definition, unmanned. It therefore does 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is difficult to place on such small aircraft. Regardless, GNARLYCAT 

PRODUCTIONS will mark its UAS in the largest possible lettering by placing the word 
v' 

"EXPERIMENTAL" on its fuselage as required by 14 C.F.R. § 45.29(f) so that the 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. Pursuant to 14 C.F.R.§§ 61.113 

(a) & (b) private pilots are limited to non-commercial operations. GNARLYCAT PRODUCTIONS 

can achieve an equivalent level of safety as 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 attendant to 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 altitudes for the operation of civil aircraft. It allows helicopters 

to be operated at lower altitudes in certain conditions. GNARLYCAT PRODUCTIONS will never 

operate at an altitude greater than 400 AGL GNARLYCAT PRODUCTIONS will, however, operate 

its UAS in cordoned off areas with security perimeters, providing a level of safety at least 

equivalent to those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of GNARLYCAT PRODUCTIONS UAS, an equivalent level of safety will 

be achieved. 

E. 14 C.F.R. 91.405 (a) (2); 417 (a) & (b): Maintenance Inspections. 

The above cited Regulations require, amongst other things, aircraft owners and operators to 

"have aircraft inspected as prescribed in subpart E ofthis part and shall between required 

inspection, except as provided in paragraph © ofthis section, have discrepancies repaired as 

prescribed in part 43 ofthis chapter. ... " 

These Regulations only apply to aircraft with an airworthiness certificate. Therefore, they will 

not apply to GNARLYCAT PRODUCTIONS should its requested exemption be granted. 

GNARLYCAT PRODUCTIONS conducts as extensive maintenance program that involves regular 

software updates and curative measures for any damaged hardware. Therefore, an equivalent 

level of safety will be achieved. 

F. Summary 

GNARLYCAT PRODUCTIONS seeks an exemption from the following Regulations: 14 C.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 request for exemption will 

reduce current risk levels and thereby enhance safety. Currently motion picture image capture 
J,- • 

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 lower altitudes and in controlled airspace. GNARLYCAT PRODUCTIONS has been analyzing 

flight data and other information in compiling novel safety protocols and the implementation of 

a flight operations manual that exceeds currently accepted means and methods of safe flight. 

There are no people on board GNARLYCAT PRODUCTIONS UAS and therefore the likelihood of 

death or serious bodily injury is significantly limited. GNARLYCAT PRODUCTIONS operation of its 

UAS, weighing less than 5 pounds and travelling at speeds lower than SO knots in cordoned off 

areas will provide at least an equivalent level of safety as that achieved under current FARs. 

Accordingly, GNARLYCAT PRODUCTIONS respectfully requests that the FAA grant its exemption 

request without delay. The FAA has the authority to issue the exemption sought by GNARLYCAT 

PRODUCTIONS pursuant to the Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act"). 

In closing, GNARLYCAT PRODUCTIONS would like to state that it would 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 fact that 

someone such as myself, who operates a very small business and will be operating a UAS on a 

very small scale is applying for this exemption shows how serous I am about safety and doing 

things properly. Thank you for your time and consideration. 

Respectfully submitted, 

Gregory Nolan Owner/Operator 2257 Lake Drive, Dunedin, Florida 34698 
. ..... 

IS 

Appendix 

Specifications 

Aircraft 

Model 

Weight (Battery Included) 

Hovering Accuracy (P Mode) 

Max Angular Velocity 

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 

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57