1

August 20th 20015

From:

Donald Bayles, Owner, UAS Operator, EyeFull Tower Airships 

Denver, Colorado and Huntington Beach, California

Sales Agent and UAS Operator for Eblimp, Laguna Hills, California

Residence 

16400 Saybrook Lane

Space 20

Huntington Beach, California 92649

Cell Phone 303 946-2751

&

Larry Fleming; Owner, Manufacturer and UAS Operator 

Eblimp a subsidiary of Micro Flight wholly owned by Larry Fleming

23011 Moulton Parkway

Unit G 11

Laguna Hills, CA 92653 

Cell Phone # 949 583-9571

To:

Federal Aviation Administration / the FAA

Subject:

FAA Modernization and Reform Act of 2012, Public Law 112-95 FEB. 

14, 2012, Section 333. Petition for relief.

Summary:

This petition of relief encompasses a manufacturer, Eblimp and its company 

UAS operators for nationwide operations of miniature remote control blimps 

within the United States of America and within the FAA prescribed Class G 

National Air Space throughout the U.S. for commercial purposes.
2

Operator background

2.1 

Larry Fleming, the manufacturer and UAS Operator of Eblimp, a subsidiary 

of Micro Flight Inc., wholly owned by the same named individual, has been 

flying indoor remote controlled blimps throughout the United States and 

outdoor remote controlled blimps for over 10 years commercially throughout 

the world where American FAA regulations have not been applicable. 

2.2

Don Bayles, Owner and Operator of EyeFull Tower Airships of Denver,

Colorado, has been flying tethered blimps in Colorado since 1993 and 

Remote Controlled Blimps inside arenas and convention centers in Denver 

for over 10 years. Don has since moved to Huntington Beach, California to 

receive training from Larry Fleming and Eblimp while retaining his ties to 

Denver, Colorado and his company EyeFull Tower Airships. EyeFull Tower 

Airships is not included in this petition. Don Bayles is an Operator for 

Eblimp.

2.3

Larry Fleming, Don Bayles and their operations have fielded multiple 

requests to fly blimps worldwide for Scientific Research, Advertising, 

Television, Video production and the Photography industry. Enquiries come 

from all over the US as well from Scientists, Conservationists, 

Agriculturalists, Forestry services, Universities, Colleges, Pre-college 

Schools, City Governments, Police, Fire and Rescue, Sports teams, and 

Advertising Agencies to cover a myriad of subjects and formats.

2.4

As these men and their companies have filled many of these requests for 

flights internationally, they now wish to include the outdoor requests in the 

United Sates of America. Current regulations and COA certification inhibits 

the use of UAS aircraft for the betterment of America and hinders

commercialization of this very noteworthy aircraft for almost every industry 

use in the entire country.

2.5

It is Larry and Don’s desire through the company Eblimp in California to be 

the American miniature blimp manufacturer and UAS blimp operators 

meeting Class G requests in the US National Air Space. 
3

Additional Operators

3.1

We also wish to extend this petition to include Eblimp Operators: Keith

Beauregard, Garrett Haines, Ryan K Marsh and Jack Komonee.

Contract Operator Keith Beauregard is in the Film Industry and has been 

flying Eblimps for 3 years.

Ryan Marsh and Jack Komonee are long time hobby R/C aircraft operators

and are exclusive Contract Blimp Operators for Eblimp. 

Garrett is employed by Eblimp and currently flies indoor blimps for the 

professional Hockey team the Anaheim Ducks.

All Operators have received 30 days of outdoor training from Larry Fleming 

and are official Operators and contract employees for Mr. Fleming and 

Eblimp.

Petitioned Aircraft 

 

3.2

The UAS petitioned in this application is for a group of Lighter Than Air

remote controlled miniature blimps.

3.3

Guidelines set forth by the FAA, stating craft weighing less than 4.4 pounds,

flying less than 35 MPH and made out of “frangible materials that break, 

distort, or yield on impact so as to present a minimal hazard to any person or 

object that the unmanned aircraft collides with”, qualifies our miniature 

blimp aircraft as Micro UAS aircraft. We wish to pursue the Micro UAS 

category, otherwise we will accept a standard UAS authorization to fly 

within the United States.
4

Blimp construction:

4.1

These airships range in length from 7 to 40 feet and 40 to 72 inches in 

diameter, depending on the payload requirements. Payloads can range from 

3 ounces to 105 ounces. Payload weight dictates the size & volume of the 

Helium envelope needed to meet and lift those payload requirements. 

4.2

The airships’ hulls or envelopes are a non rigid, non metallic, non 

conductive fabric designed to inflate with non flammable Helium gas. The 

airships’ envelopes contain gas volumes of 60 to 950 cubic feet with an 

internal pressure of less than 1 pound. This allows the blimp envelope to 

“give” creating the “frangible” effect required by the FAA for Micro status.

4.3

A release valve is installed on the gas envelope to control Helium release at 

varied and controlled levels. This allows for slow decent or rapid decent in 

the event of an emergency relating to motor or electronic control failures or 

issues relating to “see and avoid” incidents. By controlling the amount of 

Helium released, will control the rate of decent. This Helium gas pressure 

release system further enhances “frangibility”.

4.4

Anchor points are placed around the envelopes to attach steerable tail fins, 

gondola modules, scientific instrumentation and camera equipment. “Safety 

wires” in the form of nylon zip ties or monofilament line can be utilized to 

enhance onboard safety of attachments if deemed necessary by FAA 

regulations. 

4.5

The FAA serial identification number can be affixed to both sides of the 

nose of the balloon or presented on the fin surfaces, whichever the FAA 

deems effective for authorization of flight.
5

Power and Altitude Control:

5.1

The complete turret style motor system and control electronics (servos, 

speed controls and ground transmitter/receiver electronics) are contained 

within a carbon fiber housing or Gondola. This motorized Gondola controls 

up, down, forward and reverse motion.

5.2

To control ascent, decent, forward and reverse motions, 3 phase brushless 

electric motors are mounted with high grade plastic propellers. Props and 

motors are housed within a safety shroud. Motor assemblies are mated to 

machined stainless steel motor mounts which are attached to the ends of a 

carbon fiber rod and the rod inserted through portholes on either side of the 

gondola. The carbon rod is rotated 270 degrees through a motorized steel 

cable and wheel pulley drive system. This gives the blimp up, down, forward 

and previously mentioned reverses motion.

5.3

The gondola is attached to the envelope by means of crossed fiberglass rods 

inserted through portholes on top of the gondola. These rods are then 

inserted into dowel-like anchor points on the Helium envelope.

Steering Control Surfaces:

5.4

Side to side or left and right movement are controlled by servo actuated, tail 

fins. Turning power is further enhanced by a brushless motor and prop 

mounted in the lower tail fin. Other fins are located along the envelope in 

various locations to enhance steering, forward tracking and stability.

5.5

The fin assemblies are mated to the envelope with Velcro-like material on 

the base of the fin and then attached to the Helium envelope. Guy wires 

attached to the fins and to the helium envelope act as safety attachment wires 

as well as fin attitude adjustment points. 
6

Electrical Power:

6.1

Power is supplied by Nickel Cadmium (Ni-Cad) or Lithium (Li-Poly) 

batteries. These are easily purchased at most hobby stores ranging in size 

from 2,000 to 8,000 MaH. Solar assistance is being investigated but not 

valid in the configurations currently produced and operated. 

Operator Ground Controls:

6.2

Ground controls for the Operator are standardized Spektrum brand 2.4 GHz 

digital transmitter radios. They may be obtained at most Hobby Craft 

retailers and internet stores throughout the US and the world.

6.3

Spektrum branded digital remotes have a “Bind and Fly” application which 

insures quick mating and pairing of controls to the aircraft as well as 

Spektrum’s DSM2 and DSMX technology which increases frequency band 

signal width to lessen the chance of “on channel interference”.

6.4

Per Spectrum Remote Control owner’s manuals “By adding the agility of 

frequency shifts to the superior interference resistance of a wideband signal, 

DSMX is far less likely to suffer data loss from on-channel interference.” 

They further state, “In multiple tests, 100 DSMX systems were operated 

simultaneously for extended periods of time.” “In every test not a single case 

of RF link loss, latency or control degradation was experienced or recorded.”
7

Performance and Flight:

7.1

Primary lift is derived from the Helium gas in the envelope and not by 

forward motion of the aircraft. The airships’ greatest assets are to hover in 

place or move forward at extremely low speeds and the ability to also fly in 

reverse direction. The maximum speed set forth by Micro UAS regulation is 

35 MPH. As flight speed is not a requirement for lift, the blimps move at 

slower speeds than fixed wing aircraft. Additional power is available to 

overcome inherent wind conditions but forward blimp motion it is not 

expected to exceed the 35mph maximum flight regulation prescribed for 

Micro UAS status. 

7.2

Smaller blimps would operate in a smaller window of flight, requiring only 

one operator. Larger scale miniature blimps would require the Primary 

Operator and one Assistant that would double as an Observer within larger 

flight windows of G class NAS. Communication between Operator and 

Observer is verbal as they stand in close proximity of each other thoughout 

most operations.

7.3

Flight durations vary from 20 minutes up to 3 hours with possibilities for 

longer flights with further development and battery improvements along 

with potential solar panel operation. 

7.4

Once payloads have been attached and ballast has been applied, normal 

flight gross weight should be 1 to 3 pounds to readily maintain Micro UAS 

requirements.
8

Pre-Flight Construction & Safety checks: 

8.1

The blimps while being inflated and constructed and not under power

modes, are constantly anchored to ground weights in multiple locations to 

ensure redundancy and a safe airship construction. 

8.2

While still tethered to mooring lines and ground weights and before any 

electrical systems are attached, the envelope is given a complete visual 

inspection for leaks, tears and pin holes that would cause premature Helium 

loss. A simple adhesive patch is applied to complete repairs.

8.3

Once envelope integrity is complete, steering fins and the power gondola are 

attached as well as other instruments such as cameras and gimbals and safely 

secured. Banners or LED lighting may be attached to display messages and 

Sponsors.

8.4

While moored and systems are in place, all anchor points for fins and 

equipment are checked for proper attachment and necessary safety ties. Once 

electrical power is initiated, all control surfaces and servos are check for 

complete and free movement. Ballast level is checked again for proper 

weight and payloads.

8.5

Stilled moored, the blimp’s electric motors are given full throttle to check 

correct power settings and motor turrets are inspected for propeller shroud 

clearance and correct rotational parameters.
9

Launch and Landing

9.1

Launch is a simple push skyward to clear ground obstructions. Turrets are 

rotated forward and slightly upward and full throttle is applied to clear the 

takeoff area ground space.

9.2

Landings are simply returned to the area of the Operator and slowly landed 

into the hand of the Operator or the Observer.

Flight Windows of Operation

9.3

Because the best image capture is done at lower altitudes, we propose to 

operate most of our blimp flights between 50 and 200 feet, with upper 

reaches of 300 feet. The blimps’ flights are kept in line-of sight, under 

normal conditions of 1,000 feet in distance. Both measurements for height 

and distance are substantially below the FAA’s standards of 400 foot ground 

level and 1,500 foot distance requirements set for UAS aircraft. 

9.4

As described, this aircraft group, in weight, speed, flight altitude, flight 

distances and “frangibility” according to FAA, meets UAS Micro aircraft 

guidelines. 

9.5

Under Micro UAS guidelines and regulations it would be permissible to fly 

over crowds during sporting events and entertainment including but not 

limited to, concerts, motorsports racing, track & field, Triathlons, surf 

contests, aquatic animal observations, beach safety, sailing events, and many 

other spectator activities. The ability of this Blimp UAS, to fly at low 

elevations for long periods of time lends itself to many scientific studies and 

observation of subjects deemed dangerous to human life or limb.

9.6

As a note of record, our operator group has been flying inside enclosed 

arenas across the nation, over crowds and spectators for over 10 years. Many

blimps are owned and operated by the Venue owners themselves or other 

private ownership and flown by our Operators. Our manufacturer Operators 

have trained countless Operators to fly indoor blimps around America and 

have trained outdoor blimp Operators in Mexico and Israel for many years.
10

Flight Objectives

10.1

Our primary functions are photography, cinema photography, video 

recording of outdoor events and flying advertisement. Banners and signage 

will be mounted to either side of the airships’ envelope to identify 

sponsorship. 

10.2

As clientele dictates, blimps can also be involved in forest and wildlife 

conservation, aerial surveying and water conservation in California or other 

western states that may need longer flight durations than current fixed wing 

or rotor style UAS craft can maintain. These activities would most likely 

require individual COA’s in the likelihood of Governmental projects on 

public lands or other restricted areas that would benefit from long UAS 

blimp flights.

Of Historical Record

10.3

As previously stated, Larry Fleming of Eblimp and Micro Flight in Laguna 

Hills, California is a manufacturer of Remote Controlled Blimps for indoor 

and outdoor use. 

10.4

As a manufacturer Mr. Fleming has perfected electric motor powered drive 

trains and remote control camera units for his blimp systems used 

throughout the world. His outdoor UAS Blimps are approved by the Civil 

Aviation Authority of Israel and exclusively used by Skyship Israel. He has 

built and flown his Tethered and Remote Controlled blimps all over the 

world for the past 10 years, receiving 1000’s of hours of flight time and 

trained scores of operators to safely fly his manufactured miniature blimps.

10.5

Mr. Fleming as a manufacturer and operator of Remote Controlled and 

Tethered Blimps through Micro Flight and Eblimp, maintains a $2 million 

insurance policy. Over the past 10 years he is without a single incident or 

claim.
11

11.1

Don Bayles owner/operator of EyeFull Tower Airships has been flying 

tethered balloons and blimps in rarified atmospheres of Colorado since 1993 

and remote controlled blimps since 2001 in Denver, Colorado accruing over 

500 hours of experience. Don has worked with radio stations, major rock 

bands and professional sports teams flying both tethered and remote 

controlled blimp systems. Mr. Bayles is an active member of the Academy 

of Model Aeronautics and a proponent of “know before you fly”. Don has 

since moved from Denver, Colorado to Huntington Beach, California to 

work closely with Larry Fleming, Micro Flight and Eblimp.

11.2

In Conclusion: 

Larry Fleming along with Donald Bayles, Garrett Haines, Keith Beauregard

and Jack Komonee petition the FAA for relief of restricted flight 

requirements and obtain FAA approval for UAS and Micro UAS flight 

status in regards to miniature remote controlled blimps in Class G National 

Air Space under the FAA Modernization and Reform Act of 2012, Public 

Law 112-95 FEB. 14, 2012, Section 333.

Their years of flight experience and safety record in so many geographic 

locations, elevations and diverse atmospheric conditions, makes this group

of operators and this form of UAS a logical exception for the 333 petition 

approval. 

Respectfully submitted,

Donald Bayles:

EyeFull Tower Airships

16400 Saybrook Lane 

Unit 20

Huntington Beach, Ca 92649

Cell 303 946-2751

Email: dronesky@gmail.com

Larry Fleming: Residence:

Eblimps, Micro Flight 23665 Birtcher Drive

Manufacturers’ address: Lake Forest, CA 92630

23011 Moulton Parkway

Unit G 11

Laguna Hills, CA 92653