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August 20 th 20015 **From:** Donald Bayles, Owner, UAS Operator, EyeFull Tower Airships Denver, Colorado and Huntington Beach, California Sales Ag ent and UAS Operator for Eblimp , Laguna Hills, California Residence 16400 Saybrook Lane Space 20 Huntington Bea ch, California 92649 Cell Phone 303 946

- 2751 & Larry Fleming; Owner, Manufacturer and UAS Operator Eblim p 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 re lief encompasses a manufacturer, Eblimp and it s com pany UAS operators for nationwide operations of mi niature remote control blim p s 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 back ground**  **2.1** Larry Fleming, the manu facturer and UAS Operator of Eblim p , a subsidiar

y 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 Blim

ps 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 T ower Airships is not included in this petition. Don Bayles is an Operator for Eblim p. **2.3** Larry Fleming, Don Bayles and their operations have fielded multiple requests to fly blimps worldwide for Scientific Research, A dvertising , T elevision , Video production and the P hotography industr y . Enquiries come from all over the US as well from Scientists, Conservationi sts, Agriculturalists, Forestry services , Universities, Colleges, Pre

- college Schools , City Governments, Police, Fire and Rescue, Sports teams, and Advertis ing Agencies to cover a myriad of subjects and formats. **2.4** As these men and their com panies 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 UA S aircraft for the betterment of America and hinders c ommercialization 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 blim p operators meeting Class G request s in the US National Air Space

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**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 Eblim

ps for 3 years. R yan Marsh and Jack Komonee are long time hobby R/C aircraft operators and are exclusive C ontra ct Blimp O perator s for Eblimp. Garrett is em

ployed by Eblim

p 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 c ontract employees for Mr. Fleming and Eblim p. **Petitioned Aircraft 3.2**  The UAS petitioned in this application is for a group of Lighter Than A ir remote controlled mi niature blim ps. **3.3** Guidelines set forth by the FAA , stating craft w eighing less than 4.4 pounds , flying less than 35 MPH and ma de 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 ” , quali fies our mi niature blim p aircraft as Micro UAS aircraft. We wish to pursue th e Micro UAS category , otherwise we will accept a standard UAS authorization to fly within the United States.4

**Blim p 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 me et and lift those payload requirements. **4.2** The airship s’ hull s or envelope s are a non rigid, non metallic, non conductive fabric designed to inflate with non flammable Helium gas. The a irships ’ envelopes contain gas volumes of 60 to 950 cubic feet with an internal pressure of less than 1 pound . This allows the b lim p envelope to “g ive” 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 contro l led 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 “frangibi lity”. **4.4** Anchor points are placed around the envelope s 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 num ber can be affixed to both si des of the nose of the balloon or presented on the fin surfaces , whichever the FAA deem s effective for authorization of flight

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**Power and**  **Altitude Contr** **ol :**  **5.1** The com plete turret style mo tor system and control electronics (servos, speed controls and ground transmitter/receiver electronics) are contained within a carbon fiber housing or Gondola. This motorized Gondola control s up, down, forward and reverse motion. **5.2** To control ascent , decent , forward and reverse motions , 3 phase brushless electric mo tors are mounted with high grade plastic propellers

. Props and mo tors are housed within a safety shroud . Motor assemblies are mated to machined stainless steel motor mo unts 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 mo torized steel cable and wheel pulley drive system

. This gives the blimp up, down, forward and previously mentioned reverses mo tion. **5. 3**  The gondola is attached to the envelope by means of crossed fiberglass rods inserted through po rtholes on top of the gondola . These rods are then inserted into dowel

- like anchor points on the Helium envelope. **Steering C** 

**ontrol S** **urfaces: 5.4**  Side to side or left and right movement are contro lled by servo actuated, tail fin s . Turning power is further enhanced by a brushless mo tor and prop mo unted 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 insure s 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 sim ultaneously 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

**Perform ance and Flight:**  **7.1** Primary lift is derived from

the Helium gas in the envelope and not by forward moti on 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 3 5 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 maxim um flight regulation prescribed for Micro UAS status

. **7.2** Smaller blim

ps would operate in a smaller window of flight, requiring only one operator. Larger scale miniature blimps would require the Primary Operator and one A ssistant that would double as an O bserver within larger flight windows of G cl ass NAS. Communication between Operator and Observer is verbal as the y stand in close proximity of each other thoughout mo st operations. **7.3** F light 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**  **Construct ion &**  **Safety check s:**  **8.1** The blim ps while bein g inflated and constructed and not under power mo des , are constantly anchored to ground weights in multiple locations to ensure redundancy and a safe airship construction. **8.2** While still tethered to moorin g lines and ground weights and b efore 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 safe ly secured. Banners or LED lighting may be attached to display messages and Sponsors. **8 .4**  While moored and system s 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 surface s and servos are check for com plete and free movement. Ballast level is checked again for proper weight and payloads. **8 .5**  Stilled moored, the blimp’s e lectric mo tors are given full throttle to check correct power settings and motor turrets are inspected for propeller shroud clearance and correct rotation al parameters.9

**Launc h**  **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 Opera tor 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 permi ssible to fly over crowds during sporting events and entertainment including but not limited to, concerts, motorsports racing, track & field, Triathlons, surf contests, aquatic animal observation s, beach safety , sailing events, and many other s pectator 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 . M any blim ps are owned and operated by the Venue owners themselves or other private ownership and flown by our Operators . Our manufacturer O perators have trained countless O perators to fly indoor blimps around America and have trained outdoor blimp O perators 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 w ill be mounted to either side of the airship s’ envelope to identify sponsorship. **10 .2**  As clientele dictates , blim ps 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 land s or other restricted areas that would benefit from long UAS blim p 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 B lim ps 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 sy stem s used throughout the w orld. His outdoor UAS Blimps are approved by the Civil Aviation Authority of Isra el and exclusively used by Skyship Israel. He has built and flown his T ethered 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 mi niature blim ps. **10 .5**  Mr. Fleming as a manufacturer and operator of Remote Controlled and Tethered Blimps through Micro Flight and Eblimp , ma intains a $2 million insurance policy. Over the past 10 years he is without a single incident or claim

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**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 w ith 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. **1 1**  **.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 N ational A ir S pace 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. Respec tfully 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: Eblim ps, Micro Flight 23665 Birtcher Drive Manufacturers’ address : Lake Forest, CA 92630 23011 Moulton P arkway Unit G 11 L aguna Hills, CA 92653