### 3 7 Camino Celeste San Clemente, California 92673 July 31, 2015
U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., SE Washington DC 20590
Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(l) and (2); 91.417(a) and (b).
Dear Sir- or Madam, Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 (the "ReformAct") and 14 C.F.R. Part 11, Glide Aerials, LLC, a CaliforniaLimited Liability Company, an operator ofUnmannedAircraft Systems ("UASs") for aerial photography for the motion picture and television industry, hereby applies for an exemption from the FedeFal·A**viatiori1{~ulations** ("FARs") to allow commercial operation ofits UASs. Onorabout September25, 2014, the FAA granted exemptions to six UAS operators, including Astraeus Aerial (the "Astraeus Exemption"). As set forth in Glide Aerials, LLC's Flight Operations and Procedures Manual (the "FOPM") and Motion Picture Television Operations Manual (both submitted under separately under 14 CFR 11.35(b)), Glide Aerials, LLC will adhere to the terms ofthe Astraeus Exemption. Glide Aerials, LLC's requested exemption wouldpermit the operation ofsmall, unmanned UAS under controlled and "sterile" conditions in motionpicture and television airspace that is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) designed to provide greater safety in connection with aircraft operations inthe film and television industry. As established bythe exemptions already granted by the FAA, approval ofGlide Aerial's exemption would enhance safety and fulfill the Secretary of Transportation's (the FAAAdmlnistrator's) responsibilities to "
...establishrequirements for the safe operation ofsuch aircraft systems inthe national airspace system". Section 333(c) oftheReformAct.U.S. Department ofTransportation Re: Exemption RequestPursuantto Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31, 2015 Page 2

The name and address ofthe applicant is:

UAS to be used: Glide Aerials, LLC Attn: Trevor Bryson; Ph: 626-255-2438 Email: tjmbryson@yahoo.com

Address: 37 Camino Celeste

San Clemente, California 92673

The aircraft to be used with this exemptionis a DJI S1 000+ multi-rotor octocopter (8 rotors). This UAS has beenengineered and is considered a professional class UAS comparedto other consumer brand UASs. Ithas a maximum take offweight of25 lbs and a max speed of45 knots which are less than what is currently being mandated. Itis controlled viaremote control operating on a digital 2.4ghz signal. Because this is a digital signal and not analog, interference from other 2.4ghz signals would notpose a safety risk or loss ofaircraft control. This particular UAS has a real time PIC camera installed as well as providing real time telemetry information from the UAS itselfwhile in flight. Additionally the UAS will be utilizing the DJI A2 flight controllerwhich is one ofthe most advanced and robust flight controllers that have been developed from DJI which is also the manufacturer ofthe proposed UAS to be used with this exemption. S1000+ User Manual v1.2 http:/ /download.dji-innovations.com/ downloads/s1000 _plus/en! S1000 _Plus_ User_ Manual_ v1.2 _en.pdf A2 UserManual v 1.2 http:/ /download.dji-innovations.com/ downloads/a2/enl A2 _Quick_ Start_ Guide_ v 1.2_ en.pdf Safety features andredundancy: The DJI S1000+ UAS has several built-in safety features and redundancies. With the addition ofthe A2 advanced flight controller many ofthese safety features canbe utilized.

• SparkproofPlugs

• NewPower Distribution System

• Return to home (Failsafe)

• Can still be airborne and controllable by PIC with 1 motor failure.U.S. Department ofTransportation Re: Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31,2015 Page 3
Regulations from which the exemption is requested: 14 CFR 61.113(a) and (b) 14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151(a) 14 CFR 91.405(a) 14 CFR407(a)(1) 14 CFR 409(a)(2) 14 CFR417(a) and (b) Dll Inspire One and DllPhantom 2 will also be used. UASs operated by Glide Aerials, LLC weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). They operate at speeds ofno more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Glide Aerials, LLC will only operate its UASs inline ofsight and will operate only within the sterile area described inthe FOPM. Such operations will insure thatthe UAS will "not create a hazard to users ofthe national airspace system or the public." Given the small size ofGlide Aerials, LLC's UASs and the restricted sterile environment within which they will operate, Glide Aerials, LLC's UAS operations adhere to the Reform Act's safety requirements. Additionally, due to the size ofthe UASs and the limited areas in whichthey will operate, approval ofthis applicationpresents no national security issues. Based onthe substantial level ofsafety surrounding the proposed operations, and the significantpublic benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant oftherequested exemption is inthe public interest. Accordingly, Glide Aerials, LLC respectfully requests thatthe FAA grant the requested exemption without delay.


### Aircraft And Equivalent Level OfSafety The operating limitations proposed by Glide Aerials provide for at least an equivalent or higher level ofsafety because operations further enhance safety ofmovie and television filming using conventional aircraft. As set forth inthe FOPM, the limitations and conditions include:U.S. Department ofTransportation Re: Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31, 2015 Page 4

• The UASs will weigh less than 55 pounds
• Flights will be operated within line ofsight ofa pilot and/or observer.
• Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery powerreserve should that occur priorto the 30 minute limit.
• Flights will be operated at an altitude ofno more than 400 feet above ground level ("AGL"), and not more than 200 feet above an elevated platform from which filming is planned.
• Minimum crewfor each operation will consist ofthe UAS Pilot, the Visual Observer, and the Camera Operator.
• A UAS pilot will be an FAA licensed airman with at least a sportpilot's certificate.
• A UAS Pilot will be Pilot in Command (PIC). Ifa pilot certificate holder other than the UAS Pilot, who possesses the necessary PIC qualifications, is also present onset (i.e. the Aerial Coordinator), thatperson can also be designated as PIC.
• The UAS will only operate within a confined "Sterile Area" as defmed inthe FOPM. The FOPM requires the establishment ofa "Security Perimeter" for the flight operations area.
• A briefmg will be conducted for planned UAS operations prior to each day's flight. All personnel performing duties within the boundaries ofthe safety perimeter are required to attend.
• The operator will file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office ("FSDO").
• The operator will obtain consent ofall persons involved inthe filming and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation. This radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required under the FOPM. With the advanced permission ofthe FSDO, operations at closer range canbe approved.
• The operator will submit a written Plan ofActivities to the FSDO three days before the proposed shoot as required inthe FOPM.U.S. Department ofTransportation Re: Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Actfor Glide Aerials, LLC July 31,2015 Page 5

• The Pilot and observer must be trained inUAS operations and have received current information onthe particular UAS to be operated as required by the FOPM.
• The Observer andpilot will at all times be able to communicate by voice.
• Written and/or oral permission from the relevant property holders will be obtained.
• All required permissions andpermits will be obtained from territorial, state, county, or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.
• Ifthe UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre-determined location withinthe Security Perimeter and land.
• The UAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies. 14 C.F.R. § 61.113(a) and (b): Private PilotPrivileges and Limitations: Pilotin Command Sections 61.113 (a) and (b) limitprivate pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is remotely controlledby a groundbased operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated withthe use ofa UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 that allowing UAS use by a private pilot such as the PIC actually exceeds the present level ofsafety sought by 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 91.103 requires eachpilot to preflight an aircraft before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be used, anexemption is requested. However, an equivalent level ofsafety will be provided. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraftperformance databefore commencement offlight.U.S. Department ofTransportation Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31, 2015 Page 6

14 C.F.R. §91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 provides, inpertinent part, that: "except when necessary for takeoffor landing, no personmay operate an aircraft below the following altitudes:
..... (c) Over otherthan congested areas. 

### An altitude of500 feet above the surface, except over open water or sparsely populated areas. Inthose cases, the aircraft may notbe operated closer than 500 feet to any person, vessel, vehicle, or structure." Because Glide Aerials, LLC requests authority to operate at altitudes only up to 400 feet AGL, and not more than 200 feet above anelevated platform from which filming is planned, an exemption is needed to allow such operations. Except for the limited conditions stated inthe FOPM, the UAS will never operate higher than 400 feet AGL. It will, however, be operated in a restricted area within a security perimeter, where buildings and people will not be exposedto operations without their pre-obtained consent. The equivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe UAS as well as the location where itis operated. No flight will be taken withoutthe permission ofproperty owners or local officials. Because ofthe advance notice to the property owners and participants inthe filming activity, all affected individuals will be informed ofthe planned flight operations. Compared to flight operations for manned aircraft andthe lack offlammable fuel, any risk associated withthe proposed UAS operations is far less than conventional aircraft operating at orbelow 500 feet AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between a UAS and conventional aircraft. 14 C.F.R. §91.121 Altimeter Settings Section 91.121 requires eachperson operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "
...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. 

### An equivalent level ofsafety will be achieved by the operator, pursuantto the FOPM and Safety Check list, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight.U.S. Department ofTransportation Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31,2015 Page 7

14 C.F.R. §91.151(a): Fuel Requirements for Flight inVFRConditions Section 91.151(a) prohibits anindividual from beginning "aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthat for at least 30 minutes
...." The battery powering the Glide Aerials, LLC UASs provides approximately 40 minutes ofpowered flight. To meetthe 30-minute reserve requirement in 14 CFR §91.151, UAS flights will be limited to approximately 10 minutes in length. Giventhe limitations onthe UAS's proposed flight area and its proposed operations within a predetermined location, a longer time frame for flight in daylight VFRconditions is reasonable. Furthermore, operating the UASs in a tightly controlled area where only people, property owners, or official representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel does not engenderthe type ofrisk that §91.151(a) was intended to address. Glide Aerials, LLC believes that safety canbe achieved by limiting flights to 30 minutes or 25% ofbattery power, whichever occurs first. This restriction would be more than adequate to return the UAS to its pre-determined landing zone from anywhere in its limited operating area. Glide Aerials, LLC is not seeking an exemption for night-time UAS operations. 14 C.F.R. §91.405 (a); 407 (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 ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter
...," and others shall inspect or maintain the aircraft in compliance withPart 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Glide Aerials operations. Maintenance will be accomplished by the operator. An equivalent level ofsafety will be achieved because the UASs are limited in size, will carry a small payload and operate only inrestricted areas for limited periods oftime. Ifmechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided inthe FOPM, the operator will ensure thatthe UAS is inworking orderprior to flight, perform any required maintenance, andkeep a log ofany maintenance performed. Moreover, the operator isU.S. Department ofTransportation Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31,2015 Page 8

the person most familiar with the UAS and best suited to maintain it in an airworthy condition. 

### Summary for Publication Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined thatpublication is needed: Glide Aerials, LLC seeks an exemption from the following rules: 14 C.P.R.§§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanned vehicle (55 pounds orless) inmotionpicture and television operations. As established by the UAS exemptions already granted by the FAA, allowing commercial operations ofUASs inthe film industry will enhance safety by reducing risk. In conventional film operations, turbine aircraft operate at low altitudes and present the risks associated with aircraftthat weigh around 4,000 pounds, and which carry large amounts ofJet A fuel. Such aircraft must also fly to and from the film location. In contrast, a UAS weighing fewer than 55 pounds and powered bybatteries eliminates virtually all ofthat risk giventhe small size and lack ofcombustible fuel. The UAS is carried, and not flown, to a film set. Inthis regard, the UAS carries no passengers or crew and, therefore, will not expose themto the risks associated withmanned flights. The operation ofUASs conducted inthe strict conditions outlined inthe FOPM will provide an equivalent level ofsafety supporting the grant ofthe exemptionrequested herein. The UASs operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far saferthan conventional operations conducted with turbine helicopters carrying fuel and flying nearthe ground and people. 

### Privacy All flights will occur over private or controlled access areas withthe property owner's prior consent and knowledge. Filming will be only ofpeople who have giventheir consent or otherwise have agreed to be inthe area where filming will take place. Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas andU.S. Department ofTransportation Re: ExemptionRequest Pursuantto Section 333 ofthe FAA Reform Act for Glide Aerials, LLC July 31, 2015 Page 9
operationwithin visual line ofsight and national security) provide more than adequate justificationto grant Glide Aerials, LLCs requested exemption, allowing for Glide Aerials, LLC's UAS commercial operations for the motionpicture and television industry pursuantto the FOPM included herewith. Ifyouhave any questions orneed any additional information, please contact the undersigned at 626-255-2438 or attjmbryson@yahoo.com.
Yours sincerely,

Trevor J. Bryson**Member~anager** Glide Aerials, LLC TJB/jep