3 7 Camino Celeste 

San Clemente, California 

92673 

July 31, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation 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, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the 

"Reform Act") and 14 C.F .R. Part 11, Glide Aerials, LLC, a California Limited Liability 

Company, an operator ofUnmanned Aircraft Systems ("UASs") for aerial photography 

for the motion picture and television industry, hereby applies for an exemption from the 

FedeFal· A viatiori1{~ulations ("F ARs") to allow commercial operation of its UASs. 

On or about September 25, 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 of the Astraeus Exemption. 

Glide Aerials, LLC' s requested exemption would permit the operation of small, 

unmanned UAS under controlled and "sterile" conditions in motion picture 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 in the film and 

television industry. As established by the exemptions already granted by the FAA, 

approval of Glide Aerial's exemption would enhance safety and fulfill the Secretary of 

Transportation's (the FAA Admlnistrator's) responsibilities to " ... establish requirements 

for the safe operation of such aircraft systems in the national airspace system". Section 

333(c) ofthe Reform Act. 
U.S. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Glide Aerials, LLC 

July 31, 2015 Page 2 

The name and address of the 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 exemption is a DJI S 1 000+ multi-rotor octocopter (8 

rotors). This UAS has been engineered and is considered a professional class UAS 

compared to other consumer brand UASs. It has a maximum take off weight of25 lbs 

and a max speed of 45 knots which are less than what is currently being mandated. It is 

controlled via remote control operating on a digital 2.4ghz signal. Because this is a 

digital signal and not analog, interference from other 2.4ghz signals would not pose a 

safety risk or loss of aircraft control. This particular UAS has a real time PIC camera 

installed as well as providing real time telemetry information from the UAS itself while 

in flight. Additionally the UAS will be utilizing the DJI A2 flight controller which is one 

of the most advanced and robust flight controllers that have been developed from DJI 

which is also the manufacturer of the proposed UAS to be used with this exemption. 

S1000+ User Manual v1.2 

http:/ /download.dj i-innovations. com/ downloads/s 1000 _plus/ en! 

S 1000 _Plus_ User_ Manual_ v 1.2 _en. pdf 

A2 User Manual v 1.2 

http:/ /download.dji-innovations. com/ downloads/a2/enl 

A2 _Quick_ Start_ Guide_ v 1.2_ en. pdf 

Safety features and redundancy: 

The DJI S1000+ UAS has several built-in safety features and redundancies. 

With the addition of the A2 advanced flight controller many of these safety 

features can be utilized. 

• SparkproofPlugs 

• New Power Distribution System 

• Return to home (Failsafe) 

• Can still be airborne and controllable by PIC with 1 motor failure. 
U.S. Department of Transportation 

Re: Re: Exemption Request Pursuant to Section 333 of the 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 CFR 407(a)(1) 

14 CFR 409(a)(2) 

14 CFR 417(a) and (b) 

Dll Inspire One and Dll Phantom 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 of no more than 50 knots, can 

hover, and can simultaneously move vertically and horizontally. Glide Aerials, LLC will 

only operate its UASs in line of sight and will operate only within the sterile area 

described in the FOPM. Such operations will insure that the UAS will "not create a 

hazard to users of the national airspace system or the public." 

Given the small size of Glide 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 which they will operate, approval of this application presents no national 

security issues. Based on the substantial level of safety surrounding the proposed 

operations, and the significant public benefit (enhanced safety), reduction in 

environmental impacts (reduced emissions and noise), the grant ofthe requested 

exemption is in the public interest. Accordingly, Glide Aerials, LLC respectfully 

requests that the FAA grant the requested exemption without delay. 

Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Glide Aerials provide for at least an equivalent or 

higher level of safety because operations further enhance safety of movie and television 

filming using conventional aircraft. 

As set forth in the FOPM, the limitations and conditions include: 
U.S. Department of Transportation 

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 of sight of a pilot and/or observer. 

• Maximum flight time for each operational flight will be 30 minutes. Flights will 

be terminated at 25% battery power reserve should that occur prior to the 

30 minute limit. 

• Flights will be operated at an altitude of no more than 400 feet above ground level 

("AGL"), and not more than 200 feet above an elevated platform from which filming is 

planned. 

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer, 

and the Camera Operator. 

• A UAS pilot will be an FAA licensed airman with at least a sport pilot's certificate. 

• A UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the UAS Pilot, who possesses the necessary PIC qualifications, is also present onset 

(i.e. the Aerial Coordinator), that person can also be designated as PIC. 

• The UAS will only operate within a confined "Sterile Area" as defmed in the FOPM. 

The FOPM requires the establishment of a "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 of the safety perimeter are required to 

attend. 

• The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office ("FSDO"). 

• The operator will obtain consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation. This 

radius may be reduced to 30 feet based upon an equivalent level of safety determination, 

as required under the FOPM. With the advanced permission of the FSDO, operations at 

closer range can be approved. 

• The operator will submit a written Plan of Activities to the FSDO three days before the 

proposed shoot as required in the FOPM. 
U.S. Department of Transportation 

Re: Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Glide Aerials, LLC 

July 31,2015 Page 5 

• The Pilot and observer must be trained in UAS operations and have received current 

information on the particular UAS to be operated as required by the FOPM. 

• The Observer and pilot 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 and permits will be obtained from territorial, state, county, or 

city jurisdictions, 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 within the 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 Pilot Privileges and Limitations: Pilot in 

Command 

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current 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 controlled by a groundbased operator. The operational area is controlled and restricted, and all flights are 

planned and coordinated in advance. The level of safety exceeds that provided by a 

single individual holding a commercial pilot's certificate operating a conventional 

aircraft. The risks associated with the use of a 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 of safety sought 

by 14 C.F.R. §61.113 (a) and (b). 

14 C.F .R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is 

requested. However, an equivalent level of safety will be provided. The PIC will take all 

actions, including reviewing weather, flight battery requirements, landing and takeoff 

distances, and aircraft performance data before commencement of flight. 
U.S. Department of Transportation 

Re: Exemption Request Pursuant to 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 of civil aircraft. Section 91.119 

provides, in pertinent part, that: 

"except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: ..... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

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 an elevated platform from which filming is 

planned, an exemption is needed to allow such operations. Except for the limited 

conditions stated in the 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 exposed to operations without their pre-obtained 

consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of property owners or local officials. Because of the advance notice to the 

property owners and participants in the filming activity, all affected individuals will be 

informed of the planned flight operations. Compared to flight operations for manned 

aircraft and the lack of flammable fuel, any risk associated with the proposed UAS 

operations is far less than conventional aircraft operating at or below 500 feet AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between a UAS 

and conventional aircraft. 

14 C.F.R. §91.121 Altimeter Settings 

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the 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 of safety will be achieved by the operator, pursuant to the FOPM and 

Safety Check list, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 
U.S. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Glide Aerials, LLC 

July 31,2015 Page 7 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning "a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed- (1) During the day, to fly after that for at least 30 minutes .... " 

The battery powering the Glide Aerials, LLC UASs provides approximately 40 minutes 

of powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, UAS 

flights will be limited to approximately 10 minutes in length. Given the limitations on the 

UAS's proposed flight area and its proposed operations within a predetermined location, 

a longer time frame for flight in daylight VFR conditions 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 engender the type of risk that §91.151(a) was intended to address. 

Glide Aerials, LLC believes that safety can be achieved by limiting flights to 30 minutes 

or 25% of battery 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 of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in 

compliance with Part 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 of safety will be achieved because the 

UASs are limited in size, will carry a small payload and operate only in restricted areas 

for limited periods of time. If mechanical issues arise, the UAS can land immediately 

and will be operating from no higher than 400 feet AGL. As provided in the FOPM, the 

operator will ensure that the UAS is in working order prior to flight, perform any required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is 
U.S. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the 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 that publication 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 or less) in motion picture and television operations. 

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations ofUASs in the film industry will enhance safety by reducing risk. 

In conventional film operations, turbine aircraft operate at low altitudes and present the 

risks associated with aircraft that weigh around 4,000 pounds, and which carry large 

amounts of Jet A fuel. Such aircraft must also fly to and from the film location. In 

contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates 

virtually all of that risk given the small size and lack of combustible fuel. The UAS is 

carried, and not flown, to a film set. In this regard, the UAS carries no passengers or crew 

and, therefore, will not expose them to the risks associated with manned flights. 

The operation ofUASs conducted in the strict conditions outlined in the FOPM will 

provide an equivalent level of safety supporting the grant of the exemption requested 

herein. The UASs operate at slow speeds, close to the ground, and in a sterile 

environment. As a result, they are far safer than conventional operations conducted with 

turbine helicopters carrying fuel and flying near the ground and people. 

Privacy 

All flights will occur over private or controlled access areas with the property owner's 

prior consent and knowledge. Filming will be only of people who have given their 

consent or otherwise have agreed to be in the area where filming will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 
U.S. Department of Transportation 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act for 

Glide Aerials, LLC 

July 31, 2015 Page 9 

operation within visual line of sight and national security) provide more than adequate 

justification to grant Glide Aerials, LLCs requested exemption, allowing for Glide 

Aerials, LLC's UAS commercial operations for the motion picture and television industry 

pursuant to the FOPM included herewith. 

If you have any questions or need any additional information, please contact the 

undersigned at 626-255-2438 or at tjmbryson@yahoo.com. 

Yours sincerely, 

Trevor J. Bryson 

Member~anager 

Glide Aerials, LLC 

TJB/jep