# .G.li.de A..e.rial.s
37 Camino Celeste San Clemente, California 92673

C E RTIFIED MAIL , RETURN RECEIPT REQUESTED U.S. Department of Transportation Federal Aviation Administration 800 Independence A venue , SW Washington , DC 20591 

### Re: Glide Aerials, LLC Exemption # 13837 February 4 , 2016

Regulatory Docket No. 

### FAA-2015-3505

Dear Sirs , On December 2, 2015 , Glide Aerials , LLC ( " Applicant" ) , a Ca l ifornia limited liability company , was granted an Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 (the " Reform Act " ) and I4 CFR Part II to operate commercially unmanned aircraft systems ( " drones " ) 

### in connection with closed-set motion picture and television film productions. The Exemption covered the following items of equipment: a Dn S 1 000 +, a Dn Inspire 1 , and a Dn Phantom 2. Applicant hereby requests that its Exemption be extended to cover the following unmanned aircraft systems which Applicant proposes to use in providing low-altitude photography and cinematography services to third-party motion picture and television film producers : ALTA drone manufactured by Freefly Systems Inc
. with an empty weight of 1

Olbs and a maximum gross weight of 30lbs and a diamet e r (folded) of 220 mm , powere d by six ( 6) F45 Direct Drive 3-Phase PMAC Outrunner Motors with a continuous power output of350W and an instantaneous peak power of950W , and with propellers of carbon fiber with balsa cores.

# .G.li.Je A.e:ria.ls
37 Camino Ce leste San Clemente, California 92673

CE RTIFIED MAlL RETURN RECEfPT REQUESTE D U.S. Department of Tran sporta t ion Federal Aviation Ad mini s tration 800 Independence A venue, SW Wash in gton , DC 2059 1 

### Re: G lid e Aerials , LLC Exemption # 13837 Feb ru ary 4 , 2016



### Regulatory Docket No
. F AA -2015- 3505

Dear Sirs, On December 2, 20 15, Glide Aerials , LLC ( " Applicant"), a California lim ited liability company, was g rante d a n Exempt io n under Section 333 of the FAA Mode rni zation and Refo rm Act of 2 0 12 (the " Refor m Act") and 14 CFR Part 11 to operate co mm e rcially unmanned aircran syste m s ("d ron es") in con nec tion wi th clo sed-set motion p ictu r e a nd te levision film produc ti ons. The Exemption cove red the following items of eq uipment: a OJI S I 000 +, a Dn Inspire 1 , and a Dn Ph antom 2. Applicant hereby requests that its Exemptio n be ex t e nded to cover the fol lowing unmanned aircraft syste ms which Applicant proposes to use in providing l ow-altitu de p hotograp hy and c inematography serv ices to th ird -party motion picture and t e l

ev isio n film producers : ALTA d rone manufactured by Free fly Systems In c. with an emp t y we ig ht of 10lbs and a maximum gross we ig ht of30 lb s and a diameter (fo ld ed) of220 mm , powered by six (6) F45 D i rect Dri ve 3-Phase PMAC Outrunner Motors wit h a continuous power output of350W a nd an instantaneous peak power of950W , and with prope ller s of carbon fiber with balsa cores.U.S. Department of Transportation Re: Glide Aerials, LLC Exempt ion# 13837 Regulatory Docket No. FAA

- 20 15-3505 February 4 , 20 1 6 P age 2
The cove rage extens ion of its existing Section 333 Exe mption hereby requested wo uld perm it the operation of it s ALTA drone under cont rolled and "s terile " conditions in motion picture and televis ion airspace that is: ( i) limited , (ii) p redetermined, ( iii ) subjec t to contro ll ed access, and ( iv) designed to p rovide greater safety i n connec ti on with aircraft operations 

### in the film and televi s ion indu stry. As estab l ished by the exemptions a lready granted by th e FAA ( includin g the Exe mpti o n to Astrae u s Aeria l on September 25,20 14 , the terms of w hi c h A pplic a nt has ag ree d to a dhe r e to in its Exe m ptio n Request Letter of Jul y 31, 20 15), ap prova l of the coverage extensio n of Appli ca nt 's ex isti ng Exemption 

### would enhance safety and fulfill th e Sec retary ofTransportation's (the FAA Administrator's) responsibilities to "
... estab li s h requirements for th e sa fe operation of such aircraft sys te m s in the national airspace syste m "

. Sec tion 333(c) of the Reform Act. Further, insofar as its ALTA drone operatio n s are concerned, App l icant he reby agrees to abide by and comp ly with the conditions (#s I thro ug h 32, in cl u sive) se t forth in your l etter of D ecember 2, 20 1 5 grant in g Appli cant a Sect i o n 333 Exemption in connection with its co mm e r c ial drone ope rati o n s. The name and add ress of the applicant is:

UAS to be used: G lide Ae ri al s, LLC Attn: Tr evo r J. Bry so n ; Ph: 626

- 255-2438 Emai I: trevor @ g l idea e r ials.co m Address: 37 Cam ino Celeste

San Cleme nte, Cali fornia 92673

As noted, the unmanned a i rcraft to be used with this exem ption is a Fre etly ALTA multir oto r hexocopter (6 roto rs )

. The ALTA drone has been engineered a nd is considered a professional class UAS compared to other consumer bran d UASs. It has a max i mum take off weig h t of 30 l bs and a maximum speed of 45 knots, both of wh ich are l ess than w hat is currently be in g mandated. It is co nt rolled v ia re m ote cont rol operating on a dig ital 2.4g hz sig n a l. Becau se this is a d ig ita l signal and n ot analog , interfere nce from other 2.4ghz s igna ls wo ul d not p ose a safety ri s k o r loss of a ircraft contro l. Th is particular UAS ha s a real time PIC camera in s talled as we ll as providing real tim e telemetry information from the UAS i tse l f while in flight, via a Futaba te lemetry system with built-in voltage se n se port and supported radio controller and a Skyzone First -Person V iew OSD telemetry system whic h is use r configurable. Additionally , the ALTA droneU.S

. D epartmen t of Transportation R

e: Glide Ae ri a ls, LL C Exemption# 13 8 37 Re gulatory Dock e t No
. FAA-2015-3505 F e bruary 4 , 20 16 P age 3
will be utili zi ng a Free fl y synapse flight co ntro ll e r, w hi c h is one of t h e most advanced an d robust fli ght con trollers that ha ve been developed by Fre e fl y ( it s manufacturer) and whic h features manu al , he ight, pos ition , a nd return-to-home mode s.

ALTA Aircraft Flight Manual (R evisio n C) ht!Q://f r ee fl s s t e m s.co m / a ltalspecs Safety features and r ed undanc y : T he ALTA drone has seve ra l built-in safety f eat ur es and redundanc ies. With the addition of the Freefly synap se fli g ht controller , many of these safety features can be utilized:

• Sparkp roof Plugs

• New Powe r Distri bution Sys te m
• Return to hom e (Fail safe)

• Can still be a irborne and controllable by PIC w ith 1 motor fai lu re. Regulations from which the exemp ti on is reque s ted : 14 CFR 61.113(a) and (b) 14 C.F .R. 91.103 14 C.F

. R
. 9 1.11 9 14 C.F .R. 91.121 14 CF R 9 1.1 5 1 (a) 14 CFR 91.405(a) 14 CFR 407 ( a )( l) 14 CF R 409 (a)(2) 14 CFR 417(a) and (b ) T h e Freefly ALTA d ro ne referred to herein we ig h s l Oibs (e mpty ) an d has a maximum g ross take-off we ig ht (includ in g camera , le n s, and gimba l) of 3 0lb s. It o pe rates at s peed s of no mo re than 50 knot s, can hover , and ca n s imu ltaneous ly move verticall y a nd hori zo nt a ll y. A ppli cant w ill only operate it s ALTA drone in lin e o f s ig ht and w ill operate only w ithin the s t e ril e a r ea described in its F li ght Operations and Proc e dures Man u a l ("F OPM") , a copy of whic h has previou s l y been s ubmitted to the FAA. Such operat ions will ensure that the A LT A dro n e w ill " not create a hazard to u sers of the national ai rspace sys tem or th e pu b 

### Ii c."U.S

. Department of Transportation Re: Glide Aeria ls , LLC Exemption # 13 83 7 Regulatory Docket No. FAA

- 2015 -3505 February 4, 2016 Page 4

Given the s mall size of the ALTA dron e an d the restricted steri le env ironmen t within which it wi ll operate , Applicant 's operations adhere to the Reform Act ' s safety U.S. Department of Transportation requirements. Additio nall y, due to the s ize of the ALTA drone and the limited areas in whic h it will operate, approval of this app li cation presents no national secur ity issues. Based on the substantial le vel of safety surrounding the proposed ope ration s, and the s ign ifi cant public benefit (enhanced safety) , reduction 

### in environmental impacts (reduced e mi ss ion s a nd no ise), the grant of the requested coverage extens ion with regard to Ap plicant 's ex isti ng Exempt ion is in the public interest. Accordingly , Glide Aeria ls , LLC respectfully requests that the FAA grant the requested cove rage extension without delay. 

### Aircraft And Equivalent Level Of Safety The operating limitations proposed by Glide Aerial s provide for at leas t an eq ui valent or higher l eve l of safety because op e ratio n s further enh ance safety of movie and te lev is i on filming using co nv entional aircraft. As set forth in the FOPM, the limitations and conditio n s in clude:

• The ALTA drone will we i gh no more than 30lbs fully lo aded

.
• Flights wil l be operated within lin e of s ight of a pilot and/or observer.

• Max imum flight time for each operational flight will be 30 minutes. Flight s will be terminated at 25% battery powe r re se rve s hould that occur prior to the 30 minute limi t.

• F li ghts will be operated at an altitude of no more than 400 feet above ground leve l ("AGL") , and not more than 200 feet above an e levated p latform from w hi ch filming is planned.

• M inimum crew for each operation wil l consist of the ALTA dron e Pilot, the Vi s ual Observer , and the Camera Operator.

• The ALTA drone Pilot will be an FAA li ce n se d a irm an w ith at l east a s port pilot ' s certificate.

• The ALTA dron e Pilot wi ll be Pilot in Command (PIC). I f a pilot certifi cate ho ld er other than the ALTA drone Pilot , w ho possesses th e nece ssary PIC qualifications, is also prese nt on set (i.e. the Aerial Coo rdin ator) , that person can also b e designated as PI C.U.S. Departme nt of Tran sportation Re: Glide Aeria ls , LL C Exemption # 1 3837 Regulatory Docket No. FAA-2015-3505 February 4, 20 1 6 Pa ge 5

• T he ALTA drone will only operate within a confined " Steri le Area " a s defined in the FOPM. The FOPM req uires the establishment of a " Security P erimeter" for the flight o p eration s area.

• A briefing w ill be co ndu c t ed for p lanned ALTA drone ope rations prior t o eac h day's fli g ht. All p e rso nnel performing duti es wit h in the boundaries of the safety perimeter are required to attend.

• The o p e rato r wi 11 fil e a FAA Form 7711-1 , or its eq u ivalent, as modified in light of the requested exemption , wit h the appropriate Flight Stand ard s Di str ict Office ("FS DO ").

• The operator w ill o bt a in consent of a ll persons in vo lved in the filming and e n s ur e that only co n se ntin g persons w ill be allowed w ithin I 00 feet o f the flight o p eratio n. This radius ma y be red uced t o 3 0 feet ba sed up o n an eq uiv a lent leve ] of safety determination , as re quire d und e r the FOPM. With the advanced perm iss ion of the fSDO , operations at closer range can b e approved.

• Th e oper ator will s ubmit a written Plan of Activ iti es to the FSDO thre e day s before the proposed shoot a s required in the FOPM.

• The Pilot and ob se rver must be trained in unmann e d airc raft sys tem s ( " UAS " ) operations and have r eceive d current information on the parti c ular UAS t o b e ope rate d as required by the FO PM.

• The Ob se rve r and pilot will at all tim es be ab le to communicate by vo ice.
• Written and/or oral permission from the relevant property holders w ill be obtai ned.

• All required perm iss ions and p ermits w ill be obtained from territorial , s tate , county , or city jurisdictions , in c ludin g local law enfo r cement , fire, or other ap propriate governme nt a l age ncies.

• lf th e ALTA dro ne loses communications o r loses its GPS s ig nal , th e ALTA drone will h ave the capability to return to a pre-dete rmined locat ion within the Sec uri ty Perimete r and land.

• Th e ALTA drone will have the capabilit y to abort a flight in case of unpredicted obstacles or e m erge nc ie s . 14 C.F. R
. §6 1.11 3(a) and (b): Private Pilot Pri v il eges and L imitations: Pilot in Co mm a ndU.S.

**Departm~nt** of Transportation Re: Glide Aerials, LLC Exe m ption# 13837 Regulatory Docket No. FAA-20 1 5-3505 February 4, 2016 Pa ge 6

Sec tion s 61.113 (a) and (b) limit p ri vate pilots to non-commerc ial operati ons. B ecause the ALTA drone will not carry a pilot o r passengers , the proposed ope rations can achieve th e equivalent leve l o f safety for current operat io n s by requiring the PI C operating the aircraft to ha ve a privat e pilot's licen se rathe r than a commercial pilot ' s lice n se to operate a small UAS. Unlike a co nventional mann ed aircraft, anAL TA drone is re motely contro ll ed by a g round-ba sed operato r. The operational area i s contro ll ed a nd restricted , and all flight s are p lanned and coordinated in advance. The level of sa f ety exceeds that provided b y a s in g le indi vid ual holdin g a co mm e rc ial p il ot's certificate operatin g a co nventional a ircraft. Th e risks associated with the u se of anAL TA d rone are so dim inished from the leve l of risk associated with commercial operations co nt e mplated by Part 61 that allowing ALTA drone u se by a private pilot suc h as the P IC actually exceeds the present level of safety sought b y 14 C. F
. R
. §61. 11 3 (a) and (b). 14 C. F
. R. 

### § 91.1 03: Pr efl ig ht Action Section 9 1.1 03 req uires eac h pi lot to prefl i g ht a n aircraft before fli g ht to e n s ur e the safety of flight. As FAA approved rotorcraft fli gh t manua ls will not be used , an exemption i s requested. Ho wever , an equivale n t leve l of safety wi ll be provided. Th e PI C will take all actions , including reviewing weathe r , flight battery requirements, landing a nd takeoff distances , and aircraft performance data before co mm e nceme nt of flight. 14 C.F.R. §9 1.119 (c): Minimum Safe Altitudes Section 91.119 es tabli s hes safe altitudes for operation of c ivi l aircraft. Sect ion 91.119 provides , 

### in pertinent part , that:

" except when neces s ary for takeoff or landing , no person may operate an airc raft b e low the fo ll owing altitudes:

..... (c) Over other than co ngested areas. An a ltitud e of 500 feet above th e sur f ace, except over open water or sparse ly populated areas. Jn those cases , the aircraft may not be o p e rated closer than 500 feet to any person , vessel , vehicle, or structure. " Because Applicant r eq u ests authority to operate at altitudes only up to 400 feet AGL, and not more than 200 feet above an elevated platform from which fi l ming is planned , an exem pti on is needed to a llo w suc h operation s . Except for the limited condi ti ons stated in the FOPM , the ALTA drone will never operate higher than 400 feet AGL. It will , however , be operated in a restricted area within a security perimeter , w here buildings and people will not be exposed to operations wit hout their pre-obtained co n sent.U
. S

. Department ofTransportation Re: Glide Aerials, LLC Exemption# 1 3837 Regulatory Docket No. FAA-2015-3505 February 4 , 20 1 6 Page 7

The equ iva le nt level of safety will be achieved given the size, weight, and speed of the ALTA drone as well as the l ocation where it is operated. No flight will be taken without the permission of property owners or local officials. Because of the advan ce notice to th e property owners and participants in the filming activity, all affected indi v idual s will be informed of t h e planned flight operations. Compared to flight operations for manned aircraft and th e la c k of flammable fuel, any risk associated with the proposed ALTA dron e operations is far less than that associated with co nventional aircraft operating at o r below 500 feet AGL. In addition , the low-altitude operations of the ALTA drone will ensure separatio n between it and conventiona l aircraft. 14 C.P.R. §9 1.1 21 A lti meter Settings Section 91.12 1 requires eac h perso n ope rating a n aircraft to maintain cruising alt itu de by reference to an altimeter that is set "

.. . to the e levation of the departure airport or an appropriate a ltimeter setting avail ab le before departure. " As a ALTA drone may not have a barometric al timeter, but instead a GPS altitud e data, an exemptio n is needed. An eq ui valent leve l of safety wi ll be achieved by the operator , acting pursuant to the FOPM and Safety Check list, confirming the alti tu de of the launch site shown on the GPS altitud e indi cator before flight. 14 C.P.R. §91. 1 5 1 (a) : F ue l Requirements for Flight in VFR Conditions Section 9 1. 151 (a) prohibits an individual from begi

_ nning "a flight in an airplane under VFR conditions unless (co n side rin g wind and forecast weather conditions) there is enough fue l to fly to the fi r st poi n t of inte nd ed landing , and , assuming normal c rui s ing speed

- (1) During the d ay, to fly after that for at least 30 minutes

...." The two batteries powering the ALTA drone provide approximately 40 minutes of powered flight. To meet the 30-rninute reserve requirement in 14 CFR §9 1 .151 , ALTA drone flig hts w ill be limi ted to approximately 10 minutes in length. G iven the limitations o n the ALTA drone's proposed fl i g ht a r ea and it s proposed operations within a predetermined location, a longer t im e frame for flight in daylight VFR cond itions i s reasonable. Furthermore , operating the ALTA drone in a tightly contro ll ed area where only people , property owners, or official representatives who have s igned waivers will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that §91.15l(a) was intended to address. Applicant b e li eves that safety can be achieved by limiting flights to 30 minutes or 25% of battery power, whichever occurs first. T hi s restriction wou ld be more than adequate to return th e ALTA drone to its pre-determined landing zone from anywhere in i ts limited operating ar ea. Appl icant is not seek in g an exemption for night-time ALTA drone ope rations

.U.S

. Department of Transportation Re: Gl ide Aeri al s, LLC Exemption# 1 3837 Regulatory Docket No. FAA-2015-3505 February 4, 2016 Page 8

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 4 17(a) 

### & (b): Mainte nance Inspections These regulations require that an aircraft operator or owner shal l " have that aircraft inspected as prescribed in s ubp art 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 in spect or maintain the aircraft in comp lianc e with Part 43. Given that these sections and Part 43 app ly onJy to aircraft with a n airworthiness certificate , these sections w ill not app ly to Glide Aerial s operations. Main tenance wi ll be accomp li s hed by the operator. An equivalent leve l of safety will be ac hi eved because the ALTA drone is limi ted 

### in s i ze, will carry a s m a ll payload and wi ll operate only 

### in restricted areas for Limited periods of time. If mechanical issues arise , the ALTA drone can la nd imm edi ate ly and will be operating from no higher than 400 feet AGL. As provided in the FOPM, the operator will ensure that the ALTA dro ne is in working order prior to flight, perform any requ ired maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most fami li ar with the ALTA drone and best suited to maintain it 

### in an airworthy conditio n . 

### Summary for Publication
Pursuant to 14 C.F .R. Part 11 , the fol l ow in g summary is provided for publication in the Federal Register , shou ld it be determined that publi cation is needed: G lid e Aer i als , LLC seeks an exemptio n from the fo llowing rules: 14 C

. F.R. 

### §§ 6 1.11 3(a) and (b); 91

. 10 3; 91.119(c); 91.121; 9 1.1 51(a) ; 9 1. 405(a); 91 .407(a)(l ); 91.409(a)(2); and 9 1.417 (a) and (b) to operate commerciall y a s m a ll unmanned vehicle (55 pounds or less) 

### in motio n picture and television operatio n s. As established by the UAS exemptions already granted by the FAA, allowing commercial operations of ALTA drones in the film indu stry will enhance safety by reducing risk. In conventional film operatio n s , turbine airc raft operate at low altitudes and present t h e risks associated with aircraft that weigh around 4,000 po und s , and wh ich carry large amounts of Jet A fuel. Suc h aircraft must a lso fly to and from the film location. In contrast, an ALTA drone weighing no more than 30 pounds and powered by batteries elim inates virtually a ll of that risk g iven the small size and lack of comb u stib le fuel. Th e ALTA drone is carri ed, and not flown, to a 

### film set. In this regard , the ALTA drone carries no passengers o r crew and, therefore , wi ll not expose them to the risks

### U.S. Department ofTransportation Re: Glide Aerials, LLC Exemption# 1 3837 Regulatory Docket No. FAA-2015-3505 February 4 , 2016 Pa ge 9
associated with manned flights. The operation of anAL TA drone conducted in the str ict conditions outlined in the FOPM will provide an equivalent l eve l of safety s upportin g the g rant of the exemption r equested herein. The ALTA drone wi ll operate at slow speeds , close to the ground , and in a sterile env ironment. As a result, anAL TA drone is far safer than conventional operat ion s conducted with turbine helicopters carry in g fuel an d flying near the ground and people. 

### Privacy All flights will occur ove r private or controlled access areas with the property owner ' s prior consent and knowledge

. Filming will be only of people who have g i ven their co n se nt or otherwise have agreed to be in the area where filmin g will take pl ace. Satisfaction of the c ri te ri a provided in Section 333 of the Refonn Act of2012 (s i ze , we i ght , speed , operating capabilities, proximity to airports and populated areas and ope ration within visual line of s ight and national sec urity) provide more than adequate justification to grant App licant 's requested coverage extension (to ALTA drones) with respect to its ex isting Sect ion 333 Exemption , thereby allowing fo r the expansion of App li cant's UAS commercial ope ration s in support of the motion picture and television indu stry pursuant to the FOPM includ ed herewith. I f you have any questions or need any additional informat ion , p lease contact the undersigned at 626-255-2438 or at trevor @ g lideaeria l s . co m.
Yours sincere ly ,

Trevor J. 

### Bryson Member/Manager Glide Aeria ls, LLC TJB / jep