.G.li.de 

A..e.rial.s 

37 Camino Celeste 

San Clemente, California 

92673 

CERTIFIED 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 California 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 diameter (folded) of 220 mm, 

powered 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 Celeste 

San Clemente, California 

92673 

CERTIFIED MAlL 

RETURN RECEfPT REQUESTED 

U.S. Department ofTransportation 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

Re: Glide Aerials, LLC 

Exemption # 13837 

February 4, 2016 

Regulatory Docket No. F AA-2015-3505 

Dear Sirs, 

On December 2, 2015, Glide Aerials, LLC ("Applicant"), a California limited liability 

company, was granted an Exemption under Section 333 of the FAA Modernization and 

Reform Act of 20 12 (the "Reform Act") and 14 CFR Part 11 to operate commercially 

unmanned aircran systems ("drones") in connection with closed-set motion picture and 

television film productions. 

The Exemption covered the following items of equipment: a OJI S I 000+, a Dn Inspire 

1, and a Dn Phantom 2. 

Applicant hereby requests that its Exemption be extended to cover the fol lowing 

unmanned aircraft systems which Applicant proposes to use in providing low-altitude 

photography and cinematography services to third-party motion picture and te levision 

film producers: 

ALTA drone manufactured by Free fly Systems Inc. with an empty weight of 

10lbs and a maximum gross weight of30lbs and a diameter (folded) of220 mm, 

powered 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. 
U.S. Department of Transportation 

Re: Glide Aerials, LLC 

Exemption# 13837 

Regulatory Docket No. F AA-20 15-3505 

February 4, 2016 Page 2 

The coverage extension of its existing Section 333 Exemption hereby requested would 

permit the operation of its ALTA drone 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 (including the Exemption to Astraeus Aerial on September 

25,2014, the terms of which Applicant has agreed to adhere to in its Exemption Request 

Letter of July 31, 20 15), approval of the coverage extension of Applicant's existing 

Exemption would enhance safety and fulfill the Secretary ofTransportation's (the FAA 

Administrator's) responsibilities to " ... establish requirements for the safe operation of 

such aircraft systems in the national airspace system". Section 333(c) of the Reform Act. 

Further, insofar as its ALTA drone operations are concerned, Applicant hereby agrees to 

abide by and comply with the conditions (#s I through 32, inclusive) set forth in your 

letter ofDecember 2, 2015 granting Applicant a Section 333 Exemption in connection 

with its commercial drone operations. 

The name and address of the applicant is: 

UAS to be used: 

Glide Aerials, LLC 

Attn: Trevor J. Bryson; Ph: 626-255-2438 

Emai I: trevor@gl ideaerials.com 

Address: 37 Camino Celeste 

San Clemente, California 

92673 

As noted, the unmanned aircraft to be used with this exemption is a Freetly ALTA multirotor hexocopter (6 rotors). The ALTA drone has been engineered and is considered a 

professional class UAS compared to other consumer brand UASs. It has a maximum 

take off weight of 30 lbs and a maximum speed of 45 knots, both of 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, via a Futaba telemetry system 

with built-in voltage sense port and supported radio controller and a Skyzone First-Person 

View OSD telemetry system which is user configurable. Additionally, the ALTA drone 
U.S. Department of Transportation 

Re: Glide Aerials, LLC 

Exemption# 13837 

Regulatory Docket No. FAA-2015-3505 

February 4, 2016 Page 3 

will be utilizing a Free fly synapse flight controller, which is one of the most advanced 

and robust flight controllers that have been developed by Freefly (its manufacturer) and 

which features manual, height, position, and return-to-home modes. 

ALTA Aircraft Flight Manual (Revision C) 

ht!Q://freefl s stems.com/altalspecs 

Safety features and redundancy: 

The ALTA drone has several built-in safety features and redundancies. With the addition 

of the Freefly synapse flight controller, many of these safety features can be utilized: 

• Sparkproof Plugs 

• New Powe r Distribution System 

• Return to home (Failsafe) 

• Can still be airborne and controllable by PIC with 1 motor fai lure. 

Regulations from which the exemption is requested: 

14 CFR 61.113(a) and (b) 

14 C.F.R. 91.103 

14 C.F. R. 91.11 9 

14 C.F.R. 91.121 

14 CFR 91.1 51(a) 

14 CFR 91.405(a) 

14 CFR 407(a)(l) 

14 CFR 409(a)(2) 

14 CFR 417(a) and (b) 

The Freefly ALTA drone referred to herein weighs lOibs (empty) and has a maximum 

gross take-off weight (including camera, lens, and gimbal) of 30lbs. It operates at speeds 

of no more than 50 knots, can hover, and can simultaneously move verticall y and 

horizontally. Applicant will only operate its ALTA drone in line of sight and will operate 

only within the steril e area described in its Flight Operations and Procedures Manual 

("FOPM"), a copy of which has previously been submitted to the FAA. Such operations 

will ensure that the ALTA drone will "not create a hazard to users of the national airspace 

system or the pub I ic." 
U.S. Department of Transportation 

Re: Glide Aerials, LLC 

Exemption # 13 83 7 

Regulatory Docket No. FAA-2015-3505 

February 4, 2016 Page 4 

Given the small size of the ALTA drone and the restricted sterile environment within 

which it will operate, Applicant's operations adhere to the Reform Act's safety 

U.S. Department of Transportation requirements. Additionally, due to the size of the 

ALTA drone and the limited areas in which it 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 of the requested coverage 

extension with regard to Applicant's existing Exemption is in the public interest. 

Accordingly, Glide Aerials, LLC respectfully requests that the FAA grant the requested 

coverage extension 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: 

• The ALTA drone will weigh no more than 30lbs fully loaded. 

• 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 ALTA drone Pilot, the Visual 

Observer, and the Camera Operator. 

• The ALTA drone Pilot will be an FAA licensed airman with at least a sport pilot's 

certificate. 

• The ALTA drone Pilot will be Pilot in Command (PIC). If a pilot certificate holder 

other than the ALTA drone Pilot, who possesses the necessary PIC qualifications, is also 

present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC. 
U.S. Department of Transportation 

Re: Glide Aerials, LLC 

Exemption # 13837 

Regulatory Docket No. FAA-2015-3505 

February 4, 20 16 Page 5 

• The ALTA drone will only operate within a confined "Sterile Area" as defined in the 

FOPM. The FOPM requires the establishment of a "Security Perimeter" for the flight 

operations area. 

• A briefing will be conducted for planned ALTA drone operations prior to each day's 

flight. All personnel performing duties within the boundaries of the safety perimeter are 

required to attend. 

• The operator wi 11 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 obta in consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within I 00 feet of the flight operation. This 

radius may be reduced to 30 feet based upon an equivalent leve] 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. 

• The Pilot and observer must be trained in unmanned aircraft systems ("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, inc luding local law enforcement, fire, or other appropriate 

governmental agencies. 

• lf the ALTA drone loses communications or loses its GPS signal, the ALTA drone will 

have the capability to return to a pre-determined location within the Security Perimeter 

and land. 

• The ALTA drone will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 

14 C.F.R. §61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command 
U.S. Departm~nt of Transportation 

Re: Glide Aerials, LLC 

Exemption# 13837 

Regulatory Docket No. FAA-2015-3505 

February 4, 2016 Page 6 

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

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

the equivalent level of safety for 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, anAL TA drone is remotely 

controlled by a ground-based operator. The operational area is controll ed 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 anAL TA drone are so 

diminished from the level of risk associated with commercial operations contemplated by 

Part 61 that allowing ALTA drone use by a private pilot such as the PIC actually exceeds 

the present level of safety sought by 14 C.F.R. §61. 11 3 (a) and (b). 

14 C.F .R. § 91.1 03: Preflight Action 

Section 91.1 03 requires each pilot to preflight an aircraft before flight to ensure 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. 

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. Jn those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure." 

Because Applicant 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 ALTA drone 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. 
U.S. Department ofTransportation 

Re: Glide Aerials, LLC 

Exemption# 13837 

Regulatory Docket No. FAA-2015-3505 

February 4, 2016 Page 7 

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

ALTA drone 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 ALTA 

drone operations is far less than that associated with conventional aircraft operating at or 

below 500 feet AGL. In addition, the low-altitude operations of the ALTA drone will 

ensure separation between it and conventional aircraft. 

14 C.P.R. §91.1 21 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 ALTA drone may not 

have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An 

equi valent level of safety will be achieved by the operator, acting pursuant to the FOPM 

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

altitude indicator before flight. 

14 C.P.R. §91. 151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from begi_nning "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 two batteries powering the ALTA drone provide approximately 40 minutes of 

powered flight. To meet the 30-rninute reserve requirement in 14 CFR §91.151 , ALTA 

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

on the ALTA drone'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 ALTA drone 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 

§91.15l(a) was intended to address. Applicant 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 ALTA drone to its pre-determined 

landing zone from anywhere in its limited operating area. 

Applicant is not seeking an exemption for night-time ALTA drone operations. 
U.S. Department of Transportation 

Re: Glide Aerials, LLC 

Exemption# 13837 

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): 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 onJy 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 

ALTA drone is limited in size, will carry a small payload and will operate only in 

restricted areas for Limited periods of time. If mechanical issues arise, the ALTA drone 

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 ALTA drone is in working order 

prior to flight, perform any required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most fami liar with the ALTA drone and 

best suited to maintain it in an airworthy condition. 

Summary for Publication 

Pursuant to 14 C.F .R. Part 11 , the fol lowing 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.F.R. §§ 61.113(a) and (b); 91 .103; 91.119(c); 91.121; 91.1 51(a); 91.405(a); 

91 .407(a)(l ); 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 of ALTA drones 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, an ALTA drone weighing no more than 30 pounds and powered by 

batteries eliminates virtually all of that risk given the small size and lack of combustible 

fuel. The ALTA drone is carried, and not flown, to a film set. In this regard, the ALTA 

drone carries no passengers or crew and, therefore, will not expose them to the risks 
U.S. Department ofTransportation 

Re: Glide Aerials, LLC 

Exemption# 13837 

Regulatory Docket No. FAA-2015-3505 

February 4, 2016 Page 9 

associated with manned flights. 

The operation of anAL TA drone 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 ALTA drone will operate at slow speeds, close to the ground, and in a sterile 

environment. As a result, anAL TA drone is 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 Refonn Act of2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

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

justification to grant Applicant's requested coverage extension (to ALTA drones) with 

respect to its existing Section 333 Exemption, thereby allowing for the expansion of 

Applicant's UAS commercial operations in support of 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 trevor@glideaerials.com. 

Yours sincerely, 

Trevor J. Bryson 

Member/Manager 

Glide Aerials, LLC 

TJB/jep