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Memorandum: Petition for Relief of Part 333

29 December 2015

William Russell

President, Logistic Gliders

221 West A St, #1386

Dixon, CA 95620

will.russell@logisticgliders.com, 

310-941-2423

To Whom it May Concern,

Pursuant to the FAA Modernization and Reform Act of 2012 (the "Reform Act") and the procedures contained in 

14 C.F.R. 11, on behalf of Logistic Gliders Inc.(LG), a Nevada C-Corporation and developer of unmanned cargo 

gliders, hereby requests exemption from the Federal Aviation Regulations ("FARs") listed below in order to legally 

operate unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation 

Administration ("FAA"). These operations will be conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. Exemption from Part 333 will permit LG to perform test 

flights and gather critical performance data needed to complete several research & development contracts it holds 

with US military agencies. LG does not currently request any consideration for operation outside the United 

States. Specific sections requested for exemption include:

Section Rationale

14 CFR 21(h) LG intends to build and test fly prototype unmanned aircraft in order to 

develop a product line of cargo gliders for the US military. Obtaining 

airworthiness certifications for each prototype is unnecessary due to fact that 

each glider is unmanned, operated only briefly in remote regions during test 

events, and will undergo rapid improvements/changes between tests.

14 CFR 91.7(a) See above.

14 CFR 91.9(b)(2) LG believes developing and obtaining approval for flight manuals is 

unnecessary for its low-cost, development UAS systems.

14 CFR 91.203 (a) & (b) As stated earlier, LGbelieves obtaining airworthiness certificates are 

unnecessary, however all test aircraft will be registered with the FAA.

14 CFR 91.405(a) This provision would require that LG provide an Airframe and Powerplant Mechanic (A&P) with an Inspection Authorization (IA) privileges to 

sign off on design modifications. While the LG Pilot in Command (PIC)

happens to be an A&Pmechanic, he does not possess IA. Extensive 

qualifications seemto be unnecessary given the experimental and 

unmanned nature of these development aircraft. 

14 CFR 91.407(a)(1) See above

14 CFR 91.409(a)(1) & (2) See above

14 CFR 91.417(a) & (b) Same as above

14 CFR 409 (a)(2) See above
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LG was first incorporated in 2011 and has been developing the LG-X family of disposable cargo gliders for the 

United States Military since first establishing a Cooperative Research & Development Agreement (CRADA) in 2012 

with the US Army Natick Solider Center. LG is currently under contract with the Defense Advanced Research 

Projects Agency (DARPA) and the Marine Corps Warfighting Laboratory (MCWL). Staffed by several senior airdrop 

and aeronautical engineers, LG has developed several prototype aerial resupply systems for the US military. We 

are currently scheduled to drop a ful l-scale prototype glider from a commercial helicopter in March 2016.

Conducting Safe Operations

The LG-X glider is a low-cost autonomous cargo resupply glider that is released mid-air from an FAA certified (or US 

Military owned) cargo helicopter or cargo aircraft. Designed with a minimum of parts and environmentally friendly 

materials, each LG-X is discarded after a single flight. Costing less than parafoil-based airdrop systems (such as the 

Joint Precision Airdrop System or JPADS), the LG-X provides the US military with increased standoff range, allweather operation, and a high precision cargo delivery capability.

Proposed Flight Conditions

Logistic Gliders proposes that the grant of the exemption be subject to the following mandatory conditions, which 

are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of 

Waiver or Authorization, and with additional restrictions:

 All operations to occur in Class E or Class G airspace.

 All operations will occur in daylight hours only. 

 Operations to be conducted over private or controlled-access property to limit the number of persons not 

associated with the operations place at risk.

 Permission from land owner/controller will be obtained before commencing any flight.

 Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

 Glider to remain within Visual Line of Sight (VLOS).

 Above Ground Level (AGL) altitude to be restricted to less than 5,000 feet.

 Flight will not occur over sensitive infrastructure such as pipelines, roads or electrical infrastructure. 

 Launch and recovery areas will be cordoned off to limit access only to personnel associated with the flight 

operation.

 A dedicated Visual Observer (VO), other than the Pilot in Command (PIC), will be used to maintain overall 

operation situational awareness; maintain VLOS and scan for intruder traffic; monitor all radio 

communication to include “Guard” in accordance with any COA; and report on other frequencies as 

appropriate.

 All required authorizations and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other governmental agencies.

 Flight operations will be conducted with linear distances exceeding 500 feet from any person (other than 

the PIC and VO), vessel, vehicle, or structure. 5

Radio Equipment & FCC Certification

The LG-X test gliders will use existing commercial auto-pilots developed by established and experienced electronic 

manufacturers. The autopilot system will feature a radio controlled (RC) over-ride, controlled by our PIC.

Safety Precautions 

All testing procedures and formal test plans incorporate proven and redundant methods to achieve safety to ALL 

parties involved. The following paragraphs summarize our inherently safe method of flight testing. 

Safety to Personnel/Property on the Ground

The LG-X glider contains no form of onboard propulsion and its rate of descent is too high to allow it to be lifted 

significantly by atmospheric thermal energy, thus its range during a test flight event is easily limited to a known 

radius equal to glide ratio multiplied by release altitude. A minimum safety radius and c orresponding release 

altitude will be established for each and every test flight, and used when selecting a test location. All tests 

involving the LG-X gliders will be performed in locations that are unpopulated and undeveloped (flat salt lake beds, 
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prairie, desolation wilderness, etc). LG-X glides will NEVER be flown over or near populated areas or areas that 

contain sensitive infrastructure. 

Ensuring Safety for Other Aircraft

All LG-X gliders are released from their manned deployment aircraft by the pilot. Prior to releasing an LG-X test 

glider during a test event, the licensed pilot of the deployment aircraft will confirm the airspace is clear of other air 

traffic. Following release, the manned aircraft will climb to a higher altitude and maintain survei llance until the 

glider has landed. Radio communications between the manned aircraft and ground controllers (PIC and VO) will 

ensure glider flight is terminated should an unsafe flight condition suddenly develop. 

Inspection, maintenance, repair and pre-flight safety assessments

Since LG-X contains no landing gear, propulsion systems, or onboard pilot display/control/communication 

equipment of any kind, many pre-flight inspection tasks have been eliminated. However the LG-X pre-flight 

inspection will include some elements common to manned civil aircraft and will follow a written checklist. The 

checklistincludes:

 Check for damaged wings, fuselage, and empennage. 

 Check that the RC and autopilot are operating.

 Check that flight controls response to RC commands.

 Check for security of all bolts and nuts, and safety-wired devices. 

 Check that onboard cameras are turned on.

A full description of intended use and how it would provide at least an equivalent level of safety to 

that provided by the rule from which exemption is sought

LG test flights of the LG-X glider will deliver an equivalent or superior level of safety to Part 333 by operating 

exclusively in undeveloped and uninhabited areas. Coupled with the fact that LG-X gliders are un-powered and 

unable to traverse the distances needed to reach populated regions, each test flight will be inherently safe to the 

public.

Intended Area of Use

LG-X test glider will be flown only in safe, controlled, and unpopulated environments. Areas intended for test 

flights include areas which have already hosted other experimental aeronautic flights. All test operations will be 

conducted with the permission of the applicable land owner or governing body. Sites include: 

a) Eloy, AZ (Desolation Wilderness Beyond Population Centers)

b) Vernal, UT (Desolation Wilderness Beyond Population Centers)

Operation near Airports

LG-X Gliders will not be operated within 5 statute miles of any airports. All test flights will be conducted in remote 

and desolate regions and conducted only when visual observations indicate no other aircraft are present. 

Visual Line of Sight

Visual Line-of-Sight is ensured by conducting test flights in extremely flat and unobstructed test areas. By limiting

release altitude to less than 5,000 feet AGL, visual line of sight can be maintained by flying the glider in circle 

centered about the PIC and VO. This low altitude and small turn radius, coupled with the large physical volume 

and brightly colored exterior of the LG-X test gliders, will ensure visual line-of-sight is constantly maintained. 

Other Notification Requirements

Logistic Gliders will operate in Class G and E airspace only. However we will notify the air traffic control facility 

having jurisdiction over the airspace of the intended glider release no earlier than 24 hours before or no later than 

1 hour before a test operation begins. The notification is similar to how parachute operations are conducted in 

accordance with FAR Part 105. 
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How a Waiver benefits the Public Interest

Logistic Glider LG-X test glider, once flown, will deliver critical test data to mature the product to a sufficient 

degree where it can be offered to the United States military for use overseas in support of military operations. 

However, significant utility could also be derived for the public, a s Logistic Gliders aircraft could provide relief 

supplies in the face of a man-made or natural disaster occurring within the homeland. 

Summary 

I, Will Russell, the Petitioner request for exemption from the above mentioned Federal Aviation Regulations in

order to legally operate an UAS in the National Airspace System in order to perform test flights and gather critical 

performance data needed to complete several research & development contracts LG holds with several US military 

agencies. The Petitioner hopes for a timely consideration as we have a demonstration scheduled for the week of 

21 March 2016 for the Defense Advanced Research Projects Agency (DARPA) and the Marine Corp Warfighting 

Laboratory (MCWL).

Sincerely,

William Russell

President, Logistic Gliders

221 West A St, #1386

Dixon, CA 95620

will.russell@logisticgliders.com, 

310-941-2423