www.logisticgliders.com



## 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

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To Whom it May Concern,

P ursuant to the FAA Moder nization and Reform Act of 2012 (the "Reform Act") and the procedures contained in 14 C.F.R. 11, on be half of Logistic Gliders Inc. (LG)
, a Nevada C

- Corporation and developer of unmanned cargo gliders
, hereby request s exemption from the Federal Aviation Regulations ("FARs") listed below in order to legally operate unmanned aircraft systems ("UAS") commercia lly 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 per mit LG to perform test flights and gather critical pe rformance data needed to complete several research & deve lopment 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 ab ove. 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, LG believes obtaining airworthi ness certificate s are unnecessary, however all test aircraft will be registered with the FAA. 14 CFR 91.405(a) 

### This provision wou ld require that LG provide an Airframe and Power

p lant 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&P mechanic
, he does not possess IA. Extensive qualifications seem to 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 abovewww.logisticgliders.com

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 Proj ects Agency (DARPA ) and the Mar ine Corps Warfighting Laboratory (MCWL). Staffed by several senior airdrop and a eronautical 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 a n 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 JPA DS) , the LG

- X provides the US military with increased standoff range, all

weather 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 obtaine d 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
ap propriate.

 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 opera tions w ill be conducted with linear distance s exc eeding 500 feet from any person (other than the PIC and VO) , vessel, vehicle, or structure

. 5
Radio Equipment & FCC Certification The LG

- X test glider s will use existing commercial auto

- pilots developed by established and experienced electronic manufactur ers

. The autopilo t 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 e very 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,www.logisticgliders.com

prairie, desolation wilderness, etc). LG

- X glides will NEVER be flow n over or near populated areas or areas that contain sensitive infrastructure.
Ensuring Safety for Other Aircraft All LG

- X gliders are released from their m anned deployment aircraft by the pilot

. Prior to releasing an LG

- X test glider during a test even t, the licensed pilot of the deployment aircraft will confi rm the airspace is clear of oth er air traffic

. Following release, the manned aircraft will climb to a higher altitude and maintain survei llance until the glider has landed. Radio communications b etween the manned aircraft and ground contr ollers ( 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 t he LG

- X p re

- flight inspection will include some elements common to manned civil aircraft and will follow a written checklist

. The checklist include s :

 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 environment s

. Areas intended for test flights include areas w hich 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 (Desola tion Wilderness Beyond Population Centers)
Operation n ear 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 condu cted only when visual observations indi cate 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 f eet 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 hou rs 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.www.logisticgliders.com



## How a Waiver benefits the Public Interest Logistic Glider LG

- X t est glider, once flo wn, 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 opera te an UAS in the National Airspace System in order to perform test flights and gather critical
pe rformance 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

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