Bowman Consulting – 3863 Centerview Drive – Suite 300 – Chantilly, VA – 20151 – (703) 464-1000 

January 13, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC  20590

Filed at www.regulations.gov

SUBJECT: Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part

11, Bowman Consulting Group, Ltd (BCG), seeks an exemption from Federal Aviation Regulations (FARs) detailed

below for the eBee Unmanned Aircraft System  (“eBee”) manufactured by SenseFly SA of Switzerland:

 14 CFR 61.113(a) and (b)

 14 CFR 91.7(a)

 14 CFR 91.119(c)

 14 CFR 91.121

 14 CFR 91.151(a)(1)

 14 CFR 91.405(a)

 14 CFR 91.407(a)(1)

 14 CFR 91.409(a)(1) and (2)

 14 CFR 91.417(a) and (b)

BCG provides consulting engineering and surveying services to clients in the land development, oil & gas,

transportation, power & energy and mining sectors.    BCG’s mining clients own and operate open pit mines

throughout the United States, predominantly in the southwest.  The surveying services provided to these mining

clients routinely include topographic and feature mapping that is acquired through aerial photogrammetry.  Use of

the eBee UAS to produce this mapping creates benefits to the mining and construction industries and to the

environment which serve the public interest.  Specifically, use of the eBee UAS provides the following advantages:

 Safety:  The eBee UAS is constructed of flexible foam and weighs less than two pounds.  The eBee operates on

a sealed lithium‐polymer battery and does not use combustible fuel.  Use of the eBee UAS on mine sites allows

acquisition of topographic and feature data that is otherwise unobtainable due to steep terrain, pit walls, high

walls and other aggressive topography typical of active mine sites.

 Cost:  Use of the eBee provides a competitive advantage to our clients because they are able to acquire survey

data at an estimated savings of 30 to 40 percent compared to conventional aerial photogrammetry via

manned aircraft.

 Schedule:    The workflow for conventional manned aerial photography is such that the client receives

deliverables from several days to several weeks after flight date.    The eBee UAS includes post‐processing
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Bowman Consulting – 3863 Centerview Drive – Suite 300 – Chantilly, VA – 20151 – (703) 464-1000 

software that resides on BCG workstations that allows BCG to deliver the final mapping product to the client

from several hours to a few working days after flight date.

 Quality:  The eBee UAS, at normal flight heights, acquires imagery at a resolution of less than one inch per

pixel.  This resolution provides excellent clarity in the resulting ortho‐photos, and also results in very accurate

survey deliverables.

The requested exemption would authorize commercial operations using the eBee for mapping and survey

applications. These operations will be subject to strict operating requirements defined in the eBee user manual

(BCG requests that the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b) and not include

this document in the public docket) in order to ensure at least an equivalent level of safety to currently authorized

operations using manned aircrafts.

UAS CHARACTERISTICS

The eBee is a small (38 inches wingspan) and ultra‐light (maximum take‐off weight of 1.7 pounds) platform made

of flexible foam that performs precision aerial mapping missions thanks to the onboard GPS and the related flight

management software (eMotion) that allows the operator to safely and efficiently plan a mission in 3D, and then

monitor it in real‐time. Thanks to the embedded camera, protected by a foam envelope, the eBee takes a

collection of high‐definition still images that are used later to generate maps and contour lines of the surveyed

area.

The four main characteristics of the eBee are:

1. Very light weight

The eBee is so light that the operator can launch it by hand and let it land on almost any surface without

requiring a parachute or landing net (belly land). Its low kinetic energy (60 Joules (“J”) at cruise speed) also

significantly reduces the risk of hazardous situations. Finally, the wings of the eBee are detachable and made

of flexible foam with no sharp or hard edges and almost no internal strengthening structure.

2. Electric‐powered

The eBee is electric‐powered. A brushless engine technology makes it silent and reliable. The propeller is

attached with two rubber bands to the body of the plane so that it can easily flex away in case of contact with

any object.

3. Semi‐automatic flight

The artificial intelligence incorporated within the eBee autopilot system continuously analyzes data from the

Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects of the flight under the

supervision of the operator.

4. Option for Manual control

Additionally, the eBee provides an override capability that allows the operator to take manual actions during

the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated operations and

take manual control of the aircraft should it become necessary to respond emergent circumstances, thanks to

the remote controller provided with the system.

AIRWORTHINESS ASSESSMENT OF THE EBEE UAS

BCG notes that the eBee UAS, including the aircraft, the flight software, and the post‐processing software, is a

mature and established system.    The airworthiness of the eBee has been demonstrated on several different

projects in the United States involving state/federal agencies or universities, including the US Army Corps of
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Bowman Consulting – 3863 Centerview Drive – Suite 300 – Chantilly, VA – 20151 – (703) 464-1000 

Engineers (“USACE”) New Orleans, who coordinated with the Department of Army and the FAA to obtain all

authorizations required in order to operate the eBee UAS.

SenseFly has also obtained flight approvals for the eBee from the national civil aviation authority in many other

countries, including:

 Switzerland (flight approval for Visual Line of Sight “VLOS” operations)

 Canada (flight approval for VLOS operations)

 Australia (flight approval for VLOS operations)

 France (flight approval for Extended‐VLOS operations)

 Germany (flight approval for VLOS operations)

 United Kingdom (flight approval for VLOS operations)

 Norway (flight approval for VLOS operations)

 Sweden (flight approval for VLOS operations)

 Denmark (flight approval for VLOS operations)

OPERATING REQUIREMENTS

We propose to operate the aircraft with both a Pilot in Command (PIC) and a ground‐based Visual Observer (VO) in

accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the following

additional restrictions:

 All operations will occur in Class G airspace at no more than 400' AGL

 Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours

 The aircraft will remain within Visual Line of Sight (VLOS) of both PIC and VO at all times

 VLOS guaranteed with a GPS geo‐fence around operator of 0.5 miles

 Operations will be conducted over private, controlled‐access property with the permission of the land

owner (most surveys will take place over active mine sites that are characteristically large, removed from

population centers, with controlled access)

 The aircraft will not be operated over urban or populated areas, at open‐air assemblies of people, or at air

shows  

 The PIC will file a NOTAM for each operation

 The PIC must have completed the SenseFly training program for operation of the eBee

 Operations over congested areas shall be avoided;

 Operations must not interfere with manned aircraft operations, must yield the right of way to manned

aircraft, and operators must See & Avoid other aircraft and obstacles at all times

 All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination

with the airport authority, or air traffic control when a control tower is present at the airport;

 All operations shall comply with required permissions and permits established by territorial, state, county

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

 The eBee operations will be compliant with existing safety procedures inherent to the survey activities of

BCG.

OPERATOR REQUIREMENTS

The aircraft will be operated by an individual who meets the following requirements:

 Has successfully passed a manufacturer’s training program for the eBee; BCG requests the FAA treat the

eBee training program as proprietary under 14 C.F.R. 11.35(b) and does not include this document in the

public docket.

 Has a Private Pilot certificate.
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Bowman Consulting – 3863 Centerview Drive – Suite 300 – Chantilly, VA – 20151 – (703) 464-1000 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications.

The PIC will perform routine maintenance on the system and will complete a course of maintenance instruction as

part of their initial training. Due to the simplicity of the system, we do not anticipate the need for a supplemental

pilot.

CONCLUSION

Our mining clients operate in a very competitive financial global environment, and in hostile physical

environments.  Use of the eBee UAS is in the public interest because it allows these companies to reduce costs and

remain competitive.    It also supplants aircraft of significantly greater proportions carrying crew and flammable

fuel, as well as conventional survey crews that require personnel to work in difficult and unsafe terrain.  The eBee

UAS makes not only the NAS safer, it makes BCG employees on the ground safer.

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully

qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have

confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing the

same mission.

Sincerely,

Bowman Consulting

Reed Larson, PE

Vice President of Mining Services

Attachment: Exemption Requests

Transmitted separately: eBee User Manual

    eBee Maintenance Manual

    eBee Training Program

    eBee Justification of Airworthiness and Safety Assessment